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


September 9, 1999
3:00 p.m.-4:00 p.m.

On Thursday, September 9, 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)
Sally Brown, University of Washington
Bill Duncan, Cominco Ltd. Trail Operations
Scott Fredericks, U.S. Environmental Protection Agency (EPA)
Andrew Green, International Lead Zinc Research Organization (ILZRO)

Also present was Christine Hartnett of Eastern Research Group, Inc. (ERG).


PRESUMPTIVE REMEDIES

Bill Berti welcomed participants to the conference call, stating that the call's purpose was to discuss whether the RTDF should promote biosolids as a presumptive remedy. He said that this topic came up during a previous conference call; at that time, it became clear that the Action Team needed to improve their understanding of what presumptive remedies are. Berti asked Scott Fredericks to provide an explanation.

Fredericks opened his discussion by acknowledging how much work goes into choosing a remedial approach for a site. Historically, remedial project managers (RPMs) have been required to use a lengthy selection criteria process to prove that their preferred remedy is appropriate for a given site. Such efforts, Fredericks said, can be costly and time-consuming. In an attempt to circumvent part of this process, Fredericks noted, EPA has identified some presumptive remedies that have been effective at numerous sites. RPMs who choose to use these presumptive remedies do not have to generate as much paperwork to justify their remedial selection. Instead, the RPM can simply point to the existing administrative record for the presumptive remedy and then launch straight into a focused Remedial Investigation.

Some people, Fredericks said, think that EPA is endorsing a technology as being the "best" when the Agency selects it as a presumptive remedy. He said that this is an erroneous perception that must be corrected. EPA does not choose the technologies based on a side-by-side comparison of test results. Rather, the technologies are identified by evaluating the historical patterns of remedy selection across sites. For some types of sites, Fredericks said, the same two or three technologies keep getting selected as remedial approaches over and over again. These popular technologies can become listed as presumptive remedies if they are supported by a large enough administrative record. Before a presumptive remedy is released, Fredericks said, it must pass through concurrence and legal reviews; the final version is compatible with the National Contingency Plan. Fredericks acknowledged that the presumptive remedy is supposed to be reviewed every 3 years to determine whether certain technologies should be replaced by others. This effort is not currently being conducted, however.

About 3 years ago, Fredericks said, EPA began putting together a presumptive remedy for metals in soil. The effort is reaching its final stages, he said, with a draft completed and distributed for concurrence review. Immobilization technologies and stabilization technologies have been selected as the presumptive remedies. Fredericks said that some EPA Offices expressed displeasure with the draft, because it did not specifically list soil washing or biosolids as presumptive remedies. The presumptive remedy may be written broadly enough, however, that use of biosolids can be considered an immobilization or stabilization technology and, therefore, part of the presumptive remedy. If so, Fredericks said, the Action Team will not have to think further about getting biosolids specifically mentioned in the presumptive remedy. Rather, they could focus their efforts on writing a Supplemental Bulletin that provides detailed information about biosolids and summarizes the work that has been performed using this technology. Fredericks said that these bulletins appear to be an effective educational tool for RPMs. For example, he said, RPMs responded enthusiastically when the Agency issued a Supplemental Bulletin for multi-phase extraction technologies. Berti asked conference call participants whether the Action Team would be able to identify enough case studies to create an informative bulletin. He said that he knew of seven sites (Palmerton, Pennsylvania; Chicago Fulton County, Illinois; Leadville, Colorado; Galena, Kansas; Jasper, Colorado; Trail, British Columbia, Canada; and Katowicte, Poland) that could be discussed in a Supplemental Bulletin for biolsolids. Sally Brown said that Colorado State's Ed Redente is conducting a project in Summitville, Colorado. In addition, she said, some of the work performed at Bunker Hill might be applicable. (Brown noted that biosolids have been included as part of the Record of Decision for this site.)

Fredericks acknowledged that the Action Team wants to promote the use of biosolids. He suggested contacting Andrea McLaughlin, an EPA representative who is working on the presumptive remedy, to determine whether biosolids could fit under the definition for immobilization or stabilization. In the meantime, Fredericks agreed to get a copy of the definitions and to forward these to Berti. Berti said that he will distribute these definitions to Action Team members.


ACTION ITEMS