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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