United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-2151
June 1990
Superfund Design and
Construction Update
Office of Emergency and Remedial Response
Hazardous Site Control Division OS - 220
Intermittent Bulletin
Volume4 Numbers
HIGH- AND LOW-TEMPERATURE THERMAL TECHNOLOGIES
Thermal treatment is usually not the least
costly treatment alternative, but it is one of
the most acceptable and permanent avail-
able. Compared to land disposal, it offers
immediate destruction, limited liability, and
mobility, which minimizes the impact on
local neighborhoods.
Thermal treatment of soils contaminated
with organics provides immediate destruc-
tion of the organics and a non-putrescible
residual. When the thermal destruction
system has been shut down and removed
from the site, there is no longer liability.
This compares favorably with other dis-
posal methods, where contaminated ma-
terials may accumulate for years before
destruction is complete. The issues of
complete destruction of organics and lim-
ited liability makes thermal treatment a
favored option for the treatment of many
waste accumulations. By the end of 1989,
remediation by thermal destruction was
initiated or completed at over 30 NPL sites
throughout the country.
What is Thermal Treatment?
The heating of soil or other material to a
temperature where organics are released
is termed "thermal treatment." There are
two basic types of thermal treatment tech-
nologies in use for onsita applications:
incineration and low-temperature desorp-
tion. Dozens of firms market technology
services based upon the application of
these thermal destruction systems.
Incineration uses two firing chambers. In
the first, or primary, combustion chamber,
the feed (material to be treated) is raised to
a temperature in excess of 1,200°F. Or-
ganics are released from the feed to the
exhaust gas stream and pass to a secon-
dary combustion chamber. In the secon-
dary combustion chamber, the organics
are fired and burn out, turning to carbon
dioxide and water vapor An air-emis-
sions control system is normally pro-
vided after the secondary combustion
chamber to remove soils or other par-
ticulate from the exhaust gas and to
remove acid gases (such as hydrogen
chloride) that may be generated from
chlorinated organics or other materials
in the feed.
Low-temperature desorber systems are
those thermal treatment units that have
been developed for feeds contaminated
with volatile organic compounds (VOCs),
which vaporize at a temperature of less
than 160°F. The feed is heated, and
VOCs are driven off. Some organic/soil
mixtures will release organics at tem-
peratures below 800°F. The organics
are either collected for reuse, absorbed
out of the gas stream, condensed, or in-
cinerated.
The main difference between incinera-
tion and low-temperature desorption is
the temperature required in the primary
chamber of the system for effective re-
lease of organics from the contaminated
feed. When VOCs predominate, low-
temperature desorption may be the pre-
ferred thermal system.
Incineration Systems
Most onsite incineration systems use a
rotary kiln as the primary chamber, such
as the IT Corporation (Irvine, California),
the John Zmk (Tulsa, Oklahoma), and
the Vesta (Ft. Lauderdale, Florida) sys-
tems, which are all competitive systems.
The primary combustion chambers of
these systems are horizontal rotating
cylinders lined with refractory material.
Supplemental fuel is fired at one end of
the kiln to bring the unit up to operating
temperatures and to maintain these tem-
peratures during operation. Another type
of primary combustion chamber that is
used is the conveyor furnace. OH Mate-
rials (Fmdlay, Ohio), Westinghouse/Haz-
tech (Decatur, Georgia), and U.S. Waste
Thermal Processing (Fontana, Califor-
nia) use these units for onsite incinera-
tion. Waste is placed on a conveyor belt
that passes under electric heating ele-
ments or burners fired with natural gas,
propane, or fuel oil. After the 40- or 50-
foot-long conveyor belt passes through
the furnace chamber, the waste feed will
have burned out to an ash. Each of these
primary chamber systems discharges to
a secondary combustion chamber where
the organics in the off-gas are destroyed.
Destruction is normally achieved at rela-
tively high temperatures (from 1,800°F to
2,200°F) maintained for a period of 1 to 2
seconds.
Another type of transportable incinerator
in use is the circulating fluid-bed combus-
tor, manufactured and operated by Ogden
Environmental Systems (San Diego,
California). Waste discharges into a bed
of sand or limestone through a high-
velocity air stream. This system has a
single combustion chamber through
which the waste circulates for approxi-
mately 60 seconds With a retention time
this long, it has been found that a rela-
tively low temperature can be used for
destruction. For instance, while many
chlorinated organic compounds require
a temperature of 2,200°F and 2 seconds
residence time for effective destruction,
the same level of destruction can be
obtained with a temperature of from
1.300°F to 1,600°F with the 60-second
retention time. The decrease in operating
continued on p. 2
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HIGH- AND LOW-TEMPERATURE THERMAL TECHNOLOGIES
continued from p. 1
temperature significantly decreases the
operating cost (supplemental fuel cost) of
the system. Not all wastes, however, are
applicable for destruction in a fluid-bed
incinerator. In situations where constitu-
ents of the waste have relatively low
melting points (temperatures), such as
sodium or calcium salts, melting can occur
within the chamber. When this occurs,
the fluidization necessary forthis process
will not develop.
Thermal Desorbing Equipment
Chemical Waste Management (Oak-
brook, Illinois) has developed a low-
temperature thermal desorber that uses
a rotary dryer as its primary chamber.
Waste is fed to the dryer, which is
externally heated Volatiles discharged
from the waste are drawn off through
condensers, where the condensable
organics present in the off-gas condense
are removed from the system. A wet
scrubber, filters, and carbon drums in the
exhaust-gas discharge system will also
remove materials from the exhaust,
resulting in a clean discharge to the
atmosphere.
The low-temperature thermal treatment
system developed by Weston (West
Chester. Pennsylvania) heats contami-
nated soil in a primary chamber equipped
with a series of screws. Hot oil circulates
through the screws to heat the soil and
release the VOCs present. The VOCs
dischargedtothe gas stream passthrough
an afterburner for destruction. The gas
stream then goes through an air-emis-
sions control system, which includes a
baghouse, carbon filters, and a condenser,
to remove residual carbon and other
particulates in the gas stream.
Mobility
Most of the thermal systems marketed for
soil romediation are transportable sys-
tems. They are typically brought to the
site by l5to 50 trailers. The systems typi-
cally include process equipment; a mo-
bile laboratory; fuel, water, water-treat-
ment and wastewater tanks; person-
nel safety equipment; and other serv-
ice and support service equipment
and materials. The entire system
usually requires from 4 to 12 weeks for
erection. Likewise, dismantling takes
at least a month in most cases. At least
one manufacturer of incineration sys-
tems, Vesta, designed its equipment
specifically with mobility in mind. They
place the primary and secondary
combustion chambers of an incinera-
tor on one truck trailer body, as well as
the scrubber, induced draft fan, ex-
haust stack, and system controls. This
system, which has a throughput rated
at a 2000-lb/hr of dry soil, can be oper-
ating within two days of arrival at a site.
Generally, a transportable system is
designed for use for no less than six
months whereas a mobile system can
be set up immediately and can be
used economically for relatively small
amounts of contaminated materials.
REMEDIAL ACTION CONTRACTING AUTHORITY
Authority and responsibility to contract
for remedial action (RA) is vested in the
contracting party. For most RAs, the
contracting party will be a state working
under a cooperative agreement; the
Bureau of Reclamation or U.S. Army
Corps of Engineers under an interagency
agreement or an ARCS firm under a
contract. The contracting party must for-
mally designate a person as the “contract
manager/officer/administrator (CM/O/A)
with the authority to enter into, admini-
ster, modify, change, or terminate con-
tracts and make related determinations.
The CM/O/A may delegate, in writing,
some authority to another person (such
as a resident engineer) to act as their rep-
resentative.
Only the CM/OIA or an authorized repre-
sentative can issue an oral or written
change to the RA contractor or increase
the amount or duration of the contract.
Unfortunately, certain acts or the failure
to act by EPA or by unauthorized repre-
sentatives of the contracting party may
lead to increased RA costs and delays,
resulting in constructive changes and
contractor claims. A constructive change
has the effect of prescribing new ordrffer-
ent work at additional time or cost without
a formal change order or supplemental
agreement. A contractor claim is a
demand by the RA contractor for extra
money, a time extension, or a contract
change that has previously been disputed
or not acted upon by the CM/O/A.
EPA and the contracting party can pre-
vent constructive changes that result from:
• Nondisclosure of technical information
• Actions by those with apparent, not
real, authority
• Disregard for the privity of contract
between a contracting party and its
contractor or between a prime contrac-
tor and its subcontractors
• Directing a manner of performance not
specified in the RA contract or directing
the means and methods to be used by
the RA contractor
• Defective plans and specifications or
impossibility of contractor performance
• Unreasonable delay in review or ap-
proval of contractor submissions and
requests
EPA and the contracting party can miti-
gate some causes of contractor claims,
such as:
• Interference by other contractors or
unauthorized representatives
• Cumulative effect of contract modifica-
tions and EPA-caused delays
• Untimely or unfairly addressed prob-
lems
• Inadequate inspection and construc-
tion management
• Differing site conditions
• Inadequate responses to time exten-
sions and delay costs
To reduce the frequency, cost, and im-
pact of constructive changes and con-
tractor claims, EPA and the contracting
party must:
• Maintain RA schedules
• Rapidly resolve project problems
• Respond to the CM/OIA in a timely
manner
• Communicate frequently with the CM/
0/A, not directly with the RA contrac-
tor
• Require a quality assurance/quality
control program during remedial de-
sign and RA
• Require reviews of the plans, specif i-
cations, and contract documents with
regard to bids, construction, claim
prevention, operation, and value engi-
neering
For advice and technical assistance on
constructive changes and contractor
claims, contact Thomas A. Whalen, P.E.,
in DCMB at FTS or (202) 475-9755.
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FEMA TERMINATES SUPERFUND RELOCATION SUPPORT
The Federal Emergency Management
Agency (FEMA) requested in a letter to
the director, Office of Emergency and
Remedial Response (OERR),that its role
in the Superfund relocation program be
terminated.
FEMA, under Executive Order #12580.
was granted the authority to carry out all
relocations. In its letter, FEMA indicated
that its increased workload, resulting from
recent natural disasters such as the Loma
Prieta earthquake and Hurricane Hugo.
had strained its resources. OERR thanked
the Agency for its work in Superfund and
agreed to the termination, with the condi-
tion that FEMA full ill all interagency agree-
ments currently in effect and assist EPA
in any emergency situations, as neces-
saly, through the end of this fiscal year.
However, until the Executive Order is
amended through the Office of Manage-
ment and Budget, FEMA will still be re-
sponsible for the health-based reloca-
tions. EPA-HO and FEMA are working
together to amend the Executive Order
and to effect a possible redelegation in
the interim.
Currently, the Emergency Response
Division is exploring alternatives for use
in emergency relocations. The options
being evaluated include the U.S. Army
Corpsof Engineers (USACE), Emergency
Response Contractors, or EPA-HO. The
Division will be in contact with the Re-
gions once a new procedure is estab-
lished.
There are cases where an emergency
relocation, which is a temporary action as
defined in CERCLA, may become a per-
manent relocation (for example, Times
Beach and Forest Glen). In these situ-
ations, the remedial action at the site
(operable unit) is the permanent reloca-
tion of the affected population.
When the Region anticipates a perma-
nent relocation, EPA-HG must be ad-
vised All acquisitions must be approved
by the Assistant Administrator, Office of
Solid Waste and Emergency Response,
with advance concurrence from the Office
of the General Counsel. In addition, the
Facilities Management and Services
Division is the only authorized EPA corn-
ponent that may accept and hold property
on behalf of the Agency. Therefore, it
must be involved early in the acquisition
process to ensure that the acquisition
regulations are followed. USACE will assist
EPA in permanently acquiring property
and relocating all residents during the
remedial action phase of a project.
For additional information regarding the
permanent relocation procedure, please
refer to the Quick Reference Fact Sheet
9355.5-OIIFS, “Real Estate Acquisition
Procedures for USACE Projects,” dated
February 1990.
If an emergency temporary relocation is
anticipated, please contact Elizabeth
Zeller, Emergency Response Division, at
FTS or (202) 382-7735. For additional
information regarding permanent reloca-
tions, please contact J 0 Ann Griffith,
Hazardous Site Control Division, at FTS
or (202) 475-6704.
The Superfund program is entering its
second decade of operations. There have
been significant developments during the
first 10 years and public awareness of
EPA activities has grown dramatically. The
number of Superfund sites also continues
to spiral upward.
Administration of the ever-expanding
Superfund program has become increas-
ingly complex and expensive. Accurate
and efficient recordkeeping is stressed
because these elements have proven
essential to successful cost recovery.
Uniform standards for retention of the EPA
Superfund records were lacking in the
early years, making retrieval of historical
records difficult and time-consuming. The
resulting delays in production of cost-
recovery packages for the Department of
Justice proved costly. In 1986, Computer
Sciences Corporation (CSC) was issued a
work order to develop and implement a
nationwide program for Superfund rec-
ords management to aid in Superfund fi-
nancial documentation.
EPA is now advocating cost documenta-
tion standards for other federal agencies
participating in the Superfund program. In
January 1989, the Superfund Accounting
Branch issued a publication titled “Guid-
ance for Federal Recordkeeping” that
outlines these standards.
Because of their involvement in the
Superfund program, the U.S. Army Corps
of Engineers (USACE) was the first
federal agency to adopt standard
recordkeeping procedures. In the fall of
1989, CSC was selected to assist
USACE with the development and im-
plementation of their internal program
for Superfund records management.
Working at selected USACE disbursing
offices, CSC staff will review USACE
Superfund cost documentation dating
back to the inception of the program.
Two sets of files to justify expenditures
will be established. One set, the Super-
fund original files, will contain original
Superfund financial documents. A sec-
ond set of files, the site files, will contain
documented costs on a site-specific
basis. The files will be periodically rec-
onci led to ensure that EPA and USACE
records are correct and accurate. This
structure, often called the “active files
project,” has proven successful in EPA
cost-recovery actions because it com-
bines three key elements of cost recov-
ery: availability, completeness, and
accuracy.
CSC’s first task was the development of
a project plan, an outline of the compre-
hensive plan of action. CSC traveled to
the USACE facilities in Omaha to inter-
view selected personnel and to become
familiar with specific documentation and
USACE financial systems. CSC then
produced a procedures manual. The
project started up in the Omaha financial
offices during the final week of March
1990.
The USACE cost documentation project
was initiated in Omaha because of the
concentration of cost information at this
facility. The next phase will involve CSC
teams traveling to selected USACE dis-
bursing offices to process Superfund fi-
nancial records and establish original and
site-specific files for USACE projects. A
CSC team was established in Boston to
initiate the cost recovery documentation
effort for all east coast USACE offices.
There are many parallels between the
two CSC efforts. There are many vari-
ables and unknowns. The exact volume
of USACE documentation is unclear;
processing time is uncertain. The logis-
tics involved in retrieving years of histori-
cal records is staggering. Space con-
straints are anticipated at most USACE
facilities.
Arrangements for long-term storage of
the Superfund cost documentation are
continued on p. 4
COST RECOVERY FOR U.S. ARMY CORPS OF ENGINEERS’
SUPERFUND PROJECTS _____________________
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COST RECOVERY FOR U.S. ARMY CORPS OF ENGINEERS’
SUPERFUND PROJECTS _______________________
continued from p. 3
not final The nationwide scope of both
projects complicates managementS CSC
and EPA have learned that uniformity in
the effort is unrealistic, that there must be
some allowance for local variance. Proj-
ect control of both efforts will be a function
of EPA Headquarters, with local operat-
ing units each retaining some degree of
autonomy.
This effort is truly a partnership between
EPA and USACE. EPA has funded con-
tractor support and provided guidance on
cost-recovery requirements. USACE is
providing CSC with office space, equip-
mont. supplies, and ongoing technical
assistance.
For additional information, please con-
tact Cdr. William Zobel, Design and Con-
struction Management Branch, at FTS or
(202) 382-2347, or Ms. Anne Wohileban,
CSC Project Manager, at 703-538-7234.
COMPILATION OF BID TABULATIONS FOR POST-SARA REMEDIAL
ACTION START SITES _______________________________
The Design and Construction Manage-
ment Branch (DCMB) of the Hazardous
Site Control Division is in the process of
compiling all available bid tabulations (bid
tabs) for federally funded post-SARA re-
medial action start sites. The purpose of
this project is to provide EPA’s regional
and headquarters Superfund staffs with a
tool for determining the validity of bids
they may receive for future remedial ac-
tions.
There were 87 federally funded post-
SARA remedial action start sites that
were considered for inclusion in this
compilation. These comprise a subset of
the 178 sites where remedial actions had
started by the October 17, 1989, SARA
deadline. This list was later expanded to
include both first and subsequent post-
SARA RAs. Of these 87 sites, the bids for
18 FEMA or EACS (relocation or “re-
moval ”) sites were incompatible with this
study. DCMB has compiled 42 of the
remaining bid tabs and is distributing
copies of the bid tab compilation package
to each Superfund Regional Branch Chief.
Each Region will receive a copy of the bid
tab compilation package. Any other par-
ties desiring the bid tab compilation pack-
age will receive copies upon request
(contact DCMB: distribution will be lim-
ited to EPA personnel). Updates will be
distributed to the Regions periodically as
more bid tabs become available.
The bid tab compilation package will in-
clude a printout of each bid tab, two floppy
disks containing a bid tab data base and
the software for processing the bid tabs.
and a user’s manual for the software. The
printouts will contain the following infor-
mation for each site: basic site data, key
technological words that correspond to
the selected remediation technologies,
date of bid opening, project status, dollar
volume of change orders to bid, contract-
ing agency, site narrative, line item costs
and descriptions from the engineer’s bid,
the awarded bid, as well as the lowest,
second lowest, third lowest, and highest
bids received. The report options avail-
able in the software allow the user to run
summary reports or detailed reports for
each bid tab (the detailed reports will
include the same information in the print-
outs). The reports can be selected by site
name, region, or key technological word
(i e., remediation technologies). The user
can edit the bid tabs or add new ones to
the system as needed.
Although this bid tab compilation project
can offer no bottom-line guide for what
are acceptable unit prices or construction
costs, it does offer insight as to what bids
have been accepted as fair and reason-
able for specific sites. Variances in size
and geographical characteristics of sites,
reniediation technologies, or experience
of the contractors will complicate any sum-
mary or general analysis of bid tabs and
will not be included in this bid tab com-
pilation package; DCMB is,however, con-
sidering such an analysis in the future.
DCMB appreciates any suggestions,
questions, or comments concerning this
and future presentations of the bid tabs.
Contact Chris Watling of DCMB at FTS
382-3901, or commercially at 202-382-
3901.
EPA TRACKING THE “200” RA STARTS
The Comprehensive Environmental Re-
sponse, Compensation, and Liability Act
mandated 175 substantial and continu-
ous, physical onsite remedial actions (RA)
to begin by October 16, 1989. EPA met
that target with 178 first RA starts. The
second part of that mandate requires EPA
to initiate RAs at an additional 200 sites
within the 24-month period immediately
following.
The Office of Emergency and Remedial
Response (OERR) performed an initial
search of CERCLIS and identified ap-
proximately 183 projects where RAscould
be started before October 17, 1991. 01
those projects cited as possible “200”
starts, 78 are currently listed as Fund-
lead, with the remaining 105 projects
ltsted as PAP sites.
Because of cutbacks in funding, projects
slated for RA dollars in this fiscal year
(FY) were ranked through a process that
was based on the imminence and risk
level at each of the sites. Because of
budget and FTE limitations, EPA is ex-
pected to achieve only 127 RA starts by
the October 1991 deadline. However,
OERR will continue to monitor the prog-
ress of the RA completions through the
1991 deadline. Current projections indi-
cate that there will be additional projects,
where the designs have been completed,
that will be eligible for funding. It is EPA’s
goal to queue 200 projects that meet the
criteria for receiving RA funds.
If you have any questions, please contact
Ms. J 0 Ann Griffith, Design and Construc-
tion Management Branch, at FTS or (202)
475-6704.
ABOUT THE UPDATE
For comments, ideas, submissions, or questions about the Update, please contact Jo Ann Gntflth, Design and Construction Management
Branch, at FTS 475-6704 orcommercially at (202) 475-6704 For copies, contact EPAs Public Information Centerat FTS 8-382-2080 or(202)
382-2080, or wnte to EPA Public Information Center. U S Environmental Protection Agency, 401 M St S W , Washington, D C. 20460
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