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

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,: 5/5/88 CONCURRENCES

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EPA Form 1320-1 (12-70) V n—[ OFFICIAL FILE COPY

I I U

EPA/540/G-85/003 June 1985

Guidance ©n Feasibility Studies Under CERCLA

Prepared for:

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.

2-19

007431

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.

2-21

007432

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.]

OSWER Directive 9355,3cOi

Sot©rsiaQ tQStiag requiresents for bench or pilot studies, if

(So3 TBIATABILIT? TlSTSaS

Certain technologies have hQ®n sufficiently demonstrated so that

§ite=sp€cifie information collected during the site characterization is

adequate to evaluate and cost those technologies %7ithout conducting

treatability testing. For ossserple, a fround=water investigation usually

provides suffieiont inforaation fres which to size a pecked tower air

stripper and prepare a eoaparative cost estimate. Other examples of when

treatability testing say not be necessary includes

o A developed technology is «ell proven on similar applications.

o Substantial experience exists with a technology treating well

documented waste materials. (For example, air stripping or carbor.

adsorption of ground water contain organic coa joxinds that have

-. been treated previously in other applications.)

o Relatively low removal efficiencies are required (e.g., 50 to

90 percent), and data are already available.

Frequently, technologies have not been sufficiently demonstrated or

characterization of the waste alone is insufficient to predict treatment

performance or to estimate the size and cost of appropriate treatment units.

Furthermore, some treatment processes are not sufficiently understood for

performance to be predicted, even with a complete characterization of the

wastes. For esa^le, it is often difficult to predict biological toxicity

in a biological treatment plant without pilot tests. When treatment

performance is difficult to predict, an actual testing of the process may be

the only s@ans of obtaining the necessary data. In fact, in sceie situations

it say be aore eost=effeetive to test a process on the actual waste than it

would be to characterize the waste in sufficient detail to predict perfor­

mance,

007438

!

OSWER Directive 9355.3-01

( Treatability testing performed during an RI/FS is used to adequately

evaluate a specific technology, including evaluating performance, determin­

ing process sizing, and estimating costs in sufficient detail to support the

remedy^selection process. Treatability testing in the RI/FS is not meant to

be used soley to develop detailed design or operating parameters that are

more appropriately developed during the remedial design phase.

Treatability testing can be perfonned by using bench-scale or pilot-

scale techniques, %ihich are described in detail in the following sections.

Howeverf in general, treatability studies will include the following steps:

o Preparing a work plan (or modifying the existing work plan) for

the bench or pilot studies

o Performing field sampling, and/or bench testing, and/or pilot

9 testing

o Evaluating data from field studies, and/or bench testing, and/or

pilot testing

o Preparing a brief report docimenting the results of the testing

6.3.1 Bench-Scale Treatability Studies

Bench testing usually is performed in a laboratory, in which compara­

tively small volumes of waste are tested for the individual parameters of a

treatment technology. These tests are generally used to determine if the

"chemistry" of the process works and are usually performed in batch (e.g.,

"jar tests"), with treatment parameters varied one at a time. Because small

volumes and inexpensive reactors (e.g., bottles or beakers) are used, bench

tests can be used economically to test a relatively large number of both

performance and waste-composition variables. It is also possible to evalu­

ate a treatment system made up of several technologies and to generate

limited amounts of residuals for evaluation. Bench tests are typically per­

formed for projects involving treatment or destruction technologies. How-

i i^"-

OSWER Directive 9355,3-01

7,2.3.2 Cost

A cos^rehensive discussion of costing procedures for CERCLA sites

is contained in the Remedial Action Costing Procedures Manual (USEPA,

1985). The application of cost estimates to alternatives evaluation is

discussed in the following paragraphs.

Capital Costs. Capital costs consist of direct (construction) and

indirect (nonconstruction and overhead) costs. Direct costs include

expenditures for the equipment, labor, and materials necessary to

install remedial actions. Indirect costs includ© expenditures for

engineering, financial, and other services that are not part of actual

installation activities but are required to complete the installation of

remedial alternatives, (Sales t^@s normally do not apply to Superfund

actions.) Costs that must be incurred in th© future as part of the

remedial action alternative should be identified and noted for the year

in which they will occur. The distriJbution of costs over time will be a

critical factor in making tradeoffs between capital-intensive

technologies (including alternative treatment and destruction

technologies) and less capital-intensive technologies (such as pump and

treatment systems).

Direct capital costs may include the following:

o Construction costs>=°Costs of materials, labor (including

fringe benefits and worker's compensation), and equipment

required to install a remedial action

o Equipment costS'-<-Costs of remedial action and service

ec[uipment necessary to enact the remedy; (these materials

remain until the site remedy is complete)

o Land and site-development costs°>°Expenses associated with the

purchase of land and the site preparation costs of existing

property

C07440

o. Buildings and services co8ts-<>Costs of process and nonprocess

buildings, utility connections, purchased services, and

disposal costs

o Relocation expenses--^osts of tes^orary or permanent

accommodations for affected nearby residents. (Since cost

estimates for relocations can be complicated, FEHA authorities

and EPA Headquarters should be consulted in estimating these

costs.)

o Disposal costs-x-Costs of transporting and disposing of waste

material such as drums and contaminated soils

Indirect capital costs may include;

o Engineering expenses-°>Costs of administration, design,

construction supervision, drafting, and treatability testing

o LegaJ. fees and license or permit costs—Administrative and

technical costs necessary to obtain licenses and permits for

installation and operation

o Startup and shakedown costs-»Costs incurred during remedial

action startup

o Contingency allowanceS"~°Funds to cover costs resulting from

unforeseen eirctsastances, such as adverse weather conditions,

strikes, and inadequate site characterization

Annual Costs. Annual costs are post-construction costs necessary

to ensTire the continued effectiveness of a remedial action. Although

some annual costs are borne by the lead agency and others by the support

agency, this distinction should not be called out in the FS. The

following annual cost components should be considered:

7-22 007441

m^^^^Mm^^^:r^::^^-A ^:i jst^^^^^^^

OSWER Directive 9355.3-01 ^W

Operating labor costs—Wages, salaries, training, overhead,

and fringe benefits associated with the labor needed for

post-construction operations

Maintenance materials and labor costs--Costs for labor, parts,

and other resources required for routine maintenance of

facilities and equipment

Auxiliary materials and energy—Costs of such items as

chemicals and electricity for treatment plant operations,

water and sewer services, and fuel

Disposal of residues—Costs to treat or dispose of residuals

such as sludges from treatment processes or spent activated

carbon

Purchased services—Seunpling costs, laboratory fees, and

professional fees for which the need can be predicted

Administrative costs—Costs associated with the administration

of remedial action OSM not included under other categories

Insurance, taxes, and licensing costs—Costs of such items as

liability and sudden accidental insurance; real estate taxes

on purchased land or rights-of-way; licensing fees for certain

technologies; and permit renewal and reporting costs

Maintenance reserve aad contingency funds—Annual payments

into escrow funds to cover costs of anticipated replacement or

rebuilding of equipment and any large unanticipated O&M costs

Rehabilitation costs—Cost for maintaining equipment or

structures that wear out over time

007442

9 Coots of poriodie cite reviewg^^Costs for oite reviews that

aro eoaduetsd at loaot ovQry S years if wastes above

hoalth°based lovels reaaia at the site

ThQ eects ©f potsatial futurQ soaadial actions should be addressed,

and if appropriate, should be included ea there is a reasonable

osspeetatioa that a sajor eospoaent ©f the alternative will fail and

require replacement to prevent significant essposure to contaminants.

Analysis^ described under Section 7,2,3,2, "Long-term Effectiveness and

fQgaaaoncQs" should be used to doto^aiae which alternatives say result

ia future costs. It is not osspected that a detailed statistical

analysis will be required to identify probable future costs. Rather,

qualitative engineering judgment should be used and the rationale should

be ssll documented ia the FS report,

Accuracy of Cost Estimates, Site characterization and treatability

investigation iaformation should pesait the user to refine cost

estimates for remedial action alternatives. It is important to consider

tSe accuracy of costs developed for alternatives in the FS. Typically,

these "study estimate" costs made during the FS are expected to provide

an accuracy of 4'SO percent to -=30 percent and are prepared using data

available from the RI, Costs developed with es^ected accuracies other

than "S-SO percent to °30 percent should be identified as such in the FS.

Present Worth Analysis, A present worth analysis is used to

evaluate expenditures that occur over different time periods by

discotmting all future costs to a eo^aon base year, usually the current

foar. This allows the cost of resadial action alternatives to be

compared oa the basis of a single, figure representing the amount of

soney that,, if invested ia the base year and disbursed as needed, would

be sufficient to cover all costs associated with the remedial action

over its planned life.

In conducting the present worth analysis, assumptions must be made

regarding the discount rate and the period of performance, A discount

'24 ^ ^

OSWER Directive 9355.3-01

rate of 5 percent before taxes and after inflation should be assiimed.

Estimates of costs in each of the planning years are made in constant

dollars, representing the general purchasing power at the time of

construction. In general, the period of performance should not exceed

30 years for the purpose of the detailed analysis.

Cost Sensitivity Analysis. After the present worth of each

remedial action alternative is calculated, individual costs may be

evaluated through a sensitivity analysis if there is sufficient

uncertainty concerning specific assumptions. A sensitivitry analysis

assesses the effect that variations in specific assxsnptions associated

with the design, implementation, operation, discount rate, and effective

life of an alternative can have on the estimated cost of the

alternative. These assumptions depend on the accuracy of the data

developed during the site characterization and treatability

investigation and on predictions of the future behavior of the

technology. Therefore, these assumptions are subject to varying degrees

of^uncertainty from site to site. The potential effect on the cost of

an alternative because of these uncertainties C2m be observed by varying

the assumptions and noting the effects on estimated costs. Sensitivity

analyses can also be used to optimize the design of a remedial action

alternative, particularly when design parameters are interdependent

(e.g., treatment plant capacity for contaminated ground water and the

length of the period of performamce).

Use of sensitivity analyses should be considered for the factors

that can significantly change overall costs of an alternative with only

small chamges in their values, especially if the factors have a high

degree of uncertainty associated with them. Other factors chosen for

analysis may include those factors for which the expected (or estimated)

value is highly uncertain. The resxilts of such an analysis cam be used

to identify worst-case scenarios and to revise estimates of contingency

or reserve funds. ^

7444

The following factors are potential candidates for consideration in

©oadactiag a seasitivity analysiss

© ^ e Qffee^vQ life ©f a ressdial actioa

o ThQ O&M costs

© The duratioa ef eleaaup

© ' The v©l\^e of coatasiaated material, givea the uncertainty

about site conditions

o Other design parameters (e.g., the size of the treatment

o The discount rate (S percent should be used to compeire

alternative costs, however, a range of 3 to 10 percent can be

used to investigate uncertainties)

The results of a seasitivity analysis should be discussed during

the comparison of alternatives. Areas of uncertainty that may have a

significant effect on th® cost of en alternative should be highlighted,

and a ratioaale should be presented for selection of the most probable

value of the parameter,

7,2,3,6 Co^liance with ARARs

"Siis evaluation eriterioa is used to detesaiae how each alternative

ec^lies with applicable or relevant and appropriate Federal and State

requirements, as defined ia SRCLA Section 121, ^ere are three general

categories of ARARss chemical ,, l©cati©n'=, and actioa=>specific, ARARs

for each category have beea ideatified ia previous stages ©f the RI/FS

process (e.g.!, chemical^specific ARARs should be preliminarily identic

fied during scoping of the project), ^ e detailed analysis should sum­

marize which requirements are applicable or relevant and appropriate to

'744^ 7°26