United States
                      Environmental
                      Protection Agency
                                                  Office of Solid Waste
                                                  and Emergency
                                                  Response
Publication 9360.0-46FS
EPA540-F-93-020
April 1993
                             Presumptive   Remedies:
                             Technology  Selection  Guide for
                             Wood  Treater Sites
 Office of Emergency and Remedial Response
 Emergency Response Division 5202G
                                                                               Quick Reference Fact Sheet
Since the enactment of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCL A or Superfund) in 1980, the
Superfund remedial and removal programs have found that certain site categories have similar characteristics, such as: types of contaminants
present; types of disposal practices; or how environmental media are affected. Based on information acquired from evaluating and cleaning
up many of these sites, Superfund is undertaking an initiative to develop presumptive remedies that are appropriate for specific types of sites
and that are designed to accelerate the Superfund cleanup process.  The objective of the presumptive remedies initiative is to draw upon past
experiences to streamline site investigations and the remedy selection process in accordance with the Superfund Accelerated Cleanup Model
(SACM). The Agency has developed presumptions that particular technologies are appropriate for certain types of sites by  evaluating
technologies that have been consistently selected and successfully used for past sites.

The Agency is developing a Generic Presumptive Remedies fact sheet which will outline and address the common issues (e.g.,  use of risk
assessment, innovative technologies, how to rebut the presumptive remedy, etc.) anticipated with the use of a presumptive remedy  at any site.
In addition, the Agency is developing guidance on presumptive remedies for soils contaminated by volatile organic compounds, municipal
landfills, polychlorinatedbyphenols, grain storage, coal gasification sites, and contaminated ground water.

Information on technology performance for wood treater sites is presented in this Technology Selection Guide; it will be supplemented by
additional analyses of previous remedy selection decisions and remedy performance.  This additional analyses will be developed into a
Presumptive Remedy Guide. This document is intended for use by a decision-making team experienced with wood treater sites.

                                                        are presented in this guide; in addition, other technologies,
                                                        with limited performance data,  are also presented here.
BACKGROUND

Abandoned wood treater sites typically contain the following
contaminants either alone or in combination with each other
or with total petroleum hydrocarbon  (TPH) carrier oils:
creosote  (mainly, polynuclear  aromatic hydrocarbons
(PAHs)); pentachlorophenol (PCP); and chromated copper
arsenate (CCA). These contaminants may be found in pure
form (product), or in sludge, soil, sediments, surface waters,
or ground water.   Light Non-Aqueous Phase Liquids
(LNAPLs) and Dense NAPLs (DNAPLs)  may also be
present in surface or ground water.

Removal  and remedial program experience  at full-scale
projects indicates that there are some demonstrated treatment
technologies capable of achieving defined clean-up goals at
wood treater sites. These technologies
                                                        IMPLEMENTATION

                                                        Choosing among remedies requires care to match treatment
                                                        requirements with site specific conditions, but the process
                                                        can be streamlined within the scope of the National Oil and
                                                        Hazardous Substances Pollution Contingency Plan (NCP)
                                                        remedy selection requirements. A focused site evaluation by
                                                        experienced personnel with the use of the guide can greatly
                                                        limit the feasible treatment options, identify early actions,
                                                        and expedite the clean-up process.  This guide provides a
                                                        selection procedure  outline  (box  below) and practical
                                                        considerations for the facilitation of remedy selection. In
                                                        addition, three tables are included in the guide: Table I,
                                                        Technologies for Treatment of Sludge, Soil, and Sediment;
                                                        Table II, Technologies for Treatment of Surface Water and
                                                        Ground Water; and Table III, Information Needs and Process
                                                        Limitations. Many of the tasks outlined in this guide can and
                                                        should be conducted simultaneously to accelerate the process

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and to minimize cost; however, a sequential process may be
necessary at times.
            WOOD TREATER TECHNOLOGY
          SELECTION PROCEDURE OUTLINE

                  Site Characterization
 A.
 C.
   Identify Contaminant
   1.  Type (i.e., CCA, PCP, creosote, or TPH)
   2.  Alone or mixed (e.g., PCP/creosote/CCA)
B. Establish Site  Screening Criteria1 Based on Actual or
   Anticipated Land and Water Uses
   Identify Media  and Areas Needing Treatment:
   1.  Product (drums, tanks, or recoverable NAPLs)
   2.  Sludge (drums, tanks, or open or buried lagoons)
   3.  Soil and sediments from:
      a.  process areas
      b.  drip areas and storage areas
      c.  lagoon or drainage areas (on-site/off-site)
      Surface Water
      a.  ponds/lagoons
      b.  runoff or drainage pathways
      Ground Water
   Identify Possible Treatment Options  (Tables I and II)
   (include  treatability  studies  for  non-demonstrated
   technologies)
   Determine Extent, Volume, and Level of Contamination in
   Each Medium and Area of Concern
   Characterize Broadly the Physical/Chemical Nature of Each
   Treatment Medium in  View of the Possible Treatments
   (Table III Identifies Additional Information Needs):
   1.  Solids - Particle Size Distribution/ pH/Total Organic
      Carbon (TOC)/Cation Exchange Capacity/Moisture
   2.  Liquids - Phases/pH/TOC
   3.  Sludge - TOC/Moisture/Pumping Characteristics
   Select  Final Clean-up Goals  and Treatment Levels1
   Considering Anticipated Land and Water Uses and the
   Removal Efficiencies Required to Achieve Those Levels
    4.
    5.
 D.
 E.
 F.
 G.
           WOOD TREATER TECHNOLOGY
          SELECTION PROCEDURE OUTLINE
                      (continued)

                  Treatment Selection

 A.      Confirm the Volumes, Matrix Homogeneity and
         Consistency, and Contaminant Concentrations
 B.      Evaluate On/Off-Site and Pre-Treatment
         Options
 C.      Evaluate Capping/Containment Option
 D.      Assess Excavation, Segregation, and Stockpiling
 E.      Select Candidate Treatment Options (Tables I
         and II)
 F.      Evaluate Treatment Limitations and
         Information Needs Using Table III
 G.      Select Final Treatments and Perform Site
         Specific Treatability Studies to Obtain Design
         Data for Procurement Specification
 'Site Screening Criteria are operational indicators, such as action levels
 resulting from an exposure risk assessment for a specific land use; they trigger
 the need for clean-up. Clean-up Goals and Treatment Levels reflect
 projected exposures for particular land uses; these levels describe the
 suitability of a resource for its intended use.
PRACTICAL CONSIDERATIONS FOR
FACILITATING TECHNOLOGY SELECTION

1.    If the product is still in original containers it should be
     returned to the manufacturer. Reuse of material (i.e.,
     process liquids) and relocation of equipment to other
     permitted facilities  should be  considered.   Phase
     separation should be conducted; water and emulsified
     product could be  treated on  site.   LNAPLs and
     DNAPLs may or may not be recyclable depending on
     the purity of the recovered phase.

2.    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 Waste Exchanges are listed in Appendix A.
     The  alternative to reuse or recycling  is  to treat  the
     material as waste along with other contaminated liquids
     or solids.

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3.    If the product, (e.g., PCP), is in storage tanks, then it
     should be analyzed for cross contaminants such as
     dioxins/furans.  Total pumpable and non-pumpable
     sludge in tanks and drums should also be determined.

4.    Site characterization should proceed as a single, multi-
     media sampling  event whenever possible.   Field
     screening methods should  be  integrated into  the
     sampling  and analysis plan in order to accelerate
     information gathering. Data quality  objectives must
     reflect the ultimate use of the results, but all samples
     taken during a single event may not require the same
     level of data quality.

5.    Site  preparation  and  bulk material  handling needs
     require evaluation wherever soil treatment is being
     considered. Pretreatment renders a material suitable as
     feed for a treatment process.  The technology selection
     should be evaluated for consistency  with the overall
     remedy for the site.  Site preparation and pretreatment
     activities include but are not  limited to the following:

   A. Site Stabilization
       1.  Fencing and security
      2.  Capture and treatment of runoff
      3.  Containment of leaking vessels
      4.  Use of liners  and covers
      5.  Capping and  containment
      6.   Evaluation  of on-site pretreatment for off-site
         disposal

   B. Material   Handling,
      Pretreatment
       1 .  Surface material removal (poles, tanks, buildings,
         product, etc.)
      2.  Excavation & stockpiling
      3.  Sizing
         a. Screening of inert and oversized materials
         b. Particle fractionation or hydrosieving
         c. Debris handling
      4. Chemical pretreatment or Sterilization

6.    In general, other than  in processing areas and storage
     tanks, the highest  concentrations of contaminants may
     be  found  in  surface and  buried  waste lagoons.
     Contamination can migrate  vertically from these
     lagoons to significant depths.  Hydrogeologic studies
     may be necessary to discern such contamination and
     additional technologies for remediation may have to be
     considered.

7.    Surface lagoons,  soil areas, drip pads, and sediments
     should  be gridded and  sampled to determine the
Waste  Segregation,   and
                                  10.
                                  11.
                                  12.
horizontal and vertical extent of contamination.  Soil
and  sludge characterization relevant to treatment
selection should reflect the information needs detailed
in Table III.

Excavation of contaminated soil should generally not
be done until the final treatment technology has been
selected, except where it is deemed necessary to reduce
an imminent hazard or to control migration.  Where
possible,   excavated    organic    and   inorganic
contaminants, and high and low concentration materials
should be staged separately.

It is usually too expensive to ship quantities of greater
than 5,000 cubic yards of contaminated soil off-site
for disposal.  Pretreatment of soil  and water may be
required prior to shipment or  discharge  to another
treatment facility.

Circumstances   may  arise  where  capping  and
containment of material with relatively low toxicity and
mobility is an appropriate remedy. Such instances will
require careful evaluation.

Representative sampling and analysis  for verification
of expected treatment efficiencies should be consistent
with accepted  Superfund  quality  assurance/quality
control guidance.

Health  and  safety  considerations  enter into the
technology selection process as described in the Health
and Safety Plan (HASP).  Air monitoring to support
the  HASP  includes   both on-site  and  off-site
components.

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                                                    TABLE I
                         Technologies for Treatment of Sludge. Soil, and Sediment
Contaminant
CCA
PCP
Creosote
PCP + Creosote
Creosote + CCA
PCP + CCA
Treatment
Technologies
Immobilization1
Incineration1
Other Thermal
Treatment2
Biotreatment2
Dechlorination2
Incineration1
Other Thermal
Treatment2
Biotreatment2
Incineration1
Other Thermal
Treatment2
Biotreatment2
NA
NA
Treatability
(RREL Database)3
80 - 90% TCLP
(B,P,F)
90 - 99% (B,P,F)
90 - 99% (B,P,F)
95 - 99% (B,P,F)
4
4
Treatment
Trains4
Soil Washing/
Immob2
Soil Washing/Bio2
Soil Washing/Bio2
Soil Washing/Bio2
Incin/Immob Ash1
Soil Washing/Bio/
Immob2
Incin/hnmob/Ash1
Soil Washing/Bio/
Immob2
Dechlorin/Immob2
1.    This technology recommendation assumes that the specified treatment efficiency can be achieved for a given site; it assumes
     that no site-specific constraints exist.

2.    These other technologies may warrant site-specific evaluations, RI/FSs, focused feasibility studies (FFSs), or engineering
     evaluations/cost analyses (EE/CAs) because they lack full-scale performance data.  Site-specific conditions also may favor a
     subset of the major technology.  Bench-scale and/or pilot studies may be necessary to refine the selection of the most
     appropriate specific treatment method.

3.    Performance data are from the Risk Reduction Engineering Laboratory (RREL).  The database is derived from bench scale (B),
     pilot scale (P), or full scale (F) demonstration projects.  Dashes indicate insufficient data. The RREL is updated on a regular
     basis and is available through the Alternative Treatment Technology Information Center (ATTIC).

4.    Performance efficiency for treatment trains is a function of contaminant concentration, matrix and volume. It can generally be
     presumed that the performance of treatment trains will equal or exceed that of the individual treatment technologies.

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                                              TABLE II
                      Technologies for Treatment of Surface Water and Ground Water
Contaminant
CCA
PCP
Creosote
Creosote + PCP
Creosote + CCA
PCP + CCA
Treatment
Technologies
Precipitation
Reverse Osmosis
Ion Exchange
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Biotreatment
Oxidation
Carbon Treatment
Oxidation
Precipitation
Carbon Treatment
Oxidation
Precipitation
Treatability
(RREL Database)*
97 - 99% (B,P,F)
99% (P)
95 - 99% (P)
99% (B,P,F)
99% (B,P)
82 - 99% (P,F)
99% (P,F)
99% (B,P)
82 - 99% (P,F)
99% (B,P,F)
99% (B,P)
—
—
Treatment
Trains
Precip/Immob
Precip/RO/Immob
Precip/Ion Ex/Immob
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Carb
Phase Sep/Bio
Phase Sep/Oxidation
Phase Sep/Treat
Organic/Treat Metals
Phase Sep/Treat
Organic/Treat Metals
KEY:   Treat Organic = Carbon Treatment or Chemical (O3, C1O2, H2O2) or Ultraviolet Oxidation

     Treat Metals = Reverse Osmosis or Ion Exchange or Chemical Precipitation and Immobilization of Residues
*   Performance data from the RREL (Risk Reduction Engineering Laboratory). Database is derived from bench
    scale (B), pilot scale (P), or full scale (F) demonstration projects. Dashes in the table indicate insufficient data.

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                                                       TABLE III
                                     Information Needs and Process Limitations
    Treatment Technology
               Information Needs
       Process Constraints and Limitations
Thermal Treatment -
 Incineration
i) BTU value
ii) Volatile metals cones.
iii) Alkali metals (Na,K) cones.
iv) Elemental analysis (N,S,P,Cl,etc.)
v) Moisture content
vi) Pumping chars, and viscosity	
       i) High moisture content
       ii) High alkali metals soil
       iii) Elevated levels of mercury,
           organic phosphorus
       iv) Volume <3000-5000 cu. yds.
Thermal Treatment -
Desorption
i) Melting and boiling points
ii) Volatile metals cones.
iii) Flash points
iv) Elemental analysis (N,S,P,Cl,etc.)
v) Vapor pressures
vi) Optimum desorption and
   destruction temperatures
vii) Moisture content	
       i) High boiling points over 500°F
          (260°C)
       ii) Elevated levels of halogenated
          organics
       iii) Presence of mercury
       iv) Corrosivity
Immobilization
i) TOC (oils, TPH, humic material,
ii) Grain size distribution
iii) Soluble salts
iv) Cation Exchange Capacity (CEC)
etc.)
i)TPH>l%
ii) Humic matter <20%
Biotreatment -
 In-situ
i) Indigenous microorganisms
ii) Degradation rates
iii) Solubility
iv) Nutrient requirements and existing
   conditions of pH, temp., oxygen,
   moisture, etc.
v) Depth to ground water and
   thickness of contaminated zone
vi) Permeability of the soil	
       i) Toxic metals, chlorinated
         organics, pH outside 4.5-9,
         limiting growth factors
       ii) Ambient temp, below 15°C
       iii) Short time/growth season
       iv)  Rainfall/evapotranspiration
         rate/percolation rate ratios too high
       or too low
       v) Limiting initial and final cones.
Biotreatment -
 Ex-situ
i) Indigenous microorganisms
ii) Degradation rates
iii) Solubility
iv) Nutrient requirements and existing
   conditions of pH, temp., oxygen,
   moisture, etc.	
       i) Lack of indigenous microbes
       ii) Toxic metals, highly
          chlorinated organics, pH
          outside 4.5-9, limiting growth
          factors
       iii) See also "In-situ", above
Base-Catalyzed
 Dechlorination
i) Heavy metals cone.
ii) Reactivity at high pH
iii) Elemental analysis (N,P,S,C1, etc.)
iv) Redox potential
v) TOC, humic material and clay content
       i) Heavy metals and excess soil moisture
       (>20%) may require special  treatment
       ii) High organic and clay content may
       extend reaction time
Soil Washing
i) Solubilities and partition coefficients
ii) Grain size distribution
iii) TOC and humic material content
iv) Cation Exchange Capacity (CEC)
       i) High hydrophobic TOC and humic
       material content inhibits detergency
       ii) >30% silt and clay particles cancels out
       volume reduction benefit of process
       iii) Surfactant solutions may cause
       operating problems	

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REFERENCES

Contaminants and Remedial Options at Wood Preserving Sites. USEPA, ORD, RREL, September 1992

Approaches for Remediation of Uncontrolled Wood Preserving Sites. EPA/625/7-90/011, USEPA Office of Environmental
Research Information, Cincinnati, OH 45268, November 1990

"Creosote Contaminated Sites-Their potential for bioremediation," Environmental Science & Technology. Vol. 23. No. 10. p.
1197-1201, 1989

Superfund LDR Guide #6B. Obtaining a Soil and Debris Treatability Variance for Removal Actions. Superfund Publication
9347.3-068FS, USEPA, OSWER, September 1990

Guide for Conducting Treatability Studies Under CERCLA: Aerobic Biodegradation Remedy Screening - Interim Guidance.
EPA/540/2-91/013A, USEPA, ORD, July 1991

Guide to Treatment for Hazardous Wastes at Superfund Sites. EPA/540/2-89/052, USEPA Office of Environmental Engineering
and Technology Development, March  1989

Removal Program Representative Sampling Guidance. Volume 1:  Soil. USEPA, OERR Publication 9360.4-10, November, 1991

Removal Program Representative Sampling Guidance. Volume 4:  Hazardous Waste - Interim Final OSWER Directive Document
in Preparation by USEPA, OERR, June 1992

Innovative Treatment Technologies:  Overview and Guide to Information Sources. EPA/540/9-91/002, USEPA OSWER, TIO,
October 1991

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APPENDIX A - U.S. Waste Exchanges
CALIFORNIA WASTE EXCHANGE
Robert McCormick
Department of Health Services
Toxic Substances Control Division
400 P Street
Sacramento, CA 95812
(916)324-1807

INDIANA WASTE EXCHANGE
Environmental Quality Control
1220 Waterway Boulevard
P.O. Box 1220
Indianapolis, IN 46206
(317)232-8188

INDUSTRIAL MATERIAL EXCHANGE
SERVICE
Diane Shockey
2200 Churchill Road, #31
Springfield, IL 62794-9276
(217)782-0450
FAX: (217) 782-9142

INDUSTRIAL MATERIALS EXCHANGE
Bill Lawrence
172 20th Avenue
Seattle, WA 98122
(206) 296-4899
FAX: (206) 296-0188

PACIFIC MATERIALS EXCHANGE
Bob Smee
1522 No. Washington St.
Suite 202
Spokane, WA  99205
(509)325-0551
FAX: (509) 325-2086
NATIONAL WASTE EXCHANGE NETWORK
1-800-858-6625

RENEW
Hope Castillo
Texas Water Commission
P.O. Box 13087
Austin, TX 78711
(512)463-7773
FAX: (512) 463-8317
INDUSTRIAL WASTE INFORMATION
EXCHANGE
William E. Payne
New Jersey Chamber of Commerce
5 Commerce Street
Newark, NJ 07102
(201)623-7070

MONTANA INDUSTRIAL WASTE
EXCHANGE
Don Ingles
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
(406) 442-2405

NORTHEAST INDUSTRIAL WASTE
EXCHANGE
Lewis M. Cutler
90 Presidential Plaza
Suite 122
Syracuse, NY 13202
(315)422-6572
FAX: (315) 422-9051

SOUTHEAST WASTE EXCHANGE
Maxi May
Urban Institute
Dept. of Civil Engineering
Univ. of North Carolina
Charlotte, NC 28223
(704) 547-2307

SOUTHERN WASTE INFORMATION
EXCHANGE
Gene Jones
P.O. Box 960
Tallahassee, FL 32313
(904)644-5516
FAX: (904) 574-6704

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