x>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9380.3-02
TITLE: Treatability Studies Under CERCLA
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
S3 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
December 28, 1989
December 28, 1989
OSWER OS WE Ft OSWER
VE DIRECTIVE DIRECTIVE
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United!
Washington. DC 2WCO
QSWER Directive Initiation Request
. Directrve Number
9380.3-02
2. Originator Information
3. Title
of Conuet Per»on
B. VanEpps_/_ SDC
Mad COG*
OS-240
Office
OERR, 0PM,
T*epnon« Cod*
475-8864
Treatability Studies Under CERCLA
4. Summary of Directive (include bnef statement of purpose)
fhis memorandum transmits a guidance document and a fact sheet to
facilitate the performance of treatability studies early in the •
Superfund process.
5. Keywords
6*. Does This Direct/ve Superseae Previous Direct/vets)?
b. Does It Supplement Previous Directfve(s)?
7. Drift Level
j I No | j Yes Whet directive (number. We)
Yn Whet directive (number. We)
No
A-S
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
HFC 2 8
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive No. 9380.3-02
MEMORANDUM
SUBJECT: Treatability Studies Under CERCLA
Recommendation No. 38A and
FROM:
TO;
Superfund Management Review:
Recommendation No. 38B
Henry L. Longest II, Director
Office of Emergency and Remedial
Alfred Lindsey, Acting Directo
Office of Environmental Engine
Demonstration
nology
Directors, Waste Management Division, Regions I, IV, V,
VII, and VIII
Director, Emergency and Remedial Response Division,
Region II
Directors, Hazardous Waste Management Division
Region III, VI
Director, Toxic and Waste Management Division, Region IX
Director, Hazardous Waste Division, Region X
Purpose
This memorandum transmits a guidance document and a fact
sheet to facilitate the performance of treatability studies early
in the Superfund process. The document, "Guide for Conducting
Treatability-^studies under CERCLA (Interim Final)", (EPA 540/2-
89/058, December 1989), provides a systematic approach for
performing treatability studies and provides a protocol for
scoping, performing and reporting the results. A pre-publication
copy of the document is attached.
The fact sheet, "Treatability Studies under CERCLA: an
Overview", provides a summary of information presented in the
guidance document (Overview of Treatability Studies) and provides
additional administrative information to facilitate the planning
and execution of treatability studies.
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Background
The Agency is encouraging increased utilization of
treatability studies to support the Superfund decision making
process. This effort is in response to an overall Agency
initiative to ensure that decisions are based on data of known,
documented, and appropriate quality. Regions need to plan for
and implement treatability studies as early as it is evident that
insufficient data are available. The Agency is developing a
series of guidance documents and fact sheets to facilitate the
performance of and ensure the quality of treatability studies.
The Office of Research and Development (ORD) working with
the Office of Emergency and Remedial Response (OERR) has
developed a guidance document entitled "Guide for Conducting
Treatability Studies under CERCLA (Interim Final)" (EPA 540/2-
89/058, December 1989). The document describes a three-tiered
approach for conducting treatability studies that consists of:
1) laboratory screening, 2) bench-scale testing, and 3) pilot-
scale testing. Some or all of these levels may be needed on a
case-by-case basis. The document also presents a stepwise
approach or protocol for conducting treatability studies.
Although the document focuses on treatability studies in support
of remedy selection, much of the information presented has
application for treatability studies in support of remedy
implementation as well.
A companion fact sheet entitled "Treatability Studies under
CERCLA: an Overview" was developed by OERR to provide information
which will allow for the efficient planning and performance of
treatability studies. This fact sheet provides a summary and in
some cases an expansion of information presented in chapter 2 of
the guidance document. The fact sheet also provides
administrative information to facilitate the planning and
performance of treatability studies. This information includes a
discussion of: administrative planning (budget cycle), funding,
CERCLISj. .^and—technical assistance, among other topics.
Implementation
The fact sheet and the guidance document are to be utilized
by RPMs, contractors, and responsible parties for the planning
and implementation of the treatability studies. In addition, all
work assignments for treatability studies are to include a
provision requiring that a camera-ready copy of the treatability
study report be sent to the address indicated in the fact sheet
so that we may build on the information learned for future
Superfund decisions.
These guidances provide the basic framework for treatability
studies. It is recognized that treatability studies need to
consider site-specific factors, literature information, and
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technical expert judgement. The Agency will be issuing a series
of technology specific treatability studies guidance documents in
FY 90 and beyond to further aid in the quality performance of
treatability studies.
The guidance document is issued as an "interim final"
document and is tentatively scheduled to be revised early in
FY 91 based on experience to date on treatability studies and
will also address remedy implementation or post-ROD treatability
studies. The guidance as presented provides a methodology which
was developed based on input received from experts in ORD,
Regions, contractors, and industry. This basic framework is
expected to remain the same in future revisions.
The documents will be available from the U.S. Environmental
Protection Agency's Center for Environmental Research Information
(FTS 684-7562 or 513/569-7562) or purchased from the National
Technical Information Service (703/487-4650). The document is
scheduled to be distributed to the Regions and Agency contractors
in February 1990.
Treatability studies are a key component of the Superfund
process. The studies need to be planned in a systematic manner
and are to be reported utilizing a standard format. The guidance
and the fact sheet provide information to aid in this effort and
should be implemented.
cc: Superfund Branch Chiefs, Region I-X
Superfund Section Chiefs, Regions I-X
Technology support Project Forum Members, Regions I-X
Regional Quality Assurance Officers, Regions I-X
Russ Wyer
Steve Lingle
Tim Oppelt
Lloyd Guerci
Wall: Kovalick
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