United  States          Office of              Directive:9355.0-48FS
                            Environmental Protection  Solid Waste  and     EPA 540-F-93-048
                            Agency                  Emergency Response  PB 93-963346
                                                                          September  1993
    SEPA
 Presumptive  Remedies:
Site  Characterization  and Technology
Selection  For CERCLA  Sites  With
Volatile Organic  Compounds  In  Soils
Office of Emergency and Remedial Response
Hazardous Site Control Division 5203G
                                             Quick Reference Fact Sheet
      Since Superfund's inception in 1980, the remedial and removal programs have found that certain categories of sites 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 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 of acceleration within the Superfund Accelerated Cleanup Model (SACM).

      Presumptive remedies are preferred technologies for common categories of sites, based on historical patterns of remedy
      selection and EPA's scientific and engineering evaluation of performance data on technology implementation. The
      objective of the presumptive remedies initiative is to use the program's past experience to streamline site investigation
      and speed up selection of cleanup actions. Over time presumptive remedies are expected to  ensure consistency in remedy
      selection and reduce the cost and time required to cleanup 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 Comprehensive Environmental Response, Compensation, and
      Liability Act (CERCLA) sites with soils contaminated by volatile organic compounds (VOCs).  In addition, EPA is
      developing guidance on presumptive remedies for wood treatment, municipal landfill,  PCB, grain storage, coal
      gasification, and contaminated ground-water  sites. EPA has also developed  a directive entitled Presumptive  Remedies:
      Policy and Procedures, (Directive 9355. 0-47FS) which outlines and addresses the issues common to all presumptive
      remedies (e.g., role of innovative technologies, consistency with the NCP,  State, community involvement).
      PURPOSE

      The purpose of this directive is to provide guidance on
      selecting a presumptive remedy at sites with soils
      contaminated with VOCs. Specifically this guidance:

         Presents the presumptive remedies for this site
         type;

         Describes the presumptive remedy process in terms
         of site characterization and technology screening
         steps; and

         Outlines the data required  to  select these
         presumptive  remedies.

      Since a presumptive remedy is a technology that EPA
      believes, based upon its past experience, generally will
      be the most appropriate remedy for a specified type of
      site, the presumptive remedy approach will accelerate
                             site-specific analysis of remedies by focusing the
                             feasibility  study efforts. Where several presumptive
                             remedies are identified, EPA believes that all deserve
                             substantial consideration  before  utilizing  the
                             presumptive remedy approach. EPA personnel should
                             review the directive entitled Presumptive Remedies:
                             Policy and Procedures (Directive 9355.0-47FS) for
                             general information on the presumptive remedy process.

                             Soil vapor extraction (SVE), thermal resorption,
                             and incineration are the presumptive remedies for
                             Superfund  sites with VOC-contaminated soil  assuming
                             the site characteristics meet certain criteria. Table 1
                             provides a brief description of each of these presumptive
                             remedies.

                             The decision to establish these technologies as
                             presumptive remedies for this site type is based on
                             EPA's  collective knowledge about site investigation
                             and remedy selection for VOC-contaminated soils,

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                   TABLE  1
     Presumptive  Remedies for VOCs
                     in Soil
  Soil Vapor Extraction - Soil vapor extraction
  (SVE)  is an in-situ or ex-situ process which
  physically removes contaminants from vadose
  zone soils by inducing air flow through the soil
  matrix.  The flowing air strips volatile compounds
  from the solids and carries them to extraction
  wells. The recovered vapors may require further
  treatment. In-situ SVE is the primary focus of this
  document.

  Thermal Resorption - Thermal desorption is an
  ex-situ  process that uses direct or indirect heat
  exchange to vaporize organic contaminants from
  soil, sediment, sludge or other solid and  semisolid
  matrices. The vapors are then condensed  or
  otherwise  collected for further treatment.

  Incineration  -  Incineration  is  an  ex-situ
  engineered process that employs  thermal
  decomposition via oxidation at  temperatures
  usually  greater than 900  C to destroy the organic
  fraction of the waste.

  The major difference between thermal desorption
  and  incineration  is that  incineration  oxidizes
  organic compounds,  thereby destroying the
  hazardous material.   Thermal  desorption
  volatilizes contaminants,  then  concentrates them.
  Thermal desorption reduces the volume  of
  contamination, but  the concentrated waste stream
  still  requires treatment. Disposal or treatment of
  residual waste  stream, ash, and concentrated
  VOC effluent is not covered by this directive.
  Options such as off-site disposal/regeneration or
  reuse should be considered.
including field experience from the Superfund, Resource
Conservation  and  Recovery  Act  (RCRA),  and
Underground Storage  Tank (UST)  programs. In addition,
EPA conducted an analysis of FY86 to FY91 Records of
Decision (RODS) for sites where VOC contamination
drove remedy selection.  The results of this analysis,
which are provided in Appendix A, demonstrate that these
three technologies represent over 90% of the remedies
selected  in the RODS analyzed.
USE OF DOCUMENT

This directive is primarily intended for use by Superfund
site managers. However, site managers in other programs
(such as RCRA corrective action, the UST program,
States), and the private sector, may also use this directive.

This directive is not a "stand alone" document. To ensure
a full understanding of VOC site characterization and
remedy selection, site managers should refer to all
documents cited in the  directive. For assistance in
understanding complex site conditions, an experienced
site manager, the presumptive remedy expert team, the
Superfund Technical Assistance and Response Team
(START) team, or the Environmental Response Team
should be  consulted.

ANTICIPATED BENEFITS OF
PRESUMPTIVE  REMEDIES

Use of this directive will reduce cost and time in remedy
selection at VOC sites in the following ways:

1.   The directive facilitates identification of the presumed
    or likely remedial options early in the investigation
    process, hence  allowing for a more focused collection
    of data during the remedial investigation (RI) or
    removal site evaluation. In addition, knowledge of
    the presumptive remedy may facilitate collection of
    some remedial design data before  the ROD or action
    memo, thereby allowing the action to proceed more
    quickly after signature of the decision document.

2.   This directive eliminates the need for the initial step
    of identifying and screening a variety of alternatives
    during the Feasibility Study. Additionally, it will
    reduce the number of technologies identified and
    analyzed in the  EE/CA.  The National Oil and
    Hazardous Substances Pollution  Contingency Plan
    (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." EPA's
    analysis of feasibility studies for VOC-contaminated
    soil sites (see Appendix A) found that certain
    technologies are routinely screened out based on
    effectiveness, implementability, or  excessive costs,
    consistent  with NCP Section  300.430(e)(7).
    Accordingly, EPA has determined that, when using
    presumptive remedies at VOC-contaminated sites,
    site-specific  identification  and  screening of
    alternatives is not necessary. However, this directive
    and supporting documentation (see "Feasibility Study
    Analysis for CERCLA Sites with Volatile Organic
    Compounds in Soils") should be  included in the
    Administrative Record for all sites that use the
    presumptive remedy(ies) to document the basis for
    eliminating the "site-specific identification and

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                   TABLE 2
    Typical VOCs Addressed by this
                   Directive
  Halogenated Volatile Organics

  Carbon Tetrachloride
  Chlorobenzene
  Chloroethane
  Chloroform
  1,1-Dichloroethane
  1,1-Dichloroethylene
  1,2-Dichlorobenzene
  1,2-Dichloroethane
  1,2-Dichloroethylene
  1,2-Dichloropropane
  1,4-Dichlorobenzene
  1,1,1-Trichloroethane
  1,1,2-Trichloroethane
  1,1,2,2-Tetrachloroethane
  Ethylene Dibromide
  Methylene  Chloride
  Tetrachloroethylene
  Trichloroethlyene
  Vinyl Chloride

  Non-Halogenated Volatile Organics

  Ketones/Furans
  Acetone
  Methyl Ethyl  Ketone
  Methyl Isobutyl  Ketone

  Aromatics
  Benzene
  Ethyl  Benzene
  Styrene
  Toluene
  m-Xylene
  o-Xylene
  p-Xylene

  Note: Other compounds that have physical/chemical
  characteristics similar to the compounds listed may
  also be addressed by the presumptive remedy
  process.
    screening of technologies" section. In addition, other
    supporting materials (e.g., FS reports included in the
    analysis, technical reports) will be made available at
    EPA Headquarters and are available for inclusion in
    the Administrative Record if needed.

3.  This  directive streamlines the detailed analysis portion
    of the FS.  Remedial alternatives developed for a site
    must be evaluated against the nine criteria (required
    under NCP Section 300.430(e)(9)). Under this
    presumptive remedy approach, the detailed analysis
    can be limited to the three presumptive remedies (in
    addition to the no-action  alternative), thereby
    streamlining that portion of the FS. Appendix B
    provides a generic evaluation of the presumptive
    remedies for seven of the nine criteria. This evaluation
    may serve as a basis for each detailed analysis
    conducted under the  presumptive remedy process
    and should be augmented, as  needed, to address site-
    specific  conditions.

One of these presumptive remedies is expected to be used
for all  VOC sites except under unusual circumstances.
Such circumstances may include unusual site soil
characteristics, demonstration of significant advantages
of alternate (or other innovative) technologies over the
presumptive remedies, or extraordinary community and
state concerns. If such circumstances are encountered,
additional  analyses may be necessary or a  more
conventional detailed RI/FS may be performed.

PRESUMPTIVE REMEDIES  PROCESS

This section and the accompanying diagram (Figure 1)
describe the sequence of steps involved in the presumptive
remedy process (site characterization and technology
selection) for sites containing soil contaminated with
VOCs.  While the process is not mandatory, EPA believes
that following the steps outlined below will expedite the
clean-up process for this category of sites.

SVE is the primary presumptive  remedy. SVE has been
selected most frequently to address VOC contamination at
Superfund sites and initial performance data indicate that
it effectively treats waste in place  at a relatively low cost.
In cases where SVE will not work or where there is very
highly  concentrated contamination, thermal  desorption
may be the more appropriate response technology. In a
limited number of situations, incineration may be more
appropriate.

The numbered paragraphs below correspond to the
numbered  steps in Figure 1 and provide a detailed
discussion of each step.

1.   Are  VOCs Present in the Soil? The first step is to
    determine whether VOCs are the major contaminant
    present in soil at the site. Table 2 lists the VOCs that
    are amenable to the presumptive remedies outlined in
    this  directive. If VOCs are present at levels of
    concern (see forthcoming guidance on soil screening
    levels),  then the presumptive remedies outlined in
    this directive may be applicable. However,  if it is
    confirmed (at this point or at any later point during  the
    presumptive remedy process) that there  are no VOCs
    present in the soil, then this directive is not applicable
    for use in technology  selection at the site.

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                                                 FIGURE  1
  Decision Tree for Investigating  and Selecting a Remedy at Solvent Sites
                 AreVOCsinthe \  N
                  soil or sludge?
  Initiate
   early
   PRP,
  State,
   and
 Assemble
Administra-
tive Record
   Are non VOC
 contaminants presen
  that preclude the
    presumptive
      emedy?
                                         This fact sheet is not
                                             applicable.
                                                               f
                Review advantages/
                 limitations table for
               presumptive remedies.
                   See Table 2
                         Conduct time-cntical
                          removal action, if
                            necessary.
                                            Have any new
                                          contaminants been
                                            detected that
                                            preclude the
                                            presumptive
                                              remedy?
 Identify
 ARARs
and Pre-
 liminary
Remedia-
  tin
 Goals
 (PRGs)
        Complete assessment to
        determine whether there is
         an unacceptable risk to
            humans or the
         environment and refine
               PRGs.
                                                                   Is SVE still feasible
                                                                    after conducting
                                                                      pilot study?

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    Most likely, this analysis will occur during scoping
    of the RI/FS or EE/CA. However, there may be only
    limited information available at that time about the
    site. Therefore, whatever information is available
    should be used to determine whether VOCs are present
    or suspected in the soil based on prior use. Chemical
    use at a site can be ascertained from a number of
    sources such as facility  records, previous sampling
    efforts  by local  or  State  agencies or  through
    Information Request letters.

2.  Are Non-VOC Contaminants Present  That  Preclude
    the Use of Presumptive Remedies? In addition to
    determining whether VOCs are present in the soil, it
    is also necessary to  identify other  non-VOC
    contaminants, if any, present in the soil.

    The site characterization and  technology  selection
    procedures outlined in this directive are recommended
    for use primarily on soil containing VOCs only. See
    Table 2 for VOCs that are amenable to the presumptive
    remedies.

    For sites containing a mixture of VOCs and other
    contaminants in soil, the presumptive remedies should
    be considered only if they  can also be effective in
    removing the  non-VOC contaminants or combined
    with other, non-presumptive  remedies in a  treatment
    train, assuming the presumptive remedies do not
    exacerbate the problems  presented by the non-VOCs.
    For example, sites with VOCs and metals commingled
    in soil may be effectively remediated by employing
    SVE to remove VOCs followed by fixation or
    solidification  to address  the  metal contamination. In
    contrast, a VOC and polyaromatic  hydrocarbons
    (PAHs) contaminant combination may be treated
    more appropriately with  a single biological  treatment
    scheme that would be effective for both the VOCs and
    PAHs. Note that sites containing mixtures of VOCs
    and non-VOCs are varied, and, for this reason, remedy
    selection may be more  complicated than the
    framework presented in  this  directive; therefore, the
    presumptive  remedy analysis may need to  be
    supplemented  or modified on a site-specific basis.

3 .  Initiate Early Community,  State,  and Potentially
    Responsible Party  (PRP) Involvement. As early in
    the clean-up process as possible, EPA should notify
    the community, State, and any PRPs that a presumptive
    remedy is being considered for the site. It is important
    for all stakeholders to understand completely how the
    presumptive remedy process varies from the usual
    clean-up process  and  the  benefits of using the
    presumptive  remedies  process.

    Early identification of State applicable or  relevant
    and appropriate requirements (ARARs) also is a
    critical part of this process. Because the presumption
    set forth in this directive is national in scope, it does
not take into account State ARARs. For this reason,
State ARARs relating to the presumptive remedies
should be considered on site-specific basis. Regions
may want to supplement this directive  by compiling
the requirements of the States in their Regions that are
likely to be associated with the use of the presumptive
remedies and placing them in the  administrative
record for a site where presumptive remedies are
being considered.  This directive along with the
"Feasibility Study Analysis  for CERCLA Sites  with
Volatile Organic Compounds in Soils" should be
included in the administrative record for the site if one
of the presumptive remedies is proposed for a  particular
VOC-contaminated  site.

Review Advantages/Limitations of the Presumptive
Remedies. During initial site characterization, Table
3 should be reviewed to consider the advantages and
limitations of the presumptive remedies, This
information may  be useful in preparing for and/or
modifying the  site  characterization or alternatives
analysis  process.   The "Practical  Considerations"
section of this directive should also be reviewed at
this  time  to ensure  a  comprehensive  site
characterization and remedy evaluation.

Conduct Site Characterization. Site characterization
for sites using VOC presumptive remedies should be
designed to:

   Positively identify the site type (i.e., VOC site);

   Obtain data to determine whether the presumptive
    remedy  is feasible  for the site;

   Focus   (and  possibly  streamline)   site
    characterization by collecting data to support the
    selection of presumptive remedy(ies) only (e.g.,
    volume  and cost information); and,

   Collect some design data (i.e.,  pilot studies to
    determine radius of influence and flow rates of
    SVE), thereby streamlining data collection during
    the remedial  design stage.

Table 4 lists the  data that are  required  for
characterization of sites with soil contaminated  with
VOCs.  This table also includes the  rationale for
collecting these data and references for established
collection methods. Note that bench-scale and pilot/
treatability studies should be  performed whenever
possible concurrent with site characterization to define
the parameters that will be important to designing the
system.

In areas with low organic content soil  (e.g., alluvial
basins), or where  there are impediments to  obtaining
soil samples (e.g., under buildings), soil gas  sampling

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    is highly recommended as a site characterization
    technique. In addition, the use of soil gas sampling
    during implementation of SVE and confirmatory soil
    sampling afterward is  less expensive than constantly
    installing new soil borings, especially for deep
    contamination.

    If incineration or thermal desorption is under serious
    consideration, bench-scale treatability studies may
    be conducted, especially  if metals or other inorganic
    compounds are present. Thermal desorption generally
    should be considered if concentrations of VOCs are
    less than 5 to 10 percent; incineration may be
    appropriate if VOC concentrations exceed 5  to 10
    percent. Note that excavation and mixing of soil can
    produce a desorber input of less than  10 percent
    contaminant concentration and allow  thermal
    desorption to be chosen.

    Additionally,  the feasibility of excavation should be
    determined by evaluating  surface  contidions and depth
    of contaminants as well as the potential for any air
    emissions associated with the excavation. Test digs
    should be monitored closely to  assure protection of
    the public and the environment.

    It  is important to  note that during the site
    characterization, the volume and concentration of
    waste constituting the principal threats at the site
    should  be  identified.    The NCP  (Section
    300.430(a)(l)(iii)(A) and A Guide to Principal Threat
    and Low Level Threat Wastes, Superfund Publication:
    9380.3-06FS, November 1991, define principal
    threats as source materials, including liquids, that are
    highly toxic or highly mobile wastes which generally
    cannot be reliably contained or would present a
    significant risk to human health and or  environment
    should exposure occur.   In accordance with NCP
    expectations, waste constituting "principal threats"
    posed by a site generally are expected to be treated.
    The  site manager is encouraged to characterize  the
    site in terms of principal  and low-level threat areas to
    determine materials to be targeted for treatment and
    containment.

6.   Identify  Potential ARARs, To  Be Considered (TBCs),
    and Preliminary Remediation Goals (PRGs). Potential
    Federal and State ARARs and pertinent  TBCs
    information should be  identified on a chemical-,
    location-, and action-specific basis concurrent with
    site characterization.  For a more detailed ARARs
    discussion, refer to the various ARARs fact sheets.
    (See Compendium ofCERCLA ARARs Factsheets
    and Directives, EPA Publication 9347.3-15, October
    1991).

    At this  step, PRGs should also be identified  (NCP
    Section  300.430(e)(2)(c)). Note  that  different health
    risk-based PRGs are often set for soils, depending on
    depth. Shallow soil levels are usually based both on
    direct contact exposure and protection of ground
    water, while levels for deeper soils are generally
    based only on mass transport modeling of effects on
    ground water. Ecological effects may also be
    important  to consider in setting PRGs.

7.   Conduct Time-Critical Removal Action (if necessary).
    During initial site characterization, data will be
    gathered to determine whether a time-critical removal
    action will be needed and to determine whether the
    contaminants present are amenable to the presumptive
    remedies. Time-critical removal actions, such as
    drum removal  or  actions  addressing  highly
    contaminated (typically small volumes) of soil, should
    be conducted in accordance with current guidance
    and regulations. The decision to take a time-critical
    removal action may be made by  the Regional Decision
    Team (RDT) or if time does not permit, by an On-
    Scene Coordinator (OSC) or a Remedial Project
    Manager (RPM) in consultation with an OSC.

8.   Is There a Threat Posed by the Site? A risk assessment
    must be conducted to determine if a sufficient health
    or environmental threat exists to warrant a removal or
    remedial action. (Refer to Risk Assessment Guidance
   for Superfund, Volumes I and II, EPA/540/1-89/002
    and EPA/540/1-89/001). Where it is determined that
    such a threat exists, site-specific exposure data can be
    used to modify the PRGs identified in Step 6 (NCP
    Section 300.430(e)(2)(i)).  If it is determined that
    such a threat does not exist, no further action at the site
    will be required.

9.   Proceed With Technology Assessment  and Review
     "Practical Considerations " section. If the analysis
    described in step 8 confirms that the contaminants are
    a threat to human health and/or the environment,  a
    proposed remedy  should then be identified.

    If this project is a remedial action, a detailed analysis
    using the nine criteria will be required under NCP
    Section 300.430(e)(9)) to justify the selection of
    remedy decision. Appendix B provides an analysis of
    SVE, thermal resorption, and incineration against
    seven of the nine  selection criteria. In addition to the
    seven criteria discussed in Appendix B, community,
    and State acceptance must also be evaluated. If a non-
    time critical removal action is planned, the streamlined
    analysis described in the EE/CA guidance will be
    required that uses the three criteria of effectiveness,
    implementabiilty, and cost. During the  technology
    assessment, the factors listed in the  "Practical
    Considerations" section of this directive should be
    reviewed  to ensure a comprehensive evaluation of
    alternatives.

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10.  Does the Pilot /Treatability Study Indicate that SVE
    is Feasible? SVE is the primary presumptive remedy.
    Pilot/treatability  study testing of SVE should be
    conducted prior to final  remedy  selection.  Such
    testing will provide information on the rate of removal
    of contaminants. EPA/540/2-91/091A cited in the
    References section of this directive provides guidance
    on conducting the pilot/treatability study. Removal
    efficiencies and treatment effectiveness must be
    carefully considered alongside the PRGs identified in
    the FS to estimate the potential for successful remedial
    action using SVE.

11.  Is Thermal Desorption Feasible? If SVE will not be
    sufficiently effective in achieving PRGs due to low
    permeability, lithology or insufficient removal  of
    contamination during the pilot  study, thermal
    desorption should be considered as the primary ex-
    situ  presumptive remedy.

    Thermal desorption technologies cover a variety  of
    vendors  and  processes.  However, ample data are
    available to substantiate remedy  selection of thermal
    desorption for soil contaminated solely with VOCs.

12.  Is  Incineration Feasible?     If contaminant
    concentrations and bench-scale testing indicate
    thermal  resorption will not achieve desired PRO
    levels, incineration  is the second ex-situ presumptive
    remedy.

    If incineration is planned, and a substantial number of
    inorganic contaminants  are expected to be present
    based on site  characterization data, materials handling
    problems, or  slagging  problems  are likely.

    If none of three presumptive remeides is considered
    to be feasible at a particular site, it will be necessary
    to consider other technologies. (For more information,
    refer to the Practical Considerations section below.)

13.  Select Remedy for Remedial/Removal Action. At this
    point, there  should be  enough data to identify a
    preferred remedy in the proposed plan and distribute
    the plan  for public comment. Once the remedy has
    been selected  in the ROD, the user can proceed to do
    a limited design which relies largely on the substantial
    amount  of design-related data collected during the
    RI.  The  extent of additional or supplemental data
    required will  be determined on a site-specific basis.

Practical  Considerations

The following factors should be considered prior to taking
any remedial action.

Enforcement: This directive  applies to fund-lead sites  as
well as to sites where a PRP is conducting the investigation
and/or response  action. In the event that there is an
ongoing PRP-lead  RI/FS, the scope of work may be
amended to reflect the presumptive remedy approach to
site characterization  and remedy selection.  The potential
savings in time and money to be gained by using the
presumptive remedy approach are expected to outweigh
the burden of modifying the scope of work in many cases.

Initial Site Actions:  If the VOC material is still in
original, intact containers, it may be returned to the
manufacturer (if the manufacturer is willing to accept
these containers), assuming this response is a cost-effective
and feasible action  as opposed to treating the material.
Reuse of material (i.e., process liquids and relocation of
equipment  to other  permitted  facilities) should  also be
considered. Further, phase separation should be conducted
and recycling considered depending on the purity of the
recovered phase or for any existing liquids that are high
enough in concentration.  Refer to Appendix C for a list of
the currently  recognized waste exchanges.

Site Characterization: Site  characterization  should
proceed as a single, multi-media activity whenever
possible. Field  screening methods  should be integrated
into the sampling and analysis plan in order to accelerate
information  gathering. Data  quality must reflect the
ultimate use of the information.

Ground Water: The decision maker should consider the
ground-water strategy for the site since soil clean-up
levels are  often set to protect ground-water quality.
Therefore, ground-water clean-up levels may have a direct
impact on the  selected clean-up levels for soil. (See
forthcoming guidance on Soil  Screening Levels  and the
directive entitled Presumptive Remedies: Remedial
Strategy and Treatment Technologies for CERCLA Sites
with Contaminated Ground Water.)  It should be noted
that, of the VOC-type contaminants, listed in Table 2, the
halogenated volatiles are dense nonaqueous phase  liquids
(dense NAPLs  or DNAPLs) and many of the others are
light NAPLs (LNAPLs) in their pure liquid form. If
LNAPLs are present, it may be possible to address thereby
lowering the water table, removing free  product (if present),
and applying SVE. To address DNAPLs contamination,
refer to the above mentioned ground-water guidance.

Management of Different Soils:  A situation may arise
where highly contaminated shallow material cannot be
addressed by SVE. The action to address this contamination
may differ from the rest of the soil contamination and will
most likely involve  incineration or thermal desorption. If
it is suspected that soil contamination existing at greater
depths will also be treated in this manner, then the excavated
shallow material should be staged and stored in order to
treat it with the deep material.

Another situation may arise where VOCs are mixed  with
metals, and none of the presumptive remedies can address
both sets of  contaminants. The action to address this
situation may consist of a treatment train where VOCs are

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addressed through SVE or thermal resorption and the
metals are addressed through fixation.

Finally,  the site manager should be aware of situations
where a mixture of principal and low-level threat wastes
call for the use of treatment (i.e., SVE or thermal treatment)
of principal threat waste and containment (capping)  of
low-level contamination.  (See A Guide to Principal
Threat and Low-Level  Wastes in Reference  Section).

Off-Site Disposal: In general, it may not be cost-effective
to ship quantities of contaminated soil in excess of 5,000
cubic yards  for  off-site  disposal. For this reason,
pretreatment of soil and water may be required prior to
shipment or discharge  to another treatment facility.

Capping: Capping alone is not recommended to  control
the migration of VOCs. However,  capping can improve
the effectiveness of  SVE by decreasing the rate  of
infiltration of residual VOCs through the vadose zone into
the ground water as well as possibly increasing the radius
of influence  and preventing "short circuiting" of air
pathways in the vicinity of the  extraction well. Capping
can also be used  to address non-principal threat waste
unless it is more cost-effective to treat this waste along
with more highly  contaminated materials.

Patents: SVE is a patented  technology. Royalty payments
may  be required  under  certain  conditions  of
implementation.

Attainment of Remediation Goals: It should be noted
that, like other in-situ technologies, it is difficult to
ascertain with confidence whether SVE will attain
remediation goals until  the action is actually implemented.
However, the lower cost and ease of SVE implementation
will often weigh heavily in its favor, as long as protection
of human health and the environment is ensured.

Additional Technologies: If for some reason none of the
presumptive remedies is applicable to a particular site, the
site manager is encouraged to refer to EPA's forthcoming
document entitled Contaminants and Remedial Options
at Solvent Sites for a discussion of additional VOC treatment
technologies. It should be noted that this  comprehensive
document, which identifies additional  VOCs and
technologies, may be appropriate to consider on a site-
specific basis.

Thermal Treatment  Technologies:  The site manager
should refer to EPA's Draft Strategy for  Combustion of
Hazardous Waste (May 18,  1993) when considering any
thermal treatment technologies at  a particular  site.

Conclusion

For sites  containing VOC-contaminated soil and
appropriate soil characteristics, SVE is a relatively
inexpensive and efficient technology. If material needs to
be excavated, thermal desorption is preferred. In  a few
cases, incineration may be the most appropriate remedy -
- for example, where SVE and thermal desorption will not
meet clean-up criteria based on contaminant concentrations
or composition.

As remedies other than SVE, thermal desorption and
incineration become more widely  used in  the future, this
directive may be modified to reflect these trends. For
further assistance on presumptive remedy related activities
consult the Regional Presumptive Remedies contact.
    Notice:

    The policies set out in this document are intended solely as guidance to the U.S. Environmental
    Protection Agency (EPA) personnel; they are not final EPA actions and do not constitute rulemaking.
    These policies are  not intended, nor can they be relied upon, to create any rights enforceable by any party
    in litigation with the United States. EPA officials may decide to  follow the guidance provided in this
    document, or to act at variance with the guidance, based  on an analysis of specific site circumstances.
    EPA also reserves the right to change this guidance at any time without public  notice.

-------
                                                                                   TABLE 3
                                                             Comparison of Technologies for VOC Sites
PERFORMANCE'
                                              ADVANTAGES
                                                                                                          LIMITATIONS
                                                                                       COSTS'1
c
o
ts
to
+J
X
LU
^
O
Q.
re

'o
V)
Can be as high as 99%
removal of VOC
contaminants but is
typically lower than other
technologies with range of
85-99%
                            High level of effectiveness in removing VOCs.
                            Relatively inexpensive.
                            Little site disturbance; no excavation required.
                            Effective for waste under buildings or other
                            construction.
 Soil that is tight or has high moisture content (>50%) has a reduced permeability to air,
 hindering the operation of SVE.
 Soil with a high degree of heterogeneity has highly variable permeabilities, resulting in
 uneven delivery of gas glow to the contaminated regions, which in turn reduces removal
 rates by SVE.
 Soil with high organic content or that is extremely dry has a high sorption capacity for VOCs,
 which results in reduced  removal rates.
 SVE may require treating residual soil tailings, liquids, and spent activated carbon.
 Air emissions must be controlled to eliminate possible harm to the public and the
 environment.
 SVE is not effective in the saturated zone.  However, lowering the aquifer can expose more
 media to SVE (this may address concerns regarding LNAPLs).
                                                                                                                                                                       $10-150/ton
       95-99% removal of VOCs
f

O)
a
                            All compounds that are listed on Table 2 are
                            readily treated by thermal desorption.
                            Because of lower treatment temperatures and
                            often lower oxygen levels, thermal desorbers
                            should produce less nitrogen oxides and sulfur
                            dioxide than incinerators.
                            Process can be performed onsite or offsite.
                            Lower temperatures produce fewer products of
                            incomplete combustion (PICs).
                                                                         '  Requires excavation. If contamination is very deep or below the water table, excavation may
                                                                           be difficult and expensive.
                                                                         '  Mercury, if present, can be removed from soil by thermal desorption and impose additional
                                                                           treatment costs for the offgas.
                                                                         '  Soil containing high fractions of clay or silt may result in a high percentage of particulate
                                                                           carry-over from the desorber into downstream treatment devices.
                                                                         '  Soil that contains constituents greater than 1 to 2 inches in diameter will require screening or
                                                                           crushing to prevent jamming the mechanical equipment.
                                                                         '  Soil with a high moisture content (>30%) can result in low processing rates, high operating
                                                                           costs, and difficulty in materials handling.
                                                                         '  High or low pH wastes may corrode the metal components of the system, requiring
                                                                           pretreatment.
                                                                         '  Potential process residuals are treated solids, oversized debris, condensed contaminants and
                                                                           water, particulate control system solids, and contaminated activated carbon.
                                                                         '  Air pollution control system required.
                                                                                      $200-300/ton
       >99% removal of VOCs
                            Capable of accepting a wide range of media.
                            Processes can be performed onsite or offsite.
                            Metals can be concentrated  in the residuals.
                                                                          Requires excavation. If contamination is very deep or below the water table, excavation may
                                                                           be difficult and expensive.
                                                                          Soil containing high fractions of clay or silt may result in a high percentage of particulate
                                                                           carry-over from the incinerator into downstream treatment devices.
                                                                          Air pollution control equipment is required.
                                                                          High treatment temperatures, as compared to thermal desorption, can produce nitrogen
                                                                           oxides, sulfur dioxides, and PICs.
                                                                          Solids with volatile metals may require additional treatment or more elaborate air pollution
                                                                           equipment.
                                                                                      $200-
                                                                                      1700/ton
                 NOTES:
       (1)       Actual performance and cost for any remediation technology is highly site specific.  Both depend upon the original and target clean-up level concentrations of contaminants, soil quantity to
                be treated, soil characteristics, and the design and operation of the remediation technology equipment used.

-------
                                                                                   TABLE 4
                                       Information Required for Characterization and Technology Selection at VOC Sites
     INFORMATION
                         RATIONALE  FOR COLLECTING INFORMATION
           REFERENCE
All Technologies:
Site Geology
SVE is most effective in porous, permeable, homogeneous soil.  Highly heterogeneous soil (i.e., fractured porous rock or
sands interspersed with clay lenses) may exhibit air flow channeling through highly permeable soils. Also, desorption kinetics
may be slow in some situations (i.e., high organic content or high clay content soil).  In these cases, mass transfer kinetics
may reduce the rate of removal of SVE below that which is expected by calculations with a local equilibrium model or pilot
scale experiments carried out for only a few days.  Often diffusion kinetics limitations can be substantially reduced by proper
design of the SVE facility.
Guidance for Conducting Remedial
Investigations and Feasibility Studies
under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
USGS Soil Classification
For SVE to be effective, the soil must have sufficient pneumatic permeability (>106 cm2) to permit air to move through the
medium.  Sandy, gravely soils are the most conductive to SVE, while clays and silts are less conductive. However,
remediations using SVE in clays and silts have been successful. Soil permeability may need to be measured in the field.
ASTM D 2487
ASTM D 2488
Soil Moisture
High moisture content in soil may drastically decrease its air permeability and, thus, the effectiveness of SVE.  The site must
be sufficiently well drained to prevent the severe reduction in air permeability, which occurs when the percent water saturation
of the soil is greater than 50%. Conversely, organics can be strongly adsorbed onto extremely dry soils, which also impedes
SVE. The moisture content of the soil will affect the amount of energy required to heat the soil, the target temperature and
the handling properties of fine-grained soil. Thermal desorption requires that the  moisture content of the soil be less than
30%.
ASTM D 2216
ASTM D 3017
Depth to Ground Water
SVE is not effective in saturated soil. However, the water table can be lowered by pumping.  Thermal desorption and
incineration are more expensive for high moisture soil.
Guidance for Conducting Remedial
Investigations and Feasibility Studies
under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
Contaminant Identity
and Properties
Boiling Point - Thermal desorption target temperature is dependent on contaminant boiling point.
Vapor Pressure - SVE is effective for compounds with a vapor pressure greater than 0.5 mm Hg at soil temperatures.
Dimensionless Henry's Constant - SVE is effective for compounds with a dimensionless Henry's constant higher than 0.01 at
soil temperatures.
Water Solubility - SVE is more successful for componds with lower solubilities.
Liquid and Vapor Density - A contaminant with a density greater than water may form a DNAPL. A contaminant with a density
less than water may form an LNAPL. The flow characteristics of a compund's vapor for SVE is a function of its vapor density.
CRC Chemical Handbook

-------
                                TABLE 4
Information Required for Characterization and Technology Selection at VOC Sites
                              (Continued)
INFORMATION
RATIONALE FOR COLLECTING INFORMATION
REFERENCE
All Technologies: (continued)
Contaminant Concentration,
Location, Volume, and Depth
Presence of Pipes or Subsurface
Material
These data can be gathered via soil matrix and/or soil gas sampling. Soil gas sampling, both shallow and at depths, may
be more appropriate, given depth to ground water and stratigraphy.
The presence of water or electircal conduits, soil fracture lines, debris, or any other objects that are more permeable than
the surrounding soil will be the preferred pathway for the advecting gases.
Guidance for Conducting Remedial
Investigations and Feasibility Studies
under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
Geotechnical Techniques
SVE Only:
Soil/Air Filled Porosity
Soil/Air Permeability
Soil Temperature
Soil Humic Content
Contaminant Soil Sorption
Coefficient Kd (Since Kd is less
readily available, Koc, the
equilibrium between contaminants
sorbed onto organic carbon versus
the ground water is used.)
Contaminant Adsorption
Characteristics on Activated
Carbon
Porosity should be less than 40% for SVE to be effective.
Soil/Air Permeability should be greater than 10 6 cm2 for air to move throughout the contaminated soil. SVE is potentially
effective in less permeable soul (i.e., between 106 to 1010 cm2), but further pilot-scale testing and/or mathematical
modeling is recommended to better predict the time for cleanup (which is likely to be prolonged for lower permeability soil).
Contaminant vapor pressure, dimensionless Henry's Law constant, water solubility, and phase density are strong functions
of temperature.
Solvents adhere strongly to soil with high humic content, which decreases the effectiveness of SVE.
This parameter describes the tendency of the solvent to sorb onto soil or organic matter in the soil. Higher Koc's indicate
that a subsurface is more likely to bind to carbon righ media (i.e., soil) than to remain in water.
This parameter is related to the feasibility of removing contaminants from residuals by carbon adsorption. This parameter
is important since compounds such as MEK become unstable as they are adsorbed onton carbon.
Guidance for Conducting Remedial
Investigations and Feasiblitiy Studies
Under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
Guidance for Conducting Remedial
Investigations and Feasibility Studies
under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
Guidance for Conducting Remedial
Investigations and Feasiblitiy Studies
Under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
Guidance for Conducting Remedial
Investigations and Feasiblitiy Studies
Under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
RREL Treatability Database
RREL Treatability Database

-------
                                                                     TABLE 4
                                  Information Required for Characterization and Technology Selection at VOC Sites
                                                                    (Continued)
INFORMATION
RATIONALE FOR COLLECTING INFORMATION
REFERENCE
Incineration and Thermal Desorption Only:
Soil Plasticity
Soil BTU Content
Contaminant Combustion
Characteristics
Soil Particle Size Distribution
Alkaline Metal Salts
(e.g., NaS04, KS04)
Volatile Metals Content
(e.g., Hg, Pb, Cd, Zn, Sn)
Plastic soil, when subjected to compressive forces, can become molded into large particles that are difficult to heat.
The soil BTU content determines the fuel requirements for thermal desorption and incineration.
Information on combustion characteristics of a VOC is required in order to determine the combustion characteristics of the
incinerator.
Thermal desorption usually requires that soil be pretreated to a maximum soil particle size ranging from 1 to 2 inches.
Alkaline metal salts may cause refractory attack and slagging at high temperatures.
High metal content may cause ash leaching and stack emissions problems.
Guidance for Conducting Remedial
Investigations and Feasibility Studies
under CERCLA (pp. 3-3 to 3-20)
EPA/540/G-89/004
ASTM D 3286
Bench/Pilot Testing
ASTM D 422
Percentage of Na, K
Heavy Metals Analysis
 BTU = British Thermal Units
LNAPL = Light Nonaqueous Phase Liquid
 DNAPL = Dense Nonaqueous Phase Liquid
 mmHg = millimeters of mercury pressure
 NAPL = Nonaqueous Phase Liquid
 PIC = Products of Incomplete Combustion

-------
                                     APPENDIX A
               TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
This Appendix summarizes the analyses that EPA conducted of Record of Decision (ROD) and
Feasibility Study (FS) data from VOC-contaminated sites which led to establishing soil vapor extraction
(SVE), thermal desorption, and incineration as the presumptive remedies for Superfund sites with VOC-
contaminated soil. The analyses consisted  of:

       Identifying VOC-contaminated sites
       Determining the frequency of technology selection for VOC sites
       Identifying sites for the feasibility study  (FS) analysis
       Conducting the  FS analysis.

Results of these analyses, along with the scientific and  engineering analysis of the performance data
on technology application (Primary Reference document), provide a support for the decision to eliminate
the initial alternatives identification and screening step for this site type. These technical reviews found
that certain technologies are appropriately screened out based on effectiveness, implementability or
excessive costs. Review of technologies against the  nine criteria led to elimination of additional
alternatives. Provided below is a discussion of each analysis.

Identification of VOC-Contaminated Sites

The first analysis involved generating a list of signed  Records of Decision (RODS) (post-SARA),
documenting VOC contamination, from which data could be used for subsequent analyses.  The ROD
Information  Directory database was used for this purpose.  Of the 821 signed FY86-FY91 RODS,  418
are identified in the database as containing VOC contamination in source material. This list of RODS
was subsequently divided into two lists: RODS  where VOCs were the only contaminants of concern
identified in the source material and RODS containing VOCs, as well as other contamination, in source
material. For those RODS involving VOC plus other contaminants, a review of the ROD document was
conducted to identify  cases where only VOCs  were driving the selection  of remedy. To  make this
determination, the Remedial Response Objectives and  Selected Remedy sections of the ROD were
reviewed to identify specific language indicating that the  remedial  action was designed to address only
the VOCs at the site. In addition, if cleanup goals were specified only for VOCs, the assumption was
made that VOCs were driving the remedy.

As a result  of this analysis, 88 RODS were identified as VOC-only RODS or VOCs plus other
contaminants RODS where a clear determination could  be  made that VOCs were driving the selection
of remedy.

Frequency fo Technology Selection for VOC-Contaminated Sites

Table 1 presents the distribution of the 88 FY86-FY91 RODS among the treatment technologies used
to address VOCs in soil. This table demonstrates that the three presumptive remedies (SVE,  thermal
desorption, and incineration) together were selected more often (over 90% of the RODS  analyzed) than
the other applicable technologies. Presumptive Remedies were also those remedies where a fair
amount of performance  data on technology  implementation was available.  Furthermore, SVE,  chosen
in over two-thirds of the RODS analyzed, was the primary presumptive remedy selected.

Identification of Sites for Feasibility Study Analysis

The purpose of the FS analysis was to document  the technology screening step in FSs of VOC-
contaminated soil/sludge sites and identify the principal reasons given for eliminating technologies from
further consideration. To achieve a representative sample of FSs for the analysis, sites were selected
using ROD  data according to the following criteria:
                                            13

-------
APPENDIX A
TECHNICAL BASIS FOR PRESUMPTIVE REMEDIES
(Continued)
Table 1
Presumptive Remedy VOC Site Treatment
Summary Table, FY86-FY91*

TECHNOLOGIES USED TO
ADDRESS VOCs IN SOIL
Bioremediatiorr '
Incineration
Soil Flushing/Washing (1)
Soil Vapor Extraction
(2)
Thermal Treatment
Total
TOTAL
3
11
3
62
9
88



Source: ROD Information Directory (RID), FY86 - FY91
Notes: (1) Relatively limited amount of performance data available for these technologies
versus the presumptive remedies.
(2) Thermal treatment includes RODS employing thermal desorption, thermal aeration,
low-temperature thermal desorption, and the generic remedy "thermal treatment".
 A population of 418 RODS was identified for this study based on the parameters: FY 1986-1991,
and VOC contamination of source media.
        Sites were chosen, based on the selected remedy, to ensure an even distribution among the five
        treatment technologies for VOCs in soil (i.e., bioremediation incineration, SVE, soil flushing, and
        thermal treatment).

        Whenever possible, both VOC-only sites and VOC and other contamination sites were represented
        under each technology.

        Sites were selected to ensure an even distribution in geographic location, ROD signature date,
        and site size.
Feasibility Study Analysis

The FS analysis involves 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 FS and ROD.
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. (See "Feasibility Study
Analysis for CERCLA Sites with Volatile Organic Compounds in Soils", September 1993, available at EPA
Headquarters and Regional Offices.)
                                               14

-------
                                      APPENDIX A
                TECHNICAL  BASIS FOR PRESUMPTIVE REMEDIES
                                       (Continued)
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 screening criteria:  cost, effectiveness, 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 2).

For the detailed analysis and comparative analysis, information on the relative performance of each
technology/alternative with respect to the nine NCR criteria was documented on the site-specific data
collection forms. The advantages and disadvantages associated with each clean-up option were
highlighted. In some cases, a VOC technology was combined with one or more technologies that address
minor site contaminants into one or more alternatives. Only the component of the alternative  which
addressed the VOC contamination was evaluated in this analysis. 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.  All summary tables are available for
review as part of the Administrative Record.

The FS  analysis has been completed for 21 sites (representing approximately 25% of universe studied).
The information  from these FSs has been compiled and  summarized in Table 2. Additional FS analysis
is planned and will be added to the Administrative Record, when available. Table 2 demonstrates that
technologies, other than the presumptive remedies, are consistently eliminated from further consideration
in the screening phase  due to effectiveness, implementability, or excessive costs. In  addition, the
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. Together these analyses (Appendix A to this directive and "Feasibility Study
Analysis for CERCLA Sites with Volatile Organic Compounds in Soils"), along with the scientific analysis
of performance  data (USEPA (In Progress) Contaminants and Remedial Options at Solvent Sites) will
support the decision  of using presumptive remedies and  bypassing the technology identification  and
screening step for a particular site. As previously indicated,  this factsheet and accompanying analysis
should be part of the Administrative Record for the site. Further supporting materials, not found in the
Regional files, can be provided by Headquarters, as needed.
                                             15

-------
         TABLE 2  SUMMARY OF SCREENING AND DETAILED ANALYSIS FOR VOC SITES1
  REMEDIAL
TECHNOLOGY
    OR
 TREATMENT'
                                                        #RODs WHERE CRITERION CONTRIBUTED TO NON-SELECTION
Capping
21
Offsite
Nonhazardous
Landfill
Offsite RCRA
Disposal
18
12
10
Onsite
Encapsulation
Onsite
Nonhazardous
Landfill
Onsite RCRA
Landfill
14
    11
Activated
Sludge
Composting
Land
Farming
Bioremediation
(unspecified)
Ex-Situ
Bioremediation
In-Situ
Bioremediation
11
    10
Dechlorination/
APEG

-------
 TABLE 2  SUMMARY OF SCREENING AND DETAILED ANALYSIS FOR VOC SITES (Continued)1
  REMEDIAL
TECHNOLOGY
                                                                    #RODs WHERE CRITERION CONTRIBUTED TO NON-SELECTION
Other Chemical
Destruction
Reduction
Neutralization
Oxidation
 Offsite
 Incineration
 (unspecified)
16
Onsite
Incineration
(unspecified)
Fluidized
Bed
Infrared
Pyrolysis
Multiple
Hearth
Rotary
Kiln
11
Other
Incineration
13
12
Other Thermal
Treatment

-------
CO
TABLE 2  SUMMARY OF SCREENING AND DETAILED ANALYSIS FOR VOC SITES (Continued)1
REMEDIAL / b /$*/*
TECHNOLOGY /^W/YJ/i
OR A^y^x/^
TREATMENiy^^^^^
Vitrification
Wet Air
Oxidation
Low Temperature
Thermal Desorp/
Stripping
In-situ Steam
Stripping
Soil
Flushing
Soil
Washing
In-situ Vacuum
Extraction
B.E.S.T.
Process
Liquified
Gas
Other Physical
Extraction
Fixation
Stabilization/
Solidification
Aeration
12
6
13
3
15
14
17
1
1
4
7
13
12
0
1
10
2
3
2
11
0
0
0
1
2
2
11
5
3
1
12
12
6
1
1
4
6
7
10
1
0
0
0
0
0
0
0
0
0
0
4
0
2
1
1
0
0
1
0
0
1
0
0
0
1
/ /#FSs Where
<^ .^/Criterion Contributed >
$ -$S To Screening Out 3/J$
W^
8
4
1
1
9
10
6
1
1
3
6
6
9
5
3
2
0
5
9
2
0
1
0
0
2
2
0
0
3
2
0
0
10
0
0
0
0
0
1
m
0
1
7
0
3
2
2
0
0
0
1
2
1
/ / ,

0
0
2
0
1
0
0
0
0
0
0
0
0
/ #RODs WHERE CRITERION CONTRIBUTED TO NON-SELECTION
f
0
0
1
0
1
0
0
0
0
0
0
0
0
<^
^v
^
0
0
1
0
1
1
0
0
0
0
1
2
0
^
v^
0
1
2
0
2
0
1
0
0
0
1
2
1
$
0
1
7
0
2
2
0
0
0
0
0
2
1
CS*
0
1
3
0
1
2
0
0
0
0
1
0
1
X"
0
0
4
0
3
1
2
0
0
0
1
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0
^/
...
...
...
...
...
...
...
...
...
...
...
...
...
#
...
...
...
...
...
...
...
...
...
...
...
...
...

-------
  TABLE 2   SUMMARY OF SCREENING AND DETAILED ANALYSIS  FOR VOC  SITES (Continued)1
   REMEDIAL
 TECHNOLOGY
     OR
 TREATMENT2
/#RODs WHERE CRITERION CONTRIBUTED TO NON-SELECTION
                       -<$
 In-situ
 Hydrolysis
 Soil
 Slurries
1  This study was conducted on 21 RODs and their corresponding FSs.
2  This does not include the no-action or instututional control only alternatives. No RODs selected either of these as remedies.
3  FSs and RODs may contain more than one criterion for screening or non-selection of technology. Also, some FSs did not fully explain the criteria for screening out a technology. Thus, the totals for
  screening and non-selection criteria are not equal to the number of FSs and RODs considered.
4  Information on State and community concerns was not included in this analysis because FSs do not contain this information and RODs generally only
 reference supporting documentation (i.e., State concurrence letter and responsiveness summary).

-------
                                                                              APPENDIX B
                                             Criteria Evaluation for Technologies Used to Treat VOC-Contaminated Soil














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CRITERIA
Overall Protection of
Human Health and the
Environment
 Provides both short-
and long-term
protection by reducing
concentration and
exposure to VOCs in
soil.

 Depending on site-
specific conditions,
prevents further ground
water contamination.






















Compliance With
Federal ARARs
 Does not trigger LDRs
because it does not
involve placement of
waste.

 Because waste is
removed in place
through limited
construction and no
excavation, few impacts
to wetlands, floodplains,
or water quality are
likely.

 Depending on site-
specific conditions,
treats wastes to levels
that will prevent
exceedance of
groundwater clean-
uplevels.

 Emission controls are
needed to ensure
compliance with air
quality standards.







Long-Term
Effectiveness and
Permanence
 Effectively removes
contamination source.

 Is a well-demonstrated
technique for removing
VOCs from soil/sludge.

 Requires some
treatment of residuals
(spentcarbon or
concentrated VOC
waste stream)
generally through
regeneration or
disposal.

 Hazardous wastes left
in place will require 5-
year review.














Reduction of Toxicity,
Mobility, or Volume
Through Treatment
 Significantly reduces
toxicity, mobility, or
volume through treatment.

 Produces few waste
streams.



























Short-Term
Effectiveness
 Does not present
substantive risks to on site
workers or community;
potential for some dust
generation during well
installation.

 Potential air emissions are
easily controlled through
activated carbon adsorption
or other technologies.

 Generally involves
relatively short time frame
to achieve clean-up levels;
however, difficulty in
estimating time frame may
exist due to site
uncertainties (e.g., irregular
soil permeabilities).

 Effective for treating waste
under buildings. Can be
performed on active
facilities.

 Hardware, such as vacuum
blower, is readily available
from many sources, but
SVE system performance
is highly dependent upon
the lithology of the site and
system design.
Implementability
 Few administrative
difficulties. Technology is
readily available from many
sources.

 Used successfully at
numerous Superfund sites
to address VOC
contamination.

 Installing and operating
extraction wells requires
fewer engineering controls
than other technologies
(i.e., excavation and
incineration).

 Requires series of soil gas
sampling to determine
when clean-up levels are
achieved.












Cost'1'
$10-150/ton

$50/ton avg.






























r-o
o
   1.  Note: Actual cost of a remediation technology is highly site-specific. It is dependent upon the original and target clean-up level concentrations of contaminants, soil characteristics, and the
           design and operation of the remediation technology used.

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                                                                        APPENDIX B
                                         Criteria Evaluation for Technologies Used to Treat VOC-Contaminated Soil
                                                                        (CONTINUED)












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CRITERIA
Overall Protection of
Human Health and the
Environment
 Provides both short-
and long-term
protection by
eliminating exposure
to VOCs in soil/sludge.

 Prevents further
groundwater
contamination and
offsite migration.

 Requires measures to
protect workers and
community during
excavation, handling,
and treatment.














Compliance With
Federal ARARs
 Requires compliance
with RCRA removal,
treatment,
transportation (if offsite
treatment), and land
disposal regulations (if
a hazardous waste).

 Excavation,
construction, and
operation of onsite
treatment unit may
require compliance
with wetlands and
other location-specific
ARARs.

 Treats hazardous
waste to BOAT levels;
thus, there is no LDR
problem with residuals.

 Generally, treats
wastes to levels that
will prevent
exceedance of ground-
water clean-up levies.
 Emission controls are
needed to ensure
compliance with air
quality standards.
Long-Term
Effectiveness and
Permanence
 Effectively removes
contamination
source.

 Is a well-
demonstrated
technique for
removing VOCs from
soil/sludge.

 Involves some
treatment or disposal
of residuals generally
through use of carbon
adsorption/regenerato
n or disposal.














Reduction of Toxicity,
Mobility, or Volume
Through Treatment
 Significantly reduces
toxicity, mobility, or
volume of contaminants
through treatment.

 Generally requires test
runs to ensure effective
treatment.






















Short-Term
Effectiveness
 Presents potential short-
term risks to workers and
community from air
release during excavation
and treatment (if onsite
treatment).

 Involves potential short-
term risks from handling
and transporting waste (if
offsite treatment).

 Relatively short time
frame to achieve clean-up
levels.















Implementability
 Construction and
substantive permit
requirements of an onsite
treatment unit may
persent some difficulties.
Mobile incineration units
for onsite treatment are
available.

 Limited offsite treatment
capacity exists.

 Used successfully at
other Superfund sites to
address solvent
contamination.

 Requires engineering
measures to control air
emissions, fugitive
dust,run-off, erosion and
sedimentation, site
access, and
transportation.






Cost'1'
$200-
$300/ton

$250/ton
avg.

























1.  Note:  Actual cost of a remediation technology is highly site-specific. It is dependent upon the original and target clean-up level concentrations of contaminants, soil characteristics, and the
          design and operation of the remediation technology used.

-------
                                                                            APPENDIX B

                                            Criteria Evaluation for Technologies Used to Treat VOC-Contaminated Soil

                                                                           (CONTINUED)


















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CRITERIA
Overall Protection of
Human Health and the
Environment
 Provides both short-
and long-term
protection by
eliminating exposure
to solvent
contaminants in soil.

 Prevents further
groundwater
contamination and
offsite migration.

 Requires measures
to protect workers
and community
during excavation,
handling, and
treatment.













Compliance With
Federal ARARs
 Requires compliance
with RCRA removal,
treatment,
transportation (if offsite
treatment), and land
disposal regulations (if
a hazardous waste).

 Excavation,
construction, and
operation of onsite
incinerators may
require compliance
with wetlands and
other location-specific
ARARs.

 Treats hazardous
waste to BOAT levels;
thus, there is no LDR
problem with residuals.
 Treats wastes to levels
that will prevent
exceedance of ground-
water clean-up levies.
 Emission controls are
needed to ensure
compliance with air
quality standards
during excavation and
construction.
Long-Term
Effectiveness and
Permanence
 Effectively destroys
source of
contamination.

 Is a well-
demonstrated
technique for
removing VOCs from
soil/sludge.

 Involves some
treatment or disposal
of residuals generally
through use of carbon
adsorption/
regeneration or
disposal.














Reduction of Toxicity,
Mobility, or Volume
Through Treatment
 Significantly reduces
toxicity, mobility, or
volume of contaminants
through treatment.



























Short-Term
Effectiveness
 Presents potential short-
term risks to workers and
community from air
release during excavation
and treatment (if onsite
treatment).

 Involves potential short-
term risks from handling
and transporting waste (if
offsite treatment).

 Relatively short time
frame to achieve clean-up
levels.
















Implementability
 Construction and
substantive permit
requirements of an
onsite incinerator may
be somewhat difficult.
Mobile incinerators are
readily available.

 Limited offsite
incineration capacity
exists.

 Used successfully at
other Superfund sites
to address VOC
contamination.















Cost'1'
$200-
$1700/ton

$400/ton
avg.


























r-o
r-o
   1.  Note: Actual cost of a remediation technology is highly site-specific. It is dependent upon the original and target clean-up level concentrations of contaminants, soil characteristics, and the

           design and operation of the remediation technology used.

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                                 APPENDIX C
                            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 North Washington Street, Suite 202
Spokane, WA 99205
(905) 325-0551
FAX: (509) 325-2086

NATIONAL WASTE EXCHANGE NETWORK
1-800-858-6625

RENEW
Hope Castillo
Texas Water Commission
P.O. Box13087
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. Culter
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
(315) 422-6572
FAX: (315)422-9051

SOUTHEAST WASTE EXCHANGE
Maxi May
Urban  Institute
Department of Civil Engineering
University 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
                                       23

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                                             APPENDIX  D
                                              GLOSSARY
Applicable or Relevant and Appropriate Requirements
(ARARs) -CERCLA Section 121(d) and the NCP require
that onsite remedial actions must attain (or justify a waiver
of) requirements of environmental laws that are determined
to be Federal or more stringent State applicable or relevant
and appropriate requirements.
Dense Non-Aqueous Phase Liquid (DNAPU)  -DNAPLs
are immiscible hydrocarbon liquids that are denser than
water, such as chlorinated solvents (either as a single
component or as mixtures of solvents), wood preservative
wastes, coal tar wastes, PCBs and some pesticides.
DNAPLs can sink to great depths, can penetrate into
bedrock fractures, can move as a liquid in a direction
different from the flow of groundwater and can act as a
continual source of groundwater contamination over time.
Engineering Evaluation/Cost Assessment (EE/CA) -
An analysis of removal alternatives for non-time critical
removal  actions.
Ex-Situ Treatment - Removal of material from the ground
for treatment.

Feasibility Study (FS) - A description and analysis of the
potential clean-up alternatives for a site. It is generally
conducted concurrently with the  remedial investigation
(RI); together the studies are referred to as an RI/FS. (See
remedial  investigation.)

In-Situ Treatment - The treatment or remediation of
media  occurring in-place.

Innovative Treatment Technologies - Technologies that
have been tested, selected, or used for treatment of
hazardous substances or contaminated materials but lack
well-documented cost and performance under a variety
of operating conditions.
Land Disposal Restrictions  (LDRs) - The Hazardous
and Solid Waste Amendments (HSWA) to the Resource
Conservation and Recovery Act (RCRA) include specific
restrictions on the land disposal of RCRA hazardous
wastes.  These  restrictions, known as LDRs, prohibit the
land disposal of restricted RCRA hazardous wastes unless
these wastes meet treatment standards specified in 40 CFR
268  or other compliance options.

Light Non-Aqueous Phase Liquids (LNAPL) - Like
DNAPLs, LNAPLs are immiscible liquids, but are lighter
than water and  therefore float on water. As they are lighter
than water, they are most frequently  found at the ground-
water table/vadose zone interface.
Record of Decision (ROD) - A public document that
explains the basis for selecting the clean-up alternative(s)
that will be taken or served under CERCLA.

Remedial Desigh (KD) - The remedial action that involves
designing and testing to determine whether the remedy
will be effective at a site.

Remedial  Investigation  (RTV An in-depth study designed
to gather the data necessary to determine the nature and
extent of the threat posed by contamination at a Superfund
site. It also helps to establish the preliminary criteria for
cleaning up the site in the FS and supports the technical
and cost analyses of the alternatives. It is generally
completed and combined with the FS and referred to as the
RI/FS.

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 actual and
potential exposures to specific pollutants in air, water, soil
or other media.

Superfund Accelerated Cleanup Model (SACTVD - An
initiative designed to accelerate all aspects  of the Superfund
clean-up  process.

Vadnse /.one - The zone in soil that lies above the
permanent water table.

Volatile Organic Compounds (YOGs) - Any organic
compound which readily dissipates into the air.
                                                    24

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                                         REFERENCES
Primary Reference:

U.S. EPA (In-Progress). Contaminants and Remedial
  Options at Solvent  Sites.

Compound Properties:

RREL Treatability Data Base - Available through
ATTIC (Contact Glenn Shaul (513) 569-7408)

General Site Investigations:

U.S. EPA, 1986. A Compendium of Superfund Field
  Operation Methods. EPA/540/87/001.

U.S. EPA, 1988. Guidance for Conducting Remedial
  Investigations and  Feasibility Studies Under
  CERCLA. EPA/540/G-89/004, October.

U.S. EPA, 1989.  Guide for Conducting Treatability
Studies Under CERCLA, Intenm Final. EPA/540-2-89/
058.

U.S. EPA, 1991. Soil Sampling and Analysis for Volatile
  Organic Compounds. EPA/540/4-91/001.

Incineration:

Dempsey, C.R. and Oppett, E.T., "Incineration of
  Hazardous Waste:  A Critical Review Update",
  International Journal of Air Pollution Control and
  Hazardous Waste Management, Volume 43, January
  1993, pp. 25-73.

U.S. EPA,  1990. Mobile/Transportable Incineration
  Treatment Engineering Bulletin. EPA/540/2-90/014,
  February.

Presumptive Remedies:

U.S. EPA (In-Progress). Presumptive Remedies:  Policy
  and Procedures.

U.S. EPA (In-Progress). Presumptive Remedies:
  Remedial Strategy  and Treatment Technologies for
  CERCLA Sites with Contaminated Groundwater.

Soil Vapor Extraction:

U.S. EPA,  1991. Soil Vapor Extraction Technology
  Reference Handbook. EPA/540/2-91/003, February.
U.S. EPA, 1991. In-Situ Soil Vapor Extraction
  Treatment Engineering Bulletin.  EPA/540/2-91/006,
  May.

U.S. EPA, 1991. Guide for Conducting Treatability
  Studies Under CERCLA:  Soil Vapor Extraction.
  EPA/540/2-91/091A, September.

U.S. EPA, 1992. A Technology Assessment of Soil
  Vapor Extraction and Air Sparging. EPA/600/R-
  92/173,  September

Thermal Desorption:

U.S. EPA, 1991. Thermal Desorption Treatment
  Engineering Bulletin. EPA/540/2-91/008, February.

U.S. EPA, 1991. Guide for Conducting Treatability
  Studies Under CERCLA:  Thermal  Desorption
  Remedy Selection - Interim Guidance. EPA/540/R-
  92/074A, September.

Additional References:

U.S. EPA, 1991. A Guide to Principal Threat and Low
  Level Threat Wastes.  Superfund Publication
  9380.3-06FS.

U.S. EPA, 1991. Risk Assessment Guidance for
  Superfund, Volume I: Human Health Evaluation
  Manual, Part A. EPA/540/1-89/002, December.

U.S. EPA, 1989, Risk Assessment Guidance for
  Superfund, Volume II: Environmental Evaluation
  Manual. EPA/540/1-89/001, March.

U.S. EPA, 1991. Compendium of CERCLA ARARs
  Factsheets  and Directives. EPA Publication
  9347.3-15,  October.
                                                 25

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United States
Environmental Protection
Agency
Washington, D.C. 20460

Official Business
Penalty for Private Use
$300

-------