Attachment_C_-_Best_Management_Practices_for_Soils_Treatment.pdf

United States Solid Waste and Environmental Protection Emergency Response EPA530-R-97-007 Agency (5303W) May 1997

Best Mana gement Practices (BMPs) for Soils Treatment Technolo gies

Suggested Operational Guidelines to Prevent Cross- Media Transfer of Contaminants Durin g Cleanup Activities

Reproduced on Paper that Contains at least 20% Post Consumer Fiber

Attachment C

DISCLAIMER

This document was prepared by the U.S. Environmental Protection Agency (EPA) in order to provide guidance in preventing cross-media transfer of contaminants during implementation of soils treatment technologies. EPA does not make any warranty or representation, express or implied with respect to the accuracy, completeness or usefulness of the information contained in this report. EPA does not assume any liability with respect to the use of, or for damages resulting from the use of, any information, apparatus, method or process disclosed in this report. Reference to trade names or specific commercial products, commodities, or services in this report does not represent or constitute an endorsement, recommendation, or favoring by EPA of the specific commercial product, commodity, or service. In addition, the policies set out in this document are not final agency action, but are intended solely as guidance. They 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. The Agency also reserves the right to change this guidance at any time without public notice.

PREFACE

This document has been prepared by the U.S. Environmental Protection Agency's Office of Solid Waste. To minimize the cross-media transfer of contaminants during Remedial Actions (RAs) or Corrective Measure Implementations (CMIs), this effort was undertaken to develop the Best Management Practices (BMPs) for various soils treatment technologies. This document was developed by a team effort led by EPA's Office of Solid Waste. The names of team members, their affiliation, and area of assistance are listed below:

Team Members

Ed Barth, P.E. EPA/ORD/NRMRL- Other Physical/Chemical Cincinnati

Ray Cody EPA/Region 1 Vapor Extraction

Subijoy Dutta, P.E. EPA/OSW/PSPD Team Leader

Michael Forlini EPA/TIO Bioremediation

Scott Frederick EPA/OERR Superfund Coordination

Larry Gonzalez EPA/OSW/HWMMD Other Physical/Chemical

Bob Hall EPA/OSW/PSPD Management Coordination

Carolyn Hoskinson EPA/OSW/PSPD HWIR-Media Coordination

José Labiosa EPA/OSW/HWMMD Soil Washing

Shaun McGarvey EPA/OSW/HWMMD Thermal Treatment

Bonnie Robinson EPA/OSW/PSPD Comments Coordination

Larry Rosengrant EPA/OSW/EMRAD Universal Table

David Sweeny New Jersey, DEP Field Applicability

Debby Tremblay EPA/OUST Vapor Extraction

A series of seven workshops on different technology groups was held by the team in developing the document. A list of outside experts who attended these workshops and provided input is furnished below:

Outside Workshop Experts

William Anderson, P.E. AAEE, Annapolis, MD Soil Washing/Thermal Brett Campbell Geosafe Corp., WA Insitu Vitrification David Carson EPA/ORD/NRMRL Containment Harry Compton EPA/OSWER/OERR- OPC

Edison, NJ Harsh Dev, PhD IITRI, IL RF Heating Regina Dugan, PhD Institute for Defense Bioremediation

Analyses, VA David Ellis, PhD Dupont Chemicals, DE Bioremediation Evan Fan EPA/ORD/NRMRL Vapor Extraction Uwe Frank EPA/ORD/NRMRL Vapor Extraction C.C. Lee EPA/ORD/NRMRL Incineration Mark Meckes EPA/ORD/NRMRL Thermal Treatment Rick Vickery Dupont Exp. Stn. Incineration Kenneth R. Weiss Delaware DNR Incineration John Wilson, PhD EPA/ORD/NRMRL Bioremediation

EPA plans to update this document in the future, when new technologies and more effective management practices are developed.

Any questions, clarifications, or suggestions on this document should be addressed to:

Subijoy Dutta, P.E.

U.S. EPA (5303W)

Office of Solid Waste 401 M Street, SW Washington, DC 20460 email: dutta.subijoy@epamail.epa.gov i

CONTENTS

Chapter Page

LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

LIST OF FIGURES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi

LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

1.0 Chapter One: INTRODUCTION

1.1 Regulatory Background and Need for BMPs Guidance

1.2 Structure of BMPs Guidance

1.3 Examples of BMPs

2.0 Chapter Two: GENERAL BMPs for REMEDIATION ACTIVITIES

2.1 General Cross-Media Transfer Potentials for Various Treatment

Technologies

2.2 General Best Management Practices for Soils Treatment Technologies

2.2.1 Site Preparation and Staging

2.2.2 Pre-Treatment Activities

2.2.3 Treatment Activities

2.2.4 Post-Treatment Activities/Residuals Management

2.3 References

3.0 Chapter Three: CROSS-MEDIA TRANSFER CONTROL TECHNOLOGIES and MONITORING14

3.1 Available Control Technologies

3.2 Relative Costs of Implementing BMPs

3.3 References

4.0 Chapter Four: BMPs for CONTAINMENT TECHNOLOGIES

4.1 Definition and Scope of Containment Technologies (for BMPs)

4.1.1 Key Features of Containment Technologies for the Purpose of BMPs

4.2 Containment Technology Description

4.3 Cross-Media Transfer Potential of Containment Technologies

4.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Containment Technologies

4.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Containment Technologies

4.6 References

5.0 Chapter Five: BMPs for SOIL WASHING

5.1 Definition and Scope of Soil Washing (for BMPs)

5.1.1 Key Features of Soil Washing Technology for the Purpose of BMPs

5.2 Soil Washing Technology Description

5.3 Cross-Media Transfer Potential of Soil Washing Technologies

5.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Soil Washing Technologies ii

5.5 Waste Characteristics that May Increase the Likelihood of Cross-Media Contamination for Soil Washing Technologies

5.6 References

6.0 Chapter Six: BMPs for THERMAL TREATMENT

6.1 Definition and Scope of Thermal Treatment (for BMPs)

6.1.1 Key Features of Thermal Treatment for the Purpose of BMPs

6.2 Thermal Treatment Technology Description

6.3 Cross-Media Transfer Potential of Thermal Treatment Technologies

6.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Thermal Treatment Technologies

6.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Thermal Treatment Technologies

6.6 References

7.0 Chapter Seven: BMPs for VAPOR EXTRACTION

7.1 Definition and Scope of Vapor Extraction (for BMPs)

7.1.1 Key Features of Vapor Extraction Technology for the Purpose of BMPs

7.2 Vapor Extraction Technology Description

7.3 Cross-Media Transfer Potential of Vapor Extraction Technologies

7.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Vapor Extraction Technologies

7.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Vapor Extraction Technologies

7.6 References

8.0 Chapter Eight: BMPs for BIOREMEDIATION

8.1 Definition and Scope of Bioremediation (for BMPs)

8.1.1 Key Features of Bioremediation for the Purpose of BMPs

8.2 Bioremediation Technology Description

8.3 Cross-Media Transfer Potential of Bioremediation Technologies

8.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Bioremediation Technologies

8.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Bioremediation Technologies

8.6 References

9.0 Chapter Nine: BMPs for INCINERATION TREATMENT

9.1 Definition and Scope of Incineration Treatment (for BMPs)

9.1.1 Key Features of Incineration for the Purpose of BMPs

9.2 Incineration Technology Description

9.3 Cross-Media Transfer Potential of Incineration Technologies

9.4 Best Management Options to Avoid Potential Cross-Media

Transfers for Incineration Technologies

9.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Incineration Technologies

9.6 References

iii

10.0 Chapter Ten: BMPs for OTHER PHYSICAL/CHEMICAL TREATMENTS

10.1 Definition and Scope of Other Physical and Chemical Treatment (for BMPs)

10.2 In Situ Radio Frequency (RF) Heating

10.2.1 Definition and Scope of In Situ RF Heating (for BMPs)

10.2.1.1 Key Features of In Situ RF

Heating for the Purpose of BMPs

10.2.2 In Situ RF Heating Technology Description

10.2.3 Cross-Media Transfer Potential of In Situ RF Heating

10.2.4 Best Management Options to Avoid Potential

Cross-Media Transfers During In Situ RF Heating

10.2.5 Waste Characteristics that May Increase the Likelihood of Cross-Media Contamination for In Situ RF Heating

10.3 In Situ Vitrification

10.3.1 Definition and Scope of In Situ Vitrification (ISV) (for BMPs)

10.3.1.1 Key Features of In Situ Vitrification for the

Purpose of BMPs

10.3.2 In Situ Vitrification Technology Description

10.3.3 Cross-Media Transfer Potential of In Situ Vitrification

10.3.4 Best Management Options to Avoid Potential

Cross-Media Transfers During ISV

10.3.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for In Situ Vitrification Technologies

10.4 In Situ Soil Flushing

10.4.1 Definition and Scope of In Situ Soil Flushing (for BMPs)

10.4.1.1 Key Features of In Situ Soil Flushing for

the Purpose of BMPs

10.4.2 In Situ Soil Flushing Technology Description

10.4.3 Cross-Media Transfer Potential of In Situ Soil Flushing

10.4.4 Best Management Options to Avoid Potential Cross-Media

Transfers During In Situ Soil Flushing

10.4.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for In Situ Flushing Technologies

10.5 Solidification/Stabilization

10.5.1 Definition and Scope of Solidification/Stabilization (for BMPs)

10.5.1.1 Key Features of Solidification/Stabilization for the Purpose of BMPs

10.5.2 Solidification and Stabilization Technology Description

10.5.3 Cross-Media Transfer Potential of

Solidification/Stabilization

10.5.4 Best Management Options to Avoid Potential

Cross-Media Transfers During Solidification/Stabilization

10.5.5 Waste Characteristics That May Increase the Likelihood of

Cross-Media Contamination for Solidification and Stabilization Technologies

10.6 Excavation and Off-Site Disposal

10.6.1 Definition and Scope of Excavation and Off-Site Disposal (for iv

BMPs)

10.6.1.1 Key Features of Excavation and Off-Site

Disposal for the Purpose of BMPs

10.6.2 Excavation and Off-Site Disposal Technology Description

10.6.3 Cross-Media Transfer Potential of Excavation and Off-Site

Disposal

10.6.4 Best Management Options to Avoid Potential Cross-Media

Transfers During Excavation and Off-Site Disposal

10.6.5 Waste Characteristics that May Increase the Likelihood of

Cross-Media Contamination for Excavation and Off-Site Disposal Technologies

10.7 References

11.0 Chapter Eleven: FIELD VALIDATION and CASE STUDIES of BMPs

11.1 Soil Washing/Soil Leaching to Treat Metals Contaminated

Soil at an Army Ammunition Plant in Minnesota (Site 1)

11.1.1 Description of Site Remediation Activities

11.1.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.1.3 Views and Discussion

11.2 In-Situ Chemical Based Stabilization of Petroleum Contaminated Soil at a Refinery in Minnesota (Site 2)

11.2.1 Description of Site Remediation Activities

11.2.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.2.3 Views and Discussion

11.3 Stabilization and Disposal of Lead Contaminated Soils at a Closed Battery Manufacturing Facility in Virginia (Site 3)

11.3.1 Description of Site Remediation Activities

11.3.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.3.3 Views and Discussion

11.4 Particle Size Separation and Soil Washing at a Site Used Previously for Ammunition Testing and Disposal in Connecticut (Site 4)

11.4.1 Description of Site Remediation Activities

11.4.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.4.3 Views and Discussion

11.5 Soil Vapor Extraction of Solvents at a Closed Electronic Component Manufacturing Facility in Maine (Site 5)

11.5.1 Description of Site Remediation Activities

11.5.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.5.3 Views and Discussion

11.6 Excavation and Thermal Treatment of VOC-Contaminated Soil and Debris at a DOE Site in Colorado (Site 6)

11.6.1 Description of Site Remediation Activities

11.6.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.6.3 Views and Discussion

11.7 On-Site Containment of Soils in Former Manufacturing Areas at a Chromium Plant, Maryland (Site 7)

11.7.1 Description of Site Remediation Activities

11.7.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.7.3 Views and Discussion

v

11.8 Ex Situ Bioremediation of Explosives Contaminated Soils at a DoD Facility in Virginia (Site 8)

11.8.1 Description of Site Remediation Activities

11.8.2 BMPs Used to Prevent Cross-Media Transfer of Pollutants

11.8.3 Views and Discussion

11.9 Comparison of Selected Case Study BMPs With BMPs

Recommended in this Guidance

LIST OF TABLES

Table 1-1. Technology-Specific Cross-Media Transfer Concerns and Possible BMPs Table 2-1. Fractional Contributions of Various Remedial

Activities to Total Volatile Contaminant Emissions Table 3-1. Emissions Sources and Controls During Cleanup Activities Table 3-2. Technologies for Controlling Cross-Media Transfer of Contaminants During

Materials Handling Activities Table 3-3. Technologies for Reducing Contaminant Concentrations in Air

Emissions Generated During Remediation Table 3-4. Examples of Technologies for Controlling Cross-Media Transfer to Water Table 3-5. Examples of Field Monitoring Technologies Table 11-1. Key Characteristics of BMP Case Study Sites Table 11-2. Examples of Field/Case Study Findings and Relevant

Modifications of the BMP Guidance Document vi

LIST OF FIGURES

Figure 3-1. Relative Cost Effectiveness for Point Source VOC Controls Figure 4-1. Cross-Sectional View Showing Implementation of Slurry Walls Figure 4-2. Cross-Section of Multilayer Landfill Cover Figure 5-1. Basic Soil Washing Flow Diagram Figure 6-1. Schematic of a Thermal Desorption Treatment System Figure 7-1. Schematic of a Soil Vapor Extraction System Figure 8-1. Schematic for Solid Phase Bioremediation Figure 8-2. Diagram of Solid Phase Biological Treatment Using a Composting Pile Figure 9-1. Schematic Diagram of a Typical Incineration Facility Figure 9-2. Typical Liquid Injection Incinerator Figure 9-3. Typical Fixed/Sloped Hearth Incinerator Figure 9-4. Typical Multiple Hearth Incinerator Figure 9-5. Typical Rotary Kiln Incinerator Figure 10-1. Schematic Diagram of an In Situ RF Heating System Figure 10-2. Cross-Section of an In Situ RF Heating System Figure 10-3. ISV Equipment System Figure 10-4. A Cut-Away View of a Typical Treatment Cell Figure 10-5. Schematic of In Situ Flushing Field Test System Figure 10-6. Soil Flushing Sprinkler System Figure 10-7. Schematic of Soil Flushing System Figure 10-8. Generic Elements of Typical S/S Processes vii

LIST OF ACRONYMS

AEC Area of Environmental Concern APCD Air Pollution Control District ASME American Society of Mechanical Engineers ASTM American Society of Testing and Materials ATP Anaerobic Thermal Process BACT Best Available Control Technology BDAT Best Demonstrated Available Technology BOD Biochemical Oxygen Demand BMPs Best Management Practice(s) BPT Best Practicable Technology BPCT Best Practicable Control Technology CAO Corrective Action Order CAP Corrective Action Plan CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of

CFM Cubic Feet Per Minute CFR Code of Federal Regulations CMI Corrective Measure Implementation CMIPP Corrective Measure Implementation (Program Plan) COD Chemical Oxygen Demand CAMU Corrective Action Management Unit CSFS Contaminated Soil Feed Stockpiles CWA Clean Water Act DEP Department of Environmental Protection DM Dust Monitor DNAPLDense Non-Aqueous Phase Liquid DNR Department of Natural Resources DoD Department of Defense DOE Department of Energy EPA U.S. Environmental Protection Agency FACA Federal Advisory Committee Act FCC Federal Communications Commission FFA Federal Facility Agreement FID Flame Ionization Detector FR Federal Register GAC Granular Activated Carbon GC/MS Gas Chromatography/Mass Spectrometry GCLs Geosynthetic Clay Liners GPD Gallons Per Day HWIR Hazardous Waste Identification Rule HWMMDHazardous Waste Minimization and Management Division of OSW/EPA IRP Installation Restoration Program ISM Industrial, Scientific, and Medical ISV In Situ Vitrification LNAPLLight Non-Aqueous Phase Liquid LDR Land Disposal Restrictions MPCA Minnesota Pollution Control Agency viii

NIOSH National Institute of Occupational Safety and Health NPDESNational Pollutant Discharge Elimination System (CWA) NRMRLNational Risk Management Research Laboratory OD Outside Diameter OERR Office of Emergency and Remedial Response OPC Other Physical/Chemical Treatment ORD Office of Research and Development OSW Office of Solid Waste OSWEROffice of Solid Waste and Emergency Response OUST Office of Underground Storage Tanks OVA Organic Vapor Analyzer OW Office of Water PASP Perimeter Air Sampling Program PCE Perchloroethylene PIC Products of Incomplete Combustion PID Photoionization Detector PM Particulate Matter POHC Principal Organic Hazardous Constituent PPB Parts Per Billion PPM Parts Per Million (mg/l) PSPD Permits and State Programs Division of OSW/EPA PVC Polyvinyl Chloride RA Remedial Action RD Remedial Design RCRA Resource Conservation and Recovery Act RF Radio Frequency RFI RCRA Facility Investigation RI Remedial Investigation RI/FS Remedial Investigation/Feasibility Study RSKERRL Robert S. Kerr Environmental Research Laboratory SARA Superfund Amendments and Reauthorization Act of 1986 SDWA Safe Drinking Water Act SHSP Site Health and Safety Plan SITE Superfund Innovative Technology Evaluation SPCC Spill Prevention, Containment, and Countermeasure (CWA) SPLP Synthetic Precipitation Leaching Procedure (EPA Method 1312) S/S Solidification/Stabilization SU Standard Unit SVE Soil Vapor Extraction SVOC Semi-Volatile Organic Compound SWDA Solid Waste Disposal Act TCE Trichloroethylene TCLP Toxicity Characteristic Leaching Procedure (EPA Method 1311) TDU Thermal Desorption Unit TIO Technology Innovation Office TPH Total Petroleum Hydrocarbons TRPH Total Recoverable Petroleum Hydrocarbons TSDF Treatment, Storage and Disposal Facility TSS Total Suspended Solids ix

TWA Time Weighted Average USEPAU.S. Environmental Protection Agency UST Underground Storage Tank UXO Unexploded Ordnance VOC Volatile Organic Compound WIPP Waste Isolation Pilot Plant WMD Waste Management Division of OSW/EPA XRF X-Ray Fluorescence

1.0 Chapter One: INTRODUCTION

This document provides guidance on how to design and conduct soil remediation activities at RCRA and other hazardous waste sites so that transfers of contaminants from contaminated soil to other media (i.e., clean soil, air, and surface or ground water) are minimized. Its primary purpose is to provide guidance on preventing cross-media transfers of contaminants during implementation of soils treatment technologies for treating contaminated soils or solid media in compliance with applicable state and/or federal regulations. Releases that may result in transfer of contaminants from the soil or solid media to water, air or other natural media are generally referred to as cross-media transfer.

This document is not meant to direct or guide selection of appropriate treatment technologies. Rather, it is only meant to provide advice on the operational practices relating to prevention and control of cross-media contamination (hereafter referred to as "Best Management Practices" or "BMPs") that, based on research and past experience, may be best for the selected technology.

As described below, efforts to develop this document were initiated to support implementation of the proposed Hazardous Waste Identification Rule for contaminated media (HWIR-media). However, EPA believes that the guidance contained herein will be useful in many different situations involving cleanup activities, where parties implementing a soil treatment technology want to be attentive to cross-media contamination concerns and minimize any adverse impact on the overall environment. This document does not replace any existing state or federal regulations or guidance.

This document is also expected to assist in reducing worker exposure to contaminants by identifying the potentials for cross-media transfer and recommending possible control mechanisms during implementation of soils treatment technologies.

Although it is beyond the scope of this document to address the worker health and safety issues, the recommended BMPs are expected to passively alleviate many of the worker health and safety concerns during soils treatment technology implementation.

The cost of implementing the recommended BMPs are generally subsumed in the overall treatment technology implementation. No specific incremental cost estimates are available at this time for application of the recommended BMPs. However, based upon the information gathered from a few case studies, a short synopsis on the relative cost of implementing BMPs is provided in Section 3.2 of this document.

1.1 Regulatory Background and Need for BMPs Guidance

The Best Management Practices (BMPs) for Soils Treatment Technologies were developed to provide guidance on how to identify and minimize the potential for causing cross-media contamination during implementation of cleanup technologies for contaminated soils or solid media. The guidance outlines the specific potential cross-media concerns for specific activities and recommends approaches for preventing cross-media transfer of contaminants.

EPA originally began to develop the BMPs guidance in response to concerns that some cleanup activities may unintentionally cause additional contamination through cross-media transfer of contaminants. Stakeholders involved in the development of HWIR-media raised these concerns to EPA.

The BMPs guidance was not developed for and should not be used as a compliance guide for any particular set of cleanup standards, but instead should be used as a reference during implementation of those standards. The Agency expects that it will be of use in many contexts, including Superfund cleanups, RCRA Subtitle C corrective action, UST corrective action, and state cleanups. If any of the recommendations provided in this guidance causes a conflict with a state or federal regulation, such conflict is unintentional, and the applicable regulation should be followed.

BMPs are not meant to be used as a selection tool for remedial treatment technologies, rather they should be used during the implementation stage of remedies once they are selected. EPA believes that this document will be of unique assistance where parties implementing a soil treatment technology want to be attentive to cross-media contamination concerns.

1.2 Structure of BMPs Guidance

The structure of this guidance document is the result of several rounds of analysis and review of the task at hand and the information developed to accomplish it.

Developing and compiling BMPs for each existing soil treatment technology would be a monumental undertaking. To simplify the effort, the BMP team grouped technologies based on common features and similarities in their ability to give rise to cross-media transfers of contaminants. This resulted in the following seven technology categories:

& Containment Technologies & Soil Washing & Thermal Treatment & Vapor Extraction & Bioremediation & Incineration & Other Physical/Chemical Treatments

It was recognized by the peer reviewers and BMP team members that implementation of many technologies involved common activities. To streamline the document and make it easier to use, BMPs for common activities were compiled into a single chapter. Similarly, information on technologies used for controlling cross-media transfers of contaminants were also compiled in one chapter for quick reference and to minimize repetition.

Individual chapters on different technology categories are made much more technology specific. Other characteristics of initial draft guidance, such as organizing BMPs by remedial stage or phase (e.g., site preparation and staging), were also maintained but improved upon wherever possible, in accordance with reviewers’ comments.

The remainder of this BMPs guidance is structured into ten chapters as follows:

Chapter 2 presents BMPs that are not specific to any particular soils treatment technology. In most cases, these BMPs are applicable across a range of remedial activities and several or most remediation technologies. As presented, these BMPs address specific cross-media transfer concerns (e.g., fugitive dust emissions, surface and ground water contamination by runoff), providing information on operational activities that can reduce the likelihood of transfers during remediation activities. The information in this chapter is organized relative to various remedial stages: site preparation and staging, pre-treatment, and post-treatment/residuals management. Technology-specific BMPs are provided later in Chapters 4 through 10.

Chapter 3 provides information on control technologies that can be used in conjunction with BMPs to reduce the likelihood of cross-media contamination during soil remediation activities. The information in this chapter is organized in a series of five tables.

Chapters 4 through 10, respectively, present technology-specific BMPs for each of the seven technology categories and, in some cases, for specific technologies within those categories. References to Chapters 2 and 3 are provided wherever applicable. More specifically, each chapter provides the following information:

& Definition and Scope. For each technology category, the guidance provides a definition of the technology and describes the purpose and applications of the technologies in each category. A description of the key features common to all the technologies within the category is also provided. When a new technology is introduced that is not specifically addressed in this guidance, it could be matched with an existing technology category with which it shares similar key features, and the appropriate BMPs can be applied.

& Cross-Media Transfer Potential. The types of potential releases (e.g., fugitive dust emissions, volatile organic compound (VOC) emissions, leaching of contaminants to ground water) that are of concern for the general technology category and, if they differ, for specific technologies within the category are identified. Types of potential releases are tied to the remedial stage during which they are most likely to occur.

& The Best Management Options to Avoid Potential Cross-Media Transfers. For the four major stages of the remediation process, this guidance discusses those management options or practices, also called BMPs, that are generally considered best to minimize cross-media transfer of contamination. For example, the BMPs provided here address techniques that can be used to suppress fugitive dusts, gas emissions, and odors; minimize surface and ground water contamination; limit the effects of human and animal access across sites; and other methods that can help to avoid potential cross-media transfers during all activities associated with site remediation.

Most of the BMPs in many chapters address activities within the treatment stage of remediation because those tend to be the most technology specific.

Where appropriate, however, BMPs for technology-specific activities that occur in other stages are also offered.

& Waste Characteristics that May Increase the Likelihood of Cross-Media Contamination for this Technology. An overview is provided of site conditions and waste characteristics that might result in a greater likelihood of cross-media transfer of contaminants when a technology is applied in less than optimal site conditions or to treat contaminants for which its effectiveness may be limited.

& Residuals Management. Common post-treatment and residual management issues have been addressed in Chapter 2 of this guidance, which identifies the types of residuals that might be generated by the implementation of technologies within particular categories and discusses the options available for the management of residuals to prevent cross-media contamination. This guidance only addresses those residuals that have some potential for cross-media transfer of contaminants or their by-products created during treatment.

Chapter 11 provides case studies as well as information on field validation activities that EPA undertook at soil remediation sites in the Fall and Winter of 1996-1997. Useful information gleaned from these case studies and field validation activities, such as the field applicability of BMPs and associated control technologies, has been incorporated into this document as appropriate for the seven technology categories.

In order to easily identify the recommended BMPs, the 7 bullet has been used exclusively for the recommended BMPs in this document.

1.3 Examples of BMPs

Table 1-1 provides examples of the types of information that can be found in these chapters. Specifically, this table presents technology-specific cross-media transfer concerns for various technology categories and some of the possible BMPs for addressing them. This table is not meant to be comprehensive. Many other concerns, and the BMPs that should be used to address them, are outlined in the individual technology chapters, and the reader is encouraged to review all of the information that is pertinent to a particular technology grouping for best results.

Table 1-1. Technology-Specific Cross-Media Transfer Concerns and Possible BMPs

Technologies Area of Concern Possible BMPs to Mitigate Concern

Containment Post-Implementation Maintenance: Cracks, Containment structures should be periodically monitored for Technologies microfractures, other breaches of cracks, microfracture, or leaks and proper control should be containment unit resulting in leaching of exercised, when necessary, to prevent migration of materials to groundwater or release of contaminants. Details of other cross-media transfer fugitive emissions to air. concerns and possible BMPs for Containment Technologies are listed in Chapter 4 of this document.

Soil Washing Residuals Management: Soil washing Soils should be cleaned of debris and materials that would Technologies typically generates large volumes of increase the requirements for the use of water or other contaminated waste water or other liquids. solvents. For example, fine silts and clays should be Not all of these liquids can be easily screened out prior to treatment. In addition, the mixing of treated on-site. soil batches that contain dissimilar contaminants should be avoided. In this way, the liquids that are used to clean the soils can contain fewer additives, which will make them easier to treat for recycling or disposal. Details of other cross-media transfer concerns and possible BMPs for Soil Washing Technologies are listed in Chapter 5 of this document.

Thermal Process Emissions: Stack emissions from Air pollution devices should be properly designed, installed Treatment organic collection, removal, or and operated to handle all of the constituents that are Technologies destruction of vapors past the thermal anticipated to be separated from the soil under the specific desorption, vaporization, or separation design of the particular thermal technology selected.

treatment have the potential for air Products of incomplete reaction (i.e., combustion, if release of contaminants that have not been appropriate) should also be handled in the design and completely destroyed. operation of the air pollution control devices.

Additives to soil being thermally treated have the potential for encouraging complete combustion reactions, thereby reducing emissions. Details of other cross-media transfer concerns and possible BMPs for Thermal Treatment Technologies are listed in Chapter 6 of this document.

Table 1-1. Technology-Specific Cross-Media Transfer Concerns and Possible BMPs (cont'd)

Technologies Area of Concern Possible BMPs to Mitigate Concern

Vapor Extraction Disposal Of Residuals: Contaminated During construction of soil vapor extraction-based systems, Technologies debris, soils, and liquid wastes resulted construction debris should be properly handled and treated from excavation and installation of wells on-site or be disposed off-site. Details of other cross-are new sources for potential cross-media media transfer concerns and possible BMPs for Vapor transfer of contaminants. Extraction Technologies are listed in Chapter 7 of this document.

Bioremediation Surface and Ground Water Contamination: The nutrient-rich run-off should be controlled by the use of Technologies Additives used in bioremediation, such as berms, moats, or other physical barriers around phosphorus and nitrogen, have the bioremediation sites. Alternatively, ground-feeding potential to migrate into nearby water sprinkler systems operated at low volumes can minimize the bodies as runoff if not carefully amount of, and area over which, nutrient-rich water is controlled. In addition, oxygen sprayed, reducing the potential for cross-media suppliers, such as hydrogen peroxide, can contamination. Details of other cross-media transfer be flammable, and may require careful concerns and possible BMPs for Bioremediation Technologies handling. are listed in Chapter 8 of this document.

Incineration Process Emissions: Stack emissions from Air pollution devices should be properly designed, installed Technologies organic collection/destruction of vapors and operated to handle all of the anticipated constituents to using thermal desorption, vaporization, or be released from the soil during the treatment process. Air separation treatment have the potential pollution control devices should be designed to treat the for release as contaminant-laden gas products of incomplete combustion by ensuring that streams into the atmosphere. sufficient oxygen is available during all combustion activities.

Additives to the soil being incinerated have the potential for reducing the formation of products of incomplete reaction, thereby reducing emissions. Details of other cross-media transfer concerns and possible BMPs for Incineration Technologies are listed in Chapter 9 of this document.

2.0 Chapter Two: GENERAL BMPs for REMEDIATION ACTIVITIES

At many sites with contaminated soil or solid media, remediation activities will be conducted that have the potential to generate cross-media contamination. These activities generally fall within one of four major remedial stages, regardless of the selected technology (although some technologies may not require or have the same level of activity in all stages):

& Site Preparation and Staging & Pre-Treatment & Treatment & Post-Treatment/Residuals Management

These stages are not always discrete and separate from one another. (For example, residuals management is often an issue while treatment is on-going). However, for the purposes of this document, they are treated individually.

This chapter presents best management practices (BMPs) for addressing those remedial activities that are not unique to the technology selected for treating contaminated soil or solid media at a site (but that still have the potential to generate cross-media contamination). In other words, these BMPs are likely to have applicability to a wide variety of sites because they are associated with a common remedial activity, such as excavation, rather than a specific technology, such as soil washing. The BMPs are organized according to the remedial stage to which they pertain (e.g., staging and site preparation), and then to the applicable cross-media transfer concern (e.g., fugitive dust). The types of remedial activities that may give rise to each concern (e.g., clearing and grubbing, excavation) are also presented to help in determining the applicability of BMPs to a particular site.

As reflected in this chapter, BMPs most commonly associated with activities performed as part of site preparation and staging, pretreatment, and post-treatment/residuals management are not technology-specific. BMPs associated with activities that occur in the treatment stage of a remediation are generally technology specific, so they are not addressed here. BMPs for technology-specific activities and cross-media transfer concerns are found in Chapters 4 through 10, which address individual technology categories.

2.1 General Cross-Media Transfer Potentials for Various Treatment Technologies

During implementation of any soils treatment technology the following steps are generally undertaken: a) Site preparation and staging, b) Pre-treatment activities, c) Treatment activities, and d) Post-treatment activities. Specific cross-media concerns during the actual treatment activities are addressed separately under the relevant technology categories in Chapters 4 through 10. General cross-media transfer potential for contaminants mostly during the site preparation, pre-treatment, and post-treatment activities are identified below.

& There is risk of inaccurate site characterization with any soils treatment technology operation. The material encountered at the remedial site may not be like the soils studied in treatability or pilot-scale tests.

Additional contaminants may be encountered, and the percentage of the fine-grained fraction may be significantly different from that expected. These factors may lead to a long-term storage or generation of high residual volume, and thus increase the potential for cross-media transfer.

& During several different activities associated with remedy implementations, including staging and site preparation (e.g., clearing, grubbing); drilling, well installation and trenching operations;

mobilization and demobilization of equipment; excavation; transport of materials across the site; and some treatment activities, there is high potential for fugitive dust emissions due to movement of equipment at the site. In addition, these same activities can enhance the volatilization of VOCs, SVOCs, and other potentially hazardous materials into the atmosphere.

& During pretreatment operations such as excavation, storage, sizing, crushing, dewatering, neutralization, blending, and feeding, there is the potential for dust and VOC emissions from the contaminated media.

& Migration of contaminants to uncontaminated areas may occur during mobilization or demobilization.

& VOC and SVOC emissions tend to increase during periods of hot and dry weather.

& Leaching of contaminants to surface water can occur from uncovered stockpiles and excavated pits.

& Improper handling and disposal of residues (e.g., sediment/sludge residuals or post-washing wastewater) may allow contaminants to migrate into and pollute uncontaminated areas.

& Post-treatment discharges of wastewater, if improperly managed, can cause migration of contaminants.

Table 2-1 provides a summary of the fractional contributions of various remedial activities to the generation of volatile contaminant emissions, which is potentially a major source of cross-media contamination during many remedial activities.

Table 2-1. Fractional Contributions of Various Remedial Activities to Total Volatile Contaminant Emissions

(USEPA, 1991)

Remedial Activity Contaminant Emissions for the Entire Site Fractional Contribution to Total Volatile

Remediation Process

Excavation 0.0509 Bucket (Loading) 0.0218 Truck Filling 0.0905 Transport 0.3051 Dumping 0.5016 Incineration 0.0014 Exposed Soil 0.0287

Total 1.0000

2.2 General Best Management Practices for Soils Treatment Technologies

Various control practices to prevent potential cross-media transfer of contaminants during cleanup activities have been identified in Tables 3-1 to 3-5. Also, proper system design is recommended prior to implementation of the remedial treatment to avoid cross-media transfer problems during different treatment steps. However, general BMP options to control specific cross-media transfer of contaminants for different treatment technologies are furnished below:

2.2.1 Site Preparation and Staging

Prior to movement of equipment on site the following activities are most commonly undertaken:

® Site inspections; surveying; boundary staking; drilling and trenching;

sampling; demarcation of hot spots; and construction of access roads, utility connections, and fencing.

Special attention and care should be taken during site preparation activities so that the contaminated media are not disturbed. In case of unavoidable circumstances, the contaminated media should be subjected to a very minimal disturbance/alteration during these activities. The following BMPs are generally recommended:

7 Avoid entering the contaminated area. In unavoidable circumstances, build a temporary decontamination area, which could be later used during cleanup activities. Any above-ground and underground source of contaminants should be identified and located prior to starting any treatment of contaminated media.

7 Any soils and soil-gas sampling, field air permeability testing, demarcation of hot spot etc. activities should generally be followed by plugging/covering of any holes or depressions created during these activities to prevent intrusion of water. It would also be appropriate to install relevant signs at the same time so that repeated entry to the site is not called for.

7 Contaminated drilling mud from any drilling operations should be collected in a lined/contained system. This will prevent the contaminants from mixing with the normal surface water runoff from the area and the surrounding natural watercourse.

7 Contaminated waste generated during site preparation or further site characterization activities should be managed protectively as specified in Chapter 3, Tables 3-1 to 3-4.

7 Site investigation and operational plans should take into account the presence of permeable zones and account for potential pre-existing underground sewers and electrical conduits.

7 Surface drainage and subsurface utility systems should be identified.

7 Local watershed management goals and priorities should be incorporated into the surface water management plan for the cleanup activities.

2.2.2 Pre-Treatment Activities

Prior to beginning the actual treatment process the following activities are most commonly undertaken:

® Excavation, transportation, storage, sizing, crushing, dewatering, neutralization, blending, installation of feeding systems for contaminated media etc.

During the above activities, measures should be taken to control fugitive dust emissions and to prevent releases of contaminated media to the natural environment. To prevent cross-media transfer of contaminants, the following BMPs are generally recommended for the above activities:

7 Any aboveground and underground sources of contaminants, such as storage tanks, should generally be removed.

7 Any offsite runoff should be prevented from entering and mixing with on-site contaminated media by building earthen berms or adopting similar other measures, as outlined in Table 3-4.

7 Provisions should generally be made to capture on-site surface water runoff by diverting it to a controlled depression-area or lined pit.

7 Sizing, crushing, and blending activities should be conducted under an environment where the off gases, volatiles, dusts, etc. are all captured inside a hood or cover, or controlled using other options listed in Chapter

3. The dust and VOC emissions associated with these activities that exceed acceptable regulatory limits should be controlled by capturing these emissions and then treating the captured vapor/air to the extent practicable. Measures for preventing, collecting and treating dust and VOC emissions are provided in Tables 3-1 and 3-3.

7 When mixing or dewatering, the contaminated aqueous stream should be collected in a lined/contained system. This will prevent the contaminants from mixing with the normal surface water runoff from the area and the surrounding natural watercourse.

7 Protective management/disposal of contaminated debris is recommended to prevent cross-media transfer. Protective management includes debris washing, providing covers, testing, and appropriate disposal (see Section

11.6.2 (d) and (i)).

7 When treating explosive wastes, proper safety and care should be exercised to prevent any explosion during the treatment process. For conducting safe operations, recommendations provided in the Handbook (USEPA, 1993) may be used, when necessary.

7 The technology design should be checked to ensure that the corrosion factor has been taken into account in the design for all appropriate pipes, valves, fittings, tanks, and feed systems.

7 Entry to the active site should be limited to avoid unnecessary exposure and related transfer of contaminants.

7 The temporary decontamination area described in Section 2.2.1 should be used as recommended earlier to keep the site-related contaminants within the active cleanup area.

7 Fugitive dust emissions should be controlled during excavation by spraying water to keep the ground moist. During wet weather or rainfall no water spraying would be needed.

7 Consideration of climatological extremes/high wind, etc. should be taken into account when conducting any of the treatment or associated activities.

Real-time weather data could be used to monitor weather conditions and accordingly control treatment operations. During a recent field visit an onsite weather station was observed. The weather monitoring stations were reported to have nominal cost and were found to be highly useful in controlling weather-related cross-media transfers. To determine possible extreme conditions, local weather data for the past 10 years could be reviewed from publications (NOAA, 1995) of the National Climatic Data Center, 151 Patton Avenue, Asheville, NC 28801-5001, Phone: (704) 271- 4800.

7 During excavation, blending, and feeding of contaminated soils, VOC emissions should be monitored and appropriate emission control measures undertaken.

7 Operational plans should include adequate inspection procedures that look specifically for corrosion and wear.

7 It is also critical to check that the air pollution control devices are designed for the corrosive nature of the hot gases that are expected to enter these devices, when used in certain soil treatment technologies.

7 As an effective erosion control practice, scheduling of construction activities should be arranged to limit the time of exposure of disturbed segments of the site. This entails directing work to one area of a site, then completing and stabilizing that area before moving on to other areas of the site.

2.2.3 Treatment Activities

Treatment activities and relevant BMPs are specifically described for each technology category in Chapters 4 through 10.

2.2.4 Post-Treatment Activities/Residuals Management

During the post-treatment process the following activities are most commonly undertaken:

(a) Vapor (Gas) Phase

& Collection or destruction of organics & Collection of particulates & Removal of acid gases

(b) Solid and Liquid Phases

& Treatment or disposal of aqueous wastes & Disposal of dusts collected as a result of emission control during materials handling, stabilization, or any other tertiary/post-treatment

During the conduct of the above activities, measures should be taken to prevent release of contaminated media to the natural environment. The following BMPs are generally recommended for the above activities:

7 Remedial plans should be checked to ensure that they account for the anticipated differences in characteristics of the treated soil. This may involve recombination of the treated soil with uncontaminated soil from the site (or off-site) in order to approximate the original soil characteristics prior to contamination. The anticipated soil characteristics of the treated soil should be verified prior to replacement.

7 Treated wastes should be checked for leachability prior to disposal in a landfill or other similar systems. Possibilities of long-term degradation and migration of contaminants to groundwater should be carefully evaluated and checked prior to disposal of stabilized/treated material.

7 Contaminated debris, soils, and liquid wastes resulting from excavation and installation of wells should be properly handled, either treated on-site or trucked away for off-site disposal. Berms should be built around the active excavation, storage and treatment areas, if necessary, to prevent migration of contaminated runoff away from the area.

7 If solid materials such as granulated carbon filters are used to collect emissions, they should be removed carefully from the emissions system to avoid rupturing them and dissipating the contaminated carbon materials.

They should be placed into tightly covered containers until they can be recycled or properly disposed of.

7 Carbon beds used for VOC removal from the extracted vapor should be properly managed and disposed of in compliance with Subtitle C regulations, and should meet all applicable land disposal standards. If the carbon is regenerated using steam or other means, the residual contaminated, liquids should be managed as hazardous wastes, and treated or disposed of in compliance with the applicable regulations.

7 Containers that hold residual liquids should be stored where they cannot be disturbed or ruptured by large equipment. This may require construction of a residuals management unit separate from the treatment and storage areas.

7 All dusts or other particulates that are collected during emissions control activities should be tested for contamination levels and handled and disposed of properly.

7 Air stripping or other treatment of extracted (contaminated) water/liquids should meet all applicable…