United States Office of Directive:92OO.5-1 62
Environmental Protection Solid Waste and EPA/54O/R-95/1 28
Agency Emergency Response PB 95-96341 O
Washington, DC 2O46O
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Superfund
Presumptive Remedies for
Soils, Sediments, and Sludges
at Wood Treater Sites
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EPA/54O/R-95/1 28
December 1 995
Presumptive Remedies for
Soils, Sediments, and Sludges
at Wood Treater Sites
Office of Emergency and Remedial Response, 52O2G
Washington, DC 2O46O
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Notice:
The policies set out in this document are intended solely a
guidance to U.S. Environmental Protection Agency personnel
they are not final EPA actions and do not constitute rulemaking.
These policies are not legally binding and are not intended, no
can they be relied upon, to create any rights enforceable by an
party in litigation with Ihe United States. EPA officials mji
decide to follow the guflance provided in this document, or to act
at variance with the guidanc, based on an analysis of specific site
circumstances. EPA also reserves the right to change thi
guidance at any time without public notice.
Additional copies of this
document may be obtained
from:
National Technical
Information Service (NTIS)
U.S. Department of
Commerce
5285 Port Royal Road
Springfield, VA 22161
(7O3) 487-46OO
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TABLE OF CONTENTS
INTRODUCTION 1
PURPOSE 1
USE OF THIS DOCUMENT 2
ANTICIPATED BENEFITS OF PRESUMPTIVE REMEDIES
2
DESCRIPTION OF WOOD TREATER SITES 4
PRESUMPTIVE REMEDIES FOR WOOD TREATER SITES
6
Bioremediation 6
Thermal Desorption 7
Incineration 7
Immobilization 8
PRESUMPTIVE REMEDY PROCESS FOR WOOD
TREATER SITES 8
CONCLUSION 15
GLOSSARY 49
REFERENCES 51
APPENDIX A:
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES 31
APPENDIX B:
EVALUATION OF SELECTION CRITERIA FOR
TECHNOLOGIES USED TO TREAT
CONTAMINATED
SOILS, SEDIMENTS, AND SLUDGES AT WOOD
TREATER SITES 41
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LIST OF TABLES
TABLE 1 : Evaluation of Presumptive Remedy Technology
Options 11
TABLE 2: Comparison of Presumptive Remedy Technologies
2O
TABLE 3-A: Data Requirements for Bioremediation . . . 26
TABLE 3-B: Data Requirements for Thermal Desorption 28
TABLE 3-C: Data Requirements for Incineration 29
TABLE 3-D: Data Requirements for Immobilization . . . 3O
TABLE A-1 : Remedies Selected at NPL Wood Treater SitfeS
TABLE A-2: Summary of Initial Screening Phase For Wood
Treater Sites 34
TABLE A-3: Summary of Detailed Analysis Phase For Wood
Treater Sites 37
LIST OF BOXES
BOX A: Ground-Water Considerations 3
BOX B: Contacts for Additional Information 4
BOX C: Contaminants Commonly Found at Wood Treater Sites
5
BOX D: Background Information on NAPL Contamination 1 6
BOX E: Practical Considerations 18
LIST OF FIGURES
FIGURE 1: Decision Tree for Technology Selection at Wood
Treater Sites 9
FIGURE D-1 : Components of DNAPL Sites 17
FIGURE D-2: Types of DNAPL Contamination and Contaminarti
Zones at DNAPL Sites
(Cross-Sectional View) 17
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INTRODUCTION
Since the enactment of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
(CERCLA or Superfund), the Superfund remedial and
removal programs have found that certain categories of sites
have similar characteristics, such as types of contaminants
present, disposal practices performed, or environmental media
affected. Based on information acquired from evaluating and
cleaning up these sites, the Superfund program is undertaking
an initiative to develop presumptive remedies to accelerate
future cleanups at these types of sites. The presumptive
remedy approach is one tool for speeding up cleanups within
the Superfund Accelerated Cleanup Model (SACM). This
approach can also be used to streamline remedial
decisionmaking for corrective actions conducted under the
Resource Conservation and Recovery Act (RCRA).
Presumptive remedies are preferred technologies for common
categories of sites, based on EPA's experience and its
scientific and engineering evaluation of alternative
technologies. The objective of the presumptive remedies
initiative is to use the Superfund program's experience to
streamline site characterization and speed up the selection of
cleanup actions. Over time, presumptive remedies are
expected to ensure consistency in remedy selection and reduce
the cost and time required to clean up similar types of sites.
Presumptive remedies are expected to be used at all
appropriate sites except under unusual site-specific
circumstances.
This directive identifies the presumptive remedies for wood
treater sites with contaminated soils, sediments, and sludges.
EPA has developed guidance on presumptive remedies for
municipal landfill sites [33] and sites with volatile organic
compounds (VOCs) in soils [32]. EPA is also in the process
of developing guidance on presumptive remedies for
polychlorinated biphenyl (PCB), grain storage, manufactured
gas plant, and contaminated ground-water sites. In addition,
EPA has developed a directive entitled Presumptive
Remedies: Policy and Procedures [31], which outlines and
addresses the issues common to all presumptive remedies
(e.g., the role of innovative treatment technologies).
Bold and italicized terms are defined in the Glossary at the
end of this document The References section at the end of
this document provides a list of supporting guidance
documents that may be consulted for additional information on
relevant topics. Bracketed numbers [#] appear throughout the
text to indicate specific references in the References section.
PURPOSE
The purpose of this directive is to provide guidance on
selecting a presumptive remedy or combination of
presumptive remedies for wood treater sites with
contaminated soils, sediments, and sludges. Specifically, this
guidance:
• Describes the contaminants generally found at wood
treater sites;
• Presents the presumptive remedies for contaminated
soils, sediments, and sludges at wood treater sites;
• Describes the presumptive remedy process concerning
the site characterization and technology screening steps;
and
• Outlines the data that should be used to select a
presumptive remedy.
The presumptive remedies for wood treater sites with soils,
sediments, and sludges contaminated with organic
contaminants are bioremediation. thermal desorption. and
incineration. The presumptive remedy for wood treater sites
with soils, sediments, and sludges contaminated with
inorganic contaminants is immobilization. The section of this
document entitled "Presumptive Remedies for Wood Treater
Sites" provides a brief description of each of these
technologies.
The decision to establish these technologies as presumptive
remedies for this site type is based on EPA's accumulated
knowledge about site characterization and remedy selection
for wood treater sites with contaminated soils, sediments, and
sludges, including actual performance at Superfund and
RCRA sites. This decision is also based on an analysis
conducted by EPA on Feasibility Studies (FSs) and Records
of Decision (RODs) for sites where wood treating
contaminants in soils, sediments, and sludges drove remedy
selection. The results of this analysis, which are summarized
in Appendix A (Technical Basis for Presumptive Remedies),
demonstrate that these four technologies represent
approximately 84% of the remedies selected in the FSs and
RODs analyzed. The FS/ROD analysis also provides
information on why other, non-presumptive technologies
generally are not effective and/or appropriate for cleaning up
wood treater sites with contaminated soils, sediments, or
sludges.
USE OF THIS DOCUMENT
This directive is designed to assist Superfund site managers
(i.e., Remedial Project Managers (RPMs) and On-Scene
Coordinators (OSCs)) and other personnel in selecting
remedies for cleaning up soils, sediments, and sludges at wood
treater sites that are contaminated primarily with creosote.
pentachlorophenol. and/or chromated copper arsenate. Site
managers in other programs, such as the RCRA corrective
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action program or the private sector, may also find this
document useful. For example, the information contained in
this document could be used to eliminate the need for an
alternatives screening step and streamline the detailed analysis
of alternatives in the RCRA Corrective Measures Study,
which is analogous to the FS under CERCLA.
Wood treater sites that have contaminated soils, sediments,
and sludges often have contaminated ground water as well. At
some of these sites, the contaminated soils, sediments, or
sludges may not require treatment or may only need to be
contained, depending on the degree of human health and
environmental risk posed by the contaminated soils,
sediments, or sludges as determined in the removal site
evaluation and/or remedial site evaluation (i.e., the
preliminary assessment/site inspection (PA/SI)). At some
sites, a combination of treatment options may need to be
implemented to address the contamination of ground water as
well as soils, sediments, and sludges. When addressing
contamination at wood treater sites, site managers should
consider the impact of contamination across all environmental
media. In particular, site managers at wood treater sites
should consider the impacts of ground-water contamination.
EPA is currently developing guidance on a presumptive
remedy approach for responding to contaminated ground-
water sites. When available, this guidance should be used to
address ground-water contamination at wood treater sites.
Site managers should also consult existing guidance on the
remediation of contaminated ground water [6,7,17,20,38].
Box A provides a brief discussion of ground-water
considerations for wood treater sites that is consistent with
existing guidance and the forthcoming presumptive remedy
ground-water approach. In addition, Box D provides
background information on non-aqueous phase liquid (NAPL)
contaminants, including dense NAPLs (DNAPLs or sinkers)
and light NAPLs (LNAPLs or floaters).
The presumptive remedy evaluation and selection process
described in this document is consistent with and fits into the
more detailed conventional remedy selection process outlined
in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP, 40 CFR Part 300). The Agenc y
believes that the presumptive remedies set out in this
document represent appropriate response action alternatives
for sites meeting certain criteria and, therefore, generally
should be used. However, remedy selection for an individual
site may vary because of specific site characteristics or
community or state concerns. Although it may still be
possible to accelerate remedy selection for non-presumptive
technologies, such selection will not be able to take advantage
of the generic justification provided by this document Under
these circumstances, a conventional Remedial
Investigation/Feasibility Study (RI/FS) or Engineering
Evaluation/Cost Analysis (EE/CA) should be performed.
Guidance on circumstances in which a presumptive remedy
might not be appropriate is found in Presumptive Remedies:
Policy and Procedures [31]. When determining whether a
remedial or removal action is the appropriate method for
cleaning up a wood treater site, site managers should consult
the NCP and Superfund program guidance. Also, the Agency
is currently developing a fact sheet to assist RPMs and OSCs
in identifying the factors affecting the site-specific
determination of whether a Superfund early action is best
accomplished as a non-time-critical removal action or an early
remedial action.
This directive is not a stand-alone document. To ensure a full
understanding of wood treater site characterization and
remedy selection, site managers should refer to the FS/ROD
analysis, which is summarized in Appendix A of this
document, and the documents cited as references at the end of
this document Site managers unfamiliar with certain complex
site conditions at wood treater sites should consult with
experienced site managers, the contacts listed in Box B of this
document, the Superfund Technical Assistance Response
Team (START), or the Environmental Response Team
(ERT). EPA is continuing to gather and develop more
information on the remedies selected and implemented at
wood treater sites.
ANTICIPATED BENEFITS OF
PRESUMPTIVE REMEDIES
The use of this document is expected to reduce the costs and
time required for remedy selection at wood treater sites. This
directive should be used to:
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BOX A
Ground-Water Considerations
Woodtreater sites typically involve subsurface DNAPIand/or LNAPL contaminants (see Boxes C and D) in addition to
contaminated soils, sediments, or sludges. All of these materla are sources of contamination of the underlying ground water
and need to be conidered when planning an overall site response. A key element of all existing ground-water remediation
guidance is that site characterization and response actions should be implemented in phased approach. In a phased
approach, site response activities are conducted in a sequence of steps, such that information obtained from earlier steps is
used to refine subsequent investigations, objectives, or actions. The recommended strategy for sites with NAP
contamination, such as wood treater sites, includes the following response actions and objectives [17].
Site investigationsshouldbe designed to delineate both NAPL zones and aqueous plumes. NAPL zones are those portions
of the site where LNAPL orDNAPL contaminants (in thform of immiscible liquids) are suspected in the subsurface, either
above, at, or below the water table. Ajueous plumes are portions of the site where contaminants are present in solution and
not as immiscible liquids.
Early actions should be used to:
• Prevent exposure, both current and future, to ground-water contaminants;
• Prevent the further spread of the aqueous plume (plume containment);
• Control the further migration of contaminants! ground water from contaminated soils and subsurface NAPLs,
where practicable (source containment); and
• Reduce the quantity of source materiapresent in the subsurface (free-phase DNAPL), to the extent practicable
(source removal/treatment).
Long-term remedial actionsshould be used to:
• Attain those objectives listed above that were not accomplished as early actions;
• Minimias further release of contaminants from soils and subsurface NAPLs to the surrounding ground water
(source containment);
• Reduce the quantity of source material present in the NAPL zone (free- and residual-phase), to the exttn
practicable (source removal/treatment); and
• Restore as much of the aqueous plume as pssible to cleanup levels (e.g., drinking water standards) appropriate
for its beneficial uses. These beneficial uses should take into accouranticipated future land use(s) (aquifer
restoration).
For more information on NAPL contamination, see Box D.
1. Identify the presumed or likely remedy options u p Action Memorandum, thereby allowing the action to
front and allow for a more focused collection of data proceed more quickly after signature of the decision
on the extent of contamination. document.
This presumptive remedy guidance allows for the
evaluation of only the primary cleanup alternative or a
narrow range of options. The judgment as to whether
evaluation of only the primary remedy is appropriate
will depend on the degree of complexity and uncertainty
at a site. Also, it may be appropriate to collect certain
remedial design data before the drafting of the ROD or
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BOX B
Contacts for Additional
Information
Headquarters Policy Contacts:
Frank Avvisato, Wood Treater
Project Manager (703)603-8949
Scott Fredericks, Presumptive Remedies
Team Leader (703)603-8771
Technical Contacts:
Harry Allen, Environmental Response
Team (908) 321-6747
Frank Freestone, Office of Research
and Development (908) 321 -6632
Regional Contacts:
I Mike Nalipinski
II Mel Hauptman
HI Paul Leonard
IV Felicia Bamett
V Dion Novak
VI Cathy Gilmore
VII Diana Engeman
Vffl Victor Ketellapper
DC Craig Cooper
X Eric Winiecki
(617)223-5503
(212) 637-3952
(215)597-3163
(404) 347-7791
(312)886-4737
(214) 665-6766
(913)551-7746
(303)293-1648
(415)744-2370
(206) 553-6904
2. Eliminate the need for the initial step of screenin g
alternatives during the FS or EE/CA.
The NCP (section 300.430(e)(l)) states that the lead
agency shall include an alternatives screening step when
needed [emphasis added] to select a reasonable number
of alternatives for detailed analysis. The Agency
performed an analysis of FSs and RODs on the
potentially available technologies for soils, sediments,
and sludges at wood treater sites (see Appendix A) and
found that certain technologies are appropriately and
consistently screened out based on the criteria of
effectiveness, implementability, and cost (consistent
with section 300.430(eX7)). Based on this analysis, the
Agency has determined that the initial step of identifying
and screening alternatives for FSs and EE/CAs for wood
treater
sites may not be necessary on a site-specific basis;
instead, the FS or EE/CA may proceed immediately
from the identification of alternatives to the detailed
analysis, focusing on the technologies recommended in
this directive. This document and the accompanying
FS/ROD analysis must be included in the
Administrative Record to provide the basis for
streamlining the analysis for wood treater sites in this
way.
3. Streamline the detailed analysis phase of the FS or
EE/CA.
Once cleanup alternatives pass the initial screening step,
they must be evaluated against the appropriate criteria
defined in the NCP. Appendix A of this document
summarizes the analysis EPA conducted on FSs/RODs
for wood treater sites with contaminated soils,
sediments, or sludges, and Appendix B provides generic
evaluations of the different presumptive remedies
against seven of the nine remedial criteria (excluding
state and community acceptance). Both of these
appendices should be used to streamline the detailed
analysis phase of the FS. Appendices A and B can also
be used to streamline the evaluation of removal action
alternatives in an EE/CA. The generic analyses in
Appendix B should be supplemented with site-specific
information for the final response selection. For a more
detailed discussion on preparing an FS or EE/CA, see
the references listed at the end of this document [16,19].
EPA expects that at least one of the presumptive
remedies will be suitable for a wood treater site with
principal threats that require the treatment of
contaminated soils, sediments, or sludges.
Circumstances under which other approaches may be
appropriate include: unusual site soil characteristics;
demonstration of significant advantages of innovative
technologies over the presumptive remedies; and
extraordinary community and state concerns. If such
circumstances are encountered, additional analyses may
be necessary or a conventional RI/FS or EE/CA may be
performed.
DESCRIPTION OF WOOD
TREATER SITES
The wood treating industry has been in existence in the United
States for over 100 years. Wood is usually treated in
cylinders, under pressure, with one or a combination of the
following types of preservatives:
• Pentachlorophenol (PCP) in petroleum or other
solvents;
• Creosote (in petroleum or other solvents);
• Aqueous solutions of copper, chromium, and arsenic;
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• Copper and arsenic, or copper, arsenic, and zinc
solutions in ammonia; and
• Fire retardants (combinations of phosphates, berates,
boric acid, and/or zinc compounds).
Older facilities traditionally used oil-based preservatives,
while more modern facilities tend to use water-soluble
preservatives. Water-soluble processes produce little or no
wastewater, except for small amounts of metal-containing
sludges. Oil-based processes produce sludge wastes and
significant quantities of process wastewater. The processes
performed at wood treater sites generally will result in
contaminated soils, sediments, and sludges, and/or
contaminated surface and ground water.
Box C provides a list of contaminants commonly found at
wood treater sites; general chemical categories of
contaminants are provided and specific chemicals or
substances are identified under each category. As indicated in
Box C, most of the organic contaminants found at wood treater
sites are NAPLs, either in the ir pure form or as components of
other substances that are NAPLs (e.g., petroleum fuels,
creosote). Site managers should refer to Box D for
background information on NAPLs and cleanup problems
associated with these contaminants.
The three types of contaminants predominantly found at wood
treater sites, either alone or in combination with each other -
or with total petroleum hydrocarbon (TPH) carrier oils ~ are
creosote, PCP, and chromated copper arsenate (CCA).
Creosote is an oily, translucent brown to black liquid that is a
very complex mixture of organic compounds, containing
approximately 85% polynuclear aromatic hydrocarbons
(PAHs), 10% phenolic compounds, and 5% nitrogen-, sulfur-,
or oxygen-containing heterocycles. PCP is also an organic
contaminant. In its pure form, PCP is a DNAPL; however,
PCP is commonly found at wood treater sites as an LNAPL
mixed into fuel oil or other
BOXC
Contaminants Commonly Found
at Wood Treater Sites
ORGANICS
Dioxins/furans1
• Dibenzo-p-dioxins
• Dibenzofurans
• Furan
Halogenated phenols'
• Pentachlorophenol
• Tetrachlorophenol
Simple non-halogenated anomalies2
• Benzene
• Toluene
• Ethylbenzene
• Xylene
Polynuclear aromatic hydrocarbons'
• 2-Methylnaphthalene
• Chrysene
• Acenaphthene
• Fluoranthene
• Acenaphthylene
• Fluorene
• Anthracene
• Indeno(l,2,3-cd)pyrene
• Benzo(a)anthracene
• Naphthalene
• Benzo(a)pyrene
• Phenanthrene
• Benzo(b)fluoranthene
• Pyrene
• Benzo(k)fluoranthene
Other polar organic compounds
• 2,4-Dimethylphenol
• 2-Methylphenol
• 4-Methylphenol
• Benzole acid1
• Di-n-octyl phthalate
• N-nitrosodiphenylamine
INORGANICS
Non-volatile metals (compounds of)
• Chromium
• Copper
Volatile metals (compounds of)
• Arsenic
• Cadmium
• Lead
• Zinc
1 DNAPL(s) in pure form.
1 LNAPL(s) in pure form.
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light organic substances. If PCP or other chlorinated phenols
are present at a site, associated dioxins and/or furans may also
be present in the approximate vicinity. If so, these dioxins
and/or furans will likely exist in much lower concentrations
than the associated chlorinated phenols. This document is not
designed to address sites containing high levels of dioxins
and/or furans. EPA is currently gathering information on the
issue of dioxin/furan contamination; site managers should
contact the Headquarters policy contacts listed in Box B for
more information on this topic. CCA is an inorganic arsenical
wood preservative. Other metal-containing preservatives that
may be found at wood treater sites include ammoniacal copper
arsenate (ACA) and ammoniacal copper-zinc arsenal e
(ACZA).
PRESUMPTIVE REMEDIES
FOR WOOD TREATER SITES
The presumptive remedies for contaminated soils, sediments,
and sludges constituting the principal threats at wood treater
sites are described below. Bioremediation is the primary
presumptive remedy for treating organic contamination of
soils, sediments, and sludges at wood treater sites.
Bioremediation has been selected as the primary presumptive
remedy for treating organic contamination because it has been
selected most frequently to address organic contamination at
wood treater Superfund sites, and the Agency believes that it
effectively treats wood treating wastes at a relatively low cost.
If bioremediation is not feasible, thermal desorption may be
the more appropriate response technology. In a limited
number of situations (e.g., the treatment of "hot spots" such as
sludges), incineration may be the more appropriate remedy.
Immobilization is the primary presumptive remedy for treating
inorganic contamination of soils, sediments, and sludges at
wood treater sites.
An important consideration in determining which presumptive
remedy technology is the most appropriate for a particular site
is the future land use or uses anticipated for that site (see
reference [27] and Box E of this document for more
information on land-use considerations). Another important
consideration in selecting the most appropriate presumptive
remedy technology is determining what are the principal
threats and low-level threats (including possible treatment
residuals) at a site. Treatment technologies are the preferred
remedies for addressing principal threats, while containment
technologies in conjunction with institutional and/or
engineering controls, are most likely to be appropriate for
addressing low-level threats. Table 2 (Comparison of
Presumptive Remedy Technologies), which is found at the end
of this document, provides detailed information on the
advantages, limitations, and costs of each of the presumptive
remedies.
At many wood treater sites, it may be necessary to use a
combination of control and treatment options as part of an
overall treatment train to sufficiently reduce toxicity and
immobilize contaminants. Institutional and/or engineering
controls can be used in conjunction with one or more of the
presumptive remedy technologies to enhance the long-term
reliability of the remedy. Site managers should note that all ex
situ remedy options require measures to protect workers and
the community during the excavation, handling, and treatment
of contaminants, and may be subject to RCRA land disposal
restrictions. Box E (Practical Considerations) provides a
discussion of land use, institutional and engineering controls,
treatment trains, the remediation of "hot spots," and land
disposal restriction issues.
Bioremediation — Bioremediation is the chemical
degradation of organic contaminants using microorganisms.
Biological activity (i.e., biodegradation) can occur either in the
presence (aerobic) or absence (anaerobic) of oxygen. Aerobic
biodegradation converts organic contaminants to various
intermediate and final decomposition products, which may
include various daughter compounds, carbon dioxide, water,
humic materials, and microbial cell matter. Aerobic
biodegradation may also cause binding of the contaminants to
soil components, such as humic materials. Anaerobic
biodegradation converts the contaminants to carbon dioxide,
methane, and microbial cell matter.
Bioremediation may be an ex situ or in situ process. Ex situ
bioremediation refers to the biological treatment of
contaminants following excavation of the soil or other media,
and includes composting, land treatment in lined treatment
cells, treatment in soil piles, or the use of soil slurry reactors.
In situ bioremediation is the in-place treatment of
contaminants, and may involve the addition of nutrients,
oxygen, or other enhancements into the subsurface.
EPA has more experience in implementing ex situ
bioremediation than in situ bioremediation. In general, ex situ
bioremediation is faster than in situ bioremediation, although
the implementation of either ex situ or in situ bioremediation
typically can require several years, as compared to
approximately six months to a year for technologies like
thermal desorption or incineration. In situ bioremediation
may be less costly than ex situ bioremediation. However, at
some wood treater sites, ex situ bioremediation may be able to
achieve higher performance efficiencies than the in situ
process due to increased access and contact between
microorganisms, contaminants, nutrients, water, and electron
acceptors.
The effectiveness of bioremediation is site- and contaminant-
specific. Careful contaminant and matrix characterization
(with particular attention to heterogeneity), coupled with
treatability studies of appropriate scale and duration, are
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strongly recommended. Bioremediation can successfully treat
soils, sediments, and sludges contaminated with organic
contaminants, such as halogenated phenols and cresols, other
polar organic compounds, non-halogenated aromatics, and
PAHs. Studies on the bioremediation of creosote
contamination indicate that bioremediation works well on 2-,
3-, and often 4-ring compounds, but generally not as well on
5- or 6-ring compounds.
Bioremediation may not be effective for the treatment of high
levels of concentrated residual creosote in soils, sediments, or
sludges. It may be necessary to separate this material for
disposal or treatment by a different technology (e.g., thermal
desorption or incineration) before attempting bioremediation.
The remaining soils, sediments, or sludges, with lower levels
of contamination, may then be amenable to bioremediation.
Bioremediation generally is not appropriate for treating
inorganic contamination at wood treater sites. Only limited
data on the bioremediation of dioxins or furans are currently
available; EPA is currently gathering information on the
treatability of dioxins and furans (for more information,
contact the individuals listed in Box B).
Thermal Desorption — Thermal desorption physically
separates, but does not destroy, volatile and some semi-
volatile contaminants from excavated soils, sediments, and
sludges. Significant material handling operations may be
necessary to sort and size the soils, sediments, or sludges for
treatment. Thermal desorption uses heat or mechanical
agitation to volatilize contaminants from soils, sediments, or
sludges into a gas stream; subsequent treatment must be
provided for the concentrated contaminants resulting from the
use of this technology. Depending on the process selected,
this technology heats contaminated media to varying
temperatures, driving off water and volatile and semi-volatile
contaminants. Off-gases may be condensed for disposal,
captured by carbon adsorption beds, or treated with biofilters.
Treatability studies are recommended before full
implementation of the thermal desorption technology.
Thermal desorption can successfully treat halogenated phenols
and cresols as well as volatile non-halogenated organic
compounds at wood treater sites. It cannot, however,
effectively separate non-volatile metals (e.g., copper) from the
contaminated media. Some desorber units can treat PCBs,
pesticides, and dioxins/furans in contaminated soils,
sediments, or sludges.
If chlorine is present in the feed material (e.g., as a result of
PCP), dioxin and furan formation may occur in the thermal
desorber, stack, or air pollution control devices at
temperatures of 350 °F and above. Thermal treatment systems
can be designed and operated to minimize dioxin and furan
formation and to remove these compounds from the stack
gases. However, because pilot-scale devices do not always
duplicate operating conditions at full scale, bench- or pilot-
scale treatability studies alone may not be sufficient to verify
dioxin/furan formation or control. A full-scale test, called a
"Proof of Performance" test, with analyses for dioxins and
furans should be completed. Safe thermal treatment operation
should be confirmed prior to the use of thermal desorption.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs) and other laws should be considered
when determining whether thermal desorption is conducted
on- or off-site. On-site thermal desorption may be performed
with a mobile unit; however, space availability may make this
option infeasible. Thermal desorption may also be conducted
off-site; however, the facilities used must be in compliance
with the Superfund off-site rule before accepting material from
a Superfund site. EPA is currently in the process of
completing guidance that provides information on the safe
implementation of thermal treatment technologies, including
thermal desorption and incineration.
Incineration — Incineration generally treats organic
contaminants by subjecting them to temperatures typically
greater than 1,000°F in the presence of oxygen and a flame.
During incineration, volatilization and combustion convert the
organic contaminants to carbon dioxide, water, hydrogen
chloride, and sulfur oxides. The incinerator off-gas requires
treatment by an air pollution control (APC) system to remove
particulates and to neutralize and remove acid gases (e.g.,
HC1). This technology may generate three residual streams:
solids from the incinerator and APC system, water from the
APC system, and air emissions from the APC system.
Incineration has consistently been demonstrated to achieve a
performance efficiency in the 90 to 99% range. Incineration
has successfully treated wood treater soil, sediment, and
sludge contamination to cleanup levels that are more stringent
than can be consistently attained by the other wood treater
presumptive remedies. A substantial body of trial burn results
and other quality-assured data verify that incineration can
remove and destroy organic contaminants (including dioxins
and furans) to the parts per billion or parts per trillion level.
Consequently, incineration may be particularly effective in
treating "hot spots" at wood treater sites.
Incineration, however, does not destroy metals. Metals will
produce different residuals depending on the volatility of the
compounds, the presence of certain compounds (e.g.,
chlorine), and the incinerator operating conditions.
Improperly operated incinerators also have the potential to
create dioxins and furans. Incineration of large volumes of
contaminated media may be prohibitively costly.
Incineration may be performed on- or off-site. There may be
significant considerations regarding the compliance of
incineration with ARARs and other laws. On-site incineration
may be performed with a transportable incineration unit;
however, space availability and public opposition may make
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this option inappropriate. Whenever incineration is
considered as an option to fulfill remediation goals, particular
efforts should be made to provide the community with good
information on incineration and to be responsive to any
concerns raised by the community. Commercial incineration
facilities (i.e., units permitted for the incineration of hazardous
wastes, including incinerators and cement kilns) may be used
when off-site incineration is desirable. However, only a
limited number of these facilities are available nationwide.
Permitting of additional on- and off-site incineration facilities
will be affected by EPA's Strategy for Hazardous Waste
Minimization and Combustion [37].
Immobilization — Immobilization reduces the mobility of a
contaminant, either by physically restricting its contact with a
mobile phase (solidification) or by chemically altering/binding
the contaminant (stabilization). The most common
solidification binders are cementacious materials, including
Portland cement, fly ash/lime, and fly ash/kiln dust. These
agents form a solid, resistant, aluminosilicate matrix that can
occlude waste particles, bind various contaminants, and
reduce the permeability of the waste/binder mass.
Immobilization is particularly suited to addressing inorganic
(e.g., CCA) contamination.
At wood treater sites, inorganic contamination is sometimes
commingled with organic contamination. In these situations,
a treatment train should be implemented that uses
bioremediation, thermal desorption, or incineration to address
organic contamination, followed by the immobilization of any
significant residual inorganic contamination. There are
limited full-scale performance data available on the
immobilization of PAHs and PCP, either alone or commingled
with inorganic contamination, where the concentration of total
petroleum hydrocarbons is significantly more than 1%.
Immobilization has been effective in treating soils with
commingled organic and inorganic contamination with a total
organic content of as much as 20-45%. Immobilization alone
is not effective for treating volatile organic contaminants.
Site-specific treatability studies should be conducted to ensure
that a solidification/stabilization formulation can be developed
that meets site-specific requirements for low teachability and
permeability, and high compressive strength. EPA is currently
in the process of developing guidance on conducting
solidification/stabilization treatability studies.
PRESUMPTIVE
PROCESS FOR
TREATER SITES
REMEDY
WOOD
This section and the accompanying "Decision Tree for
Technology Selection at Wood Treater Sites" (Figure 1)
describe the process for selecting a presumptive remedy or
combination of remedies for cleaning up contaminated soils,
sediments, and sludges at wood treater sites. This remedy
selection process is consistent with and fits into the overall site
remediation process outlined in the NCP.
Under the NCP, alternative remedies are to be evaluated and
the preferred alternative is to be selected based on nine
criteria. Presumptive remedies are technologies that have
been found to be generally superior under the nine criteria to
other technologies. This generic evaluation makes it
unnecessary to conduct a detailed site-specific analysis of the
other technologies.
The "decision tree" approach recommended here is a further
streamlining of the usual NCP analysis. The decision tree is
based on the Agency's findings that,
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among the recommended technologies, a single preferred
technology can be identified based on the nine criteria, but that
the determination of which technology is preferred will depend
on a few key variables such as the types of contaminants
present and the feasibility of the technology. Once these
factors are determined, the single recommended approach can
be identified. This conclusion represents a judgement that,
under the circumstances at the site, the preferred technology
will be superior under the nine criteria. However, the decision
tree avoids the need to go through a full nine-criteria analysis
at the site-specific level; in effect, most of that analysis has
already been performed and the only information needed to
complete the analysis relates to variables specified in the
decision tree.
The presumptive remedy process generally begins at the point
in the overall NCP process where the removal and/or remedial
site evaluation and Hazard Ranking System scoring steps
have been completed and development of the RI/FS or EE/CA
is about to begin. The presumptive remedy process
streamlines the site characterization, technology assessment,
and remedy selection steps.
The decision tree describes a presumptive remedy process that
is dynamic, where site characterization, the evaluation of
presumptive remedies, and the establishment and refinement
of remedial action objectives (including future land use
assumptions and Preliminary Remediation Goals (PRGs))
are conducted interactively and concurrently. Site managers
should attempt to involve the state, community, and potentially
responsible parties (PRPs) in the presumptive remedy process
as early as possible.
Presumptive remedy options should be evaluated considering
their associated performance efficiencies and the cleanup
levels they might achieve, and the future land uses that their
implementation may make available. In most cases,
treatability studies should be performed for the treatment
technologies being considered. As discussed previously, the
identification of presumed or likely remedies early in the
cleanup process will allow for a more focused collection of
data on the extent of contamination, eliminate the need for the
initial step of identifying and screening alternatives during the
FS or EE/CA, and streamline the detailed analysis phase of the
FS or EE/CA.
The numbered steps and decision points in Figure 1, the
"Decision Tree for Technology Selection at Wood Treater
Sites," correspond to the similarly numbered paragraphs
below. These paragraphs provide information and the
underlying assumptions for each of the different steps and
decision points in the presumptive remedy process. The
decision tree should be used as a guide through the specific
decision points and considerations that are necessary to choose
a presumptive remedy.
1. Are Creosote, PCP, or CCA Present at the Site ?
This document focuses on cleaning up soils, sediments,
and sludges at wood treater sites contaminated primarily
with creosote, PCP, or CCA; if these contaminants are
not present at the site, the presumptive remedy selection
process outlined in the document is not appropriate for
the site, and the conventional RI/FS or EE/CA process
should be followed. Information on contaminants
present at the site may be available from data collected
during the removal and/or remedial site evaluation. If
this information is not available, past chemical use at a
particular facility can be ascertained from a number of
sources, such as information from facility records, past
sampling efforts by state or local agencies, or through
information request letters.
2. Initiate Early PRP, State, and Community
Involvement Site managers should initiate a dialogue
with the community, state representatives, and PRPs
early in the process of identifying potential presumptive
remedy options for a site. This dialogue should include
a discussion of reasonably anticipated future land use.
This discussion should be beneficial in establishing
remedial action objectives and state ARARs, which, in
conjunction with federal requirements, may provide
PRGs. In addition, site managers should begin
assembling the Administrative Record for the site.
3. Review Advantages/Limitations Table fo r
Presumptive Remedies. Using information on the
contaminants present at the site, site managers should
begin reviewing the presumptive remedies for wood
treater sites. Table 1 provides a listing of the
presumptive remedies for wood treater sites and the
contaminants for which they are applicable. Table 2
provides detailed information on the advantages,
limitations, and costs of each of the presumptive
remedies.
Steps 4 and 5 of the decision tree represent separate
aspects of initial site cleanup activities. However, these
steps should be undertaken concurrently, with each step
using information obtained from the other step.
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TABLE 1
Evaluation of Presumptive Remedy Technology Options
Contaminants
Present at Site
Oreanics:
Creosote,
PCP, or
Creosote and PCP
Inorganics:
CCA
Oreanics and Inorganics:
Creosote and CCA;
PCP and CCA; or
Creosote, PCP, and CCA
Presumptive Remedy
Technology Options
Bioremediation
Thermal Desorption
Incineration
Immobilization
Bioremediation, Thermal
Desorption, and/or Incineration,
followed by Immobilization
Demonstrated Performance
Efficiencies1
64-95% for PAHs and 78-98% for
chlorophenols (F)2
82-99% (B,P,F)
90-99% (B,P,F)
80-90% TCLP3(B,P,F)
See above
1 Performance represents a range of treatability data. Percentages may vary depending on the contaminants). Bench-(B), pilot-(P),
or full-scale (F) demonstration data may not be available for all contaminants. All performance efficiency data are taken from EPA's
Contaminants and Remedial Options at Wood Preserving Sites [8], unless noted otherwise.
2 These data represent current full-scale performance data for ex situ bioremediation conducted at three U.S. wood treater sites (all
of which are listed on the National Priorities List (NPL)) and one Canadian wood treater site. The use of bioremediation at these four
sites achieved remediation goals in all cases. Because the monitoring of biodegradation at these sites stopped after remediation goals
were achieved, actual performance efficiencies at these sites may be higher than these numbers indicate. For a more detailed discussion
of these performance data, see "Full-Scale Performance Data on the Use of Bioremediation at Wood Treater Sites," a technica 1
background document for the wood treater site presumptive remedy initiative that is available at EPA Headquarters and the Regional
Offices. EPA's Contaminants and Remedial Options at Wood Preserving Sites (1992) [8] provides the following pilot-scale
performance data for bioremediation: an average of 87% for PAHs and 74% for halogenated phenols and cresols. The effectiveness
of bioremediation tends to be highly variable and very site-specific. A significant component of this variability is the range o f
effectiveness in the remediation of different kinds of PAHs; studies on the bioremediation of creosote contamination indicate that
bioremediation works well on 2-, 3-, and often 4-ring PAHs, but generally not as well on 5- or 6-ring PAHs. For example, the use
of ex situ bioremediation at one of the wood treater NPL sites resulted in 95% removal of 2-ring PAHs, 83% removal of 3-ring PAHs,
and 64% removal of 4+-ring PAHs. In practice, in situ bioremediation typically results in lower performance efficiencies than the ex
situ process because in situ reactions are less controlled and involve lower mass transfer rates. To obtain additional performance data
for bioremediation, contact the U.S. EPA's Center for Environmental Research Information (CERT) at: 26 W. Martin Luther Kin g
Drive, Cincinnati, Ohio 45268. CERI maintains a bioremediation data base called "Bioremediation in the Field Search System "
(BFSS), which may be accessed electronically through bulletin boards at (301) 589-8366 or (513) 569-7610.
3 TCLP (toxicity characteristic leaching procedure) is a specific analytical method; this method has been widely used in the past to
evaluate the performance of immobilization. However, current information indicates that the SPLP (synthetic precipitation leaching
procedure) or other procedures using distilled or site-specific water will produce more accurate results.
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4. Conduct Site Characterization. Site characterization
activities for wood treater sites using the presumptive
remedy process should be designed to:
• Positively identify the site type (i.e., a wood treater
site with creosote, PCP, or CCA contamination);
• Obtain data to determine whether the presumptive
remedies are feasible for the site;
• Focus and streamline the collection of data to
support the selection of presumptive remedies
only; and
• Collect design data, thereby streamlining the data
collection required during the remedial or removal
design stage.
The overall site characterization process should proceed
using multimedia sampling events whenever possible.
Field screening methods should be integrated into the
sampling and analysis plan to accelerate information
gathering. Data quality objectives must reflect the
ultimate use of the results; consequently, all samples
taken during a single event may not require the same
level of data quality.
Surface lagoons, soil areas, drip pads, and sediments
should be sampled in a grid-like manner to determine
the horizontal and vertical extent of contamination. Site
managers should ensure that sampling for dioxins and
furans is conducted at all wood treater sites known to
have used chlorinated phenols, such as PCP. Soil,
sediment, and sludge characterization relevant to
treatment selection should reflect the information needs
described in Tables 3A-D.
If a wood treating or other chemical at an abandoned site
is still in its original containers, it should be returned to
the manufacturer, if possible. Where any of the
principal wood treating chemicals (creosote, PCP, or
CCA) can be recovered in high enough concentrations
to warrant reuse in any process, recycling becomes the
preferred technology. The recognized U.S. Waste
Exchanges are listed in Appendix A of the Technology
Selection Guide for Wood Treater Sites [43].
During site characterization, a site-specific baseline risk
assessment (or streamlined risk evaluation for a removal
action) should be conducted to characterize materials
that constitute principal threats (i.e., source materials,
including liquids, that are highly toxic or highly mobile
wastes that generally cannot be reliably contained or
would present a significant risk to human health and the
environment should exposure occur). This risk
assessment should be conducted to determine whether
sufficient threats or potential threats exist to warrant a
response action.
The site-specific risk assessment should be used to
determine remediation goals for the site. Risk-based
remediation goals are often different for soils, sediments,
and sludges at different depths. Shallow remediation
goals are usually based on direct contact risks, while
deeper remediation goals are usually based on ground-
water impacts. Site managers should consider the
ground-water strategy for the site because remediation
goals for soils, sediments, and sludges are often set to
protect ground-water quality. As discussed above,
existing guidance on the remediation of ground water [6,
7, 17, 20, 38] and the forthcoming guidance on a
presumptive ground-water approach, when available,
should be consulted.
EPA is currently in the process of developing guidance
on soil screening levels [30]; these levels represent
contaminant concentrations in soil below which there is
generally no need for federal concern for the protection
of human health in a residential setting. When the final
guidance is available, site managers should use it as a
screening tool in determining the need for further
assessment of soil contamination during the RI stage of
cleanups at National Priorities List sites. For more
information on conducting site characterization activities
and risk assessments, site managers should refer to the
references listed at the end of this document [1,8,16,
19,23,3435,36].
Establish Remedial Action Objectives (Includin g
Land Use Assumptions) and SetPRGs. Promulgated
federal and state standards should be assessed as
potential ARARs for the site. As appropriate, othe r
criteria, advisories, or guidance should be assessed as
potential to be considereds (TBCs). For a more detailed
discussion on identifying ARARs and TBCs, see the
references listed at the end of this document [3,4,41].
Superfund site managers should also continue to
evaluate the presumptive remedies and begin to develop
remedial action objectives for the site. The following
steps, as depicted in Figure 1, should be undertaken by
site managers.
Review Presumptive Remedies and Associated
Performance Efficiencies
Site managers should continue the review of the
presumptive remedies that was initiated in Step 3, using
additional information on site characteristics obtained
under Step 4. Tables 1 and 2 provide data on
performance efficiencies for the different presumptive
remedy technologies. Information contained in these
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tables should be used to focus the information gathering
activities being conducted under the site characterization step.
Set Preliminary Remediation Goals
As part of the overall remedial action objectives for the
site, site managers should set PRGs. Initially, PRG s
should be developed based on readily available
information, such as ARARs and TBCs. Technical,
exposure, and uncertainty factors should also be used to
establish PRGs (see section 300.430(e)(2) of the NCP).
Site managers should modify PRGs, as necessary, as
more information becomes available. When setting
PRGs for wood treater sites, site managers should also
consider the performance efficiencies of the different
presumptive remedies. In most cases, treatability
studies will be necessary to determine the site-specific
capabilities of a specific presumptive remedy.
Reasonably anticipated future land use(s) of the site
should also be considered when establishing PRGs. Site
managers should consult EPA's guidance on land use in
the Superfund remedy selection process [27]. This
guidance calls for early interaction with citizens, local
governments, and other entities to gather information to
develop assumptions regarding anticipated future land
use. These assumptions may be used in the baseline risk
assessment, the development of alternatives, and remedy
selection. Refer to Box E (Practical Considerations) for
more information on future land use considerations.
Prepare Information and Present to Public
It is important that site managers involve the public at an
early stage in the consideration of the various
presumptive remedy options. Site managers should
encourage the public to review the advantages and
limitations of the presumptive remedies against each
other and should consider this public input when
selecting a presumptive remedy for a site. In particular,
efforts should be made to engage the community and
other interested parties in discussions concerning the
establishment of PRGs and future land use issues.
Input from the community, state representatives, and
PRPs may be obtained through a variety of methods,
such as informal contacts or meetings with community
leaders or groups. This early input on remedy selection
should assist site managers in fostering community
acceptance at later stages of the presumptive remedy
selection process. Before seeking public input, the site
manager should do the following: (1) contact Regional
community relations staff for information on community
acceptance (if further assistance is necessary, the
individuals listed in Box B should be contacted); and (2)
prepare a matrix of the applicable presumptive remedy
options for the site. This matrix should contain data on
the performance efficiencies, advantages, limitations,
costs, and implementability of the various options, and
should emphasize the full range of trade-offs between
the alternatives. This information should be presented
to the public to assist them in providing input on the
remedy selection process. For a more detailed
discussion on holding public meetings and community
relations at Superfund sites, see the references listed at
the end of this document [5,42].
Evaluate Public Reaction to the Presumptive Remedy
Options
If the public reacts favorably to one or more of the
presumptive remedy options, site managers should
proceed to the next step of the presumptive remedy
process. However, if the public does not react favorably
to any of the presumptive remedy options under
consideration, site managers may wish to consider
reviewing non-presumptive technologies, including
innovative technologies, to determine if there are other
options that may receive greater community acceptance
while providing for sufficient overall protection of
human health and the environment If this is the case, a
conventional RI/FS or EE/CA could be performed, or
the FS could consider the presumptive remedy plus any
specific alternatives believed to warrant consideration to
establish a site-specific Administrative Record that
supports the selection of a technology that is not
specifically identified as a presumptive remedy. Site
managers should note that all alternatives should
generally be evaluated in a full nine-criteria analysis,
even if objections are raised by members of the
community. However, if opposition is intense, it may be
justifiable to screen out an alternative early in the
process for reasons of implementability.
Conduct Time-Critical Removal Action, i f
Necessary. Information from site characterization
activities may indicate that the performance of a time-
critical removal action is warranted. If so, site managers
should conduct the removal action in accordance with
the NCP and EPA removal program guidance. If
subsequent non-time-critical removal actions or
remedial actions are still required at the site, site
managers should follow the presumptive remedy
process, if appropriate.
Identification of New Contaminants. Continuing site
characterization efforts performed under Step 4 may, at
any time, identify new contaminants at the site. Newly
identified contaminants should be evaluated to determine
if their presence precludes using presumptive remedy
technologies or makes the use of these technologies
inappropriate. For example, the detection of significant
DNAPL contamination of ground water at a site may
indicate that contaminated soils, sediments, or sludges
do not pose a principal human health and environmental
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threat and, therefore, may not require treatment or may only
need to be contained. In these situations, site managers should
follow the presumptive remedy approach for contaminated
ground-water sites, when available. If newly identified
contaminants do preclude or make inappropriate the use of a
presumptive remedy identified in this document, this directive
may not be applicable and the conventional RI/FS or EE/CA
process may need to be followed.
8. Refine PRGs. Is There a Need for Further Action?
Using additional information obtained from the site-
specific baseline risk assessment, site managers should
determine whether the site poses an unacceptable risk to
human health or the environment. If the site does not
pose an unacceptable risk, no further action is required.
However, if it appears that an unacceptable risk does
exist, site managers should proceed to the next step in
the presumptive remedy process. Information from the
baseline risk assessment should be used to refine the
PRGs for the site.
9. Proceed with Technology Assessment and Revie w
"Practical Considerations." After it has been
determined that a cleanup action is warranted at the site,
site managers should review the different presumptive
remedy options and identify a proposed option. For a
remedial action, presumptive remedy options must be
evaluated against the nine criteria required by section
300.430(eX9) of the NCP; this should be documented in
the detailed analysis section of an FS or Focused FS.
Appendix A of this document summarizes the analysis
EPA conducted on FSs/RODs for wood treater sites
with contaminated soils, sediments, or sludges, and
Appendix B provides generic evaluations of the different
presumptive remedies against seven of the nine remedial
criteria (excluding state and community acceptance).
Both of these appendices should be used to streamline
the detailed analysis phase of the FS. Appendices A and
B can also be used to streamline the evaluation of
removal action alternatives in an EE/CA. The generic
analyses in Appendix B should be supplemented with
site-specific information for the final response selection.
During technology assessment, the factors listed in the
"Practical Considerations" section (Box E) of this
document should be reviewed to ensure a
comprehensive evaluation of response alternatives.
10. Begin the Technology Selection Process Based o n
the Types of Contamination Present at the Site. If
the only contaminants present at significant levels (i.e.,
levels that may justify treatment) are inorganics, site
managers should follow Path A in Figure 1 (i.e., proceed
to Step 11) and evaluate the feasibility of
immobilization. If the only contaminants present at
significant levels are organics, site managers should
follow Path B in Figure 1 (i.e., proceed to Step 12) and
evaluate the feasibility of bioremediation. In situations
where significant levels of both inorganic and organic
contamination are present at the site, site managers
should follow Paths A and B concurrently. In these
situations, a treatment train should be implemented that
uses bioremediation, thermal desorption, and/or
incineration to address the organic contaminants and
immobilization to address the inorganic contaminants.
11. Is Immobilization Feasible? Immobilization is the
primary presumptive remedy for addressing significant
levels of inorganic contamination in soils, sediments,
and sludges at wood treater sites. If immobilization is
not considered feasible for addressing inorganic
contaminants present at the site, this document is not
applicable and site managers should review other non-
presumptive technologies. If the use of immobilization
is feasible, site managers should proceed to Step 15.
12. Is Bioremediation Feasible? Bioremediation is the
primary presumptive remedy for treating organic
contamination of soils, sediments, and sludges at wood
treater sites. However, the effectiveness of
bioremediation is very site- and contaminant-specific.
In addition, implementation of bioremediation remedies
requires considerably more time than the
implementation of the other presumptive remedies (i.e.,
several years for bioremediation as compared to
approximately six months to a year for thermal
desorption and incineration). Bioremediation can
successfully treat soils, sediments, and sludges
contaminated with organic contaminants such as
halogenated phenols and cresols, other polar organic
compounds, non-halogenated aromatics, and PAHs
(particularly 2- and 3-, and often 4-ring compounds).
However, bioremediation may not be feasible if a site
exhibits high levels of concentrated residual creosote or
dioxins and furans. Pilot/treatability study testing
should be conducted to assess the feasibility of using
bioremediation at a site. If the use of bioremediation is
feasible, site managers should proceed to Step 15. If the
use of bioremediation is not feasible, site managers
should assess the use of thermal desorption.
13. Is Thermal Desorption Feasible? If bioremediation
will not be sufficiently effective in achieving PRGs for
the site, thermal desorption should be considered as the
presumptive remedy for addressing organic
contamination. Treatability studies should be conducted
(including a Proof of Performance test if dioxin and/or
furan formation is a concern) to ensure that thermal
desorption is feasible for the site and will achieve the
desired PRGs. If the use of thermal desorption i s
feasible, site managers should proceed to Step 15. If the
use of thermal desorption is not feasible, site managers
should assess the use of incineration.
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14. Is Incineration Feasible? If high contaminant
concentrations and/or treatability testing indicate that
thermal desorption will not achieve the desired PRGs for
the site, incineration should be considered as the
presumptive remedy. If the use of incineration is
feasible for the site, site managers should proceed to
Step 15. If none of the three presumptive remedy
options for treating organic contaminants are considered
feasible for the site, this document is not applicable and
site managers should review other non-presumptive
technologies.
15. Proceed with ROD or Action Memorandum. At this
point in the process, site managers should possess
sufficient information to set final remediation goals and
identify a preferred presumptive remedy option. This
preferred option should be presented to the public for
review and comment in the proposed plan. Because
substantial community input has already been factored
into the remedy selection process under Step 5, it is
envisioned that significant negative input from the
public should not be received at this point.
The final step in the selection of a presumptive remedy
is to document the decision in a ROD for a remedial
action or an Action Memorandum for a removal action.
As was discussed above, if a presumptive remedy is
selected in the ROD or Action Memorandum, a copy of
this document and its accompanying attachments must
be included in the Administrative Record for the site.
These materials will assist in justifying the selection of
the presumptive remedy, and will support the
elimination of the initial screening step of the FS or
EE/CA and the streamlining of the detailed analysis
phase of the FS or EE/CA.
CONCLUSION
The presumptive remedies for cleaning up soils, sediments,
and sludges at wood treater sites that are contaminated
primarily with creosote, PCP, or CCA are bioremediation,
thermal desorption, incineration, and immobilization.
Bioremediation is the primary presumptive remedy for treating
organic contaminants, followed by thermal desorption and
incineration, respectively. Immobilization is the primary
presumptive remedy for treating inorganic contaminants.
Based on site-specific information and remediation goals
established for the site, one or more of these treatment
technologies should be selected. If a wood treater site does
not meet the conditions described in this document, the
document is not applicable and the conventional remedy
selection process should be followed.
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BOX D
Background Information on NAPL Contamination
A non-aqueous phase liquid (NAPL) is a liquid that, in its pure form, does not readily mix with water but slowly partitions into the
water phase. Dense NAPLs (DNAPLs) sink in water, while light NAPLs (LNAPLs) float on water. When present in the subsurface,
NAPLs slowly release vapor and dissolved phase contaminants, resulting in a zone of contaminant vapors above the water table and
a plume of dissolved contaminants below the water table. The term NAPL refers to the undissolved liquid phase of a chemical o r
mixture of compounds, and not to the vapor or dissolved phases. NAPLs may be present in the subsurface as either "free-phase" or
"residual-phase" NAPLs. The free-phase is that portion of the NAPL that can continue to migrate and can flow into a well. Th e
residual-phase is that portion trapped in pore spaces by capillary forces, which cannot generally flow into a well or migrate as a
separate liquid. Both residual- and free-phase NAPLs are sources of vapors and dissolved contaminants.
The most common LNAPLs are petroleum fuels, crude oils, and related chemicals, which tend to be associated with facilities tha t
refine, store, or transport these liquids. The following factors tend to make LNAPLs generally easier to locate and clean up tha n
DNAPLs: (1) LNAPL contamination tends to be more shallow than DNAPL contamination; (2) LNAPLs tend to be found at the water
table; and (3) LNAPLs are usually associated with specific types of facilities. However, LNAPL contamination that is trapped in soil
pores below the water table may not be significantly easier to remediate than DNAPL contamination in the saturated zone.
DNAPLs pose difficult cleanup problems. These contaminants include chemical compounds and mixtures with a wide range o f
chemical properties, including chlorinated solvents, creosote, coal tars, PCBs, PCP, and some pesticides. Some DNAPLs, such as
coal tars, are viscous chemical mixtures that move very slowly in the subsurface. Other DNAPLs, such as some chlorinated solvents,
can travel very rapidly in the subsurface because they are heavier and less viscous than water. A large DNAPL spill not only sinks
vertically downward under gravity, but can spread laterally with increasing depth as it encounters finer grained layers. These chemicals
can also contaminate more than one aquifer by penetrating fractures in the geologic layer that separates a shallow aquifer from a deeper
aquifer. Thus, large releases of DNAPLs can penetrate to great depths and can be very difficult to locate and clean up.
The contamination problem at DNAPL sites has two different components: (1) the aqueous contaminant plume, and (2) the DNAPL
zone, as shown in Figures D-l and D-2. The aqueous contaminant plume includes those portions of the site where only dissolve d
contaminants are present in ground water. The DNAPL zone includes those portions of the site where immiscible liquids are present
in the subsurface, either as free-phase or residual-phase compounds. Depending on the volume of the release and the subsurfac e
geology, the DNAPL zone may extend to great depths and over large lateral distances from the entry location.
For a more detailed discussion on DNAPL contamination, see the references listed at the end of this document [7,10,11,12,13,15,
17].
Page 16
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Page 17
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BOX D
Background Information on NAPL Contamination
(continued)
FIGURE D-1
Components of DNAPL Sites
FIGURE D-2
Types of DNAPL Contamination and Contaminant Zones at
DNAPL Sites
(Cross-Sectional View)
Page 18
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BOX E
Practical Considerations
Land use: In general, remedial action objectives should be formulated to identify response alternatives that will
achieve cleanup levels appropriate for the reasonably anticipated future land use of a site. Early community
involvement, with a particular focus on the community's desired future uses of property associated with the site,
should result in a more democratic decisionmaking process, greater community support for remedies selected as
a result of this process, and, in many cases, more expedited cleanups. Factors to consider may include: any
recommendations or views expressed by members of the affected community; the land use history and current uses
of the facility and surrounding properties, and recent development patterns where the facility is located; and the
proximity of the contamination to residences, sensitive populations or ecosystems, natural resources, or areas of
unique historic or cultural significance. For example, if it is anticipated that a site will be used for futur e
industrial/commercial development, it may be appropriate to select a presumptive remedy (e.g., in situ
bioremediation) that results in higher residual contaminant levels but is less costly than other options. EPA has
developed guidance on land use in the Superfund remedy selection process [27].
Institutional and/or engineering controls: It may be appropriate to use institutional and/or engineering controls
in conjunction with the presumptive remedy technologies described in this document to reduce current or potential
human exposure via direct contact with contaminated soils, sediments, and sludges or through the use o f
contaminated ground water. Engineering controls are physical systems requiring construction and maintenance,
such as soil caps, caps with liners, and vertical barrier walls. Institutional controls include the use of physica 1
barriers, such as fences and warning signs, and the use of administrative restrictions, such as deed or leas e
restrictions. When vigorously enforced, institutional controls limit direct contact with and ingestion of soils,
sediments, and sludges; however, unlike some engineering controls (e.g., caps), institutional controls do not reduce
the potential for wind dispersal and inhalation of contaminants. Monitoring is generally needed to determine the
effectiveness of institutional and/or engineering controls.
Institutional and/or engineering controls alone do not satisfy CERCLA's preference for achieving reductions of
toxicity, mobility, or volume through treatment as a principal element of the remedy. Consequently, they are not
generally recommended as the sole response to address contaminants that are deemed a principal threat at wood
treater sites. However, the use of institutional and/or engineering controls after the treatment of a principal threat
by one or more of the presumptive remedy technologies can enhance the long-term reliability of the remedy.
A cap is an engineering control that may be particularly useful in improving the overall protection of a presumptive
remedy. A simple cap may involve only covering the treated area with uncontaminated native soil and/or seeding,
fertilizing, and watering the area until vegetation has been established. A simple cap (soil only) may be
appropriate for situations where direct contact and/or erosion are the prime threats, and is particularly appropriate
following bioremediation because it ensures oxygen availability for continuing biodegradation. Caps that are
intended to prevent surface water infiltration are typically comprised of soil and several other components,
including a drainage layer, a geomembrane, and a compacted clay layer. Such caps, in addition to being effective
in limiting direct contact exposure and reducing erosion, are also effective in limiting surface water infiltration,
minimizing the vertical migration of residual contaminants, and minimizing ground-water contamination.
However, caps that prevent infiltration will inhibit aerobic biodegradation, which generally makes the use of such
caps following bioremediation inappropriate. For a more detailed discussion on the factors affecting the
appropriate uses of caps, refer to the references listed at the end of this document [14,18,29].
Page 19
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BOX E
Practical Considerations
(continued)
Treatment trains: A single technology may not be sufficient to clean up an entire wood treater site. Remediation
of sites often requires a combination of control and treatment options in order to sufficiently reduce toxicity and
immobilize contaminants. The treatment train concept combines pretreatment and/or post-treatment activities with
treatment technologies to achieve site-specific objectives and acceptable residual contaminant levels. For example,
the implementation of a remedy might include institutional controls to control direct contact exposure,
bioremediation to treat organic contamination (including excavation, capping, and monitoring activities), and
immobilization to treat residual inorganic contamination. The pretreatment and post-treatment portions of the
treatment train should be selected based on site-specific considerations.
"Hot spots": Hot spots (e.g., highly contaminated sludges) are generally defined as discrete areas within a site
that contain hazardous substances, pollutants, or contaminants that are present in high concentrations, are highly
mobile, or cannot be reliably contained, and would present a significant risk to human health or the environment
should exposure occur. Hot spots will usually be considered principal threats at a site, as defined by the NCP.
Site managers should be aware that the limitations of certain presumptive remedies (e.g., bioremediation) may
preclude their use in cleaning up certain hot spots. In addition, responding to hot spots may require additiona 1
pretreatment and post-treatment activities, such as the use of institutional controls or capping. (For additional
information, see the references listed at the end of this document [23].)
Land disposal restrictions (LDRs): All technologies that treat hazardous waste ex situ may cause the waste
being treated to be subject to RCRA LDRs. In situ treatment of hazardous waste does not trigger LDRs because
"placement" of the waste does not occur. LDRs establish treatment standards that must be met before a waste can
be land disposed. These treatment standards are either concentration-based (hazardous constituents must b e
reduced to a set concentration) or, less frequently, technology-based (waste must be treated using a specified
technology). EPA has promulgated LDR treatment standards for specific wood preserving wastes (K001 -
sediments and sludges from the treatment of wastewaters resulting from processes using creosote or PCP) and
anticipates proposing treatment standards for other wood preserving wastewaters in 1995. The Agency has also
promulgated LDR treatment standards for RCRA characteristic wastes. If a wood treater waste exhibits one or
more of the identified hazardous characteristics, it is subject to RCRA LDRs.
Wood treater wastes that qualify as "remediation wastes" and are placed in a Corrective Action Management Unit
(CAMU, see 58 FR 8658-8685), whether at a Superfund site or RCRA corrective action site, do not have to meet
LDRs. (Whether LDRs are triggered depends on whether remediation wastes are "placed" in a land-based unit,
not on whether they are treated. LDRs do not apply to remediation wastes treated on-site and then placed in a
CAMU.) The EPA Region is responsible for setting site-specific requirements for a CAMU, which could include
LDRs. The LDR program also pro vides four exceptions to meeting LDRs that may be applicable to wood treater
sites: (1) the treatability variance (see 40 CFR 268.44); (2) equivalent treatment; (3) the no-migration exemption
(see 40 CFR 268.6); and (4) de-listing. The treatability variance is anticipated to be the primary route of
compliance with LDRs for contaminated soil and debris; for more information, see the references at the end of this
document [39,40]. Site managers should consult with Regional RCRA program staff when addressing LDR issues
at specific wood treater sites.
Page 20
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TABLE 3-A
Data Requirements for Bioremediation
DATA REQUIREMENT
General Data Requirements
Biochemical oxygen demand
(BOD)
Chemical oxygen demand
(COD)
Contaminant solubility
Degradation rates of
contaminants
Indigenous microorganisms
Inorganic contaminants
Limiting initial and final
concentrations of
contaminants
Metals, inorganic salts
concentrations
Moisture content
Nutrients
Oil and grease content
Organic content
Particle size
Total organic carbon (TOC)
IMPORTANCE OF INFORMATION
Provides estimate of biological treatability of soil, sediment, or sludge.
Another estimate of biological treatability. The measure of the oxygen equivalent of
organic content that can be oxidized by a strong chemical oxidant.
Components with low solubility are difficult to remove from soil, sediment, or sludge
because of low bioavailability.
Should be determined through treatability studies. Important to determine
applicability of remedy.
The PAH biodegradation activity of indigenous organisms must be measured to
determine if appropriate microorganisms are present in sufficient quantity.
Important to determine applicability of remedy.
Should be determined through treatability studies with respect to the specific process.
High metal concentrations may inhibit microbial activity. Some inorganic salts are
necessary for biological activity.
May inhibit solid-phase aerobic remediation of soils, sediments, or sludges if greater
than 80% of field capacity; soil, sediment, and sludge remediation inhibited if less
than 40% of field capacity. Soil slurry reactors may operate with 80-90% moisture
content (water/weight of soil).
Lack of certain nutrients reduces activity.
Oil and grease concentrations may inhibit soil, sediment, and sludge remediation at
concentrations greater than 5% by weight, which may result in unacceptable lag
times.
Important to determine applicability of remedy. Important to determine horizontal
and vertical extent of contaminants and to ensure that appropriate detection limits are
used.
Particle size affects access and contact between microorganisms, contaminants,
nutrients, water, and electron acceptors.
Indicates total organic carbon present and can be used to estimate waste available for
biodegradation.
Page 27
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TABLE 3-A
Data Requirements for Bioremediation
(continued)
DATA REQUIREMENT
IMPORTANCE OF INFORMATION
General Data Requirements (continued)
Variable waste composition
Redox potential (Eh)
Large variations affect biological activity.
Aerobic degradation: oxidation-reduction potential of the soil, sediment, or sludge
must be greater than that of the organic contaminant for oxidation to occur.
Specific In Situ Data Requirements
Soil, sediment, or sludge
temperature
Position of water table
Site geology
Soil, sediment, or sludge
permeability
High or low temperatures affect microbial activity for in situ treatment (high
temperatures tend to increase activity, low temperatures tend to decrease activity).
Important for remedy selection and implementation.
Important to determine mass transfer capability.
Affects movement of water, oxygen, and nutrients for in situ treatment.
Specific Ex Situ Data Requirements
Toxicity Characteristic
Leaching Procedure (TCLP)
analysis
Needed to determine if the soil, sediment, or sludge is a RCRA hazardous waste.
Page 28
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TABLE 3-B
Data Requirements for Thermal Desorption
DATA REQUIREMENT
Bulk density of soil, sediment,
or sludge
Contaminant physical
properties
Inorganic contaminants
Metals content
Extent of organic
contaminants
Moisture content
Sulfur, chlorine, and organic
phosphorous content
Particle size
PH
Salt content
Soil, sediment, or sludge
plasticity
Toxicity Characteristic
Leaching Procedure (TCLP)
analysis
Flash point of soil, sediment,
or sludge
Total organic carbon (TOC)
Total chloride
IMPORTANCE OF INFORMATION
Used in converting weight to volume in material handling calculations.
Information on physical properties, such as boiling point, determines the required
characteristics of the thermal desorption unit.
Important to determine applicability of remedy.
Metals (As, Cd, Cr, Pb, Zn) can vaporize at high temperatures and must be removed
from emissions.
Need to determine horizontal and vertical extent of organic contamination to be
excavated.
High moisture content increases feed handling and energy requirements.
Contribute to acid gas formations at high concentrations.
Oversized debris hinders processing. Fine particles can result in high participate
loading in flue gasses. Clay content will impede material handling and may interfere
with waste processing.
Extreme pH may be harmful to equipment.
High salt content, depending on temperature, may cause material in the thermal unit to
slag.
Plastic soil, sediment, or sludge, when subjected to compressive forces, can become
molded into large particles that are difficult to heat.
Needed to determine if the soil, sediment, or sludge is a RCRA hazardous or listed
waste.
Important to determine safe temperature parameters for the desorber unit.
Provides estimate of material available for combustion, which may affect the
temperature range available for thermal desorption.
Influences metal partitioning to the gas phase.
Page 29
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TABLE 3-C
Data Requirements for Incineration
DATA REQUIREMENT
Bulk density of soil, sediment,
or sludge
Contaminant combustion
characteristics
Heating value
Inorganic contaminants
Metals content
Extent of organic
contaminants
Moisture content
Sulfur, chlorine, and organic
phosphorous content
Particle size
pH
Salt content
Soil, sediment, or sludge
plasticity
Toxiciry Characteristic
Leaching Procedure (TCLP)
analysis
Total organic carbon (TOC)
IMPORTANCE OF INFORMATION
Used in converting weight to volume in material handling calculations.
Required to determine the incinerator's combustion characteristics.
Affects throughput and energy requirements.
Important to determine applicability of remedy.
Metals (As, Cd, Cr, Pb, Zn) can vaporize at high temperatures and are difficult to
remove from emissions.
Need to determine horizontal and vertical extent of organic contamination to be
excavated due to cost concerns.
High moisture content increases feed handling and energy requirements.
Contribute to acid gas formations at high concentrations.
Oversized debris hinders processing. Fine particles can result in high particulate
loading in flue gasses.
Extreme pH may be harmful to equipment.
High salt content will cause material in the incinerator to slag.
Plastic soil, sediment, or sludge, when subject to compressive forces, can become
molded into large particles that are difficult to heat.
Needed to determine if soil, sediment, or sludge is a RCRA hazardous or listed waste.
Provides estimate of material available for combustion.
Page 30
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TABLE 3-D
Data Requirements for Immobilization
DATA REQUIREMENT
Coal or lignite content
Cyanides content
Halide content
Inorganic salts content
Metals content
Phosphate concentration
Oil and grease content1
Organic content1
Particle size
Phenol concentration
Sodium arsenate, borate,
phosphate, iodate, sulfide,
sulfate, carbohydrate
concentrations
Solids content
Semi-volatile organics
Volatile organic
concentrations
IMPORTANCE OF INFORMATION
May affect product quality.
Affects bonding (greater than 3,000 ppm).
Retards setting; leaches easily.
Reduces product strength and affects curing rates (soluble salts of Mn, Sn, Zn, Cu,
and Pb).
Important for process considerations.
Phosphate is a key reagent in some solidification/stabilization mixes to reduce metals
(especially Pb) solubility; in high concentrations, phosphate may cause problems.
Affects cementation, mix design, and cost.
Affects cementation, mix design, and cost.
Affects bonding (if less than 200 mesh or greater than 1/4 inch diameter). Concrete is
able to use larger particles.
Affects product strength (greater than 5%).
Retards setting and affects product strength.
Low solids content indicates that de-watering is needed.
Requires the use of special mixes, and may inhibit bonding
(if greater than 10,000 ppm).
Volatiles have not been successfully treated with solidification/stabilization alone;
volatiles should be removed or otherwise treated.
1 Immobilization with lime or proprietary additives has been used to treat oily soils and petroleum sludge at petroleum industry sites;
however, the structural properties of the product are poor, even when the material passes the TCLP (Toxicity Characteristic Leaching
Procedure). High concentrations (e.g., greater than 20%) of naturally-occurring mimic matter may also interfere with cement-based
processes, but some success with higher levels of organics has been reported using modified lime products.
Page 31
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APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
This Appendix summarizes the analyses that EPA conducted on Feasi bility Study (FS) and Record of Decision (ROD) data
from Superfund wood treater sites, which led to establishing bioremediation, thermal desorption, incineration, an d
immobilization as the presumptive remedies for wood treater sites with contaminated soils, sediments, and sludges. The
analyses consisted of the following activities:
• Identifying wood treater sites;
• Determining the frequency of technology selection for wood treater sites;
• Identifying sites for the FS/ROD analysis; and
• Conducting the FS/ROD analysis.
Results of the FS/ROD analysis, along with a technical analysis of performance data on technology application, are part
of the Administrative Record for this directive, which is available at EPA Headquarters and the Regional Offices. These
analyses provide support for the decision to eliminate the initial alternatives identification and screening step for this site
type. These analyses found that certain technologies are appropriately screened out based on effectiveness,
implementability, and/or cost. Review of technologies against the nine remedial criteria led to elimination of additional
alternatives. A discussion of each of the analyses is provided below.
Identification of the Universe of Wood Treater Sites
EPA identified the universe of wood treater sites listed on the National Priorities List from information contained in the
following two sources: (1) Contaminants and Remedial Options at Wood Preserving Sites, U.S. EPA, EPA/600/R -
92/182,1992; and (2) Innovative Treatment Technologies: Annual Status Report (Sixth Edition), U.S. EPA, EPA 542-R-
94-005,1994. The first source contained comprehensive lists of NPL and non-NPL wood treater sites prior to 1992. The
second source contained information, current as of 1994, on the status of the implementation of innovative treatment
technologies at a wide range of sites, including wood treater sites. By cross-checking the information in both of thes e
documents, an overall list of 58 NPL wood treater sites was identified.
Frequency of Technology Selection for Wood Treater Sites
Table A-l presents the distribution of remedial technologies selected at 52 of the 58 NPL wood treater sites (data o n
remedy selection were not available for the remaining six sites). These data were obtained from the two sources cite d
above and EPA's Superfund Records of Decision CD-ROM data base (March 1995). Table A-l demonstrates that the
four wood treater site presumptive remedies (bioremediation, thermal desorption, incineration, and immobilization)
together were selected more often (39 out of the 50 sites for which remedy selection information was available, o r
approximately 78% of the time) than the other applicable technologies. Bioremediation, the primary presumptive remedy
for treating organic contamination, was the remedy selected more often than any other technology (18 out of the 5 0 sites,
or approximately 36% of the time).
Page 32
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APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
(continued)
TABLE A-1
Remedies Selected at NPL Wood Treater Sites
Primary Technologies Selected
to Address Contaminated Soils,
Sediments, and Sludges at
Wood Treater Sites
Bioremediation
Thermal Desorption
Incineration
Immobilization
Dechlorination
Solvent Extraction
Soil Flushing/Washing
Landfilling
Institutional Controls/Monitoring
To Be Determined2
Total Number of
Sites Selecting
Technology1
18
3
13
13
2
1
6
4
2
2
1 The total number of primary technologies selected is greater than the total of 50 sites for which remedy selection data
were available because several sites selected more than one primary technology to address the principal threat of
contaminated soils, sediments, and sludges (e.g., bioremediation to treat organic contamination and immobilization to
treat inorganic contamination). Secondary technologies selected as part of a treatment train are not documented in this
table.
2 Remedial technology for contaminated soils, sediments, and/or sludges not yet selected.
Identification of Sites for the FS/ROD Analysis
The purpose of the FS/ROD analysis was to document the technology screening step and the detailed analysis in the
FSs/RODs of wood treater sites, and to identify the principal reasons given for eliminating technologies from further
consideration. To achieve a representative sample of FSs/RODs for the analysis, sites were selected according to the
following criteria:
Page 33
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Page 34
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APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
(continued)
• Sites were chosen to ensure a balanced distribution among the primary technologies for addressing contaminated
soils, sediments, and sludges at wood treater sites (i.e., bioremediation, thermal desorption, incineration,
immobilization, dechlorination, solvent extraction, soil flushing/washing, landfilling, and institutional
controls/monitoring); and
• Sites were chosen to ensure an even distribution in geographic location and ROD signature date.
Using these criteria, a set of 25 NPL wood treater sites wa s chosen for the FS/ROD analysis; this represents approximately
43% of the total universe of NPL wood treater sites.
FS/ROD Analysis
The FS/ROD analysis involved a review of the technology screening phase, including any pre-screening steps, followed
by a review of the detailed analysis and comparative analysis phases in each of the 25 FSs and RODs. Information derived
from each review was documented on site-specific data collection forms, which are available for evaluation as part of the
Administrative Record for this directive (available at EPA Headquarters and the Regional Offices).
For the screening phase, the full range of technologies considered was listed on the data collection forms, along with the
key reasons given for eliminating technologies from further consideration. These reasons were categorized according to
the three initial screening criteria: cost, effectiveness, and/or implementability. The frequency with which specific reasons
were given for eliminating a technology from further consideration was then tallied and compiled into a screening phase
summary table (Table A-2).
For the detailed analysis and comparative analysis, information on the relative performance of each technology /alternative
with respect to the nine NCP criteria was documented on the site-specific data collection forms. In most cases, several
different remedial technologies were combined in the FSs and RODs to form a remedial alternative or cleanup option. The
disadvantages of a technology/alternative were then compiled into a detailed analysis/comparative analysis summary table,
under the assumption that these disadvantages contributed to non-selection. The advantages and disadvantages associated
with each cleanup option were highlighted. Table A-3 provides the summary information for the detailed analysis an d
comparative analysis phases.
Tables A-2 and A-3 demonstrate that non-presumptive remedy technologies are consistently eliminated from further
consideration in the screening phase due to effectiveness, implementability, and/or excessive costs. In addition, the
FS/ROD analysis indicates that, although certain technologies routinely passed the screening phase, these technologies
were selected infrequently because they did not provide the best overall performance with respect to the nine criteria. This
analysis (in addition to the technical background documentation in the Administrative Record) will support a decision by
site managers to bypass the technology identification and screening step for a particular wood treater site and select one
or more of the presumptive remedies for contaminated soils, sediments, and sludges. As previously discussed, thi s
document and the accompanying FS/ROD analysis should be part of the Administrative Record for the site. Additional
supporting materials not found in the Regional files can be provided by Headquarters, as needed.
Page 35
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GLOSSARY
Action Memorandum — A document that provides a concise written record of the decision selecting a removal action.
It describes the site's history, current activities, and health and environmental threats; outlines the proposed actions and
costs; and documents approval of the proposed action by the proper EPA Headquarters or Regional authority.
Administrative Record — A formal record established by the lead agency, it contains the documents that form the
basis for the selection of a response action (e.g., analysis report, Feasibility Study, Record of Decision, Directives, etc.).
Applicable or Relevant and Appropriate Requirements (ARARs) —Applicable requirements are cleanup
standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal
environmental or facility siting laws that specifically address a hazardous substance, pollutant, contaminant, remedial
action, location, or other circumstance found at a CERCLA site. Relevant and appropriate requirements are cleanup
standards, standards of control, and other substantive requirements, criteria, or limitations promulgated under federal
environmental or facility siting laws that, while not "applicable" to a hazardous substance, pollutant, contaminant,
remedial action, location, or other circumstances at a CERCLA site, address problems or situations sufficiently similar to
those encountered at the CERCLA site and are well-suited to the particular site.
Engineering Evaluation/Cost Analysis (EE/CA) — Required for non-time-critical removal actions, the EE/CA
contains information on site characteristics, removal action objectives, and removal action alternatives. It is intended to
identify the objectives of the removal action and to analyze the various alternatives that may be used to satisfy these
objectives for cost, effectiveness, and implementability. The EE/CA process includes: conducting a removal site
evaluation, notifying PRPs of their liability, preparing an EE/CA approval memorandum, and preparing a study
documenting the removal action options. Although an EE/CA is similar to the RI/FS conducted for remedial actions, it
is less comprehensive. The EE/CA is part of the Administrative Record file and is subject to the public comment and
comment/response requirements for the Administrative Record.
Feasibility Study CFS) — A study undertaken by the lead agency to develop and evaluate options for remedial design.
The FS emphasizes data analysis and is generally performed concurrently and in an interactive fashion with the
Remedial Investigation (RI), using data gathered during the RI.
Hazard Ranking System (HRS) — The method used by EPA to evaluate the relative potential of hazardous substance
releases to cause health or safety problems, or ecological or environmental damage.
Innovative Treatment Technologies — Technologies that have been tested, selected, or used for the treatment of
hazardous substances or contaminated materials but lack well-documented cost and performance data under a variety of
operating conditions.
National Priorities List (NPU — The list compiled by EPA, pursuant to CERCLA section 105, of hazardous
substance releases in the United States that are priorities for long-term remedial evaluation and response.
On-Scene Coordinator (OSO — The federal official predesignated by EPA or the U.S. Coast Guard to coordinate and
direct federal responses under Subpart D of the NCP, or the official designated by the lead agency to coordinate and
direct removal actions under Subpart E of the NCP.
Preliminary Remediation Goals (PRGs) - Initial cleanup goals developed as part of the overall remedial action
objectives. PRGs are established and refined based on a variety of information, including ARARs and TBCs, the
baseline risk assessment, anticipated future land use(s) of the site, and technical, exposure, and uncertainty factors.
Principal Threats - Principal threats include liquids, areas contaminated with high concentrations of toxic compounds,
and highly mobile materials.
Page 51
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GLOSSARY
(continued)
Record of Decision (ROD) — The final remedial action plan for a site or operable unit, which summarizes problems,
alternatives, remedies, and the selected remedy. The ROD also includes the rationale for the selection of the final
remedy, and explains how the selected remedy meets the nine evaluation criteria stated in the NCP.
Remedial Investigation (RR — A process undertaken by the lead agency to determine the nature and extent of the
problem presented by a release. The RI emphasizes data collection and site characterization, and is generally performed
concurrently and in an interactive fashion with the Feasibility Study.
Remedial Project Manager (RPM) — The official designated by the lead agency to coordinate, monitor, or direct a
remedial action under Subpart E of the NCP.
Remedial Site Evaluation — A process undertaken by the lead agency to collect data, as required, and evaluate a
release or threat of release of hazardous substances, pollutants, or contaminants. The evaluation may consist of two
steps: a preliminary assessment (PA) and a site inspection (SI).
Removal Site Evaluation — A process undertaken by the lead agency to identify the source and nature of a release or
threat of release; it may include a removal preliminary assessment and, if warranted, a removal site inspection.
Risk Assessment — The qualitative and/or quantitative evaluation performed in an effort to define the risk posed to
human health and/or the environment by the cumulative presence or potential presence and/or use of specific pollutants.
Superfund Accelerated Cleanup Model (SACM) - The purpose of SACM is to make hazardous waste cleanups more
timely and efficient. This will be accomplished through a greater focus on the front end of the process and better
integration of all Superfund program components. The approach involves: (1) a continuous process for assessing site-
specific conditions and the need for action; (2) cross-program coordination of response planning; (3) prompt risk
reduction through early action (removal or remedial); and (4) appropriate cleanup of long-term environmental problems.
To Be Considereds fTBCs) — Non-promulgated advisories or guidance issued by federal or state governments that are
not legally binding and do not have the status of potential ARARs. In many circumstances, TBCs will be considered
along with ARARs as part of the risk assessment and may be used in determining the necessary level of cleanup for
protection of health or the environment.
Treatabilitv Studies — Preliminary studies in which a hazardous waste is subjected to a treatment process to determine
if the waste is amenable to the process, what pretreatment activities are necessary, what the optimal process options are,
and what is the efficiency of the process.
Page 52
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REFERENCES
Approaches for Remediation of Uncontrolled Wood Preserving Sites. EPA/625/7-90/011, US EPA, Office of
Environmental Research Information, Cincinnati, OH, November 1990.
Rioremediation in the Field Search System (BFSS). Version 1.0., US EPA, available through CLU-IN Bulletin Board
(301-589-8366).
3. CERCLA Compliance with Other Laws Manual: Interim Final. EPA/540/G-89/006, US EPA, OERR, August
1988.
CERCLA Compliance with Other Laws Manual: Part II. Clean Air Act and Other Environmental Statutes and State
Requirements. EPA/540/G-89/009, US EPA, OSWER, August 1989.
Community Relations in Superfund: A Handbook (Interim Guidance). OERR/HSCD Publication 9230.0-03B, US EPA,
June 1988.
6bnsiderations in Ground Water Remediation at Superfund Sites. OSWER Directive 9355.4-03, US EPA, October 18,
1989.
Considerations in Ground-Water Remediation at Superfund Sites and RCRA Facilities - Update . OSWER Directive
9283.1-06, US EPA, May 27,1992.
Kontaminants and Remedial Options at Wood Preserving Sites. EPA/600/R-92/182, US EPA, ORD, RREL, October
1992.
9Creosote Contaminated Sites — Their Potential for Bioremediation," Environmental Science and Technology. Vol. 23.
No. 10. PP. 1197-1201,1989.
10. Dense Nonaqueous Phase Liquids - A Workshop Summary. Dallas. Texas. April 16-18.1991. ORD Publication
EPA/600/R-92/030,1992.
11. DNAPL Site Evaluation. EPA/600/R-93/022, Cohen, R.M., and J.W. Mercer, 1993.
12. Estimating Potential for Occurrence of DNAPL at Superfund Sites. OSWER Publication 9355.4-07FS, US EPA,
1992.
13. Evaluation of the Likelihood of DNAPL Presence atNPL Sites. National Results . OSWER Publication 9355.4-13,
EPA/540/R-93/073, US EPA, September 1993.
14. Field and Laboratory Evaluation of Petroleum Land Treatment System Closure. NTIS #PB 86-130 564/AS, US
EPA, 1986.
15. Ground Water Issue: Dense Nonaaueous Phase Liquids. EPA/540/4-91/002. US EPA. 1991.
16. Guidance for Conducting Remedial Investigations and Feasibility Studies (RI/FSs) Under CERCLA. EPA/540/6-
89/004, OERR Publication 9355.3-01, US EPA, October 1988.
17. Guidance for Evaluating Technical Impracticability of Ground-Water Restoration. OSWER Directive 9234.2-25,
EPA/540/R-93/080, US EPA, September 1993.
18. Guidance Manual on Hazardous Waste Land Treatment/Post-Closure 40 CFR Part 265 . US EPA. 1987.
19. Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA. EPA/540/R-93/057. OERR
Publication 9360.0-32, US EPA, August 1993.
Page 53
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REFERENCES
(continued)
20. Guidance on Remedial Actions for Contaminated Ground Water at Superfund Sites. OSWER Directive 9283.1-2,
EPA/540/G-88/003, US EPA, December 1988.
21. Guide for Conducting Treatabilitv Studies Under CERCLA: Biodegradation Remedy Screening - Interim
Guidance. EPA/540/R-93/519a, US EPA, August 1993.
22. Guide for Conducting Treatabilitv Studies Under CERCLA: Thermal Desorption Remedy Selection - Interim
Guidance. EPA/540/R-92/074A, US EPA, September 1991.
23. Guide to Principal Threat and Low-Level Wastes. Superfund Publication 9380.3-06FS, US EPA, 1991.
24. Guide to Treatment for Hazardous Wastes at Superfund Sites. EPA/540/2-89/052, US EPA, Office of
Environmental Engineering and Technology Development, March 1989.
25. "Incineration of Hazardous Waste: A Critical Review Update," International Journal of Air Pollution Control and
Hazardous Waste Management Vol. 43. pp. 25-73, January 1993.
26. Innovative Treatment Technologies: Overview and Guide to Information Sources. EPA/540/9-91/002, US EPA,
OSWER, TIO, October 1991.
27. Land Use in the CERCLA Remedy Selection Process. OSWER Directive 9355.7-04, US EPA, May 25,1995.
28. Mobile/Transportable Incineration Treatment Engineering Bulletin. EPA/540/2-90/014. US EPA. February 1990.
29. Mobility and Degradation of Residues at Hazardous Waste Land Treatment Sites at Closure. EPA/600/2-90/018.
US EPA, April 1990.
30. Notice of Availability with Request for Comment on Draft Soil Screening Guidance. 59 Federal Register 67706.
December 30,1994.
31. Presumptive Remedies: Policies and Procedures. OERR Publication 9355.0-47FS, US EPA, September 1993.
32. Presumptive Remedies: Site Characterization and Technology Selection For CERCLA Sites With Volatile Organic
Compounds In Soils. OSWER Directive 9355.0-48FS, EPA/540/F-93/048, US EPA, September 1993.
33. Presumptive Remedy for CERCLA Municipal Landfill Sites. OSWER Directive 9355.0-49FS, EPA/540/F-93/035,
US EPA, September 1993.
34. Removal Program Representative Sampling Guidance. Volume 1: Soil. OERR Publication 9360.4-10, US EPA,
November 1991.
35. Risk Assessment Guidance for Superfund. Volume 1: Human Health Evaluation Manual. Part A. Interim Final.
OERR/HSED Publication 9285.7-01B, US EPA, December 1989.
36. Risk Assessment Guidance for Superfund. Volume 2: Environmental Evaluation Manual. Interim Final. Part A .
OERR/HSED Publication 9285.7-01A, US EPA, March 1989.
37. Strategy for Hazardous Waste Minimization and Combustion. EPA/530/R-94/044, US EPA, November 1994.
38. Suggested ROD Language for Various Ground Water Remediation Options. OSWER Directive 9283.1-03. US
EPA, October 10,1990.
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REFERENCES
(continued)
39. Suoerfund LDR Guide #6A. Obtaining a Soil and Debris Treatabilitv Variance for Remedial Actions . OSWER
Publication 9347.3-06FS, US EPA, September 1990.
40. Superfund LDR Guide #6B. Obtaining a Soil and Debris Treatabilitv Variance for Removal Actions . OSWER
Publication 9347.3-06BFS, US EPA, September 1990.
41. Superfund Removal Procedures: Guidance on the Consideration of ARARs During Removal Actions. OSWER
Publication 9360.3-02, US EPA, August 1991.
42. Superfund Removal Procedures: Public Participation Guidance for On-Scene Coordinators: Community Relations
and the Administrative Record. OERR Publication 9360.3-05, US EPA, June 1992.
43. Technology Selection Guide for Wood Treater Sites. OERR Publication 9360.0-46FS, US EPA, May 1993.
44. Thermal Desorption Treatment Engineering Bulletin. EPA/540/2-91/008, US EPA, February, 1991.
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