United States
         Environmental Protection
         Agency       f
6PA/540/G-86/001
OSWER 9380.2-3
December 1986
         Superfund
&EPA   Superfund liwovative
         Technology Evaluation
         (SITE) Strategy and
         Program Plan

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                          EPA/540/G-86/001
                            OSWER 9380.2-3
                             December 1986
Superfund Innovative Technology
  Evaluation (SITE) Strategy and
           Program Plan
   OFFICE OF RESEARCH AND DEVELOPMENT
   OFFICE OF SOLID WASTE AND EMERGENCY
              RESPONSE
  U.S. ENVIRONMENTAL PROTECTION AGENCY
         WASHINGTON, DC 20460
         w^V J^O j  A.*..'

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OSWER 9380.2-3
                          Disclaimer


  This document  has been  reviewed in accordance  with the U.S.
Environmental Protection Agency's peer and administrative review policies
and approved for presentation and publication.

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                                                     OSWER 9380.2-3
                            Contents


Chapter                                                        Page

  I.  Executive Summary	1

 II.  Background	3
      II.A.  Nature of the Problem	3
      II.B.  Goals, Scope, and Objectives of the SITE Program  	5

 III.  Impediments to Development and Commercial
     Use of Innovative Technologies	7
     III.A.  Informational Impediments	7
     III.B   Regulatory Impediments	8
     III.C.  Institutional and Other Impediments	10

 IV.  Demonstration Program	13
     IV.A.  Objective	13
     IV.B.  Scope	13
     IV.C.  Selection of Demonstrations	20
     IV.D.  Evaluation Plan	25
     IV.E.  Site-Specific Community Relations Activities	29
     IV.F.  Dissemination of Results	29

 V.  Application Analysis	32
     V.A.  Operating Range of the Technology	32
     V.B.  General Assessment of the Technology	32
     V.C.  Economic Analysis	33

 VI.  Development Program	34
     VI.A.  Monitoring and Influencing Nonfederal R&D 	34
     VLB.  Conducting the Development Program	36

VII.  Communications	39
    VILA.  General   	39
    VII.B.  Major Communications Activities	40

Appendix A—List of Acronyms and Abbreviations	42

Appendix B—Evaluation Information and Criteria Considerations
            for a Proposed Technology	44

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OSWER 9380.2-3
                             Figures
                                                              Page
 11-1   Development Process for Alternative Technologies	6
IV-1   Demonstration Program Structure	22

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                                                     OSWER 9380.2-3
                   I.   Executive Summary


  Concern is growing over the use of land-based containment technologies
to mitigate the  problems caused by releases of hazardous substances at
Superfund sites. This concern has been expressed by the public, the Office
of Technology Assessment, and EPA's Science Advisory Board and has been
discussed extensively in  Congress. EPA recognizes this concern and is
responding in several ways. The Office of Emergency and Remedial Response
(OERR), within the Office of Solid Waste and Emergency Response (OSWER),
recently issued  guidance to increase the use of alternative technologies at
Superfund  sites. Also, in response to  the  Superfund Amendments and
Reauthorization Act of 1986 (SARA) the Office of Research and Development
(ORD) and  OSWER  have established  a  formal  program to  accelerate  the
development, demonstration, and use of new or  innovative technologies.
In addition, it has been recognized that our ability to characterize or assess
the extent of contamination, the chemical and physical  character of  the
contaminants,  or the  stresses imposed  by the contaminants on complex
ecosystems is limited, and new, innovative technologies are needed ORD
has, therefore, established a second program to demonstrate and evaluate
new,  innovative measurement  and monitoring technologies.  These two
program  areas are called the Superfund Innovative Technology Evaluation
or the SITE program. This document presents EPA's strategy for implementing
the SITE program.
  The  primary  purpose  of  SITE is  to  enhance  the  development and
demonstration, and thereby establish  the  commercial availability,  of
innovative technologies at Superfund sites as alternatives to the containment
systems presently in use.

  There will be four parts to the SITE program:

  1.  To  identify and,  where possible, remove  impediments to  the
     development and commercial use of alternative technologies.

  2.  To conduct a demonstration program of the more promising innovative
     technologies to establish reliable performance and cost information
     for site characterization and cleanup decisionmaking.

  3.  To develop procedures and policies that encourage selection of available
     alternative treatment remedies at Superfund sites.

  4.  To  structure  a development  program  that nurtures  emerging
     technologies.

  EPA recognizes that a number of  forces  inhibit the expanded  use of
alternative technologies  at Superfund sites.  The objective of the first part
of the program  is to identify and evaluate these impediments and remove
them or design methods to promote expanded use of alternative technologies.
This effort will include identifying both incentives and disincentives that may
be implemented or removed, as appropriate. Three types of problems have
been identified: informational, regulatory, and  institutional.
  Insufficient information on testing and evaluation  methodologies, costs,
and available markets has been recognized as informational impediments.
Regulatory incentives and disincentives  may  result from EPA policies,

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OSWER 9380 2-3

regulations, and procedures, as well as non-EPA legislative and regulatory
requirements.  Institutional  problems considered will  include public
acceptance  of  innovative technologies, economic  factors, and liabilities
assumed by developers and users of a new technology. In each case, barriers
to be overcome and methods to promote the use of alternative technologies
will be evaluated, as appropriate. EPA  intends to phase this study so that
incentives and impediments under EPA's control are identified first. Those
that will  require action outside of EPA will be addressed later. In this way,
EPA will act early in the overall program on areas over which it has influence.
  The second part of the SITE program is the demonstration and evaluation
of selected technologies. This is intended to be a significant, ongoing effort
involving ORD,  OSWER, EPA regions, and the private sector. The objective
of the demonstration  program is to evaluate fully developed technologies
to make available cost-effectiveness information. Superfund decisionmakers
will thus have the necessary information to consider these technologies for
future cleanup or site characterization projects. To be consistent with pending
legislation, the  first  round  of demonstrations  will include at least  10
technologies. The first round  process will include selection  of technologies
appropriate for demonstration, the setting of priorities among wastes, media
and sites for demonstration,  and development  of a community relations/
technical information transfer program for each site chosen.
  Periodically  in  the demonstration  program, candidate alternative
technologies will be solicited and selected for Superfund sites. In each round,
ORD will solicit proposals to demonstrate existing and  developed technologies
and will screen those  proposals for inclusion in the demonstration program.
In addition, OSWER will screen various Superfund wastes and sites to select
those of high priority for demonstration. The combined efforts will result
in the final selection of approximately 10 demonstration projects representing
various combinations of high-priority wastes, sites, and innovative alternative
technologies. Additional activities will include the development of testing,
quality  assurance and  quality  control  (QA/O.C), and data  evaluation
procedures  For each technology/waste/site combination chosen, ORD and
OSWER will work with the inventor (or developer) to conduct a demonstration.
It is EPA's intent that  the private sector participant will conduct  the
demonstration, with EPA evaluating performance. The result will be (1) a
series of reports issued by EPA evaluating specific  technologies and their
applicability to Sueprf und site investigations or cleanups and  (2) a companion
technology transfer program.
  During the initial selection phase of each round, EPA will solicit public
comment and conduct an outreach program to keep all interested parties
informed of progress. Additionally, once a specific  demonstration is being
considered, EPA will  establish a community relations program to allow for
input from the  public  m the area surrounding the demonstration site. After
a demonstration is completed,  EPA will ensure that the results are made
available to all interested parties
  As information becomes available from the demonstration program, EPA
will evaluate those results in  the context of existing  policies and procedures
to determine how successful technologies can best be used in the Superfund
program. The result will  be guidance to decisionmakers on when and how
each technology is appropriate  for conducting  site characterizations or
remedial and removal actions
  The final part of the  SITE program will accelerate and promote development
of promising innovative technologies that are not ready for demonstration.
This effort will be conducted by ORD. Activities will include evlauations of
emerging  technologies  and  support  to the development  of  particularly
promising technologies, where warranted.

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                                                       OSWER 9380.2-3
                         II.   Background


   Concern over our ability to fully characterize  contamination at sites and
 the long-term reliability of containment technologies used for cleanup actions
 at Superfund sites is receiving much attention. At present, remedial actions
 usually consist of moving wastes to land disposal sites (which themselves
 may become Superfund candidates) or containing the waste in the ground
 onsite. In some cases, hazardous substances continue to be released to the
 environment. In response to these concerns regarding both characterization
 of sites and reliability of technologies, the public and Congress are demanding
 that innovative and alternative technologies be used to effect permanent
 cleanups.

 II.A.  Nature of the Problem

   In preparing to reauthorize CERCLA,  Congress required the  Office of
 Technology Assessment (OTA) to review the lessons learned from the initial
 Superfund program and to prepare a strategy for improving the  Superfund
 program. One of the three principal goals  of the  review was "to understand
 future Superfund needs and how permanent cleanups can be accomplished
 in a cost-effective manner for diverse types of sites."1
  The OTA study concluded that land disposal approaches, even though they
 may be proven technologies  for their original applications in construction
 engineering, are not proven to be effective over the long term in containing
 hazardous wastes Nor are their immediate costs indicative of the likely total
 long-term costs, including monitoring, operation and maintenance, and the
 costs of future cleanup actions, especially for  cleaning up contaminated
 groundwater. The OTA report further concluded that not enough research,
 development, and demonstration (RD&D) efforts are devoted to  innovative
 cleanup technologies and that  many innovations exist, but few have overcome
 institutional and other barriers. Considering the  high cost of the Superfund
 program,  spending more  RD&D  money  on innovative cleanup and  site
 characterization technologies could offer considerable economic advantages
 in the long term.
  OTA also  recommended  that barriers to the demonstration be removed
 and that the use of innovative technologies  be examined OTA urged Congress
 to direct EPA to  (1) reduce the time and cost of obtaining RCRA permits
 for waste treatment facilities, (2) establish  protocols to evaluate new cleanup
 technologies; (3) make it easier to obtain samples of waste and contaminated
 materials  from uncontrolled sites and  to transport them to test facilities;
 (4) streamline the RCRA procedure for delistmg harmless residues of waste
 treatment operations;  and (5) continue  to remove the bias  in favor  of land
 disposal over waste treatment options  in  Superfund cleanups, particularly
 by establishing a  procedure for performing cost-effectiveness analyses that
 more accurately reflect the full, long-term  costs of land-based technologies.

  The Science Advisory Board's (SAB) Environmental Engineering Committee
was  concerned  that  enormous expenditures  were  being  made under
Superfund without an adequate technological data  base to support
^Superfund Strategy. U S Congress, Office of Technology Assessment, OTA-ITE-252, April 1 985
Washington, DC

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OSWER 9380.2-3

rehabilitation of hazardous waste disposal sites. In a formal resolution, the
SAB committee expressed this concern to the EPA  Administrator and to
members of Congress who were considering amendments to CERCLA. The
resolution recommends a comprehensive research (RD&D) program  to
develop effective,  long-term  permanent  solutions.  The resolution also
recommends changes to the cost-effectiveness standard  and the potential
liability  of contractors.  Also,  the  SAB  recommended that administrative
problems related to the use of Superfund sites as field laboratories be resolved.
The SAB committee reported that private industry has little incentive to solve
Superfund  cleanup  problems through innovative technology because of
administrative problems and institutional barriers similar to those identified
in the OTA report.
  EPA is also  concerned about the  use of conventional land-based
technologies for cleaning up Superfund  sites that may result in  short-term
solutions. In recent months, the Office of Emergency and Remedial Response
(OERR) issued new offsite disposal guidance that should increase the use
of alternative treatment technologies in Superfund cleanup actions. A number
of innovative technologies  have already been chosen for  implementation at
Superfund sites.
  EPA concurs with the SAB and OTA that  there should be a comprehensive
program to assist industry in developing long-term permanent solutions for
characterizing and cleaning up  abandoned  hazardous  waste  sites. The
reauthorized CERCLA establishes an RD&D  program for alternative and
innovative technologies. In response to the legislation, and after considering
reports  and recommendations discussed  above,  ORD and OSWER have
developed a  joint strategy for an RD&D program called the  Superfund
Innovative Technology Evaluation (SITE) program.
  An  outside group of  experts (the SITE Strategy Review Group) provided
guidance and review of the  strategy. The SITE Strategy  Review  Group
consisted of individuals from  large and small  companies, academia, state
governments, environmental  groups, and consulting  engineering  firms.
Personnel from ORD Headquarters,  OSWER, and the  Hazardous  Waste
Engineering Research Laboratory (HWERL) met with the SITE Strategy Review
Group to obtain guidance and assistance on the SITE implementation strategy.
A broad range of comments and advice was given; the major points offered
for EPA consideration are summarized below.
  The Strategy Review  Group highlighted the following major impediments
and administrative issues that also appeared  in the OTA and SAB reports:
(1) the time necessary  for permitting demonstrations and dehsting wastes
resulting from demonstrations; (2) the  liability of demonstrators for suits
brought against cleanup activities; (3) the lack of performance  criteria for
acceptability; (4) the lack of accurate market information; and (5) the difficulty
in gaining public acceptance of new technology. Also, it was suggested that
EPA encourage and stimulate entrepreneurs and inventors who  have ideas
that warrant development.
  One of the major  points made  by  the  group was that acceptance of a
new technology is driven by the level of decisionmaker and public confidence.
Confidence  is gained only by pilot-  or full-scale  demonstrations at a site
adequate to define process operability. Since one focus of the SITE program
is to  move developed alternative  technologies to  routine acceptance, the
strategy  group  identified  a number  of mechanisms  for accelerating the
commercial  availability  of such technologies.
  The group recommended that EPA establish a demonstration  program to
evaluate new technologies on Superfund sites. The group also recommended
that EPA establish a test and  evaluation facility to evaluate new hazardous
waste technologies offsite. By providing testing to obtain the necessary cost

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                                                       OSWER 9380 2-3

and  performance information, EPA could promote a more rapid transition
of new technologies from pilot tests through demonstrations.
   EPA's crucial role in the SITE demonstration program is to ensure credible
results by providing the testing protocol and procedures and the analytical
and  QA/QC work plans so that the performance data can be consistently
and  accurately interpreted.
   The group  recommended that EPA define Superfund site  problems and
cleanup  schedules more  clearly so that the industry  will  have accurate
information for forecasting markets and determining the need for developing
new technologies
   The group  also  pointed out the  need for developers to obtain samples
of Superfund wastes for test purposes
   The group  recommended that EPA clarify the policy  on the  use  of new
products where  patents have not been filed or are pending  on Superfund
sites. Specifically, EPA should expand  the  policy to allow demonstrations
and  cleanups to  use inventions that could involve the use of confidentiality
or secrecy agreements
   The group further recommended that EPA establish a research program
to support laboratory and bench-scale studies to  develop  alternative
technologies. This is important because small businesses and entrepreneurs
have difficulty obtaining support for such seed projects where  there  is no
widespread application.
II.B.   Goals, Scope, and Objectives of the SITE Program

  The overall goal of the SITE program is to maximize the use of alternatives
to land disposal  m  cleaning  up  Superfund  sites and to encourage the
development and  demonstration  of new,  innovative measurement  and
monitoring technologies.
  At the outset it is important  to define, for purposes of the SITE program,
some of the terms  used  in this document and in the program The terms
"alternative technology" and "innovative technology" are widely used central
concepts in the SITE program
  SARA defines an "alternative technology" as a series of unit operations
or any unit operation that permanently alters the  composition of  hazardous
waste through chemical,  biological, or physical means so as to significantly
reduce  toxicity, mobility,  and/or  volume  of the hazardous  waste or
contaminated materials being treated. For the purpose of the SITE program,
SARA  also defines as  an alternative technology  those methods that
characterize or assess the extent of contamination, the chemical and physical
character of the contaminants, and the stresses imposed by the contaminants
on complex ecosystems at sites In  essence, alternative technologies are
any technologies  that are alternatives  to current procedures  or  practices
regardless of the technology's state of development (see Figure  11-1).

  For the  SITE program, alternative  technologies  are  categorized by their
development status as follows

  1.  Available Alternative Technology.  A technology, such as several forms
     of incineration, that is fully proven and m routine commercial or private
     use

  2  Innovative Alternative Technology.   Any fully developed technology for
     which cost or  performance information is incomplete, thus hindering
     routine use at CERCLA hazardous waste sites An innovative alternative

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OSWER 9380.2-3

Figure II-1.     Development process for alternative technologies.


                                                             Alternative
                                                             Technology
                Concept        Technology        Demonstration Proven and
Concept         Proven         Developed            Data       Available
   III                  II
   •               •	•	•          •
        Lab Scale          Pilot
      Development       Scale Up         Demonstration    Guidance
               "Emerging"
                         Innovative
                                                        Available
      technology requires full-scale field testing before it is considered proven
      and available for routine use.

  3.   Emerging  Alternative  Technology.   An alternative technology in an
      earlier  stage of development; the research has  not  yet successfully
      passed laboratory- or pilot-scale testing.

  The SITE program is designed to accomplish the following objectives, which
correspond to the program's four parts:

  1.   To  identify  and, where  possible, remove  impediments to the
      development and commercial use of alternative technologies.

  2.   To conduct a demonstration program of the more promising innovative
      technologies to establish reliable performance and cost information
      for site characterization and cleanup decisionmaking.

  3.   To develop procedures and policies that encourage selection of available
      alternative treatment remedies at Superfund sites.

  4.   To  structure  a development program  that nurtures emerging
      technologies.

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                                                       OSWER 9380 2-3
  III.   Impediments to Development and Commercial
                   Use of Innovative Technologies


  There are a number of major informational, regulatory, and institutional
impediments to the  acceptance and use of innovative technologies for the
detection, characterization, or treatment of hazardous wastes at Superfund
sites.
  OSWER  will  investigate various  incentives and  disincentives to  the
development and use of innovative technologies in conjunction with ongoing
efforts in this area  within EPA.  For instance, OSWER will coordinate its
efforts with the Superfund Mobile Treatment Task Force*. In addition, detailed
evaluations will  be made of selected  informational,  regulatory,  and
institutional barriers. The  conclusions of these efforts will help to refine
the objectives and implementation of the demonstration program. Actions
that are within EPA's authority to implement will be identified and evaluated
first  so that EPA can remove  such  impediments and  implement such
incentives as quickly as possible.

III.A.   Informational Impediments

  The shortage  of standardized performance and cost data is inhibiting the
commercial development and use of innovative technologies. The potential
user is unable to judge the incremental technical benefits and costs of these
technologies compared to  conventional technologies because there are no
consistent and uniform testing protocols and no adequate baseline data on
performance and  cost for conventional technologies.  Consequently,
performance and cost data for innovative technologies, even when available,
are viewed  with skepticism.
  EPA has  not established performance  standards, such  as design  and
operating   parameters, for many treatment  technologies. Furthermore,
treatment standards for Superfund sites (i.e., cleanup levels) vary from site
to site and are subject to change. Such targets of performance are necessary
in order to provide developers with the information and incentives to develop
innovative technologies.
  Uncertainty regarding capital and operating costs  for new technologies
is perhaps the  most important  barrier to the commercialization  of these
technologies. The  economic  risks  to the  developer and end-user  are
substantial in scale-up of  designs from bench or pilot  scale. Furthermore,
uncertain  cost  baselines for conventional technologies present additional
risks to the  developer and user. As noted previously, one of the demonstration
program objectives  is to provide  a consistent set of cost and performance
data so that cost-effectiveness assessments can be made between innovative
alternative  and conventional technologies.
  The  uncertainties surrounding marketing represent another  major
impediment to attracting risk venture capital for innovative technologies. The
most  obvious  questions  involve  whether there  is a  market  for these
technologies and the size of any  such  market. These questions are related
to issues such as:
'Joint EPA and state task force that is addressing regulatory impediments to the use of mobile
 treatment units at Superfund sites

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OSWER 9380 2-3

 • The uncertainty of toxicity/risk data for high-priority pollutants (e.g., dioxin,
   PCBs) and what the  performance and  treatment  standards  for these
   pollutants will be.

 • The willingness of the Agency and other end-users to pay a higher initial
   price for alternative technologies that produce permanent solutions, but
   ultimately have lower costs over the long term.

 • The nation's long-term priority and financial commitment to site cleanups.

  These  uncertainties cannot  be clarified by the demonstration program
alone. The development of reliable cost and performance information through
standardized  technology demonstrations will help to validate performance
and  cost data,  but other ways to remove information barriers need to be
developed, such as.

 • Use of technology transfer techniques to disseminate information, to
   emphasize the Agency's commitment to  innovative  technologies, and to
   indicate support for future use.

 • Issuance  of  clear policy and  regulations that define the  future role of
   both the government and the private sector in accelerating the use of
   treatment  technologies for site cleanups.

 • Consultation with treatment industry associations and representatives to
   ensure that their concerns have been identified and are being addressed.

 • Identification and  publication  of  more  detailed  short- and  long-term
   schedules for Superfund site cleanups

III.B.  Regulatory Impediments

  Despite recent  recognition  by  EPA  and  Congress  that innovative
technologies need to be encouraged to achieve Superfund cleanup objectives,
regulatory impediments to the commercial development of innovative cleanup
technologies  still exist. This section discusses steps that may be taken to
reduce such regulatory impediments
  OSWER's  proposed  approach  to  reducing regulatory barriers consists of
two parts: (1) regulatory barriers will be identified and analyzed to characterize
the nature of  the problem and (2) options to reduce or overcome key barriers
identified in the first phase will be developed  Reducing regulatory obstacles
can range from  modifying regulations to remove barriers to more widespread
use  of innovative technologies;  that is, creating regulatory incentives to
encourage innovative  cleanup technologies and  developing "disincentives"
that  discourage the use of traditional but less desirable technologies such
as land disposal or m situ containment of buried  hazardous substances.
OSWER's goal  is to remove unnecessary impediments while maintaining
needed levels of environmental protection.
  Regulatory  barriers  emanate from at least two sources. The first is the
different  federal, state, and local environmental regulatory programs that
control the discharge or release of  hazardous substances  For  example,
environmental permitting procedures can cause substantial delays, increase
costs dramatically, and create uncertainties that discourage  investment in
innovative technologies. Although current CERCLA procedures do not require
the issuance of environmental permitsforonsite response actions, permittmg-
related impediments are still  likely to be  significant because (1) offsite

                                  8

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                                                       OSWER 9380.2-3

 development and testing of new technologies will often be necessary and
 will require  permitting; (2) Superfund  onsite responses  must still  meet
 technical requirements associated with permitting; and (3) states may impose
 additional requirements.
   Dehsting has also been identified as an impediment to  commercializing
 innovative technologies. Traditionally, delisting petitions are  submitted to
 EPA (or an authorized state) and include data on the quality of treated residues.
 After an often protracted regulatory process, the petition is approved or denied.
 The time  and red tape necessary  to accomplish delistings are viewed as
 impediments. Also, the ability of a treatment process to  render  a waste
 "delistable" is often the main incentive for installing a treatment technology.
 New,  innovative  technologies  do,  however,  lack  a  history  of  delisting
 successes and often lack experimental data on the quality of residues  resulting
 from treatment of a variety of wastes. Thus,  potential users are reluctant
 to invest  in a new technology when the "delistability" of the residues is
 uncertain.
   Through systematic analysis of relevant RCRA procedures and standards,
 OSWER will identify the key constraints posed to new  technology
 development. Regulatory requirements that will be scrutinized include lengthy
 permitting  or onsite review  procedures,  RCRA financial assurance
 requirements, and RCRA delisting of treatment residues.
   A second category of regulatory barriers  emanates from federal
 procurement procedures.  In particular, the federal government's policy on
 competitive procurements may be an  obstacle to  many small firms  that
 develop new technologies but, because of their size, cannot assemble the
 resources required to  respond to a major competitive procurement.  Also,
 competitive procurement  precludes specifying proprietary equipment and
 processes that are available from only one source, a source which may be
 appropriate for Superfund site cleanups. OSWER will seek  assistance from
 the Office of Administration in this area of investigation.
   Once regulatory impediments have been identified and analyzed, options
 can be developed to. modify regulatory programs to overcome major obstacles
 to the  increased commercial use of treatment technologies while providing
 appropriate and adequate  protection to human health and the environment.
 Potential modifications could range from changing program guidance while
 leaving regulations in place to encouraging legislative changes that would
 result  in a major  overhaul of existing  regulations and/or the  development
 of new regulations.
   In addition to reducing  regulatory barriers,  regulatory incentives can be
 created to spur the development and use of innovative technologies. OSWER
 will evaluate options in this area.
   Finally, OSWER will investigate regulatory disincentives for traditional but
 less desirable cleanup technologies such as land disposal. Although HSWA
 establishes a land disposal restrictions program to reduce use of land disposal
 for certain hazardous wastes, there may need to be  additional measures
 available to discourage land disposal and containment technologies,  such
 as regulatory bans under CERCLA.
   Several regulatory problems  may apply to  implementation of the SITE
 demonstration program itself.

•  Will  states ^llow the  demonstration  program to  proceed under  the
   requirements of the NCP or will they  seek  to impose state permitting
   requirements?

•  Can  EPA establish testing and  evaluation  (T&E) facilities  for  testing
  different pilot-scale processes that can be regulated under a single generic
  permit?

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OSWER 9380.2-3

  Currently, the Agency is addressing these and other related issues through
 OSW/OERR work groups and through implementation of SARA. OSWER,
 in consultation with regions and states, is  also developing procedures to
 comply with RCRA and other permit requirements. The objective of these
 work groups will be to resolve these issues in a timely manner in coordination
 with implementation of the SITE program.
  In performing analyses of regulatory barriers to innovative  technology
 development and developing options to reduce or overcome those barriers,
 OSWER will seek input from knowledgeable  and potentially affected  parties
 such as the hazardous waste treatment industry, environmental groups, and
 Congressional staff.  OSWER plans to act as quickly as possible to address
 permitting and  delisting  issues.  However,  implementing  recommended
 options that  involve  amending existing regulations,  developing new
 regulations, or modifying legislation will necessarily occur over an extended
 period. Some of these problems may, therefore, create difficulties in meeting
 near-term  SITE program milestones. Solving these problems should help,
 however,  to assure attainment  of the long-term objectives of the SITE
 program. As noted before,  it is  EPA's intent to take  such actions  as  are
 under its control as soon as possible after they are identified as appropriate.
III.C.   Institutional and Other Impediments

  Institutional barriers may also impede the commercial development and
use of hazardous substance treatment technologies—perhaps even more than
regulatory barriers. This section describes the actions OSWER will take to
characterize institutional and other barriers and to reduce those barriers,
where possible. OSWER's proposed approach for reducing institutional and
other barriers  is conceptually similar to its approach for reducing regulatory
barriers. The  first step  is to identify  and analyze institutional  barriers to
characterize the problem.  The second step is to develop options to reduce
or overcome key barriers identified in the first step.
  There are categories of institutional  barriers relating to the three affected
parties: (1)  private parties such as technology developers or  potentially
responsible parties (PRPs),  (2) governments, and (3) communities surrounding
sites where innovative technology is being employed.
  Liability concerns of private parties  can be an important obstacle to both
the development and  use of innovative  hazardous substance  treatment
technology. For example, developers of innovative technologies may find that
liability insurance to cover their operational risks during development and
testing of those technologies is difficult or impossible to obtain. Uncertainties
concerning developer liability, if an innovative technology demonstration fails,
may further exacerbate difficulties  that developers face in  raising capital
in an uncertain market; any failure may severely damage their  reputation.
In addition, PRP concerns about liability associated with innovative technology
failure may be an institutional barrier if PRPs are either reluctant to select
new technologies or vigorously  oppose  EPA cost recovery actions for fear
of increased liability.  However,  SARA allows for some indemnification of
contractors participating in SITE  demonstrations, as well as indemnification
for cleanup contractors in  routine response  actions.  EPA is  developing
procedures to  implement these provisions.
  Additionally, marketplace factors affecting developers of new technologies
may serve as  institutional  barriers. For example, current cost-effectiveness
comparisons may encourage the selection of more traditional containment-
based technologies over alternative treatment technologies. Generally, such
traditional technologies are lower in  initial capital costs than  alternative

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                                                       OSWER 9380.2-3

treatment technologies but  have higher  long-term  release  risks (and,
therefore, costs) than alternative treatment technologies. Typical discount
rates used to compare remedial options often result in lower present value
of corrective action costs  associated with containment technologies than
present value costs associated with alternative technologies.
  Another marketplace factor affecting  developers  involves patent or
proprietary rights. Without procedures to protect patent or proprietary rights
of firms that have completed bench- and pilot-scale research and development
but still need a field demonstration to assure acceptance of their technology,
such firms may fear the risks of losing the benefits of their research.
  Governmental (state and/or federal) factors, the  second  category of
institutional  obstacles, could also be significant and require study A possible
example  is the CERCLA cost-sharing requirement that states must pay 10
percent (or more) for a remedial action. States may hesitate to use innovative
technologies given the  perceived uncertain reliability of such technologies.
States may be reluctant to assume  operation and maintenance (O&M) costs
of innovative technologies or replacement costs if the equipment ultimately
fails. They may also believe that a decision to participate could infringe upon
their fiduciary responsibilities, i.e , their statutory  requirements to assure
that money  is  properly spent.  If  it can be demonstrated that innovative
alternative technologies result in lower long-term costs, states may become
more supportive of using them.
  Community concerns represent the third category of institutional barriers
to developing and using innovative technologies at CERCLA sites. Generally,
concerned communities surrounding Superfund sites tend to prefer remedial
alternatives  that remove  all hazardous substances to  a remote hazardous
waste management facility. Innovative technologies involving onsite
treatment may, therefore, appear to be less than optimal from the community's
point of view.  Using EPA or other government facilities for demonstrations
may alleviate the level of concern, but communities may  view innovative
technologies as unproven  and  more likely to fail than other alternatives.
Additionally, they may resent being  used as "guinea pigs" in what they
might consider a research program  or experiment.
  Once institutional barriers have  been identified  and analyzed, options to
remove them and/or create incentives that would promote development must
also be established. Examples of these include:

• Clarifying cost-effectiveness  criteria to allow selection of remedies  that
   do not present the lowest initial capital cost.

• Establishing  procedures  to  assure  proprietary  rights  at  SITE
   demonstrations.

• Identifying ways to inform the  public of treatment versus land disposal
   and reducing fears (e.g., present data on effectiveness, safety, and costs
   of innovative technology plus the resulting risk reduction).

  Additional analyses should be performed  simultaneously with efforts to
reduce institutional barriers.  First, EPA's  experience in  implementing  the
innovative and alternative technology incentive program for municipal and
industrial wastewater treatment plants should be analyzed. EPA's successes
and failures with encouraging innovative and alternative technologies under
the construction grants program could be especially valuable as the Agency
embarks upon another program to encourage technology development and
use. Evaluations of other efforts to develop innovative  approaches to
environmental  problems will  be considered.  Second, innovative technology

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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.
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                                                       OSWER 9380.2-3
                IV.   Demonstration  Program


IV.A.   Objective

  The major objective of the demonstration program is to develop reliable
cost and performance information on innovative alternative technologies so
that they  can be adequately considered in Superfund  decision making.
Emphasis will be placed on demonstrating alternatives to current land disposal
and onsite containment practices that have been developed to the extent
that a successful demonstration on a hazardous waste site will likely lead
to commercialization.  In addition, limited resources  will be  used to
demonstrate and evaluate new, innovative or alternative measurement and
monitoring technologies. However, the demonstration program discussed in
this volume has been developed for the SITE program evaluation of treatment
technologies alone.  Although many aspects of this program may apply to
measurement and monitoring technology demonstrations, the methodology
for demonstrating these technologies will be discussed  in a forthcoming
addendum to this SITE Strategy and Program Plan.
  The demonstration should provide performance, cost-effectiveness, and
reliability data so  that potential users have sufficient information to make
sound judgments as to the applicability of the technology for a specific site
and to compare it to other alternatives.  The results of the demonstration
should identify the limitations of the technology, the potential need for pre-
and post-processing, the wastes and media  to which the process can be
applied, the potential operating problems, and the approximate capital and
operating  costs The demonstration should permit some evaluation of long-
term operating and maintenance costs and long-term risks. Demonstrations
should take place  under conditions that either duplicate or closely simulate
actual wastes and conditions found at Superfund sites to assure the reliability
of the  information collected and the acceptability of the data by  the user
community.


IV.B.   Scope

/V.B.I.  Technology Focus

  As discussed in Chapter II, several phases precede commercialization in
the development  of  a technology.  Ideally, a technology passes  from the
conceptual phase by laboratory-scale testing to the "proof of concept" phase.
Pilot-scale evaluations then lead to a developed phase followed by full-scale
evaluations that determine the cost-effectiveness of the technology. Based
on the results of these evaluations, guidance can be provided to users, and
the technology can be available for routine use At this point, technologies
are no longer considered innovative but routinely available.
  The SITE program focuses on the demonstration of technology to accelerate
its acceptance in  routine use to treat Superfund wastes. EPA will choose
for the demonstration program only those technologies that have been fully
developed and require  only the collection  of cost-effectiveness and
performance  information  to establish the  credibility  of  the  technique.
Technologies currently considered available  and thus not innovative (e.g.,
some forms of incineration) will not be considered for this program unless

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OSWER 9380.2-3

significantly modified and improved from the standpoint of performance or
cost.
  To  maximize  the usefulness of the  SITE demonstrations,  EPA  will
demonstrate  technologies designed to treat Superfund wastes for  which
treatment options need to be identified and studied. These high priority wastes
include the following:

• Wastes that are difficult  to treat—few or no treatment  options currently
   available, or options are very expensive.

• Wastes that frequently occur at Superfund sites and occur in large volumes
   (particularly contaminated soils).

• Wastes  with   a  large potential for creating  adverse health and/or
   environmental effects.

• Wastes projected to be restricted by EPA from land disposal in the near
   future.

  The technologies selected will also meet one or more of the  following
criteria:

  1.  Provide  a  permanent solution  (i.e., destroy  the  contaminant or
     significantly reduce the contaminant toxicity, mobility, volume, or any
     combination thereof).

  2.  Can be  used onsite as opposed to requiring costly transport of  waste
     (although offsite technologies will also be considered).

  3.  Have significantly lower costs than current methods.

  4.  Have  significantly better  performance  than current  methods (e.g.,
     provide  better treatment or destruction and are easier to operate).

  5.  Produce emissions, effluents,  and/or residues that are easy to manage
     from environmental, cost, and health standpoints.

  6.  Are easy and safe to operate.

  Because of  numerous waste types and complex settings at Superfund sites,
a single innovative technology will seldom be a sufficient  remedy for an
entire facility. Such technologies, however, may be very  useful as part of
an overall processing scheme and will  be demonstrated, where appropriate.
In these situations,  the impact of pre- and post-process  steps on  the
performance  and  cost  of  the  technology will  have  to be part  of  the
demonstration.

IV.B.2.   Sources of Technologies

  To find the best available technologies, an extensive search will be
necessary. The major source of these technologies will be private enterprise.
EPA will  use two approaches to identify  and  select  technologies for
demonstration. Under the first approach, notices will be placed periodically
in the Commerce Business Daily (CBD). A screening and  selection process
will determine which applications warrant demonstration.  In addition to the
general criteria  listed above, other information will  be  requested  of the

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                                                       OSWER 9380.2-3

technology developer and will be considered when selecting technologies
for demonstration. The areas in which information will be requested from
the developer are presented in Appendix B.
  The second approach will focus on conducting evaluations of alternative
technologies that were selected for use at specific Superfund sites during
routine response actions associated with both removal and remedial activities.
Evaluations of these technologies may be conducted before the technology
is used to clean up the site. For instance, a preliminary test of a technology
may  be performed in the  remedial investigation (Rl) or feasibility study (FS)
for a site.  The technology may also be evaluated during  its use for full-
scale cleanup at either a removal or remedial site. Such routine response
action demonstrations will generally be evaluated under the SITE program
when the technology chosen meets the criteria for selecting technologies
presented in Section IV.B. 1 or when the demonstration meets the information
objectives presented in Section IV.B.3. New technologies are now developed
in EPA's ongoing research programs in ORD. These are often demonstrated
by EPA but are not part of the SITE program. The SITE program demonstrations
focus on privately developed technologies.
  Other federal  agencies, notably the  Department of  Defense (DOD) and
the Department of Energy (DOE), have  begun  major initiatives to clean up
uncontrolled waste  sites  and develop new technologies.  ORD is working
with  these agencies to develop cooperative demonstration projects under
the SITE  program.  Memorandums of understanding already exist with the
DOD and the DOE for these activities.

IV.B.3.   Demonstration Information Objectives

  Common measurement, monitoring,  and  evaluation   guidelines  and
protocols  will  be developed by  ORD and  used to collect the data  and
information from the demonstrations. Following is a list  of the technical
data  to be collected. The  list is not all-inclusive  and  additional information
may  be required on a case-by-case basis:

• Performance and design parameters.

• Characteristics of wastes handled and  treated, including physical states
   and properties, range of chemical composition, and restrictions on wastes
   handled. For  in  situ demonstrations,  this would include  site-specific
   considerations of factors such  as  site size, hydrogeologic characteristics,
   and the configuration of the waste deposit.

• Destruction and  removal efficiencies, including  those  for  major  unit
   operations and for the  overall  process or treatment tram, and the effect
   of variable conditions such as temperature and altitude.

• Process residues and wastes,  including type and composition of wastes
   generated, emissions to the environment,  and other data required to
   establish the potential  for delisting these wastes or to obtain air/water
   discharge permits.

• Operations  and  maintenance,  including  labor, energy, and supply
   requirements for operations, scheduled maintenance requirements, and
   durability and  reliability data for equipment.

• Operational  safety, including evaluation of engineered safeguards and
   the effects of process upsets, human error, and equipment malfunctions
   on health and  safety.

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OSWER 9380.2-3

 • Mass flow/energy balances for feed and types and quantities of residues,
   emissions, and utilities, including data needed to verify engineering scale-
   up factors.

 • Setup,  startup, decontamination, and takedown procedures, including
   time, labor, and other mobilization factors.

 • Instrumentation and control, including ability to control  critical  process
   parameters and to respond to transient and upset conditions.

 • Quality assurance, data necessary  to ensure compliance with EPA test,
   measurement, and analytical guidelines and protocols.

  EPA will document public acceptability of the demonstrated technology,
as reflected in public hearings, and reaction to community relations efforts.
The Agency will also document regulatory information, such as federal, state,
and local requirements for operations of the technology, and any permitting
or associated  regulatory  problems that occurred.  This information will be
included in individual reports or demonstration project results.

  EPA will collect cost and schedule data using standardized EPA accounting
and costing guidelines. These data include but are not limited to:

• Costs for capital, operation, and maintenance.

• Costs for unscheduled  maintenance, spills, and other emergencies.

• Costs for disposal of residues and other wastes.

• Costs for quality assurance and monitoring.

• Costs for administration, including permitting and insurance.

• Time required for design,  permitting, manufacture,  construction,  and
   mobilization.

/V. B. 4.   Scale of Demonstration

  The scale and  time required  for a  demonstration will be established case
by case. Criteria are presented below  to provide general guidelines for the
scale and duration of a demonstration.
  A demonstration should be full scale or of a size or capacity that  permits
(1) valid comparison to  conventional technologies  in terms of technical
performance and cost and (2) direct scale-up to commercial size. In effect,
the nominal size or  capacity of  competitive conventional treatment  units
becomes the reference scale  for the  demonstration. Less  than full-scale
demonstrations also may  be valid in those instances where scale-up would
normally be accomplished by simply replicating the unit to be demonstrated
rather than building a bigger unit.
  In some cases, it may be desirable to conduct pilot-scale or even bench-
scale  evaluations  before  full-scale demonstration to establish  operating
parameters  or design  details. Pilot-  or bench-scale tests may also be
conducted after  a  demonstration to establish the range of applicability of
the technology to other waste/media types. This  work would normally be
carried out at the  developer's facility  or one of EPA's test  and evaluation
(T&E) facilities.

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                                                        OSWER 9380.2-3

   The effects of a smaller scale on the validity of the performance and cost
 data collected will be evaluated before selection. This evaluation will allow
 design parameters and test protocols to be adjusted so that any uncertainties
 in scale-up to  commercial size  will be reduced to acceptable limits. The
 developer's proposal must present an  analysis of the implications of less-
 than-full-scale demonstration. EPA will establish a methodology and process
 to analyze scale-up impacts in these cases.
   Because many variables need  to be considered,  the  length or duration
 of a demonstration  must be determined case by case. Some of these factors
 include:

 • Characteristics of process—batch vs. continuous, mobile vs. stationary,
   and type (e.g., biological processes are usually considerably slower than
   chemical processes).

 • Variability of process performance—the greater the variability, the longer
   the time required to obtain an average  level of performance (e.g., variable
   feed characteristics, such as occur in the treatment of contaminated soils,
   can cause variability in  process performance).

 • Data considerations—each demonstration must be of  adequate  length to
   derive statistically significant data.

 • Reliability—sufficient time must  be allowed to determine equipment
   reliability  and long-term environmental  suitability  of residuals  through
   monitoring (e.g.,  solidification technologies).

   There are  policy, budget, and  institutional  issues  that  will also affect
 decisions on the duration  of a demonstration. At some sites, gaining public
 acceptance of the demonstration may require the demonstration program
 to clean up the entire site. The type, location, and funding of the demonstration
 project are other factors. For example, a demonstration sponsored with other
 government agencies and PRPs could support a longer period of operation,
 whereas demonstrations at one test site (e.g., an EPA test and evaluation
 facility) would only  support a short demonstration for comparison purposes.
 Demonstrations are also  likely to be quite expensive for  developers. The
 developer's ability and willingness to fund the demonstration may affect the
 length of the test  period as well.  (This would  not be  a problem with
 demonstrations as  a part  of  routine response  actions.)  These factors will
 be considered when individual evaluation  plans are developed.

IV. B. 5.   Location of Demonstrations

  SITE demonstrations will usually be conducted at uncontrolled hazardous
 waste  sites (including  EPA removal  and  remedial sites), state sites, sites
 from other federal agencies, and developers' sites (including privately owned
 treatment facilities). Selection of sites will be done cooperatively by OSWER,
 ORD,  EPA regional offices, and the states. More than one demonstration
 could be conducted at a single site, thereby providing comparative results
as well as demonstrating technologies. Demonstrations will not necessarily
 be aimed at cleaning up an entire site; however, cleanup may be completed
 in cases where a site is small or the nature of the technique requires that
the entire site be involved.  The demonstration may also serve as a precursor
to full  cleanup  of a site using the  same technology. These "exceptions"
will be more common under the second (routine response action) approach
to selecting  technologies for  demonstration under the SITE program. The

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OSWER 9380.2-3

criteria  for selecting  sites for  demonstrations of technologies that were
selected under the first approach (CBD notices) will be established by OSWER.
The purposes of the  criteria are to select sites  representative of priority
problems and to provide results  acceptable to the user community.
  OSWER will establish criteria  for  waste site  selection  for  each
demonstration. Criteria that will be used to screen and select candidate sites
for  target demonstrations include the following:

• Compatibility of site waste with technology.

• Volume of waste.

• Variability of waste.

• Availability of data characterizing waste.

• Accessibility of waste (e.g., degree of excavation required).

• Contribution of demonstration to site cleanup efforts.

• Availability of required utilities (e.g., power and water sources, sewers).

• Support of community, state  and local  governments, and potentially
  responsible parties.

• Potential for adverse effects to public health and the environment.

  No permitting will be necessary for  demonstrations carried out at NPL
Superfund sites. However, OSWER will conform to the functional equivalent
of any applicable or relevant and  appropriate laws and regulations as required
by the National Oil and Hazardous Substances  Pollution Contingency Plan
(NCP) (40 CFR Part 300).
  Permits will be required for  demonstrations  conducted at either  offsite
private facilities owned by a technology developer (e.g., at its manufacturing
or  research facility) or at a commercial offsite facility that  has proper
equipment. In these cases, the facility owner will be responsible for obtaining
the  permit; however, OSWER may assist to some extent.
  Occasionally, demonstrations will be conducted at EPA/ORD T&E facilities,
as determined by the safety requirements, the need for specialized equipment
or facilities,  the QA/QC needs, or the  lower cost. T&E facilities will have
basic permits requiring, at most, modification for demonstration activities.
In these cases,  ORD will be responsible for obtaining any necessary permit
modifications. ORD T&E facilities also will have the latest pollution control
and safety equipment in place so that they can test technologies to failure
and can fully determine capabilities without fear of pollutant releases. T&E
facilities thus would provide quick access for moderate-sized activities, safety
and controlled conditions, and  lower cost demonstrations. In  some  cases
EPA believes that tests at a T&E facility may be necessary as  a precursor
to a field demonstration to determine appropriate design details  or operating
conditions. Such tests may also serve as a post-test, followup  study  to
determine the flexibility of a technology to treat additional wastes and/or
media. These tests might be conducted with the demonstration equipment
or with pilot-scale equipment. In any event, the demonstration will normally
be conducted on waste obtained from a hazardous waste site. The results
of these demonstrations must be  shown to  be applicable to "real world"
situations at actual Superfund sites regardless of where the demonstration
is carried out.

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                                                      OSWER 9380.2-3

  EPA/ORD is presently considering several facilities that could be developed
as T&E facilities for SITE demonstrations, e.g., the Mill Creek T&E Facility,
Cincinnati,  Ohio; the Center  Hill  T&E Facility,  Cincinnati, Ohio; the
Combustion Research Facility (CRF), Pine Bluff, Arkansas; the Edison, New
Jersey facility;  and the Air and Energy  Engineering Research Laboratory,
Research  Triangle Park, North Carolina. None  of these facilities  are fully
equipped now to conduct demonstrations nor do they all have the necessary
permits.

IV. B. 6.  Funding Mechanisms

  Funding and contractual arrangements may differ depending on the mode
of technology selection. Under the first approach, selection is normally made
from proposals  responding to a CBD solicitation. In these cases, agreements
between EPA and the developer will be either letter agreements or cooperative
agreements. Since no money will be exchanged, the agreement  does not
constitute a contract. In those cases where a  SITE demonstration  is part
of the  RI/FS process or the clean-up itself, the funding mechanisms will
be those routinely utilized for clean-up actions.
  Arrangements with other federal agencies will be made through normal
interagency agreements. There  may be  situations where a demonstration
uses special funding  mechanisms arranged through OSWER or an ORD
contractor.
  SARA authorizes expenditures of up to  $20 million each year through
fiscal year 1991 for the SITE program. EPA expects to receive $10 million
for the SITE program for the remainder of fiscal year 1987. The SARA limits
the amount of  Federal funds for any full-scale field demonstration project
to a maximum of  50 percent of the total  cost of the project at  the time
of agreement  with the developer. Since funding is limited  at the outset,
the Agency will not provide any Federal assistance for any part of  a full-
scale field demonstration project unless the developer can demonstrate that
he cannot obtain appropriate private financing on reasonable terms and
conditions sufficient to carry out the demonstration project without Federal
assistance.

IV.B. 7.   Quality Assurance/Quality Control (QA/QC)

  If the results of a demonstration are to be defensible and acceptable to
the  user community, a strong QA/QC program for each project is critical.
ORD and the developer will develop a QA/QC plan for each demonstration
that will be part of the Evaluation  Plan for the project. A discussion  of the
Evaluation  Plan requirements for demonstrations, including  QA/QC, is
presented  in Section IV.D. EPA will  be responsible for approving  the plan
and ensuring that the plan is followed. EPA and its contractor will collect
samples, conduct analyses, and interpret the data.

IV. B.8.   Reporting

  ORD will document the  results  of each  demonstration in a report that
includes testing procedures, data  collected, and QA/QC conducted. This
report will summarize the  results  in terms  of performance (effectiveness)
and cost.  It  will also discuss issues such  as applicability, pre- and post-
treatment requirements,  and advantages/disadvantages  compared  to
available technologies. EPA will be responsible for the report's distribution.
Data from  each demonstration will be available to the public following QA/
QC review and  approval. An applications analysis and technology transfer
program will also ensue from the demonstrations (see Chapter V).

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OSWER 9380.2-3

IV.B.9.   Proprietary and Patented Processes

  The demonstration program will not discriminate against proprietary or
patented processes. In fact, EPA will  give priority to processes owned by
firms that intend  speedy  commercialization.  EPA will  not  claim  these
proprietary and patented processes. However,  developers will be required
to make available  to  EPA, under appropriate  confidentiality  agreements,
sufficient design and operating information to evaluate process  potential.

IV. B.I 0.  Annual Site Program Plan

  The SITE demonstration program will be administered  by a steering
committee composed of individuals from OSWER and ORD. This committee
will evaluate the technology proposals submitted  under the first approach
(CBD notices) and, with assistance of EPA Regional offices  and other federal
agencies,  will tentatively match these technologies with appropriate sites.
The committee  will  then develop an annual program plan and distribute it
for public review.
  The plan will  list the demonstrations planned for the coming year, the
tentative locations for these demonstrations,  the resource  requirements for
conducting the  demonstrations, and the means for public  involvement and
input. The plan  will  also outline the overall SITE program and describe how
developers may submit their technologies for consideration  as demonstration
projects in subsequent solicitations.
  Technology evaluations conducted under routine  response actions (second
approach) will be included  in the annual SITE program plan to the extent
practical.  Some  evaluations may be identified, planned, and conducted in
less than one year, and thus will not be referenced  in  the annual  plan.
The  ORD/OSWER steering committee will establish overall guidelines to
be followed by the offices in conducting their respective portions of the
program.  Implementation  of  the  program  will  be within existing  line
organizations of OSWER and ORD and will include  extensive  coordination
with EPA regional offices and/or state agencies. The steering committee
will resolve issues and provide for Agency overview of the program's activities
and progress.

IV.C.   Selection  of Demonstrations

  The demonstration program is a cornerstone of  the SITE program.  SARA
calls for at least 10  demonstrations annually. Because  of its scale and
complexity and because all technology developers should be given access
to the program,  a multi-step procedure is envisioned. Figure IV-1 diagrams
the conceptual  flow of the program. The figure represents both approaches
to identifying and conducting demonstrations. As  previously discussed, the
conduct of demonstrations as a part of routine response actions will provide
an alternative to the proposal process and  the technology-site matching
process for identifying technologies and sites for evaluation.
   The solicitation and selection process outlined in Figure IV-1 is designed
to ensure that available technologies are identified and screened, that those
with the most potential are selected for demonstration, and that all developers
have access to the  program. The difficulty with the  current process is that
it calls for a relatively long lead time. It is probable that the lead time necessary
will become compressed as EPA gains experience with the process.
   The  principal steps  for selecting  demonstrations  are  (1) identifying
technologies ready for demonstration, (2) matching technologies with priority
sites, and (3) negotiating with the applicant. These steps are discussed in
more detail in the following sections.

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                                                       OSWER 9380.2-3

IV.C.1.   Identification of Technologies Ready for Demonstration

  To comprehensively conduct the demonstration portion of the SITE program,
it is essential that  as  many technologies as possible that are potentially
useful for cleaning up Superfund sites be considered. Technologies
considered will include  those developed privately as well as those developed
with the assistance of agencies other than EPA (e.g., DOD, DOE, states).
EPA already routinely demonstrates technologies that it has developed.
  Advertisements will  be placed in the Commerce Business  Daily (CBD).
These  ads will represent formal EPA solicitation  to provide all interested
parties with the opportunity to present the Agency with ideas, concepts,
or technologies that they believe are  ready for demonstration. The CBD
advertisement will tie directly to a planned annual selection of technologies
to be demonstrated in the SITE program. Individuals who miss the solicitation
will be considered during later selection cycles.
  Advertisement  will  be the primary process for identifying  privately-
developed technologies for potential demonstration.
  As discussed earlier, other approaches to solicit technologies, such as
evaluation of routine response actions, announcements at conferences and
symposia, and  review  of RD&D permits, will be used from time to time.
Under  these other approaches,  the  criteria for selecting technologies will
not change (see Section IV.B.1 and Appendix B).

IV. C.2.   Matching of Technologies with Priority Sites

  As discussed in Section IV.B.1,  technologies selected for demonstration
must be  able to treat high priority wastes, such as those wastes that are
difficult to treat or that are present frequently or in large volumes at Superfund
sites.
  To identify priority wastes, EPA will use (and modify, as needed) ongoing
OSWER studies of the types and quantitites of wastes present at Superfund
sites. Sources of information  include Records of Decision (RODs), ongoing
RIs and FSs, and Superfund site data bases, such as CERCLIS and Hazard
Ranking System (MRS).
  Once  EPA  has chosen promising  technologies  that   are ready for
demonstration, the  Agency will determine which  hazardous waste site is
most appropriate for each demonstration. As noted before, the sites of highest
priority for SITE demonstrations will  be Superfund  sites. However, EPA will
also  consider state, DOD, DOE, and private  site cleanups.  The overriding
criterion for site selection will be where the demonstration can be performed
expeditiously and the most useful information gathered. The important factors
that  EPA will consider  in choosing the location of a demonstration are  in
Section IV.B.1.
  OSWER will work closely with the EPA Regional Superfund staff, the states,
and other agencies to determine the sites most appropriate for demonstrating
the available  technologies.   Under  the  second  approach to identifying
demonstrations as  a  part of routine response  actions,  an independent
evaluation of the technology and the site will not be necessary. Most  likely,
EPA will have already  considered the factors given above  in the decision
to respond to the site cleanup using the chosen technology. However, EPA
will consider whether a SITE demonstration in conjunction with the planned
action  will  provide information  useful to  other sites. EPA expects that,  in
most of these cases, the demonstration will be beneficial.
  If EPA identifies more candidate demonstrations than the annual program
can accommodate, the  Agency will perform the demonstrations in order of
priority, considering  such factors as the availability of each developer's unit
and the urgency of the  need for testing the technology and/or waste. The

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     Figure IV-1.     Demonstration program structure.
                                                                                                 O
                                                                                                 GO
                 Identify and Prioritize
                   Wastes of Interest
                       f OSWER)
10
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     Identify and
Prioritize Technologies
  of Interest tOSWER)
                                                  Screen/Prioritize
                                                        Sites
                                                     tOSWER)
                                                      Evaluate
                                                     Community
                                                     Acceptance
                                                 tOSWER/Regions)
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  Activities (OSWER)
                                                               Revise/Resubmit
                                                                  (Applicant)
                                                   Incomplete
                                                   Application
                                                          Project
                                                          Not
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                                                          Interest
                                                   Not Ready
                                                    for Demo
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                                           Low Priority, Inadequate Resources
                                                                                Match Technologies
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                                                                                tOSWER/Regions)
                                                   No Available Site
                                                                                  _T
33
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00
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-------
     Figure IV-1     (Continued)
Implement Site-
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Relations Activities
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Draft and Publish
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(OSWER/ORDf
ro
u
                              Conduct
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  Analysis
  /OSWERI
                            Publish NT/S
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                               (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
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    f    ) indicates Office with lead responsibility
Publish Final
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Finalize Technology/ Site
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Write Technical •*- Demonstration
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Develop Evaluation
Plan
fORD)


Negotiate Agreement
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                                                                                                                      33
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OSWER 9380.2-3

final ranked list of demonstration  projects for each round will be chosen
by the  steering committee  consisting of representatives from ORD  and
OSWER. EPA will compile information on each of these demonstrations in
the Annual SITE Program Plan. ORD will publish and solicit  comments on
this document from the public, other EPA offices, and other agencies. After
revisions based on the comments,  the document will become the baseline
for tracking the execution of the SITE demonstrations.

IV. C.3.  Negotiations with Applicant

  Successful candidates  (or applicants whose technologies were selected
by public solicitation) will  negotiate  with the Agency to determine:
• The   mechanism  used  for  the  agreement  (e.g., contract, cooperative
  agreement, letter agreement).

• The  degree of cost sharing, if any.

• The  conditions placed on each party by the agreement.

  In carrying out the SITE program, the  SARA authorizes this Agency to
enter into contracts and cooperative agreements with, and make grants to,
persons, public entities and nonprofit private entities which are exempt from
tax under the Internal Revenue Code. In addition, the Agency is encouraged,
to the   maximum extent  possible,  to  enter  into appropriate cost sharing
arrangements.  This  financial  mechanism has  the advantage of greater
flexibility than the previous law which did not permit cooperative agreements
to private  and nonprofit organizations  for  research,  development,  and
demonstration purposes.
  The  degree  of cost sharing required of an applicant may depend on  a
number of factors such as the status  of process  patents,  the ability  of the
applicant to finance  the  demonstration,  the  financing  available  from the
Agency, the priority of a particular technology/waste/site  combination, and
the number of technologies available for demonstration during the particular
selection cycle. Usually, the developer will  pay all costs to build, locate onsite,
operate, and dismantle cleanup equipment  being demonstrated. Normally,
there will be no direct payment to the applicant. EPA may fund some activities
associated with site  preparation (e.g.,  construction of concrete pads). EPA
will pay for the specific costs associated with sampling and analysis, quality
assurance and  quality control, evaluating data, and preparing reports. EPA
will also assist the developer with permit development, as required. EPA
personnel and a support contractor will evaluate each project. If a technology
is unique, high in financial risk, unusually promising, and the developer is
unable to pay, EPA will consider bearing  a greater  portion of the total cost
of the  project. Where EPA bears these costs, a contractor other than the
developer will normally be employed.
  An important aspect of any agreement with  an applicant will be the
particular conditions that  the Agency requires. These conditions could vary
from demonstration to demonstration, will be devised at  selection time, and
will include such factors as:

  1.  The specific experimental design for the demonstration indicating  waste
     type, quantity of waste, operating conditions,  points of  sampling and
     analysis, needed replicates for analysis, and the statistical degree of
     confidence.

 2.  An evaluation  plan  showing approved  EPA  sampling  and analysis
     methods and appropriate quality assurance.

                                 24

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                                                        OSWER 9380.2-3

  3.  The location of the demonstration (e.g., National Priorities List [NPL]
     sites, proposed NPL sites, DOD sites, and offsite locations).

  4.  The definition  of the  party responsible for activities related to  the
     demonstration (e.g., obtaining permits and site activity liability).

  5.  Responsibility and procedures for reporting demonstration results.

  6.  An agreement  to include the technology in a cross-comparison with
     technologies evaluated in other demonstrations, and/or any long-term
     monitoring and testing required to verify expected long-term results.

  7.  Communication with the public before and during the demonstration.
  These factors are usually considered after the applicant is selected. The
time required  for ORD to negotiate the conditions  may be as long as six
months.
  Under  the  second technology selection  approach,  where  technologies
selected  by the response action for application  at  a  given site  are to be
evaluated, normal Superfund contractual arrangements will  be  used and
will often be  in place by the time  EPA decides the  conditions of the SITE
evaluation. In a few instances, it may be necessary to modify such contracts
to accommodate the particular aspects of the evaluation.
IV.D.  Evaluation Plan

  The developer of the technology (developer) and the EPA Project Manager
(PM), along  with the  site  manager  (the EPA Regional  Project Manager at
an NPL site),  will develop a mutually satisfactory detailed design of  the
technology demonstration, testing, and  evaluation program  The  design
should include specifications of all activities needed to meet the information
objectives described previously These activities should include, but not be
limited to, the following.

• Testing program duration and schedule

• Testing site requirements.

• Development of a detailed evaluation design

• Sampling and analytical program.

• QA/QC program.

• Health and safety requirements.

• Public information fact sheets, newsletters.


  The time needed to  prepare, review, and approve each test plan will vary
with the complexity of the plan.  Once several  plans have been designed
and successfully executed and a detailed, successful "model" is available,
EPA expects that approximately 60 days will usually be required.

                                  25

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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

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                                                      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

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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

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                                                       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

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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

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                                                        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

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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

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                                                       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

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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

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                                                       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

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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.

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                                                         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

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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.
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                                                      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

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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

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                                                    OSWER 9380 2-3

Waste News, Industrial Chemical News, Plant Engineering, Science, and
Journal of Environmental Engineering. Also, program  information and
updates of demonstrations will be sent to professional associations m
hazardous waste technology industries for notices to be placed in their
journals  These magazine and journal articles will encourage companies
with "ready-to-demonstrate" treatment processes to contact designated
individuals at EPA's Hazardous Waste  Engineering Research Laboratory
Representatives of the SITE program will  attend major hazardous waste
conferences that are  held in  the  United  States to explain the program
and solicit projects from interested process developers.
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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

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PRP




QA/QC




RCRA




Rl




R&D




RD&D




RFP




ROD




SAB




SARA




SITE




T&E
                                  OSWER 9380.2-3



Potentially Responsible Party




Quality Assurance/Quality Control




Resource Conservation and Recovery Act




Remedial Investigation




Research and Development




Research, Development, and Demonstration




Request for Proposal




Record of Decision




Science Advisory Board




Superfund Amendments and Reauthorizatlon Act




Superfund Innovative Technology Evaluation




Testing and Evaluation
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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
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                                                        OSWER 9380.2-3

A.   Technology Factors

      1.   Description of Technology

          Describe in detail the technology the developer is proposing for
          demonstration or development testing. Include the concepts on
          which the technology is based and all equipment and  process
          steps involved in its use. Provide narratives, diagrams, drawings,
          and/or  photographs of the technology.  Appropriately label
          proprietary or confidential information so that the information can
          be protected.
      2.   Identification  of Effective Operating Range

          Describe  in  detail the  operating range,  effectiveness, and
          limitations of  the proposed technology. Operating  limitations may
          be physical, chemical, or other. Examples of limiting  factors are
          concentration, temperature, viscosity, and volatility of contami-
          nants, or the presence of certain types of interfering compounds.
          Append technical papers, operating data, existing permit-related
          information, and other specific support information, if  available.

      3.   History of Development

          Describe the relevant progressive stages of development that cover
          the technology  from its conception to its present stage  of
          development, including work by others; bench-, laboratory-, and
          pilot-scale tests;  and/or in-field applications. Append  detailed
          performance data, if available.
      4.   Applications to Hazardous Waste Site Cleanup

          Describe any applications relating to hazardous waste site cleanup,
          with specific references to the applicable types of contaminants
          and types of wastes (water, soil, sediments, sludges, etc.).  Discuss
          the versatility of application. Provide specific  references for
          previous or related  uses, if  available. Provide details regarding
          specific  materials  handling  or  feed  preparation  requirements,
          including detailed specification  of any pre-  and  post-treatment
          processes. Identify whether the process is  primarily onsite or
          offsite.

      5.   Mobility of Equipment

          Include the following points in  a description and discussion of
          a mobile treatment system:

          •  Suitability  to endure transport to  sites  and onsite assembly
             without extensive maintenance.

          •  Ease  and  safety  of operation under field conditions, with a
             minimum of personnel.

          • Time  required to mobilize and demobilize the system and to
            decontaminate it after use.

          • Specific site operating requirements, including specific details
            regarding power, fuel(s), water, and wastewater.

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OSWER 9380.2-3

      6.  Capital and Operating Costs

            Document and discuss the following cost items:

          •  Capital  cost,  including a breakdown of major components of
             this cost.

          •  Operating cost, including a detailed list of types of requirements
             and the cost of each.

          •  Waste pre-treatment  and post-treatment costs, if applicable,
             including  specific description  of  any feed  preparation
             requirements and associated costs.

          •  Ability to recycle residues, or process streams, if applicable.

       7.  Advantages Over Existing Comparable Technologies

          Identify and describe the most significant commercially available
          comparable technology that now performs essentially the same
          function  as  the  proposed technology. Present a detailed
          comparison  of the advantages and  disadvantages  of  the
          comparable  and the  proposed technology, and  tell why  the
          proposed technology is a  significant improvement when compared
          to the technology currently being used. The comparable technology
          does not have to be similar m design but must perform the same
          overall function as the  proposed  design.  Describe  specific
          comparisons with   regard to  hazardous waste  site cleanup.
          Comparisons should include logistics, effectiveness, health  and
          safety, environmental effects, and details of cost  competitiveness.
          If the proposed technology addresses a hazardous waste handling/
          cleanup problem where no conventional technology exists, make
          the comparisons in relation to present practices.

       8.  Identification of Health, Safety,  and Environmental Problems

          Describe any potential risks to the health and safety of operating
          personnel and to  the  environment  by systematic and/or
          inadvertent release of hazardous materials resulting from the use
          of the technology  Include any results of bioassays performed on
          feed materials, emissions, or discharges generated during the use
          of the technology and on final residues after treatment, if any
          A description of how the developer will deal with any anticipated
          problem is also required For example,an emergency vent or high
          pressure  treatment  process  valve  may open under specific
          operating conditions. What materials would be vented and in what
          volumes?  What conditions would cause the vents to open?  Will
          the process have any potential to create an explosive or flammable
          atmosphere? If so,  under exactly what conditions,  and  how are
          these conditions controlled?

B.   Capability of the  Developer

      1   Development of Other Technologies

          Describe and  discuss any prior or current work relevant to  the
          technology development and testing of the proposed technology.

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                                                       OSWER 9380.2-3

          Place particular emphasis on technologies for hazardous material
          handling  and  cleanup  and on  the  degree of  success  of  the
          technologies. Provide specific references, if available.

      2.   Completion of Field Tests

          Describe field tests programs and demonstration tests that have
          been completed. Emphasize the application of hazardous material
          control technologies. Append  data, technical papers,  and other
          specific reference materials, if available.

      3.   Experience of Personnel

          Describethe level of relevant experience of key personnel proposed
          for the testing program, as well as the personnel involved in
          developing the offered  technology  Provide  references for each
          key person. Discuss the experience and training of all operating
          personnel

      4.   Assignment of Personnel

          Describe and discuss the extent to which the developer proposes
          to dedicate time of key personnel to the testing  program

      5.   Credentials of Personnel

          Describe  and  discuss  the level  of academic  and  professional
          achievement or recognition (degrees,  awards, patents, etc  ) of
          proposed key personnel

      6.   Capability  to Commercialize Technology

          Describe  and discuss the extent to which  the developer
          demonstrates the financial capability and  commitment to make
          the technology widely commercially available,  including sources
          of capital and financial statements Provide independent sources
          of information, if possible. Provide a certification of commitment
          to the future use of the technology by a  corporate officer

      7.   Marketing  of Technology

          Describe  and  discuss  the extent to which the developer  has
          analyzed and targeted the market for the offered technology  and
          has developed  a marketing plan.  Provide examples of successful,
          related  marketing  efforts.  Provide  independent  sources of
          information, if possible

C.  Approach to Testing

      1   Operations Plan

          Describe  and  discuss  the developer's step-by-step  plan  for
          conducting the evaluation program. Include in the plan all  details
          that the  developer considers relevant m showing that  the
          evaluation will be conducted smoothly  and  will demonstrate  the
          advantages of the  technology  Emphasize factors relating to

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OSWER 9380.2-3
          hazardous waste site cleanup, including the health and safety
          of operating personnel. Discuss the effectiveness of the technology
          with regard to the range of materials and  conditions that  are
          applicable.  Describe in the plan how the necessary equipment
          and materials will be  mobilized and set up for tests. Discuss the
          anticipated site preparation activities. Show how each step of the
          testing program  is  expected  to contribute to  the  overall
          demonstration of the  effectivenesss and  range of application of
          the technology. Address  decontamination and demobilization of
          the equipment and the estimated duration of the testing program.

       2.  Materials and Equipment

          Describe and identify  materials (including  feedstock) and
          equipment necessary to conduct the testing program.

       3.  Range of Testing

          Describe the degree to which the developer proposes to  test the
          technology to its extremes of effectiveness and applicability (e.g.,
          identify the limitations and constraints of the technology). Specify
          the variables to be adjusted and the effect of each, as described
          in the Statement of Work,  "Development of  Detailed Evaluation
          Plan."

       4  Monitoring Plan

          Describe and discuss the  proposed  monitoring of the technology's
          effectiveness and  coordination with the operations plan. In the
          monitoring plan include  sampling  and analytical plans,  QA/QC
          plans, any plan for statistical validation of results, and accounting
          for mass balance of  materials. The developer will conduct the
          sampling and analytical  activity needed  to  monitor the  correct
          operation of the system.  EPA will conduct the sampling  and
          analytical activity to determine  the  removal or  reduction of
          contaminants in treated wastes.

       5.  Quality Assurance Project Plan

          Provide information from which a quality assurance project plan
          will be developed if your technology is selected. This information
          shall include the following:

          • A statement of policy concerning the developer's commitment
             to implement a QA program.

          • An organizational chart  showing the  position  and  the
             identification of the QA person(s) within the organization

          • A delineation of the authority and responsibilities of the QA
             group members and their  related  quality assurance respon-
             sibilities to the organization.

          • The procedures for sample  collection,  handling,  identification,
             preservation, transportation, and storage.

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                                                   OSWER 9380.2-3

      • A description of measurement methods or test procedures with
        statement  of  performance  characteristics  if methods  are
        nonstandard.

      • The standard QA/QC procedures to be followed (nonstandard
        procedures to be documented).

      • The statistical objectives clearly set forth.

 6.  Assignment of Responsibilities

      Describe and identify responsibilities of the testing personnel and
      assignment of responsibilities to specific individuals. Also, identify
      individuals responsible for executing  the QA/QC aspect of the
      testing program.

 7.   Backup Treatment System Plan

      Describe and discuss the proposed plan for control of discharges
      of residual hazardous materials resulting from the testing program
      (e.g., from stacks or as processed liquids or solids) that may occur
      if the tested system is intentionally operated outside of its intended
      operating range. To what extent would "back-up" emission control
      equipment for vapor/gaseous  release or  additional treatment
      equipment for liquid or solid discharges be necessary?

 8.   Regulatory Compliance Plan

      Describe, identify, and cite the measures that have been  taken
      to ensure compliance  with applicable federal, state, and  local
      regulations. Also,  describe the steps that  need to  be  taken to
      ensure compliance with regulations. EPA will assist in obtaining
      permits for conducting the evaluation.

      Note:  The developer may propose to evaluate  the technology
            either at a test facility (see #9 below) or at  a hazardous
            waste site (see #10 below).

 9.   Test Facility Requirements

      a.  Testing at the  Developer's Facility. Describe and identify the
         proposed test facility and the extent to which the facility meets
         the  requirements of  the  testing program. The facility must
         be available for testing.

      b.  Testing at EPA -designated Facility. Describe requirements for
         a testing facility that will be necessary to conduct a successful
         evaluation of the technology.  EPA will select, in cooperation
         with the  developer, a suitable testing facility from among
         several EPA-owned testing facilities.

10.  Waste Site Requirements

     Propose that testing be conducted either at the developer's own
     waste site,  at another private waste site, or at a Superfund site.
     Describe and discuss the site characteristics that will be necessary

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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.
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