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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