United States
                            Environmental Protection
                            Agency
                         Office of
                         Solid Waste and
                         Emergency Response
Publication No. 9380.3-02FS
       December 1989
        vvEPA
Treatability  Studies  Under
CERCLA:  AN  OVERVIEW
 Office of Emergency and Remedial Response
 Hazardous Site Control Division OS-220
                                                 Quick Reference Fact Sheet
    Section 121(b) of CERCLA mandates EPA to select remedies that "utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable" and to prefer remedial actions in which
treatment "permanently and significantly reduces the volume, toxicity, or mobility of hazardous substances, pollutants, and
contaminants as a principal element." Treatability studies provide data to support treatment technology selection and remedy
implementation and should be performed as soon as it is evident that insufficient information is available to ensure the quality
of the decision. Regional planning should factor in the time and resources required for these studies.

    This fact sheet provides a synopsis of information to facilitate the planning and execution of treatability studies in support
of the RI/FS and the RD/RA processes. Detailed information on designing and implementing treatability studies for the RI/FS
process is provided in the "Guide for Conducting Treatability Studies under CERCLA," Interim Final, EPA 540/2-89/058,
December 1989.  A summary of Chapter 2 (Overview of Treatability Studies) is incorporated in this paper. The remainder of
that document provides protocols for implementing the studies.
DEFINING TREATABILITY STUDIES

   Treatability studies are laboratory or field tests designed
to provide critical data needed to evaluate and, ultimately, to
implement one or more treatment technologies. These studies
generally involve characterizing  untreated waste  and
evaluating the performance of the technology under different
operating conditions.  These results may  be qualitative or
quantitative, depending on the level of treatability testing.
Factors that influence the type or level of testing needed
include:  phase  of the   project   [e.g.,   remedial
investigation/feasibility  study  (RI/FS)  or  remedial
design/remedial  action   (RD/RA)],   technology-specific
factors, and site-specific factors.

   •   Treatability studies conducted during the RI/FS to
       support remedy  selection  are generally used to
       determine whether the technology can achieve the
       anticipated Record of Decision (ROD) goals and to
       provide information  to support the nine  evaluation
       criteria to the extent possible.
                           •  Treatability   studies   to   support   remedy
                              implementation during  RD  are generally used to
                              verify that the technology can achieve the ROD
                              goals, optimize design  and operating conditions
                              necessary to ensure performance, and improve cost
                              estimates.

                        LEVEL OF TREATABILITY STUDIES

                           Treatability studies should be performed in a systematic
                        fashion to ensure that the data generated can support the
                        remedy  evaluation   and  implementation  process.  A
                        well-designed treatability study can significantly reduce the
                        overall uncertainty associated with the decision, but cannot
                        guarantee that the chosen alternative will be completely
                        successful. Care must be exercised to  ensure that the
                        treatability study is representative of the treatment as it will
                        be employed (e.g., sample is representative of waste to be
                        treated) to minimize the  uncertainty in the decision. The
                        method presented below provides  a resource-effective
                        means for evaluating one or more technologies.
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    There are three levels or tiers of treatability studies:
laboratory screening, bench-scale testing, and pilot-scale
testing.  Some or  all of the levels  may be needed on a
case-by-case basis. The need for and the level of treatability
testing required are management decisions in which the time
and  cost necessary to  perform  the  testing are balanced
against the risks inherent in the decision (e.g., selection of a
treatment alternative). These decisions  are based on the
quantity and quality of data available  and on other decision
factors  (e.g.,  State and  Community acceptance of the
remedy, new site  data). The flow diagram for the tiered
approach in Figure 1 traces  the stepwise review  of study
data and the decision points and factors to be considered.

    •   Laboratory screening is the first level of testing. It
        is used to  establish the validity of a technology to
        treat a waste. These  studies are generally  low cost
        (e.g., $10K-50K) and usually require hours to days
        to complete. They yield data that can be used as
        indicators   of  a technology's  potential  to meet
        performance goals  and  can  identify operating
        standards   for  investigation  during  bench-   or
        pilot-scale testing. They generate little, if any,
design or cost data and generally are not used as the
sole basis for selection of a remedy.
Bench-scale testing is the second level of testing.
It is used to identity the technology's performance
on a waste-specific basis for an operable unit. These
studies  generally  are  of  moderate cost  (e.g.,
$50K-250K) and may  require days to  weeks to
complete. They yield  data  that  verify  that  the
technology can meet expected cleanup goals  and
can provide information in support of the detailed
analysis of the alternative (i.e., the nine evaluation
criteria).

Pilot-scale testing is the third level of testing. It is
used to provide quantitative performance, cost,  and
design information for remediating an operable unit.
This level of testing also can produce data required
to   optimize  performance. These  studies are  of
moderate to high cost (e.g., S250K-1,OOOK) and may
require weeks to months  to complete. They yield
data that verify
                                                        Figure 1. Flow Diagram of the Tiered Approach
                                                                             MANAGEMENT DECISION FACTORS:!
                                                                              • Sm»*iif Community Acc*pta/K«
                                                                              • SchKiutoConstalnts
                                                                              • Addiiona! Data
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       performance to a higher degree than the bench-scale
       and provide detailed design information. They are
       most  often   performed   during   the  remedy
       implementation phase of a site cleanup, although this
       level may be appropriate to  support the remedy
       evaluation of innovative technologies.

Technologies generally are evaluated first at the laboratory
screening level and progress through the bench-scale to the
pilot-scale testing level. A technology may enter, however, at
whatever level is appropriate based on  available data on the
technology  and  site-specific  factors.  For  example,  a
technology  that has  been  studied  extensively  may  not
warrant laboratory screening to determine whether it has the
potential to work. Rather, it may go directly to bench-scale
testing to verify that performance standards can be met.
DETERMINING THE NEED FOR
TREATABILITY STUDIES

    Treatability  studies   for   remedy  evaluation   and
implementation represent good engineering practice. The
determination of the need for and the appropriate level of
   Figure 2. Decision Tree Showing When Treatability
   Studies Are Needed to Support the Evaluation and
   Selection of an Alternative
                              MANAGEMENT DECISION FACTORS.
                               • Stan rt Community AcopOoct
                               • Sdwiub ComlralnK
                               • AdcHondDm
           DETAILED ANALYSIS
            OF ALTERNATIVES  I
a treatability study(ies) required is dependent on site-specific
factors, the literature information available on the technology
, and technical expert judgment. The latter two elements  -
the literature search and expert consultation - are critical
factors in determining if adequate data are  available or
whether a treatability study is needed to provide those data.
Figure 2 provides a decision tree for treatability studies in the
RI/FS. Additional studies may not be needed if previous
studies  or  actual  implementation  have  encompassed
essentially identical site conditions. The data and information
on which this decision is based should be documented. Given
the lack of full-scale experience with innovative technologies,
pilot-scale testing will generally be necessary in support of
remedy selection and implementation.

SUPERFUND PROCESS - TIMING OF
TREATABILITY STUDIES

    Treatability studies should be planned and implemented
as soon  as  it is  evident that insufficient information is
available  in the literature to support the decision necessary
for remedy selection or implementation. Treatability testing
of technologies may begin during the scoping phase, the initial
phases of site characterization and technology screening, and
continue through the RI/FS and into the RD/RA to support
remedy implementation.  Additional treatability studies of
alternate technologies or treatment trains also may be needed
later in the RI/FS  process  as other  promising remedial
alternatives are identified.

    For many site types, initial data are available to identify
potentially applicable technologies early during the scoping
phase of the RI/FS for all or parts of the site. In those cases,
the literature search, the planning, and the implementation of
the treatability study can proceed. The planning of the studies
should coincide with the scoping of the RI/FS to the extent
practicable to ensure that data are gathered during the RI to
support the technologies and associated treatability studies.

    Similarly, treatability  studies  to  support  the  remedy
implementation also should be conducted as early in the RD
as  appropriate.  As  with the RI/FS  treatability   study,
additional technology-specific site characterization data may
be needed to aid in the design and implementation  of the
study.

TREATABILITY STUDY GOALS

    Each level of treatability study  requires appropriate
performance goals. These goals should be specified before
the test is conducted. The goals may need to be reassessed
to   determine   appropriateness    following   test-
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ing performance as a result of new information  (e.g.,
ARARs), treatment train considerations  or other factors.
Pre-ROD treatability study goals will usually be based on the
anticipated performance standards to be established in the
ROD. This is because cleanup criteria are not finalized until
the ROD is signed due to continuing analyses and ARARs
determinations. The treatability goals should consider the
following factors independently or in combination:

    •   Levels that are in protective of human health and the
       environment (e.g., contact,  ingestion, leaching)  if
       treated waste is left unmanaged or is managed;

    •   Levels  that are  in compliance  with ARARs,
       including the land disposal restrictions;
       Levels that ensure a reduction of toxicity, mobility, or
       volume;
    •   Levels acceptable for delisting of the waste; and

    •   Levels set by the State or Region for another site
       with contaminated media with similar characteristics
       and contaminants.

    Further, the program has as the treatment goal and
expectation that treatment technologies and/or treatment
trains generally achieve a 90 percent or greater reduction in
the concentration or mobility of individual  contaminants of
concern. This goal  complements the site-specific risk-based
goals. There will be situations where reductions outside this
range  that  achieve health-based or  other  site-specific
remediation  goals,   may  be   appropriate.   Treatment
technologies should be designed and operated such that they
achieve reductions beyond the target level  indicated to
ensure that the stated goals are achieved consistently.

    Laboratory screening of treatability study goals allows
for a go/no-go decision. For example, the goal may  be a 50
percent reduction  in  mobility which would indicate the
potential to achieve greater reduction (e.g., 90 percent)
through additional refinement of the study. The achievement
of this goal might indicate the advisability of expending
additional resources on a bench-scale test to obtain a  more
definitive  evaluation  of the  technology. Bench-   and
pilot-scale testing goals  are those needed to select and/or
implement the technology. For example, the bench-scale
testing goal for solidification/stabilization could be to  achieve
a 90 percent or greater reduction in mobility of the principal
constituents.  In addition,  the  goals  for   the  bench-  or
pilot-scale studies
also may  involve multiple waste treatment levels — the
performance of which dictates the ultimate disposition of the
waste (i.e., clean closure or landfill closure).

    Post-ROD treatability study goals should reflect those
performance standards specified in the ROD. They should
also be achieved in the most resource-efficient manner.
ADMINISTRATIVE PLANNING

    The planning process for treatability studies begins during
the budget  cycle  in the  year  prior  to the  planned
performance. At that time, the potential need for treatability
studies  and their cost is estimated to ensure  adequate
resources and to factor the study into the planning for the site
(e.g., scheduling the RI/FS). In many cases, the RI/FS will
not have been initiated at this time, and assumptions will need
to be made. In view of the limited literature information that
is  currently available  on technology performance,  it is
anticipated that one  or more treatability  studies may  be
necessary for most sites. Funding for treatability studies
is  separate from RI/FS funding and is  over and beyond
the target of RI/FS cost of$750K.

    Planners  need to take into consideration treatability
studies to be performed by  contractors, EPA, and  other
Federal Agencies (e.g., Corps of Engineers) to  support the
ROD and  the  RD/RA.  Treatability  study funds will  be
needed   for   Fund-lead   sites   and   for  selected
Enforcement-lead sites if the Responsible Party (RP) is not
performing the study. Funds also will be needed for oversight
of the studies. Oversight of Fund-lead treatability studies will
be allocated as part of the treatability study. Oversight of
RP-lead treatability  studies  will  be funded through the
enforcement budget.
FUNDING

    Treatability studies in support of the RI/FS or the RD/RA
are funded from the "Other Remedial" account if they are
Federally-funded. The amount of treatability study funding
required is dependent on technology and site-specific factors.
The section in this fact sheet entitled "Levels of Treatability
Studies" provides a rough estimate  of resources  and time
required to perform the studies. Resources required may
vary greatly depending on site conditions and data needs.

    In the event that treatability study funding requirements
exceed planned treatability study allocations (either due to
the costs of the studies or due to the  need for
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studies which were not planned for), these studies should be
funded from the Region's "Other Remedial" account or other
Regional monies through the SCAP process. Regions should
contact Tom Sheckells (OERR/OPM, FTS  382-2466) for
clarifications.

    All  treatability  studies,  whether  performed   by  a
contractor or EPA, are funded out of the Regional SCAP
account. Procurement Requests (PR) used to initiate work
should  have  activity code "9"  to ensure  proper record
keeping.
CERCLIS

    Treatability studies are coded in CERCLIS under the
event code "TS" that provides for separate event coding for
each  treatability study for a given site.  This allows for
multiple treatability studies with separate  funding  (e.g.,
Federal-,  State-,  or Responsible  Party-lead  treatability
studies).

PERFORMANCE OF TREATABILITY STUDIES

    Fund-lead treatability studies generally will be conducted
through  the  REM  or  ARCS  contractors  or   their
sub-contractors or contractors working for States. A list of
vendors  that  have expressed  interest  in  performing
treatability studies has been compiled in the "Inventory of
Treatability  Study Vendors."  A preliminary draft  copy is
scheduled for distribution in January 1990. Companies on this
list should be notified of requests for proposals (RFPs) for
treatability studies in accordance with the Federal Acquisition
Regulations.

    EPA and other Federal Agencies such as the Bureau of
Mines also  may perform select treatability studies  on a
case-by-case basis. Again, the funding of these activities is
through the Regional SCAP allocations.

    Enforcement-lead treatability studies generally will be
accomplished through the  RP contractor. There may be
exceptions to this where the complexity of the site requires
alternative options (e.g., State- or Federal-lead treatability
studies  for  all  or  part  of  a  site).  The  planning and
performance of the study should be directed by the Region
to ensure that the study results in the type and quality of data
needed to support the decision.

TREATABILITY STUDY PROTOCOLS

    Treatability studies need to be  carefully  planned to
ensure that sufficient  data of  known, documented, and
appropriate quality are generated to support the decision.
The site-specific treatability study protocol is outlined in the
Work Plan and the Sampling and Analysis Plan. These plans
should, among other things, clearly describe: the experimental
design, the  treatability study goals, the Quality Assurance
Project Plan,  data management  and interpretation, and
reporting.

    The treatability study work assignment is to require that
the treatability study be  developed in accordance  with
Agency  guidance,  factoring  in  literature,  site-specific
information, and  expert  consultation. The  "Guide  for
Conducting Treatability Studies Under CERCLA" provides
a general approach for treatability studies and provides a
protocol for the preparation of the Work Assignment, Work
Plan, Sampling and Analysis Plan, Health and Safety Plan,
and the Community Relations Plan. The Agency also is
developing  a number of technology-specific  treatability
guidances which should be followed; the first of these on soil
washing is  scheduled to  be issued in the second quarter of
FY 1990. For more information on these documents, other
sources of  treatability study information, and for technical
assistance in reviewing and performing treatability studies
please contact Ben Blaney  (ORD) at FTS/684-7406 or com.
513/596-7406.
TREATABILITY STUDY REPORT

    The  Agency has  initiated an  effort to ensure  the
consistency of treatability study reports and to provide a
central  repository  of  treatability  studies  to  facilitate
information  dissemination.  The "Guide  for Conducting
Treatability Studies under CERCLA" contains a standard
report format that is to be followed for all treatability study
reports.  All work assignments and consent decrees are to
contain a statement requiring that documents be developed
in accordance with Agency policy.

    Further, all Fund-lead and enforcement-lead oversight
treatability work  assignments  are to include a provision
requiring that a camera-ready master copy of the treatability
study report be sent to the following address:

    Attn: Ken Dostal
    U.S. Environmental Protection Agency
    Superfund Treatability Data Base
    ORD/RREL
    26 W. Martin Luther King Drive
    Cincinnati, Ohio 45268

Information contained  in these reports will be available
through the Alternative Treatment Technology Information
Center (ATTIC). For more information on ATTIC please
call FTS 382-5747 or com. 202/382-5747.
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TECHNICAL ASSISTANCE

    Literature information and consultation with experts are
critical factors in determining the need for and ensuring the
usefulness of treatability studies. A reference list of sources
on  treatability studies  is  provided  in the  "Guide for
Conducting Treatability Studies Under CERCLA."

    It is recommended that a Technical Advisory Committee
(TAG) be used. This committee may include experts on the
technology(ies) to provide technical support from the scoping
phase of the treatability study through  data evaluation.
Members of the TAG may include representatives  from
EPA (Region and/or ORD), other Federal Agencies, States,
and consulting firms. Technical assistance may be obtained
through the following:

    •   The  Office  of Research  and  Development
       (ORD)  provides  technical  assistance  on  site
       remediation and treatability studies. The Superfund
       Technical Assistance Response Team (START)
       provides  long-term site-specific  support from the
       scoping phase through  remedial  design  for sites
       identified by Regional management and selected for
       START support. The Technical Support Project
       (TSP) provides  short-term support of  a similar
       nature.   ORD   assistance  in  the  planning,
       performance, and/or review of treatability studies
       can be accessed through either mechanism. ORD
        also has the Treatability Assistance Program (TAP)
       which is developing technology-specific treatability
       study  protocols,  bulletins,  and  a computerized
       database. For  further information on treatability
       study support or the TAP please contact Ben Blaney
       (ORD) at FTS 684-7406 or com. 513/569-7406, Rich
       Steimle  (OSWER)  at  FTS  382-7914  or com.
       202/382-7914, or a Regional Forum member.

       Bureau of Mines (BOM) has technical expertise
       and experience in the development of technologies
       to remove  metals and other inorganic chemicals
       from solids and liquids. Contact William Schmidt at
       FTS 634-1210 or com. 202/634-1210 for information.

       The U.S. Army Corps of Engineers  (COE) may
       perform or oversee treatability studies  required for
       RI/FS or  RD/RA. For information,  contact  Joe
       Grasso (COE) at com. 402/691-4532.
FOR FURTHER INFORMATION

    In  addition  to  the contacts  identified  above,  the
appropriate Regional Coordinator for each Region located in
the Hazardous Site Control Division/Office of Emergency
and Remedial Response  or  the  CERCLA Enforcement
Division/Office of Waste Programs Enforcement should be
contacted for additional information or assistance.
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