UNITED STATES ENVIRONMENTAL PROTECTION AGENCY /?(/ SDMS Document 66359 HAY e 5 1988 Mr. Bruce Hartm.ann, P.E. Facility Coordinator ' ' - - - Chemical Leaman Tank Lines, inc. •• - ' " ' •. • . 102 P i c k e r i n g Way 4;. -.- - Exton, PA -19341-0200 Dear Mr. Hartmann; 'o ; .; As we discussed today, enclosed,are copies of selected portions' of the U.S. Environm.ental Protection Agency's guidance on i „ i Remedial Investigations/Feasibility Studies on'the subjects of treatability studies and cost estimation. If you would like to discuss this information, please call me at (212) 264-5388. Sincerely yours. John E. La Padula , P.E., Chief Southern Kev.' Jersey Compliance Section Enclosure cc: S. Gilliland, ERfl, I n c . (v;/enclosure) S>'- ERRD:SCB:SNJCS:LUCKEYJ SYMBOL k SURNAME k DATE i SNJCS LUCKEY ( SNJCS LAPADULA 'KiJ^ir^ ,: 5/5/88 CONCURRENCES ..Qf).^.."..^^. UO i q.^ n IS EPA Form 1320-1 (12-70) V n—[ OFFICIAL FILE COPY
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY /?(/
SDMS Document
66359
HAY e 5 1988
Mr. Bruce Hartm.ann, P . E . F a c i l i t y C o o r d i n a t o r ' ' - - -Chemical Leaman Tank L i n e s , i n c . •• - ' " ' •. • . 102 P i c k e r i n g Way 4;. -.- -E x t o n , PA -19341-0200
Dear Mr. Har tmann; 'o ; .;
As we d i s c u s s e d t o d a y , e n c l o s e d , a r e c o p i e s of s e l e c t e d p o r t i o n s ' of t h e U . S . Environm.enta l P r o t e c t i o n A g e n c y ' s g u i d a n c e on i „ i Remedial I n v e s t i g a t i o n s / F e a s i b i l i t y S t u d i e s o n ' t h e s u b j e c t s of t r e a t a b i l i t y s t u d i e s and c o s t e s t i m a t i o n .
If you would like to discuss this information, please call me at (212) 264-5388.
Sincerely yours.
John E. La Padula , P.E., Chief Southern Kev.' Jersey Compliance Section
Enclosure
c c : S. G i l l i l a n d , ERfl, I n c . ( v ; / e n c l o s u r e )
Hazardous Waste Engineering Research Laboratory Office of Research and Development
U.S. Environmental Protection Agency Cincinnati, Ohio 45268
and
Office of Emergency and Remedial Response and
Office of Waste Programs Enforcement Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency Washington, D.C. 20460
Source con t ro l measures seek to completely remove, s t a b i l i z e , and/or conta in the hazardous subs tances . Source con t ro l measures may be used in many s i t u a t i o n s where they w i l l c u r t a i l fur ther r i s k to humans or the env i ronment. In these c a s e s , only a l imi ted publ ic hea l t h assessment may be n e c e s sary in s e l e c t i n g a c o s t - e f f e c t i v e remedy.
Where prevent ing migra t ion appears i n f e a s i b l e , measures t ha t w i l l reduce future migra t ion from the source should be cons ide red . In these c a s e s , a more ex tens ive ana lys i s w i l l be necessary to s e l e c t a c o s t -e f f e c t i v e remedy t h a t adequate ly p r o t e c t s publ ic h e a l t h . Chapters 5 and 6 address the cons ide ra t ions involved in these a n a l y s e s . In such s i t u a t i o n s , management of migra t ion measures should be considered in conjunct ion with source con t ro l measures .
Where a source con t ro l a l t e r n a t i v e involves o f f - s i t e t rea tment [an a l t e r n a t i v e in ca tegory ( a ) ] , d e s t r u c t i o n , or d i sposa l of wastes following removal , s ec t i on 300.70(c) of the NOP r e q u i r e s t h a t EPA determine t h a t t h i s a l t e r n a t i v e i s e i t h e r "(1) more c o s t - e f f e c t i v e than o ther remedial a c t i o n s ; (2) w i l l c r ea t e new [waste management] c a p a c i t y . . . ; or (3) i s necessary to p r o t e c t [human hea l t h and the e n v i r o n m e n t ] . . . . " To aid in t h i s e v a l u a t i o n , the user must, in those in s t ances where an o f f - s i t e t r a n s p o r t , t r e a t m e n t , s t o r a g e , or d i sposa l a l t e r n a t i v e i s among the l i s t of response a c t i o n s , inc lude a comparable o n - s i t e a l t e r n a t i v e for e v a l u a t i o n . For example, when o f f - s i t e d i sposa l at a l a n d f i l l approved under RCRA i s among the a l t e r n a t i v e s to be eva lua ted , c o n s t r u c t i o n of such a l a n d f i l l on the s i t e should be evaluated as w e l l .
2.4.2 Management of Migration Remedies
Management of migration remedial actions are necessary where hazardous substances have migrated from the original source of contamination and pose a significant threat to public health, welfare, or the environment; for example, where contamination exceeds relevant and applicable public health or environmental standards, guidance, and advisories. Any management of migration measure that adequately protects public health, welfare, and the environment (by reducing contaminant levels) should be considered for implementation. Particular consideration should be given to technologies that permanently contain, immobilize, destroy, or recycle contaminants.
An example of a site at which management of migration action may be appropriate would be one at which a contaminated ground water plume has moved downgradient from the site, beyond site boundaries, and is threatening private drinking water wells. At such a site, management of migration measures such as aquifer pumping and treatment may be appropriate.
Management of migration alternatives may also involve measures that prevent or minimize impacts through means such as substitution. An example of such an alternative would be provision of an alternative drinking water source in cases i^ere ground water contamination threatens private weljs.
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guidelines are recommended for use when defining the level of effort in cost screening:
• Data sources should be limited to the "Remedial Actions Cost Compendium" (ELI, 1984), Handbook: Remedial Action at Waste Disposal Sites (U.S. EPA, 1982), the remedial investigation (for revising design assumptions where necessary), standard costs indices, and other readily available information.
• The time for preparing screening cost estimates should be limited to a few days.
• The objective in calculating the costs is to achieve an accuracy within -50 to +100 percent.
Cost screening should be undertaken for all remedial alternatives remaining from the public health and environmental screening. The cost screening can be divided into three basic tasks: (1) estimation of costs, (2) present worth analysis, and (3) cost screening evaluation.
2.5.2.1 Estimation of Costs
- Remedial alternatives are screened on the basis of both capital costs and operating and maintenance costs. These costs should reflect site-specific conditions and should be revised using the cost compendium (ELI, 1984) or other standard cost guidance references.
Capital costs should include the following:
• Relocation costs
• Costs of land acquisition or obtaining permanent easements
• Land and site development costs
• Costs of buildings and services
• Equipment costs
• Replacement costs
• Disposal costs
• Engineering expenses
• Construction expenses
• State and local legal fees, licenses, and permit costs
• Contingency allowances
• Startup and shake-down costs
• Costs of anticipated health and safety requirements during construction.
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In some cases, wastes removed from a site, such as fuel oils or other hydrocarbons, may be recoverable. In such cases, revenues from the sale of removed materials should be considered in the present worth analysis.
2.5.2.3 Cost Screening Evaluation
The user should compare present worth costs of competing alternatives with similar environmental, public health, and public welfare benefits. Alternatives should be eliminated if they are deemed much more expensive (an order of magnitude or more) and offer similar or smaller environmental and public health benefits but no greater reliability than competing alternatives. Alternatives that are more expensive but offer substantially greater environmental and/or health benefits should not be eliminated.
i ' 2-23
6.1.2 Overview of Treatability Investigations
Treatability studies to collect data on teduiologies identified during
the alternative develppnent process are conducted, as appropriate, to pro
vide additional inforaation for evaluating technologies. The RI/FS contrac
tor and the lead agency's RPM stust review the existing site data and avail
able information on technologies to determine if treatability investigations
are needed. As discussed earlier, the need for treatability testing should
be identified as early in the RI/FS process as possible. A decision to
conduct treatability testing may be made during project' scoping if
information indicates such testing is desirable. However, the decision to
conduct these activities atust be made by weighing the cost and time required
to cooplete the investigation against the potential value of the information
in resolving uncertainties associated with selection of a remedial action.
In some situations, the need for treatability investigations may not be
identified until later in the process and, therefore, may be postponed until
the remedial design phase.
"-The decision process for treatability investigations is shown concep
tually in Figure 6-1 and consists of the following steps:
o Determining data needs
o Reviewing existing data on the site and available literature on
technologies to determine if existing data are sufficient to eval
uate alternatives
o Performing treatability tests, as appropriate, to determine per
formance, operating parameters, and relative costs of potential
remedial technologies
o Evaluating the data to ensure that data quality objectives are met
007434 A_'9
HBSiS
• ^ '
F I G U R E 6 - 1 OSWER Directive 9355.3-01
TREATABILITY INVESTIGATIONS
[
Determine Daia needs
Data Adequate
to Screen or
\
\ Evaluate Existing Technology Data
Evaluate Existing Site Data
YES S. Eva^ate j f
\^^ AKematives ? y ^
NO 7
Treatability Study
. ^ - -
S.2 SETERMINATICSJ OF DATA ^QU2^M1S«?S
To th@ @xt@nt p9Ssi^l@o Sata sequi^od to assess th@ feasibility of
technologies should h® gatho^sd during th@ sit@ characterisation (e.g.,
moisture and heat eontsnt da t a should b@ collected if incineration of an
organic wast® is b@ing eonsidsred). 3<seau@@ data requirements will depend
on the specific treatment proe@@s snd th@ eontaainants and matrices being
considered, th« rssults of thQ site eharactsrisation will influence the
types of alternatives developed sad oereensd, which %fill in turn influence
additional dats n@eds. Ho i ver; &&t& eolldcted during site characterizatioi;
will not always b@ adequat® for assessing the feasibility of remedial tech°
nologies, and, in fact, th@ a@@d for detail@d data from treatability tests
may not become apparent until the initial screening of alternatives has beer,
eoB^leted. A description of data requirements for selected technologies is
presented in Table S°l. The Technology Screening Guide for Treatment of
Contaminated Soils and Sludges (S?A, under preparation) summarizes data
needs for a larger nus^er of available and innovative technologies. The
Superfund Innovative Technology Evaluation (SITE) program is another source
to assist with the identification of data needs and to obtain performance
information on innovative technologies.
Additional data needs can be identified by conducting a more exhaustive
literature survey than was originally conducted when potential technologies
were initially being identified. The objectives of a literature survey are
as follows:
o Setesmine whether the performance of those technologies under con
sideration have been sufficiently documented on similar wastes
considering the scale (e.g.; bench, pilot, or t \ i l l ) and the nusiber
of times the technologies have been used
o Gather inforaation ea relative costs, applicability, removal effi
ciencies, O&M requirements, and i^lementability of the candidate
technologies
•007436 6=4
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OSWER Directive 9355.3-01
TABLE 6-1. TYPICAL DATA REQUIREMENTS FOR REMEDIATION TECHNOLOGIES
Technology
Thermal Destruction
Waste Matrix
Soils
Air Stripping
Liquids
Ground Water
Exas^le Data Required
Moisture content Heat value Chlorine content Destruction efficiency
Heat value Concentration of metals Destruction efficiency
Concentration of volatile contaminants
Concentration of nonvolatile contaminants
Contaminant removal efficiencies (obtainable from mathematical models)
Metal Hydroxide Precipitation
Ground Water Metals concentration Contaminant removal
efficiency Sludge generation rate and composition
In Situ Vapor Extraction
Soils Soil type Particle size distribution
Concentration of volatile compounds
Presence of non-volatile contaminants
Contaminant removal efficiencies (usually requires bench- or pilot-scale work) '
(Note: Tables used in this outline are only partial examples.]