SUMMARY OF THE REMEDIATION TECHNOLOGIES DEVELOPMENT FORUM
IN-PLACE INACTIVATION AND NATURAL ECOLOGICAL RESTORATION
TECHNOLOGIES SOIL-METALS ACTION TEAM
CONFERENCE CALL


August 17, 1999
3:00 p.m.-4:00 p.m.

On Tuesday, August 17, 1999, the following members of the Remediation Technologies Development Forum (RTDF)'s In-Place Inactivation and Natural Ecological Restoration Technologies (IINERT) Soil-Metals Action Team met in a conference call:

Bill Berti, DuPont Life Sciences (Action Team Co-Chair)
Beth Brown, U.S. Environmental Protection Agency (EPA)
Bill Duncan, Cominco Ltd. Trail Operations
Andrew Green, International Lead Zinc Research Organization (ILZRO)
Carl Ma, EPA
David Mosby, Missouri Department of Natural Resources

Also present was Sarah Dun of Eastern Research Group, Inc. (ERG).


PRESUMPTIVE REMEDIES DISCUSSION

Bill Berti began the conference call by reopening a discussion that began at the June 23, 1999, IINERT Action Team meeting. This discussion concerned the role that the RTDF should take in developing a presumptive remedy using biosolids. (Carl Ma noted that he is writing a brief summary of these discussions for inclusion in the meeting summary. He will forward this text to ERG shortly.) The first step in understanding RTDF's role is gaining an understanding of the presumptive remedy process. To that end, Berti identified the nine criteria, listed below, that a presumptive remedy must meet for acceptance. He noted that these nine criteria also mirror the IINERT Action Team's goals.

Reviewing these nine criteria prompted participants to discuss ARARs--what they are and how they are incorporated in a presumptive remedy. Elizabeth Brown and David Mosby explained that ARARs are federal, state, county, or local regulations that may apply to remedial activities at a site. ARARs are chemical-, location-, or activity-specific. Examples of chemical-specific ARARs include water-quality criteria or drinking-water standards. Regulations addressing activities in floodplains or wetlands are examples of location-specific ARARs. Examples of activity-specific ARARs include Occupational Safety and Health Administration (OSHA) regulations or solid-waste disposal regulations that govern how specific activities at a site can be conducted. Berti stated that ARARs are site-specific based on this definition, but a presumptive remedy is generic and used at hazardous waste sites nationwide. To address this apparent conflict, Mosby suggested that perhaps the four or five most commonly applied ARARs could be included in the presumptive remedy. Brown noted that ARARs are not specifically addressed in existing presumptive remedies, such as capping municipal solid waste landfills. She assumes that a presumptive remedy, such as a landfill cap, must be designed to meet site-specific ARARs.. Brown noted that she had sent Berti an e-mail listing the nine criteria and summarizing the feasibility study process. This e-mail is included as Attachment A.

Call participants also discussed their understanding of the term "presumptive remedy." Bill Duncan's understanding was that presumptive remedies are tools or options for remediation that can be selected at certain sites. Selecting a presumptive remedy for a site would shorten the regulatory process. Mosby thought that presumptive remedies serve as the default remedial action at a site; the IINERT Action Team's research under this definition, is better called an innovative technology than a presumptive remedy. Brown felt that presumptive remedies are selected when a preponderance of evidence indicates that a remedial action is the best means to address site contamination. For example, at municipal solid waste landfills, managers at many different sites followed the feasibility study process of examining many different remedial actions, but continually found that capping was the best option. Capping, therefore, was selected as a presumptive remedy to avoid the lengthy feasibility study process. Call participants agreed that Scott Fredericks of EPA should be consulted to clarify the term "presumptive remedy."

Call participants agreed that currently available information about the use of biosolids is insufficient to support a presumptive remedy. At this stage, the IINERT Action Team can best expend their efforts in identifying data gaps in research, conducting additional studies to address these data gaps, and preparing a fact sheet describing the technology. Conference call participants also agreed that the IINERT Action Team should help EPA (by providing background information and conducting research) to develop biosolids as a presumptive remedy, instead of developing the presumptive remedy themselves.

During discussions, call participants also suggested several IINERT Action Team goals. Andrew Green suggested that the team's short-term goals are to identify data gaps and develop a fact sheet about the biosolid technology. The long-term goals could include conducting research to fill data gaps and supporting a presumptive remedy. Call participants supported this approach. Berti listed several sites that may be sources of data: Palmerton, Pennsylvania; Chicago Fulton County, Illinois; Leadville, Colorado; Galena, Kansas; Jasper, Colorado; Trail, British Columbia, Canada; and Katowicte, Poland.

Brown thought the team should produce a fact sheet detailing how biosolids meet the nine criteria, since this would allow site managers to include a biosolid option in their feasibility studies. Green pointed out one outstanding question: what types of sites would be served by a biosolid presumptive remedy? Green suggested that developing a fact sheet may answer this question. Brown indicated that EPA's Engineering Bulletins could serve as an example fact sheet. Ma stated that he had several old copies of Engineering Bulletins and he would e-mail these examples to call participants. Green also mentioned that a comprehensive review is underway to examine the success and failure of different in situ remedial actions. The results of this review will be available to the team in 9 months and may serve as another source of information. Berti posed two questions that the team needs to answer while developing the fact sheet: What types of sites would use biosolids as a presumptive remedy? What kinds of solutions (remedial actions) are considered valuable? He also encouraged them to continue to discuss the group's ultimate goal--developing a fact sheet supporting biosolids as a presumptive remedy or developing a biosolid presumptive remedy.

At the end of the discussions, call participants agreed that they needed more information about presumptive remedies, both to further their general understanding and to better define the IINERT Action Team's goals. Berti stated that he would contact Fredericks to confirm his offer to participate in a conference call. Fredericks may be able to provide the information the IINERT Action Team needs. Berti will also ask Fredericks for the names of others who may be helpful and invite them to participate.


ACTIVITIES RELATED TO THE JOPLIN, MISSOURI, SITE

Mosby provided an update of activities at the Joplin, Missouri, site. He has been conducting a statistical analysis to compare changes in bioavailability between soil samples collected in May 1997 and samples collected in October 1998. Preliminary data indicate that apparent differences in bioavailability are not statistically significant over time. Berti asked if there are significant differences in bioavailability between different treatment sites. Mosby stated that the samples from the 1% treated plot showed a statistically significant reduction in bioavailability compared to the untreated (control) plot. Some reductions, but not any that were statistically significant, were recorded in the 0.5 percent phosphorus plot versus the control plot. The 1 percent phosphorus/1 percent iron plot had an increased bioavailability compared to the control plot. The greatest reduction in bioavailability (38 percent) was seen in the 1 percent phosphorus plot tested 18 months after treatment. Mosby will be summarizing results in a report to be completed in October or November 1999.

Mosby and Berti discussed the available data sets for conducting statistical analyses and comparisons. Mosby is now obtaining plant sampling data from September 1997. All the test plots were sampled for total metals in soil in May 1998. These data will be compared to the September 1997 and October 1998 data. Berti noted that each plot should have also been sampled in spring 1997 and 1998. Mosby will investigate if total metals data for plants and soil are available. Mosby indicated that there are current plans to collect another round of timed samples, approximately 2.5 years after treatment, and examine bioavailability.

Berti and Mosby agreed that a separate conference call should be scheduled to discuss the Joplin site. They planned to contact each other offline to schedule this call.


ACTIVITIES RELATED TO THE TRAIL, BRITISH COLUMBIA, CANADA, SITE

Bill Duncan provided an update of activities at the Trail, British Columbia, Canada, site. Currently, soil samples are being re-analyzed with a different buffering technique. Mosby asked if any plant samples had been collected to assess bioavailability and to check that the remedy is successful. Duncan stated that no plant samples have been collected, because the greatest concern at the site is human exposures and the goal is to remediate the site to human health standards. At this site, he said, the existing sod was removed, various chemical amendments were tilled in, and a layer of clean sod was placed down. This remedial approach is being investigated as an alternative to excavating contaminated soil and disposing of it off site. Duncan said that investigators are also experimenting with biosolids at this site to address ecological concerns. This work involves direct application, tilling, and revegetation efforts.


NEXT CONFERENCE CALL

A date for the next conference call was not established. Berti will contact group members to agree upon a date and time for the next call. Berti will try to schedule the call for the week of September 6, 1999.


ACTION ITEMS


ATTACHMENT A

FEASIBILITY FACT SHEET FROM BETH BROWN

The Feasibility Study Fact Sheet

The FS process consists of the development and screening of remedial action alternatives and a detailed analysis of a limited number of the most promising options to establish the basis for a remedy selection decision.

A range of viable alternatives should be developed that meet the response objectives. This range should reflect the NCP's expectations to address the principal threats posed by the site (i.e., liquids and highly toxic and/or highly mobile waste) through treatment, and consider engineering controls (e.g., containment) to address low-level contaminated material and wastes for which treatment is impracticable.

Development and Screening Activities

Develop General Response Actions

General response actions (e.g. no action, institutional controls, containment, treatment, removal/extraction, or disposal/discharge) are identified to satisfy the remedial action objectives. General response actions may be combined to form alternatives such as treatment of highly toxic material with containment of the treatment of residuals.

Identify and Screen Appropriate Technologies

For each General Response Action there are various remediation methods, or technologies, used to carry out the response action. The term technology refers to general categories of technology types, such as thermal treatment. Each technology may have several process options, which refer to the specific material, equipment, or method used to implement a technology. For example, under the technology category of in situ treatment of soils, there may be stabilization or phytoremediation. These technologies describe broad categories used in remedial action alternatives but do not address the details, such as performance data, associated with specific options.

Process options and entire technology types were eliminated from consideration if they were difficult to implement due to their compatibility with site characteristics, or if the technology had not proven to effectively control the COCs. These screening criteria were applied based on published information, experience with the technologies and process options, knowledge of site characteristics, and engineering judgment.

Select Representative Process Options

To simplify the development and evaluation of alternatives, one representative process option should be selected. Process options that survive the initial screening are reevaluated on the basis of effectiveness, implementability, and cost.

Assemble Technologies into Alternatives

General response actions should be combined to form a range of alternatives. For example, an alternative might call for incinerating the most highly contaminated soil from a portion of the site, while using biosolids on other less contaminated areas. When combining alternatives, it is necessary to consider interactions between groundwater and soils.

Screen Alternatives, If Required

Each alternative developed is evaluated to determine its overall effectiveness, implementability, and cost. These criteria for alternative evaluation are similar to that previously used to evaluate the process options. After each criterion is evaluated, remedial alternatives with the most favorable overall evaluations are retained to undergo detailed analysis.

Detailed Analysis Activities

Alternative Definition

The alternatives progressing from the development and screening phase of the FS will need to be better defined to adequately evaluate them during the detailed analysis. If available, additional site characterization and treatability study data should be utilized at this time..

Individual Analysis of Alternatives

Once the remedial action alternatives are sufficiently defined to allow for further evaluation, each alternative is assessed against nine evaluation criteria.

Threshold Criteria (each alternative must meet these criteria - unless and ARAR waiver is invoked)

Balancing Criteria (primary technical criteria upon which analysis is based)

Modifying Criteria (generally assessed after public comment)

Comparative Analysis

Once the alternatives have been fully described and individually assessed against the nine criteria, a comparative analysis should be conducted to evaluate the relative performance of the alternatives in relation to each specific evaluation criterion. The purpose of the comparative analysis is to identify the advantages and disadvantages of each alternative relative to one another so the tradeoffs that will have to be balanced to select a remedy are fully understood. The comparative analysis generally will focus on the differences between alternatives with respect to the primary balancing criteria since these factors play the major role in determining which options are cost-effective and which remedy utilizes permanent solutions and treatment to the maximum extent practicable.