&EPA
            United States
            Environmental Protection
            Agency
              Office of
              Research and Development
              Cincinnati, OH 45268
EPA/540/R-01/501
May 2002
EcoMat Inc.'s Biological
Denitrification Process
            Innovative Technology
            Evaluation Report
                   SUPERFUNO INNOVATIVE
                   TECHNOLOGY EVALUATION

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                                      EPA/540/R-01/501
                                         May 2002
     EcoMat Inc.'s Biological
     Denitrification Process

Innovative Technology Evaluation Report
           National Risk Management Research Laboratory
             Office of Research and Development
             U.S. Environmental Protection Agency
                Cincinnati, Ohio 45268

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                                      Notice
The information in this document has been funded by the U.S. Environmental Protection Agency
(EPA) under Contract Nos.  68-C5-0036 and 68-COO-179 to Science Applications  International
Corporation (SAIC).  It has been subjected to the Agency's peer and administrative reviews and has
been approved for publication as an EPA document. Mention of trade names or commercial products
does not constitute an endorsement or recommendation for use.

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                                     Foreword
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's land,
air, and  water resources.  Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the
ability of natural systems to support and nurture life. To meetthis mandate, EPA's research program
is  providing data and technical support for solving environmental  problems today and building a
science  knowledge base necessary to manage our ecological resources wisely, understand how
pollutants affect our health, and prevent or reduce environmental risks in the future.

The  National  Risk  Management  Research  Laboratory (NRMRL) is  the Agency's center for
investigation of technological and management approaches for preventing and reducing risks from
pollution that threatens human health and the environment. The focus of the Laboratory's research
program is on methods and theircost-effectiveness forprevention and control of pollution to air, land,
water, and subsurface resources; protection of water quality in public water systems; remediation of
contaminated sites, sediments and ground water; prevention and control of indoor air pollution; and
restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster
technologies that reduce the cost of compliance and to anticipate  emerging problems.  NRMRL's
research provides solutions to environmental problems by: developing and promoting technologies
that protect and improve the environment; advancing scientific and engineering information to support
regulatory and policy decisions; and providing the technical support and information transfer to ensure
implementation of environmental regulations and strategies at the national, state, and community
levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan. It
is  published and made available by  EPA's  Office of Research and  Development to assist the user
community and to link researchers with their clients.
                                            Hugh W. McKinnon, Director
                                            National Risk Management Research Laboratory

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                                      Abstract
This report summarizes the findings of an evaluation of a biodenitrification (BDN) system developed
by EcoMat Inc. of Hayward, California (EcoMat). This evaluation was conducted between May and
December of  1999  under  the U.S.  Environmental  Protection  Agency Superfund Innovative
Technology Evaluation (SITE) Program; it was conducted in cooperation with the Kansas Department
of Health and Environment (KDHE).  The demonstration site was the location of a former public water
supply well in Bendena, Kansas. The well water is contaminated with high levels of nitrate. Based on
historical data, nitrate concentrations in the water have ranged from  approximately 20 to 130 ppm,
well above the regulatory limit of 10 mg/l. Low concentrations of volatile organic compounds (VOCs),
particularly carbon tetrachloride (CCI4), have been a secondary problem. The overall goal of EcoMat
was to demonstrate the ability of its  process to reduce the levels of nitrate in the groundwater to an
acceptable concentration, thus restoring the water supply well as a drinking water source.

EcoMat's process is a two component process consisting of 1)an exs/fuanoxicbiofilterBDN system,
and 2) a post-treatment system.  The BDN system utilizes specific biocarriers and bacteria to treat
nitrate-contaminated water, and employs a patented reactorfor mixing the suspended biocarriers and
retaining biocarrier within the reactors to minimize solids carryover. Methanol is added to the system
as a carbon source for cell growth and for inducing metabolic processes that remove free oxygen
and encourages the bacteria to consume nitrate. EcoMat's post-treatment system can be subdivided
into two primary treatment parts: one part for oxidation and a second part for filtration.  The oxidation
treatment  is intended to oxidize residual nitrite back to nitrate, oxidize any residual methanol, and
destroy  bacterial matter exiting the BDN system. The oxidation treatment may consist of ozonation
or ultraviolet (UV) treatment, or a combination of both. Filtration usually consists of a clarifying tank
and one or more filters  designed to remove suspended solids generated from the BDN process.

The demonstration  consisted of four separate sampling events interspersed over a 7% month period
of time. During these events  EcoMat operated its system to flow between three and eight gallons per
minute.  During this same time period nitrate levels in the well water varied from greater than 70 mg/l
to approximately 30 mg/l.  For Event  1, chlorination was the only post-treatment used. Post-treatment
for Event 2 consisted of clarification; sand filtration; cartridge filtration using 20um rough filters; and
UV oxidation. Post-treatment for Event 3 consisted of ozone; UV oxidation;  clarification; cartridge
filtration using 20um rough filters, Sum high efficiency filters, carbon adsorption, and 1um polishing
filters. Post-treatment for Event 4 consisted of chlorination, clarification, Sum high efficiency filtration,
air stripping, and 1um polishing filtration.

The primary objective of the study focused on three performance estimates.  The first performance
estimate was  to determine if the  BDN portion of the process was capable of reducing combined
nitrate-N/nitrite-N (total-N) to less than 10.5 mg/l.  The  second performance estimate included
evaluation of  the post-treatment  for its ability to  produce treated groundwater that would meet
applicable drinking  water  standards with respect to nitrate-N, nitrite-N, and total-N, using a level of
significance of 0.10. This required reducing high levels of nitrate-N to less than  10.5 mg/l, maintaining
nitrite-N levels to less than 1.5 mg/l, and achieving  a total-N level of less than  10.5 mg/l.  When
rounded to whole numbers, these  performance estimates would meet the regulatory maximum
contaminant limits (MCLs) of 10, 1, and 10 mg/l for nitrate-N, nitrite-N, and total-N  respectively. The
                                            IV

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                                 Abstract (Cont'd)

third performance estimate involved evaluating the final effluents for other parameters, such as
turbidity, pH, residual methanol, suspended solids, and biological material.

Results for the final system outfall indicate that when the  post BDN effluent contains nitrite-N levels
in excess of the regulatory limit of 1 mg/l the EcoM at post-treatment components failed to adequately
and reliably reduce the nitrite-N levels to below the 1 mg/l level.  The post-treatment system was
varied  considerably throughout the demonstration.  For Event 1,  chlorination was the only post-
treatment used. Post-treatment for Event 2 consisted of clarification; sand filtration; cartridge filtration
using 20um rough filters; and UV oxidation. Post-treatment for Event 3 consisted  of ozone; UV
oxidation; clarification; cartridge filtration using 20um rough filters, Sum high efficiency filters, carbon
adsorption, and  1um polishing filters.  Post-treatment for  Event 4  consisted  of chlorination,
clarification, Sum high efficiency filtration, air stripping, and 1um polishing filtration. Comparison of
samples collected immediately upstream and immediately downstream of the post-treatment systems
indicated that none of the combinations used were  effective for removing residual methanol. In all
instances methanol levels were virtually the same or higher in final effluent exiting  the post-treatment
systems.

Since the post-treatment system implemented by EcoMat varied foreach of the four events, data from
the four events was first analyzed separately. Formal statistical analyses were used to address the
first two performance estimates discussed  above, using a significance level of  0.10.  The overall
conclusion from these tests was that:

•      Events 1 and 2 were found  to be successful in meeting the first two performance goals for
       significantly reducing levels of nitrate-N and nitrite-N after BDN and after post treatment.

•      Event 3 and 4 were not shown to be successful in significantly reducing levels of nitrate-N
       and nitrite-N after BDN and  after post treatment.

Daily dissolved oxygen (DO) field measurements indicated that the de-oxygenating step of EcoMat's
BDN process may not have been optimized throughout the demonstration, and especially during
Events 3 and  4. The  desired DO level of partially biodenitrified  (partial BDN) water  in the  De-
oxygenating Tank is <. 1 mg/l. However, DO values below 1 mg/l were measured only during the first
two events.

The effectiveness of the post-treatment systems were variable for different parameters. Comparison
of samples collected  immediately upstream and immediately downstream of the post-treatment
systems indicated that none of the combinations used were effective for removing residual methanol
to the demonstration objective of £ 1 mg/l. In all instances, downstream methanol levels were virtually
the same or higher than upstream methanol levels. Methanol concentrations averages in final effluent
were between 15 and 98 mg/l during the four events,  the first two events appear to have had a
substantial beneficial impact on solids carryover.   Residual bacterial content in the final effluent,
decreased significantly in Events 3 and 4, likely the  result of adding "high efficiency" (Sum)  and
"polishing" (1 urn) filters to the post-treatment system. Nevertheless, the levels of total heterotrophic
and facultative anaerobe bacterial matter measured in the final effluent for all events was well above
corresponding inlet water levels.

An economic analysis was also conducted for estimating the cost of implementing EcoMat's biological
denitrification technology  at full-scale.  For a 100 gpm system, the estimated cost to treat nitrate-
contaminated groundwater over a one year period is $490,000, or approximately $0.012/gal. The
cost over  5, 10,or 15 years is estimated  to increase to approximately$730,000 ($0.0034/gal.);
$1,000,000 ($0.0024/gal.) and $1,300,000 ($0.002/gal.),  respectively.

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                                     Contents
Notice	   ii
Foreword  	iii
Abstract  	  iv
Tables	  ix
Figures	  xi
Abbreviations and Acronyms 	xii
Acknowledgments  	xiv
Executive Summary	ES-1

1.0    Introduction	1
       1.1     Background 	1
       1.2     Brief Description of the SITE Program	2
       1.3     The SITE Demonstration Program and Reports  	2
       1.4     Purpose of the Innovative Technology Evaluation Report (ITER)	2
       1.5     Technology Description 	3
       1.6     Key Contacts  	4

2.0    Technology Applications Analysis	5
       2.1     Key Features of the BDN and Post-Treatment Processes	5
       2.2     Operability  of the Technology	6
       2.3     Applicable Wastes  	7
       2.4     Availability and Transportability of Equipment	7
       2.5     Materials Handling Requirements  	8
       2.6     Range of Suitable Site Characteristics	8
       2.7     Limitations  of the Technology	9
       2.8     ARARS for the EcoMat BDN Technology 	10
              2.8.1   Comprehensive  Environmental  Response,  Compensation, and
              Liability Act (CERCLA)	10
              2.8.2   Resource Conservation and Recovery Act (RCRA)	12
              2.8.3   Clean Air Act (CAA)	12
              2.8.4   Clean Water Act (CWA)  	12
              2.8.5   Safe Drinking Water Act (SDWA) 	13
              2.8.6   Occupational Safety and Health  Administration (OSHA)
                     Requirements 	13

3.0    Economic Analysis  	15
       3.1     Introduction	15
       3.2     Conclusions 	19
       3.3     Factors Affecting Estimated Cost	19
       3.4     Issues and  Assumptions 	19
                                          VI

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                                Contents (Cont'd)
               3.4.1   Site Characteristics	19
               3.4.2   Design and Performance Factors	19
               3.4.3   Financial Assumptions  	20
       3.5     Basis for Economic Analysis  	20
               3.5.1   Site Preparation	20
               3.5.2   Permitting and Regulatory Requirements 	21
               3.5.3   Capital Equipment	21
               3.5.4   Startup and Fixed Costs  	22
               3.5.5   Labor	22
               3.5.6   Consumables and Supplies	23
               3.5.7   Utilities	24
               3.5.8   Effluent Treatment and Disposal	25
               3.5.9   Residuals Shipping and Disposal  	25
               3.5.10  Analytical Services  	25
               3.5.11  Maintenance and Modifications	25
               3.5.12  Demobilization	26

4.0    Demonstration Results                                                         27
       4.1     Introduction	27
               4.1.1   Project Background	27
               4.1.2   Project Objectives	27
       4.2     Detailed Process Description	27
               4.2.1   BDN System  	28
               4.2.2   Post-Treatment System  	31
       4.3     Field Activities 	31
               4.3.1   Pre-Demonstration Activities	31
               4.3.2   Sample Collection and Analysis 	32
               4.3.3   Process Monitoring 	32
               4.3.4   Process Residuals  	32
       4.4     Performance and Data Evaluation	34
               4.4.1   Event 1   	34
               4.4.2   Event 2  	45
               4.4.3   Event 3  	54
               4.4.4   Event 4  	65
               4.4.5   Inter-Event Comparison  	74
               4.4.6   Data Quality Assurance  	76

5.0    Other Technology Requirements  	80
       5.1     Environmental Regulation Requirements	80
       5.2     Personnel Issues  	80
       5.3     Community Acceptance	80

6.0    Technology Status	81
                                           VII

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                             Contents (Cont'd)
       6.1    Previous Experience  	81
       6.2    Ability to Scale Up  	81

7.0    References 	82
Appendix A- Developer Claims and Discussion  	A-1
                                       VIM

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                               Tables
Table	Page
2-1
3-1
3-2
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
4-12
4-13
4-14
4-15
4-16
4-17
4-18
4-19
4-20
4-21
4-22
4-23
4-24
4-25
4-26
4-27
4-28
4-29
4-30
4-31
4-32
4-33
Federal and State ARARS for the EcoMat BDN Process 	
Cost Estimates for Initial Year of 1 00 GPM BDN System, Online 80% 	
Cost Estimates for EcoMat's BDN System for Multi-Year Treatment Scenarios . . .
Demonstration Objectives 	
Summary of Laboratory Analyses Conducted for the Demonstration 	
Summary of Field Measurements Conducted for the Demonstration 	
Event 1 - Summary Statistics 	
Event 1 - Nitrate-N and Nitrite-N Results 	
Event 1 - Summary of Treatment Effectiveness 	
Event 1 - Dissolved Oxygen Measurements 	
Event 1 - pH Measurements 	
Event 1 - Turbidity Measurements 	
Event 1 - TSS Results 	
Event 1 - Microbial Results (TCH, FA, and FC) 	
Event 1 - Methanol Results 	
Event 1 - Supplemental Analyses Results 	
Event 2 - Summary Statistics 	
Event 2 - Nitrate-N and Nitrite-N Results 	
Event 2 - Summary of Treatment Effectiveness 	
Event 2 - Dissolved Oxygen Measurements 	
Event 2 - pH Measurements 	
Event 2 - Turbidity Measurements 	
Event 2 - TSS Results 	
Event 2 - Microbial Results (TCH, FA, and FC) 	
Event 2 - Methanol Results 	
Event 2 - Supplemental Analyses Results 	
Event 3 - Summary Statistics 	
Event 3 - Nitrate-N and Nitrite-N Results 	
Event 3 - Summary of Treatment Effectiveness 	
Event 3 - Dissolved Oxygen Measurements 	
Event 3 - pH Measurements 	
Event 3 - Turbidity Measurements 	
Event 3 - TSS Results 	
Event 3 - Microbial Results (TCH, FA, and FC) 	
Event 3 - Methanol Results 	
Event 3 - Supplemental Analyses Results 	
... 11
	 16
... 17
... 29
	 33
33
... 36
... 37
... 38
... 39
... 39
... 40
	 41
... 42
... 43
43
... 46
... 47
... 48
... 49
... 49
... 50
	 50
... 51
... 52
53
... 55
... 56
... 58
... 59
... 59
... 60
	 60
... 61
... 62
... 63
                                  IX

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                                 Tables (Cont'd)
4-34   Event 4 - Summary Statistics  	66
4-35   Event 4 - Nitrate-N and Nitrite-N Results  	67
4-36   Event 4 - Summary of Treatment Effectiveness 	68
4-37   Event 4 - Dissolved Oxygen Measurements	69
4-38   Event 4 - pH Measurements  	69
4-39   Event 4 - Turbidity Measurements 	70
4-40   Event 4 - TSS Results	70
4-41   Event 4 - Microbial Results (TCH, FA, and FC) 	72
4-42   Event 4 - Methanol Results	73
4-43   Event 4 - Supplemental Analyses Results  	73

4-44   Inter-Event Comparison of Demonstration Criteria for Final Effluent  	76
4-45   Nitrate Matrix Spike Percent Recovery Summary	78
4-46   Nitrite Matrix Spike Percent Recovery Summary 	78
4-47   Nitrate MS/MSD Relative Percent Difference Summary	78
4-48   Nitrite MS/MSD Relative Percent Difference Summary  	78
4-49   Nitrate Field Duplicate  Summary	79
4-50   Nitrite Field Duplicate Summary 	79

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                                      Figures
Figure	Page

3-1     Cost Distributions - EcoMat Biodenitrification Multi-Year Treatment Scenarios	18
4-1     Flow Diagram Showing EcoMat's Treatment System and Sample Collection Points ... 28
4-2     Detailed Schematic of the EcoMat Denitrification Reactor	30

4-3     Event 1 - Treatment Effectiveness for Averaged Test Results  	35
4-4     Event 1 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N
       Concentrations  	44

4-5     Event 2 - Treatment Effectiveness for Averaged Test Results  	45
4-6     Event 2 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N
       Concentrations  	54

4-7     Event 3 - Treatment Effectiveness for Averaged Test Results  	55
4-8     Event 3 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N
       Concentrations  	64

4-9     Event 4 - Treatment Effectiveness for Averaged Test Results  	65
4-10   Event 4 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N
       Concentrations  	74

4-11   Inter-Event Comparison - Treatment Effectiveness for Nitrate-N/Nitrite-N  	75
                                           XI

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                       Abbreviations and Acronyms
AQCR
AQMD
ATTIC
ARARs
BDN
cm3
CAA
CCI4
CERI
CERCLA
CFR
CSCT
cfu
CWA
Dl
DO
EcoMat
EDA
FA
FC
FS
FID
ft2
gpm
GC/MS
G&A
g/cm3
HSWA
ICP
ITER
KDHE
kW/Hr
LDR
LOS
m3
MS/MSD
MCLs
MCLGs
MDL
MeOH
mg/l
Air Quality Control Regions
Air Quality Management District
Alternative Treatment Technology Information Center
Applicable or Relevant and Appropriate Requirements
Biodenitrification
Cubic centimeter
Clean Air Act
Carbon tetrachloride
Center for Environmental Research Information
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
Consortium for Site Characterization Technologies
Colony forming units
Clean Water Act
Deionized
Dissolved oxygen
EcoMat Inc. of Hayward, CA
Exploratory data analysis
Facultative anaerobes
Fecal coliform
Feasibility study
Flame lonization Detector
Square feet
Gallons per minute
Gas chromatography/mass spectroscopy
General and administrative
Gram per cubic centimeter
Hazardous and Solid Waste Amendments
Inductively coupled plasma spectroscopy
Innovative Technology Evaluation Report
Kansas Department of Health and Environment
Kilowatts per hour
Land disposal restriction
Level of significance
Cubic meter
Matrix spike/matrix spike duplicate
Maximum contaminant levels
Maximum contaminant level goals
Method detection limit
Methanol or methyl alcohol
Milligrams per liter
                                         XII

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                  Abbreviations and Acronyms (Cont'd)
MPN          Most probable number
NAAQS       National Ambient Air Quality Standards
NCR          National Oil and Hazardous Substances Pollution Contingency Plan
NIST          National Institutes of Standards and Technology
NOAA         National Oceanographic and Aeronautic Administration
NPDES       National Pollutant Discharge Elimination System
NPL          National Priorities List
NRMRL       National Risk Management Research Laboratory (EPA)
NSCEP       National Service Center for Environmental Publications
Nitrate-N      A measure of nitrate in which each mg/l of nitrate-N equates to 4.4 mg/l of nitrate
Nitrite-N       A measure of nitrite in which each mg/l of nitrite-N equates to 3.2 mg/l of nitrite
ND           N on-detectable, not detected, less than detection limit
NPDWS       National primary drinking water standards
NTU          Normal turbidity unit
OSHA         Occupational Safety and Health Administration
ORD          Office of Research and Development (EPA)
OSWER       Office of Solid Waste and Emergency Response (EPA)
OSC          On-scene coordinator
PLFA         Phospholipid fatty acids
POTW         Publicly owned treatment works
PPE          Personal protective equipment
POL          Practical quantitation limit
POA          Project Objective Agreement
PVC          Polyvinyl chloride
PWS          Public water supply
POTW         Publicly owned treatment works
QAPP         Quality assurance project plan
RPD          Relative percent difference
RI/FS         Remedial Investigation / Feasibility Study
RPM          Remedial project manager
RCRA         Resource Conservation and Recovery Act
SAIC          Science Applications International Corporation
SARA         Superfund Amendments and Reauthorization Act
SDWA         Safe Drinking Water Act
SOP          Standard operating  procedure
SW-846       Test methods for evaluating solid waste, physical/chemical methods
SWDA         Solid Waste Disposal Act
SITE          Superfund Innovative Technology Evaluation
S.U.          Standard units
TER          Technology Evaluation Report
TCH          Total culturable heterotrophs
TOC          Total organic carbon
TSCA         Toxic Substances Control Act
TSD          Treatment, storage, and disposal
THM          Trihalomethanes
ug/l           Micrograms per liter
UV           Ultraviolet
US EPA       United States Environmental Protection Agency
VOC          Volatile organic compound
WSR          Wilcoxon signed rank
                                         XIII

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                               Acknowledgments
This report was prepared under the direction of Dr. Ronald Lewis (retired) and Mr. Randy Parker, the
EPA Technical Project Managers for this SITE demonstration at the National  Risk Management
Research Laboratory (NRMRL) in Cincinnati, Ohio.  EPA NRMRL  peer review of this report was
conducted by Mr. Vicente  Gallardo.  Mr. Andrew Matuson  of Science Applications International
Corporation  (SAIC) served as the SITE  work assignment manager for the  implementation of
demonstration field activities and completion of all associated reports.

The demonstration required the combined services of  several individuals from EcoMat  Inc., the
Kansas Departmentof Health Services (KDHE), the town of Bendena, KS,and SAIC.  Peter Halland
Jerry Shapiro of EcoMat, Inc. served as logistical and technical con tacts for the developer. Rick Bean
of the KDHE was instrumental for making provisions for the treatment shed and associated utilities,
and for conducting additional sampling and analysis independent of the SITE Program. Iraj Pourmirza
of the KDHE Bureau of Water- Water Supply Section provided technical support regarding drinking
water issues. The  cooperation and efforts of these organizations and individuals  are gratefully
acknowledged.

This report was prepared by Joseph Tillman, Susan Blackburn, Craig Chomiak,  and John Nicklas,
of SAIC.  Mr. Nicklas also served as the SAIC QA coordinator for data review and validation. Joseph
Evans (the SAIC QA Manager), Dr. Herbert Skovronek, and James Rawe, all  of SAIC, internally
reviewed the report. Field sampling and data acquisition was conducted by William Carrier, Dan Patel,
Steve Stavrou, and Joseph Tillman.
Cover Photographs: Clockwise from top left are 1) "EcoLink" - synthetic polyurethane cubes, 1 cm on a side,
used as biocarrier medium; 2) Gas detector tube monitoring above overflow tank (dark tank in background is
the "EcoMat Reactor", also known as "R2"); 3) Concrete cap for 23 ft. ID Public Water Supply Well # 1 (vent
pipe  visible on right side of cap);   4) Post-BDN effluent discharging to overflow tank;  5) Overview  of
biodenitrification system - Overflow tank (front), 2 m3 EcoMat Reactor (center), and De-oxygenating Tank (far
right); 6) Portion of post-treatment system (clarifying tank at left); and 7) Shed for housing treatment system.
                                           XIV

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                                       Executive Summary
This re port summarizes the findings of an evaluation of the
EcoMat Biodenitrification (BDN) treatment process.  The
process was tested for treating ground water contaminated
with high levels of nitrate at the location of a former public
water supply well in Bendena, Kansas.  This evaluation
was conducted under the  U.S. Environmental Protection
Agency  (EPA)   Superfund   Innovative  Technology
Evaluation (SITE) Program.

It should be noted that BDN processes have been used for
some years for treatment of wastewater and groundwater.
However, the technology has been known in the past to be
applied to the treatment of groundwater for drinking water
purposes.   Thus, the SITE  Program's  interest was to
evaluate such an application.

Overview of Site Demonstration

The  EcoMat BDN  process  is  a type  of  fixed  film
bioremediation that uses specific biocarriers and bacteria
to treat nitrate-contaminated water.  Fixed film treatment
allows rapid and compact treatment of nitrate with minimal
byproducts. Unique to the EcoMat system is a patented
mixed reactor that retains the  biocarrier within the system,
thus minimizing solids carryover.  Methanol is added to the
system  as a source of carbon for cell growth and for
inducing metabolic processes  that remove free oxygen and
encourage the bacteria to consume nitrate. Methanol is
also important to  assure that the nitrate conversion results
in  the production of nitrogen  gas rather  than the
intermediate nitrite, which is considered to be more toxic.

EcoMat's BDN system was  evaluated under the  SITE
Program at the location of a former public water supply well
#1 (PWS) in Bendena, Kansas. The primary contaminant
in the well water was nitrate. Based  on  historical  data,
nitrate   concentrations  in   the  water  ranged  from
approximately 20 to 130 ppm, well above the regulatory
limit of 10 mg/l. Low concentrations of VOCs, particularly
carbon tetrachloride (CCI4), were a secondary problem.
The overall goal of EcoMat was to demonstrate the ability
of its process to reduce the levels of nitrate in the extracted
groundwater and restore the public water supply well as a
drinking water source.
The central goal of EcoMat was to demonstrate that its
system could produce groundwaterfrom PWS Well # 1 that
would be in compliance with the drinking water MCLs for
nitrate-N, nitrite-N, and total-N, while at  the same time
meeting  requirements  for  other  parameters  such  as
turbidity,  pH,  residual methanol, suspended solids,  and
biological material. With respect to both the BDN and post-
treatment components of the system, EcoMat proposed the
following three performance estimates:

       With incoming groundwater having nitrate-N of 20
       mg/l or greater, and operating  at a flow through
       rate of 3-15 gpm, the BDN  unit would reduce the
       combined nitrate-N and nitrite-N level (total-N) in
       PWS  Well #1  groundwater to at or below  a
       combined concentration of  10 mg/l.

       The post treatment or polishing unit would produce
       treated  groundwater meeting applicable drinking
       waterstandards with respect to nitrate-N (10 mg/l),
       nitrite-N (1 mg/l), and total-N (10 mg/l).

       Coupled with the planned or alternative post-
       treatment, the product water would consistently
       meet  drinking water requirements, except  for
       residual chlorine.  Specifically it would not contain
       turbidity of greater than 1 NTU, detectable levels
       of  methanol  (1  mg/l), or increased  levels of
       biological material or suspended solids, and would
       have a pH in the acceptable 6.5-8.5 range.

For the purposes of  these evaluations, demonstration
criteria were chosen  that, when rounded to the  nearest
whole number, they would be consistent with the  Kansas
Department of  Health  and Environment (KDHE) MCL
values. The KDHE MCL values for nitrate-N, nitrite-N, and
total-N were 10,1, and 10 mg/l, respectively. Thus, values
less than the nitrite-N demonstration criterion of 1.5 mg/l
(i.e., <_ 1.49 mg/l) would reduce to 1  mg/l. Values less than
the nitrate-N and total-N demonstration criterion  of 10.5
mg/l (i.e., <_ 10.49 mg/l) would reduce to 10 mg/l.
                                                   ES-1

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Conclusions from this SITE Demonstration

Since the post-treatment system implemented by EcoMat
varied foreach of the fourevents, data from thefourevents
were first analyzed separately. Formal statistical analyses
were used to address the first two performance estimates
previously discussed (i.e., total-N level less than 10 mg/l,
and nitrate-N and nitrite-N levels less than 10 mg/l and 1
mg/l, respectively), using a significance level of 0.10. The
overall conclusion from these tests was that:

•       Events 1 and  2 were determined  successful in
        meeting the  1st and  2nd performance  goals.
        Concentrations of total-N,  nitrate-N, and nitrite-N
        were  significantly  reduced   to  below  MCLs
        immediately following BDN treatment and after
        post treatment.

•       Event  3 and 4  were determined not successful in
        meeting the 1st and 2nd performance  goals for
        significantly  reducing levels of total-N,  nitrate-N,
        and  nitrite-N after BDN and after post treatment.

A number of additional  conclusions may be drawn from the
evaluation  of   the  EcoMat BDN and  post-treatment
processes as a whole, based on  extensive analytical data
supplemented  by field  measurements.  These include:

        The filtration systems incorporated following  the
        first event appear  to  have  had  a  substantial
        beneficial impact on solids carryover.  Based on
        laboratory and field  measurements, the  Sum high
        efficiency and 1 urn polishing filters used during the
        last  two  events produced  better results  for
        reduction of biological material, total suspended
        solids, and turbidity  in the final effluent.

        Specific to  turbidity,  which  has  a  secondary
        drinking water criterion of 1 Normal Turbidity Unit
        (NTU), average field measurement  results  for
        Events 3 and 4 final effluents were 1.2 and 0.96
        NTU, respectively.  These results were  improved
        in  comparison to the 1.8 NTU  average value for
        Event 2 final effluent, in which "sand filtration" and
        "rough  filtration" (20um) were used; and where
        greatly improved in comparison  to the 4.4 NTU
        average value for Event 1 final effluent, in which
        no filtration was used.

        Total suspended solids  (TSS) laboratory  results
        were similar to the  turbidity field  measurements.
        The demonstration criterion for TSS in finaleffluent
        was to be less than or equal to  that of the inlet
        water,  in which TSS  was consistently measured to
        be below the detection limit of 5  mg/l for  all four
events. TSS results for Event 1  were consistently
above this 5 mg/l threshold and averaged 10 mg/l.
During Events 2,  3, and 4  TSS was measured
above 5 mg/l in 3 of 9, 7of 9, and 7 of 8 of the final
effluentsamples collected,respectively.  However,
the average TSS value forthese events was below
the detection limit of 5 mg/l.

The demonstration criterion  for residual bacterial
content  in the final effluent  was also to be less
than or equal to that of the inlet water. The highest
bacterial counts in final effluent occurred for Event
2.  This  was likely due to  the  fact that  no
disinfection (i.e., chlorine, ozone, etc.)  was used
and that"rough"filtration (20  um)was the smallest
filtration  size used  during   Event  2.  Residual
bacterial content in the final effluent, decreased
significantly in Events 3 and 4, likely the result of
adding  "high efficiency"  (Sum) and "polishing"
(1um)  filters  to  the  post-treatment  system.
Nevertheless, the levels of total heterotrophic and
facultative anaerobe bacterial matter measured in
the final effluent for all  events was well above
corresponding inlet water levels.

None of the post treatment system combinations
used during the demonstration was effective in
removing residual methanol  to the demonstration
objective of £  1  mg/l.  Methanol  concentration
averages in final effluent were between  15 and 98
mg/l during thefourevents. Methanol was actually
measured on average to be higher in the final
effluent  samples  than  in  post  BDN  samples
(collected upstream of the post-treatment system)
for three of the four events.  This may  be  an
anomaly  attributable  to  ongoing   methanol
degradation in the post BDN  samples prior to
analysis.  The  final  effluent  samples   were
disinfected (preserved)so thatfurtherreaction was
halted.

There appears to  be  an   inverse correlation
between flow rate and nitrate removal (i.e., higher
flow  rate  correlating  to less  effective nitrate
removal),   based  on   a   per  sample  round
comparison of  system  flow  rate  and Total-N
concentration in finaleffluent. However, it was  not
possible to confirm that  this was a cause/effect
relationship because of (a)  the narrow range of
flows actually investigated and (b) variations in
performance that occurred or became necessary
due to upsets, and other  operational problems.
                                                   ES-2

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pH was not altered by the EcoMat BDN or post-
treatment systems. For Events 1 and 2 there was
a very slight increase in pH  from the inlet water to
the post BDN effluent. No discernable change in
pH between  inlet water and  final  effluent was
measured for Event 3.  For Event 4, the pH values
for inlet water ranged from 8.3 - 9.2 (outside of the
acceptable drinking water limits of 6.5-8.5). Final
effluent pH values were slightly lower and ranged
from  6.8 - 8.9.

Daily dissolved oxygen (DO) field measurements
indicated thatthe de-oxygenating step of Eco Mat's
BDN process may not have been optimized. The
desired DO level of partially biodenitrified (partial
BDN) water in the de-oxygenating tank is <_1 mg/l.
However, DO values below 1 mg/l were measured
only  during  the first two events.  Average  DO
during  Events 1  and  2 were 1.1 and  1.0 mg/l,
respectively.  DO in partial BDN  effluent during
Event 3 were consistently measured above 1 mg/l
and averaged 2.1 mg/l.  DO in partial BDN effluent
during  Event 4  was also consistently measured
above  1 mg/l and averaged 2.8 mg/l.  Because
Events 3 and 4 had poorer nitrate removal than
Event  1 and  2, the inability to optimize the de-
oxygenating  step of the BDN process during the
last two events could  have negatively  impacted
results.

The quality assurance analyses of critical sample
data indicated adequate data quality was achieved
for evaluating the  EcoMat  technology.   With
respect   to   data  accuracy,   the  overall
demonstration recovery average for 44 nitrate-N
MS/MSD sample  sets was approximately 95%.
The overall demonstration recovery average for44
nitrite-N MS/MSD sample sets was approximately
96%. With respect to data precision, the overall
demonstration average relevantpercentdifference
for those MS/MSD sets for nitrate-N and nitrite-N
were 2.7 and 2.1, respectively.

Carbon tetrachloride, which had been historically
detected in PWS Well #1  water, was not detected
in inlet water or final effluent samples. Thus, the
effectiveness   of   any   of  the  post-treatment
combinations for treating this compound could not
be evaluated.

For a 100 gpm system, the estimated cost to treat
nitrate-contaminated groundwater over a one year
period is $490,000, or approximately $0.012/gal.
The cost over 5,  10,or 15  years is estimated to
increase to approximately$730,000 ($0.0034/gal.);
$1,000,000   ($0.0024/gal.)   and  $1,300,000
($0.002/gal.),  respectively.
                                           ES-3

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                                              Section 1.0
                                             Introduction
This section provides background information  about the
Superfund  Innovative  Technology  Evaluation  (SITE)
Program,  discusses the  purpose  of this  Innovative
Technology  Evaluation  Report  (ITER),  and  describes
EcoMat Inc.'s Biological Denitrification (BDN) process. Key
contacts are listed at the end of this  section for inquiries
regarding additional  information about the SITE Program,
this technology, and  the demonstration  site.

1.1    Background
The EcoMat Inc. BDN process was demonstrated under
the Superfund Innovative Technology  Evaluation (SITE)
Program at a former public water supply  (PWS) well  in
Bendena,  Kansas.  The  demonstration  project,  which
occurred in cooperation  with the  Kansas Department  of
Health and Environment (KDHE), evaluated  an  ex situ
anoxic BDN technology developed  by EcoMat  Inc.  of
Hayward, California. The technology is a type of fixed-film
biofilter that   uses  specific  biocarriers  and naturally
occurring anoxic bacteria  to treat nitrate contaminated
water. During this demonstration the technology was part
of  an overall   system   that  included   four different
combinations of post-treatment systems. Each of the four
post-treatment systems included an oxidation component
to convert  residual  nitrite back  to nitrate.   A filtration
component was included in three of the fourpost-treatment
systems to remove suspended solids. Both the biological
denitrification process and post-treatmenttechnology were
evaluated during this demonstration.

The well of concern, the  Bendena Rural Water District #2
Public  Water Supply (PWS) Well #1, and surrounding
monitoring  wells have  been  the subject of numerous
groundwater investigations since 1985.  Historical data
from these investigations revealed elevated concentrations
of nitrate and carbon tetrachloride (CCI4). The data  show
that nitrate concentrations in the groundwater range from
approximately 20 to 130  ppm, which is well  above the
National Primary Drinking WaterStandards(NPDWS) limit
of 10 mg/l.  The historical data show  a  history of CCI4
concentrations between 2 ug/l and 31 ug/l  (the current
MCLforCCI4is 5 ug/l).

Numerous sampling investigations at PWS Well #1 have
been  unsuccessful in identifying the  specific source  of
contamination for both  nitrate and CCI4.  Since the land
surrounding  the  city is  primarily agricultural,  non-point
runoff of contaminated surface water from agricultural land
was considered as a possible contamination source for
nitrate. This explanation was not supported by the low
concentrations  of  ammonia  (<  0.8 mg/l)  found  in
groundwater samples. There was also reason to suspect
an industrial leak upgradient of the well as the source  of
nitrate, but this has not been confirmed.

The demonstration  project, which occurred between May
and December 1999, consisted of four separate sampling
events.  During these events, EcoMat operated its system
with a flow rate between approximately three and eight
gallons per minute.  During this time period, nitrate levels
in  the well water varied from greater than 70  mg/l  to
approximately 30 mg/l.

The overall goal of EcoMat was to demonstrate the ability
of its process to reduce the levels of nitrate in the extracted
groundwater and restore the public water supply well as a
drinking water source. Specifically, the Primary Objectives
for this SITE demonstration included the following:

       demonstrate, that with an incoming groundwater
       nitrate-N concentration of 20 mg/l or greater, and
       operating at a flow rate of 3 to 15 gpm, the BDN
       unit will reduce the combined nitrate-N and nitrite-
       N   (i.e.,   total-N)  level  in   the   PWS  Well
       #1groundwater to  less than 10.5 (which would
       reduce to less than orequal to the MCL of 10 mg/l
       when rounded to a whole number).
       demonstrate  that  the post-treatment  unit will
       produce  treated  groundwater  that will  meet
       applicable drinking water standards with respect to
       nitrate-N (i.e., to less than  10.5 mg/l), nitrite-N (i.e.,
       to less than 1.5  mg/l) and  combined nitrate-N and

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       nitrite-N (i.e., to less  than  10.5  mg/l).   These
       demonstration criteria would reduce to less than or
       equal to the MCLs  of 10, 1, and  10 mg/l when
       rounded to whole numbers).
and  remediation  at  Superfund  sites.    The  goal  of
technology  transfer activities  is to develop  interactive
communication  among  individuals requiring  up-to-date
technical information.
1.2    Brief Description of the SITE Program    1.3
The SITE Program is a formal program established by the
EPA's Office of Solid Waste and Emergency Response
(OSWER)and Office of Research and Development(ORD)
in  response   to   the  Superfund   Amendments  and
Reauthorization Act of 1986 (SARA).  The SITE Program
promotes the development, demonstration, and use of new
or innovative  technologies  to clean up Superfund sites
across the country.

The SITE Program's primary purpose is to maximize the
use of alternatives  in cleaning hazardous waste sites by
encouraging the development and demonstration of new,
innovative  treatment  and  monitoring technologies.  It
consists of three major elements:

       the Demonstration Program,

       the   Consortium   for   Site   Characterization
       Technologies (CSCT), and

       the Technology Transfer Program.

The objective  of the Demonstration Program is to develop
reliable  performance  and  cost  data   on  innovative
technologies  so that  potential  users can  assess  the
technology's  site-specific  applicability.    Technologies
evaluated are  either available commercially or close to
being available for full-scale remediation of Superfund
sites.  SITE demonstrations usually  are  conducted  at
hazardous  waste  sites  under conditions  that closely
simulate full-scale remediation conditions, thus assuring
the usefulness and reliability of the information collected.
Data collected are used to assess: (1) the performance of
the technology; (2) the potential  need for pre- and post-
treatment of wastes; (3) potential operating problems; and
(4)  the  approximate  costs.   The  demonstration  also
provides opportunities to evaluate the long term risks and
limitations of a technology.

Existing  and new technologies and test procedures that
improve field  monitoring and site  characterizations are
explored  in  the  CSCT  Program.   New monitoring
technologies,  or analytical  methods that  provide faster,
more  cost-effective contamination  and site assessment
data are supported by this program. The CSCT Program
also  formulates the  protocols  and standard operating
procedures for demonstration methods and equipment.
The Technology Transfer Program disseminates technical
information   on   innovative   technologies   in  the
Demonstration and CSCT  Programs through various
activities.  These  activities increase awareness  and
promote the use of innovative technologiesforassessment
       The SITE Demonstration Program and
       Reports
In the past technologies have been selected for the SITE
Demonstration  Program through  annual  requests  for
proposal (RFP). EPA reviewed proposals to determine the
technologies with  promise  for use at hazardous waste
sites. Several technologies  also entered the program from
current Superfund projects, in which innovative techniques
of broad interest were identified for evaluation under the
program.
Once the  EPA has  accepted a proposal, cooperative
arrangements are established among EPA, the developer,
and  the stakeholders.  Developers  are responsible for
operating their innovative systems at a selected site, and
are expected to pay the costs to transport equipment to the
site,   operate  the   equipment  on-site   during   the
demonstration, and remove the equipment from the site.
EPA is responsible  for project planning, sampling and
analysis, quality assurance  and quality control, preparing
reports, and disseminating information. Usually, results of
Demonstration  Programs   are   published  in   three
documents:  the  SITE  Demonstration   Bulletin,   the
Technology  Capsule, and  the  Innovative Technology
Evaluation Report (ITER).   The  Bulletin describes  the
technology and provides preliminary results of the field
demonstration. The Technology  Capsule provides more
detailed information aboutthe technology, and emphasizes
key  results of the SITE field demonstration.

The ITER provides detailed  information on the technology
investigated, a categorical cost estimate, and all pertinent
results of the  SITE  field demonstration.   An  additional
report, the  Technology Evaluation  Report  (TER),  is
available   by  request   only. The  TER  contains  a
comprehensive presentation of the data collected during
the   demonstration  and  provides  a  detailed  quality
assurance review of the data.
For  the EcoMat Inc. Biological   Denitrification process
demonstration,  there is a SITE  Technology Bulletin,
Capsule, and  ITER; all of which  are intended  for  use by
remedial managers for making a detailed evaluation of the
technology for a specific site and waste. A TER  is also
submitted for this demonstration  to serve as verification
documentation.
1.4    Purpose of the Innovative Technology
       Evaluation Report (ITER)
This  ITER provides information on both 1) EcoMat Inc.'s
Biological Denitrification process for treatment of nitrate in

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waterand on 2) the post-treatment system fortreatment of
organics (e.g., VOCs, methanol),  solids and  microbes in
water. This report includes a comprehensive description of
this demonstration and its results. The ITER is intended for
use by  EPA remedial project managers, EPA on-scene
coordinators  (OSCs), contractors, and  other decision-
makers  carrying out specific remedial actions. The ITER
is designed to aid decision-makers in evaluating specific
technologiesforfurtherconsideration as applicable options
in a particular cleanup operation.  This report represents a
critical step in the development and commercialization of a
treatment technology.
To  encourage  the  general  use   of  demonstrated
technologies, the EPA provides information regarding the
applicability of each  technology  to  specific sites  and
wastes.  The  ITER includes information on  cost  and
desirable site-specific characteristics.  It also discusses
advantages,  disadvantages,  and  limitations  of  the
technology.
Each SITE  demonstration evaluates the performance of a
technology in  treating  a specific waste  matrix.    The
characteristics of other wastes and other sites may differ
from the characteristics of the treated waste. Therefore, a
successful field demonstration of a technology at one site
does not necessarily ensure that it will be applicable  at
other sites. Data from the field demonstration may require
extrapolation for estimating the operating ranges in which
the technology will perform satisfactorily.   Only  limited
conclusions  can   be  drawn   from  a   single  field
demonstration.

1.5     Technology Description
Fixed film bioremediation using a biocarrier is the treatment
of contaminated groundwater using bacteria appropriate to
the contaminants of concern attached  to some form  of
supporting  substrate.  Using EcoMat's  patented  mixed
reactor,  the biocarrier is designed to be retained  in the
system, thereby minimizing solids carryover.  In the case
of the  Bendena water  well,  elevated  nitrate   in the
groundwater is the primary problem; low concentrations of
volatile organic compounds (VOCs) (particularly CCI4) are
a secondary problem.  Fixed film  treatment allows rapid
and compact treatment of nitrate with minimal  byproducts.
Methanol is added as a source of carbon forthe metabolic
processes and cell growth of the bacteria that convert the
nitrate to nitrogen gas.

The  mechanism for  anoxic biodegradation of  nitrate
consists of initial removal of excess oxygen followed by
two sequential  reactions  as shown in  the following
equations.
                                   Denitrification Step 1:
Oxygen Removal:
CH3OH + 1 .5O2
CH3OH
               3NO
                                                                              3NO  + CO
                                                                      2H2O
                                   Denitrification Step 2:
CH3OH
         2NO
                            N  + CO  + 2OKT
                                                                                                H2O
                                                  (2)
                                                                                    (3)
                                   Overall Denitrification Reaction:
5CH3OH
                6NO
                                                                              3N + 5CO + 6OKT
                                                                             7H2O  (4)
CO
                            2H2O
(1)
Note: The subsequent discussion refers to  nitrate- and
nitrite-nitrogen values (nitrate-N and nitrite-N, respectively),
in which each mg/l of nitrate-N is equivalent to 4.4 mg/l of
nitrate and each mg/l of nitrite-N is equivalent to 3.2 mg/l of
nitrite.
Available oxygen must first be consumed to  a dissolved
oxygen concentration of < 1 mg/l so that the  bacteria are
forced to substitute the  nitrate as the electron acceptor
(Equation 1 ). The nitrate is then reduced to nitrite (Equation
2). In Equation 3, the nitrite is further reduced to nitrogen
gas. The overall denitrification reaction is presented  in
Equation 4.
Nitrite production is an intermediate step and there is no a
priori reason to assume that the second reaction is at least
as fast and/or favored as the first reaction in the presence
of a specific  bacterial  population. Consequently, any
evaluation scheme must establish  that there is no buildup
of nitrite, particularly since the  nitrite-nitrogen MCL is 1
mg/l, one-tenth that of nitrate.   High  concentrations  of
nitrate and high nitrate/methanol ratios may also affect the
concentration of residual nitrite.
The  effluent from  the denitrification system  will  contain
small amounts of bacteria and suspended  solids which
must be removed  by a post-treatment system, and also
may contain some concentration  of nitrite.   EcoMat can
incorporate an  oxidation  component  (ozonation and/or
ultraviolet (UV) disinfection) into its post-treatment system
to  accomplish some degree  of chlorinated hydrocarbon
destruction as well as oxidation of remaining nitrite back to
nitrate, oxidation of any residual methanol, and destruction
of bacterial matter.  A filtration component can also be
incorporated into the post-treatment system to  remove
suspended solids. Although ozonation and UV oxidation
may also result in disinfection of treated water, additional
chlorination would also be required before the treated  water
could be used as  a drinking water  supply in Kansas.
Although this demonstration is being carried out on drinking
water, anoxic BDN using a biocarrier should be applicable
to  industrial  waste waters  as well as  leachate  from
commercial,  industrial,   and  hazardous  waste  sites
containing various levels of nitrate. The presence  of other
contaminants  could   play  a  significant  role  in the
effectiveness and viability of the overall treatment system.
The post treatment system components selected for the
Bendena site were intended to produce final  effluent that
met drinking water standards for nitrate and nitrite and  to

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also provide some removal of methanol.  If the planned
ozonation  system  proved to be  inadequate  for VOC
removal, EcoMat had planned to reactivate an inactive air
stripper at the site. With more complex waste waters, the
post-treatment system may play a larger role in the overall
effectiveness of the total system.
Design of the treatment process/system for a particular site
requires the characterization of the  contaminant types,
concentrations, and variability in the water source that will
become the feed to the system. This information  is used to
properly size the BDN unit and the post-treatment system.
For the Bendena site, it was also necessary to assure that
discharge of the treated water to a septic system did not
unintentionally recharge the aquifer in such a way as to
significantly  alter (decrease) the  nitrate  (or chlorinated
hydrocarbon) content of the aquifer feeding PWS Well#1.

1.6   Key Contacts
Additional information regarding EcoMat Inc.'s  Biological
Denitrification process,  the  company's  other  treatment
processes, and  the SITE Program  can be obtained from
the following sources:

Technology Developer
EcoMat Inc.
Peter Hall
26206 Industrial Blvd.
Hayward, CA 94545
Phone: (510) 783-5885
Fax: (510) 783-7932
e-mail: info@ecomatinc.com
www.ecomatinc.com
The SITE Program

Mr. Robert A. Olexsey
Director, Land Remediation and Pollution Control Division
National Risk Management Research Laboratory
U.S.  Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7861
FAX: 513-569-7620

Mr. Randy Parker
U.S.  EPA SITE Project Manager
National Risk Management Research Laboratory
U.S.  Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7271
e-mail: Parker.Randy(5).epa.qov

Information on the SITE Program is available through the
following on-line information clearinghouses:

•      The SITE Home page (www.epe.gov/ORD/SrTE)
       provides general  program  information, current
       project status, technology documents, and access
       to other remediation home pages.

•      The OSWER  CLU-ln electronic bulletin  board
       (http://WWW.clu-ln.org) contains information  on the
       status of SITE technology demonstrations. The
       system  operator can be reached at (301) 585-
       8368.

Technical   reports   may  be  obtained   by writing  to
USEPA/NSCEP, P.O. Box 42419, Cincinnati, OH 45242-
2419, or by calling 800-490-9198.

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                                             Section 2.0
                              Technology Applications Analysis
This section addresses  the general applicability  of the
EcoMat  Inc.  BDN  Technology  to  sites  containing
groundwater contaminated with nitrate.  The  analysis  is
based on results from and observations made during the
SITE   Program  demonstration  and   from  additional
information received from EcoMat Inc. SITE demonstration
results are presented in Section 4  of this  report. The
vendor had the opportunity to discuss  the applicability,
other studies  and performance  of the technology  in
Appendix A.

2.1    Key Features of the  BDN and Post-
       Treatment Processes
The EcoMat Inc. BDN Technology is designed to quickly
and  effectively  treat nitrate-contaminated  groundwater
while  generating minimal byproducts.  This system  is
appropriate for treating  potential drinking water supplies
and may also be effective in treating industrial wastewater
or leachate from commercial, industrial, and  hazardous
waste sites. The system may be most suitable for treating
water supplies  in agricultural  regions that are subject  to
increased nitrate concentrations due to seasonal fertilizer
application. The system can also treat inorganic pollutants,
other than nitrate, through cultivation of different types  of
microbes.

The  EcoMat  Inc.  BDN  Technology  is  a  fixed-film
bioremendiation process using a biocarrier and bacteria
appropriate to the contaminant of concern.  In the case  of
the Bendena water well, the contaminant of concern  is
nitrate.  EcoMat's  patented mixed  reactor retains the
biocarrier  in  the  system,  thereby  minimizing  solids
carryover. In addition, the fixed film treatment allows rapid
and compact treatment of nitrate with minimal byproducts.
Overall, the denitrification process is intended to convert
nitrates in the groundwater to nitrogen gas. In addition  to
demonstrating EcoMat's BDN Technology, the project also
included  demonstration  of a  post-treatment system
designed  to   destroy   or  remove   any  intermediate
compounds  potentially generated during  the  biological
breakdown of the nitrate (e.g., nitrite),  and also remove
small amounts of bacteria and suspended solids that are
not attached to the biocarrier. Treatment of VOCs present
in  the  influent can also be accomplished  by  the  post-
treatment  system by  incorporating traditional  treatment
methods, such as ozonation and air stripping.
The denitrification process is accomplished in two reactors.
Reactor 1 (R1), referred to as the "De-oxygenating Tank,"
includes bioballs loaded with denitrifying bacteria. These
bacteria are fed a 50 percent aqueous methanol solution to
act as a carbon source for the metabolic  processes that
remove free oxygen and to act as a carbon source for cell
growth. The second reactor (R2), which receives the de-
oxygenated water from Reactor 1, is packed with 1-cubic
centimeter (cm3) cubes  of a   synthetic  sponge-like
polyurethane biocarrier called  "EcoLink."  The Ecolink
medium  hosts  the colonies of   bacteria cultured  for
degrading nitrate. An important feature to this medium is
that small  contiguous  holes are  incorporated into the
medium to maximize surface area for the active bacteria
colony and to permit the exit of the nitrogen gas formed
during the denitrification process.

Reactor 2 also  includes a  specially  designed  mixing
apparatus to direct the  incoming de-oxygenated  water into
a circular motion, thus keeping the media in constant
circulation and maximizing contact between the water and
media. Methanol is also fed to this reactor to encourage
nitrate consumption and to act as a carbon source for the
anaerobic bacteria degrading the nitrate to  nitrogen gas.
The effluentfrom R2 received additional treatment, referred
to  here as  post-treatment.  During  the  course of the
demonstration,  four   different   combinations  of   post-
treatment  were incorporated into  the  overall  treatment
system.   Each of the  four systems utilized during the
demonstration  incorporated  one  or  more  oxidation
components, such as chlorination, ultraviolet (UV) light, or
ozonation.  In  addition  to destroying any  active bacteria
exiting the BDN system,  the oxidation component was

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designed to oxidize:  1) residual nitrite back to nitrate 2)
residual methanol, and 3) VOCs in the water (e.g., CCI4).

During  the  majority  of  the  demonstration,  the post-
treatment system  also incorporated a filtration component
designed to remove suspended solids generated from the
BDN process.  In addition to using a clarifying tank,  a
variety of filter combinations were used, including a sand
filter, a carbon filter, and different sized cartridge filters (i.e.,
rough, high efficiency, and polishing filters).
The developer believes that the denitrification technology
is capable of effectively converting nitrate and methanol to
nitrogen gas and carbon  dioxide.  This aspect  was of
primary interestforthis demonstration. The developeralso
claims  that the post-treatment or polishing step  can 1)
oxidize any  residual  nitrite to nitrate, 2) oxidize residual
methanol,  3) destroy bacterial matter exiting the EcoMat
reactor, and 4) remove suspended  solids.  No claim was
made concerning  the removal of VOC's.

2.2     Operability of the Technology
The prime factor  in  determining the effectiveness of the
EcoMat Inc. BDN Technology is the growth of a healthy
population   of    naturally-occurring   anoxic  bacteria
(denitrifiers) to reduce nitrate to nitrogen gas  and  carbon
dioxide in the presence of methanol.  The growth of these
denitrifiers is dependant upon a numberof factors including
nitrate-N concentration,  pH,  temperature, and  carbon
concentration. In addition,  continuous operation with
minimal process disruptions, includingshutdowns, is critical
to maintaining a healthy microbial population.  Overall, the
EcoMat technology  is  designed  to  provide optimum
conditions for growing and sustaining  an active bacteria
colony.
The EcoMat technology is an ex situ process consisting of
a BDN and a post-treatment system.  The BDN system
includes two reactors in series, followed by an overflow
tank. Each reactor is two cubic meters in size with a water
capacity of approximately 1,100 gallons. The first reactor
(R1), referred to as the "Deoxygenating Tank" is equipped
with ports  for both the tank's influent and  effluent, and a
methanol feed. The second reactor (R2), referred to as the
"EcoMat Reactor," is also equipped with  ports  for the
influent, effluent, and methanol feed. The final component
of the BDN  system  is a small overflow tank capable of
holding approximately 200 gallons.

Prior to system start-up, a shakedown period is required to
begin BDN by developing the necessary biological growth
on the "biocarrier" in the bioreactor chamber under full
recycle.    The   shakedown  period  normally   takes
approximately six weeks.  This 6-week period gives the
system operators an opportunity to adjust water flow and
methanol feed rates  based on observed nitrate and nitrite
concentrations and other factors.
Since each of the reactors maintains large populations of
sensitive microbes, continuous operation of the system is
critical. The growth of denitrifying bacteria on the biocarrier
in the Deoxygenating Tank is dependent upon achieving
both a relatively low dissolved oxygen concentration (e.g.,
~1 mg/l) and an environment rich in carbon. As a result,
methanol is routinely fed to the De-oxygenating Tankto act
as  the  source of carbon.  To  ensure that  a  healthy
population of denitrifiers is maintained, routine  monitoring
of the methanol concentration is performed.
The  Deoxygenating  Tank  requires little attention and
maintenance.  The groundwater simply enters the top of
the reactor, flows through  the bioballs and exits  the bottom
of the reactor.  Level  switches near the top of the tank
control flow into the tank; these do require routine service.

Continuous operation ofthe EcoMat Reactor is also critical.
Specialized bacteria for degrading nitrate are cultured in
this reactor. Since an anaerobic environment is necessary
to accomplish  denitrification, dissolved oxygen levels are
routinely monitored to ensure a concentration of less than
1.0  mg/l.

The EcoMat Reactoris equipped with a patented mixerthat
is designed to circulate the water within  the reactor without
the  aid  of moving parts.  This reactor contains  EcoLink
media which also are circulated by the mixing apparatus.
Like the  de-oxygenating  tank,  the EcoMat Reactor also
requires  minimal operational attention  and maintenance.
The most common maintenance activity would be periodic
replacement of the EcoLink biocarrier, which occasionally
becomes overloaded and  falls out of suspension.

Specific to the  demonstration, delivery ofthe  groundwater
to   the   treatment  system  was accomplished  by  a
submersible pump installed within PWS Well #1.  The
submersible pump was  originally controlled  by a  float
switch in Reactor #1. To prevent potential burn-out of the
submersible pump, the float switch was replaced first with
a pressure switch and finally with a "flapper." The  line
delivering the  groundwater to the treatment system was
equipped with  a totalizer to monitor flow rate.  Totalizers
were also installed at the treatment system discharge point
and on the recycle line for the SITE evaluation.

The  post-treatment  system  included different treatment
components during each ofthe four demonstration events.
The four post-treatment scenarios are presented  below.

Event 1  -       Chlorination

Event 2  -       Clarification,  Sand  &
               Rough (20um) Filtration,
               and UV Oxidation
EventS-       Ozone, UV Oxidation,
               Clarification,   Rough
               (20um) & High Efficiency

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               (5|jm) Filtration, Carbon
               Adsorption, &  Polishing
               (1 |jm) Filtration

Event 4 -       Chlorination,
               Clarificatio n,   High
               Efficiency  (5|jm  filter)
               Filtration, Air Stripping,
               and  Polishing  (20|jm)
               Filtration

Each component used in the post-treatment system was
purchased  "off the  shelf" from  equipment  suppliers.
Operation of the equipment was learned in the field during
the demonstration period and appropriate adjustments to
feed   and  flow  rates  were  made  to  maximize  the
effectiveness of treatment. General maintenance of the
post-treatment system during the demonstration included
flushing  out  the  entire  post-treatment system,  back
washing  of the sand filter, drainage of the clarifier, and
replacement of the cartridge filters.
Both the  BDN and post-treatment systems were installed
inside a storage building that was twelve feet wide, twenty
feet long, and twelve feet high.  The shed was equipped
with 1) electricity to operate pumps and provide heat, 2) a
potable water supply  for cleanup and decontamination
activities, and 3) a  telephone  and  facsimile  machine
hookup. The shed also provided sufficient work space and
room for  storage of equipment and reagents.

The  process,  including  both the  BDN  and  the  post-
treatment system, was designed to operate unattended;
however, during the four sampling events  seven system
shutdown periods   required the  presence of on-site
personnel to address the operational problems and bring
the system back online.  Shutdowns were  caused by a
combination of mechanical problems and electrical storms
causing  power outages.   Numerous shutdowns during
sampling Event 2 resulted in a decision to abort the event
and restart when mechanical problems were corrected. It
should be noted that additional shakedown  periods were
required  after some  of the  shutdowns to reestablish
microbial populations in the reactors.

2.3    Applicable Wastes
The EcoMat BDN technology is an  ex situ fixed- film BDN
system designed to destroy or remove nitrates in water. In
addition to  using the technology on a potential  drinking
water source during this demonstration,  the technology
should be  applicable  to  industrial  wastewaters  and
leachate from commercial, industrial, and hazardous waste
sites containing elevated nitrate concentrations.

During the  demonstration,  a  post-treatment  system
designed to remove chlorinated hydrocarbons from water
was also evaluated. The developer also claims  that the
technology is suitable for treating other types of inorganic
pollutants since the EcoMat reactor can effectively cultivate
microbes that can degrade different contaminants.

An EcoMat biological reactor is currently being used at a
Department  of Defense facility in Southern California to
treat perchlorate. Also, there are EcoMat systems installed
at aquariums for removing nitrate from saltwater.

2.4    Availability  and   Transportability  of
       Equipment
The EcoMat  Biological Denitrification and Post-Treatment
Process requires  a level pad, ideally concrete,  and a
heated building.  The size of the  pad and  building is
dependent on  the size  of the process  installed at a
particular site.  EcoMat has indicated that it is feasible to
install  a   treatment  system  outside, which may  be
necessary for very large systems.  In such instances, heat
tracing would be installed to provide temperature control.
At the  Bendena  site,  the  process  consisted  of  a
Deoxygenating  Tank, the EcoMat Reactor, an  overflow
tank,  and the  post-treatment  system  (ozone unit, UV
treatment, clarifier, sand filter, cartridge filters, air stripper,
and carbon filters).  This entire process (except for the
existing air stripper) and necessary support equipment fit
inside a shed that was twelve feet wide, twenty feet long,
and twelve feet  high. Since this system is designed to be
unattended,  a trailer or additional office space  in the
building housing the process should not be necessary.

Equipment and supplies associated with the process were
transported to the site by one truck. Each two cubic meter
(m3) reactor  tank  was delivered to the site in halves to
permit for easy handling and assembly. The remainder of
the  treatment units and  associated  equipment  can be
handled and  installed by one person.
Depending on well availability at sites  intending to use this
technology,  a drill rig with associated drilling  equipment
mightbe necessary. Fortunately, during this demonstration
a former railroad well constructed in the early  1900's
served  as  the source  for  the nitrate-contaminated
groundwater.  The total well depth  is 73.4  feet below
ground  surface  (bgs)  and  the  static  water  level is
approximately  45  bgs;   the  inside  well diameter is
approximately 23 feet.
During the demonstration  the  EcoMat BDN  and  Post-
Treatment systems required periodic maintenance of a
number of process units and replacement was necessary
for a number of units. Some of the equipment changes
necessary during system operation included new pressure
switches for  controlling tank levels, new PVC piping and
hoses  to rectify leaks, and new filters  to prevent filter
microbial buildup. All  replacement  equipment was either
purchased locally or delivered to the site via courier.

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Treated water from the system was discharged to a 1,000
gallon septic system specifically purchased and installed
for  the  demonstration.  Heavy equipment  such  as  a
backhoe may be required for septic system installation.
If the application for septic system installation had  been
denied due to reasons such as a percolation, slope, depth
to groundwater, etc., other discharge options would have
been investigated.  During this demonstration numerous
options were available including discharge to  1) a down
slope drainage network, 2) a return line back to the PWS
Well #1, or 3)  the ground up  gradient of PWS Well #1.
Ultimately, the intent of this system is to treat the water to
meet drinking water standards. Therefore, in an actual
installation treated water would be routed directly into the
distribution system  for  delivery to  customers in the
community. Therefore, the availability and transportability
of equipment related  to delivery of water into  a  specific
distribution system would need to be investigated.

2.5    Materials Handling Requirements
The major materials handling requirement for the EcoMat
BDN and Post-Treatment systems was installation of the
individual  process  units which  make-up  the  treatment
system. The KDHE  provided a shed and a pumped line
from PWS Well #1 to the shed.  The shed  included all
necessary services such as potable water, electricity, heat
and a  phone line.

The entire system was delivered to the site on one truck.
Installation of the system  required the support of one
person over a  period of approximately one  week.  All
process unitsand associated equipmentaresmall and light
enough to permit this one person to unload and install the
equipment.
Prior to beginning the demonstration, a variety of activities
were necessary to prepare the BDN and Post-Treatment
systems for  start-up,  including  a  shake  down of the
equipment.  The materials handling  requirements  for
bringing water from the well were minimal since a pumping
and groundwater delivery  system  had already  been
installed within  the PWS well.
The shakedown period  simply involved developing the
necessary biological  growth on  the  "biocarrier" in the
bioreactor chamber.  With the exception of more frequent
sampling and adjustments to water flow and methanol feed
rates, the activities performed during the shakedown period
were no  different from  those  that would  be  performed
during  routine   operation of the system under normal
conditions.

If the BDN and Post-Treatment systems are utilized to treat
groundwater, installation of one or more  wells  may be
necessary. Drilling services are generally subcontracted to
a company which has both  the required equipment (drill
rigs, augers, samplers) and personnel trained in drilling
operations  and  well  construction.   If work is  to  be
performed on a hazardous waste site, drilling personnel
must have the OSHA-required 40-hour health and safety
training.   Once  the  well(s)  are drilled  each must  be
equipped with a  pump to deliver the groundwater to the
treatment system. An equalization tank may be necessary
to store the feed water rather than pumping directly to the
system. All pumps chosen must be able to perform under
a variety of conditions.

Depending on the characteristics of the  source  water,
installation  of  a  pretreatment system may be required.
Parameters in the source water that may cause inhibition
of  the  BDN  system  include  pH,  dissolved  oxygen,
temperature, and heavy metals.

The  BDN  system does not generate any  hazardous
residuals;  however, extremely small quantities of non-
hazardous residuals are generated by various units in the
post-treatment system.   Sludge  is  generated  by the
clarifying tank and the cartridge filters periodically become
clogged and need to be flushed or  replaced. Residuals
generated during the demonstration  included spent filter
cartridges and biocarrier media; these were placed  in
plastic trash bags and discarded in an on-site  dumpster.

2.6    Range  of Suitable Site Characteristics
Locations suitable for on-site  treatment using the EcoMat
Denitrification and Post-Treatment System must be  able to
provide relatively  uninterrupted electrical  power  and
potable water for cleanup activities. Electrical  power was
required fora control panel equipped with high level  alarms
and reset buttons, and for operation of several electrically
driven  pumps  throughout  the system, including  a
submersible pump to draw water from the well.  Power was
also required  to provide heat  to the shed via an electrical
heater. Heat was necessary to maintain a minimum water
temperature of 60°F in the treatment system and to protect
equipment  and  personnel   during  cold  temperatures.
Overall, the  EcoMat  Biological  Denitrification  System
requires a 115-volt, 3-phase electrical service. During the
four  demonstration  sampling events the average  and
maximum  energy usage for the  overall system were 8.2
kW-hr and 12.6 kW-hr, respectively.

There  were  minimal  storage  space  requirements  for
process chemicals.  Process chemicals required  for the
demonstration included 50%  methanol aqueous solution
and a liquid chlorine solution.  The methanol solution was
stored in a 100-gallon plastic tank nearthe de-oxygenating
and EcoMat reactors.  The chlorine solution was stored in
a 5-gallon pail beside the post- treatment system. Any
reagents  required for system monitoring (e.g., Nitrate-N,
Nitrite-N, DO,  pH, etc.) were stored in small Styrofoam
shipping  containers on  shelving inside  the  shed.   All
process residuals (spent filters  and  biocarriers, clarifier

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sludge) were placed in plastic trash bags and stored in the
shed until final disposal as domestic trash.

2.7    Limitations of the Technology
The  EcoMat  BDN technology  is a  treatment  system
designed to remove excess nitrate and, with appropriate
post-treatment may also remove chlorinated hydrocarbons
(e.g., CCI4), methanol, and microorganisms. The maximum
removal of nitrates was achieved during the demonstration
when the flow through the system was in the 3.0 - 5.0 gpm
range.  At this flow rate it is obvious that the system would
not  be  appropriate  for  supplying   large  residential
communities with adequate supplies of treated water. The
system may be more applicable to reducing or eliminating
nitrate  in small  community  water  supplies,  in industrial
wastewaters, orin the leachate fromcommercial, industrial,
or hazardous waste sites.
The growth of healthy microbial populations within each of
the system's reactors is the key factor in determining the
effectiveness of the  technology.  The growth of these
organisms is dependant upon factors such as a sufficient
source of carbon,  a  continuous low dissolved  oxygen
concentration (< 1.0 mg/l), an acceptable steady  pH and
temperature  range, and intimate  contact between the
biocarrier  and  contaminated water.   Also, like  most
biological systems, the system can be inhibited by toxics
(e.g., heavy  metals) in the source water. Many of these
factors are dependent upon  a system that has minimal
operational/mechanical problems and system shutdowns.

During the course of  the  demonstration  project, the
EcoMat Biological Denitrification System, which is designed
to   operate   unattended,   had   numerous
operational/mechanical problems that required immediate
attention   from   on-site  demonstration  staff.   System
shutdowns occurred on approximately seven occasions;
two of which  occurred due  to electrical storms and five
occurring from system mechanical problems. A number of
other operational problems  occurred, impacting  effluent
quality but not causing system shutdown.
The   majority  of  operational/mechanical  problems
encountered  during the  demonstration were remedied
quickly; normally within  minutes to a couple hours of
learning of the  problem.   However, during  the  second
sampling  event,  a  faulty compressor switch  in  the de-
oxygenating   tank  caused  a chain-reaction of other
problems downstream of the tank, thereby forcing the
demonstration team to abort the event.

It should  be  noted that the  SITE team was  not  present
during periods between the four events to monitor system
perturbations  (if  they  occurred).  System   shutdowns
occurring  during  demonstration  events  that were not
caused by an electrical storm are summarized below:

       Just prior  to starting Event  2 (in  July 1999)
       compressor switches in the de-oxygenating tank
       failed to monitor the water level in the tank. This
       prevented   the  switch   from  controlling  the
       submersible pump delivering waterfrom the well to
       the system.  The malfunctioning  switches were
       replaced with a "flapper" to control  flow to the tank.
       This delayed the start of Event 2.

       Replacement of the compressor switch in the de-
       oxygenating tank required system shutdown and
       drainage of the tank.  This  maintenance activity
       caused  the biocarrier to settle  in the EcoMat
       reactor and clog the lower perforated screen used
       to separate the biocarrier mixing zone from the
       lower portion of the  reactor. EcoMat drained the
       water level in the tank to allow pressure washing
       of the screen. The draining disrupted the microbe
       colonies and further delayed the start of Event 2.
       Activation of the high level alarm occurred on four
       separate  occasions while no high levels were
       observed. The high level alarm shuts off the pump
       routing  water  to  the  EcoMat  reactor. The
       shutdowns occurred twice during the aborted
       Event 2 in early July 1999, and twice again during
       Event 3 in October 1999.
       Towards the end of Event 3,  a high level alarm
       was activated and the system was shut down due
       to excessive biological growth occurring on one of
       the post-treatment system filters. The filters were
       bypassed to complete the sampling event.
As stated earlier,  other problems encountered during the
demonstration  affected the concentrations of parameters
that are critical to treatment effectiveness and compliance
with federal drinking water standards. These problems are
summarized below.
       During Event4 EcoMat discovered airentering the
       de-oxygenating reactor via the reactor feed pump.
       This increased thedissolved oxygen concentration
       in  the  reactor  and   disrupted  the   anoxic
       environment inhabited by the denitrifiers. EcoMat
       switched pumps to mitigate the problem.

       An ozone leak was  found in  the post-treatment
       system at the start of Event 3. This leak reduced
       the system's ability  to oxidize residual nitrite to
       nitrate, oxidize residual methanol, and destroy
       bacteria. EcoMat replaced a  leaking hose soon
       after the leak was discovered via gas detector tube
       monitoring.

       The pump feeding methanol either malfunctioned
       or was inadvertently turned  off during Event 4.
       With no methanol being fed into the system, there
       was no carbon source for bacterial cell growth and
       nitrate consumption was reduced.

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       Significant solids carryover from the BDN system
       to the post-treatment system caused unexpected
       frequent maintenance  on the filters and clarifier.
       This occurred routinely during Event2, when filters
       were  first incorporated into  the  post-treatment
       system. Maintenance activities included replacing
       filters,  back  washing  filters,  and  draining  the
       clarifier. Also, large concentrations of heterotrophic
       bacteria and high turbidity readings in the system's
       final effluent  made  the water unacceptable for
       drinking purposes.

       High methanol concentrations (range: 14.6 - 98
       mg/l)  in the final effluent also made  this  water
       unacceptable for drinking purposes. These high
       methanol   concentrations   were   caused  by
       excessive feed rates, or by the failure of the post-
       treatment systems to oxidize residual methanol.


2.8    ARARS    for   the    EcoMat    BDN
       Technology

This subsection discusses specific  federal environmental
regulations pertinent to the operation  of the  EcoMat
Biological Denitrification  and Post-Treatment  processes
including  the transport, treatment, storage, and disposal of
wastes and treatment residuals. These  regulations  are
reviewed with respect to the demonstration results. State
and local  regulatory requirements, which may be more
stringent, must also be addressed by remedial managers.
Applicable  or  relevant  and  appropriate  requirements
(ARARs)  include the following: (1) the  Comprehensive
Environmental Response, Compensation, and Liability Act;
(2) the Resource Conservation and Recovery Act; (3) the
Clean Air Act; (4)  the  Clean  Water Act; (5) the Safe
Drinking Water Act, and (6) the Occupational Safety and
Health Administration  regulations. These six  general
ARARs are discussed below; specific ARARs that may be
applicable to  the  EcoMat  BDN  and  Post-Treatment
Process are identified in Table  2-1.

2.8.1   Comprehensive  Environmental Response,
       Compensation, and Liability Act (CERCLA)

The CERCLA  of 1980 as amended by  the  Superfund
Amendments  and Reauthorization Act (SARA) of 1986
provides  for federal funding to respond  to releases or
potential  releases of  any hazardous  substance  into the
environment,  as well as to  releases of pollutants  or
contaminants that may present an imminent or significant
danger to public health and welfare  or to the environment.
As part of the requirements of CERCLA, the EPA has
prepared  the  National  Oil  and Hazardous Substances
Pollution   Contingency   Plan    (NCP)  for hazardous
substance response. The NCP is codified in Title 40 Code
of Federal Regulations (CFR) Part 300, and delineates the
methods and criteria used  to determine the appropriate
extent  of removal and  cleanup for  hazardous waste
contamination.

SARA states a strong  statutory preference for remedies
that are  highly reliable and provide long-term protection.  It
directs EPA to do the following:

•       use  remedial alternatives that  permanently and
        significantly reduce the  volume, toxicity, or the
        mobility of hazardous substances, pollutants, or
        contaminants;

•       select remedial actions that protect human health
        and  the  environment,  are cost-effective,  and
        involve  permanent solutions  and  alternative
        treatment or resource recovery technologies to the
        maximum  extent possible; and

•       avoid off-site transport and disposal of untreated
        hazardous substances or contaminated materials
        when practicable  treatment technologies  exist
        [Section 121(b)].
In  general, two  types  of responses are possible under
CERCLA: removal and remedial  action.   Superfund
removal  actions  are  conducted  in   response  to an
immediate threat  caused by a  release of a hazardous
substance.  Many removals involve small quantities of
waste of immediate threat requiring quick action to alleviate
the hazard.  Remedial actions are governed by the SARA
amendments to   CERCLA.  As stated  above, these
amendments promote remedies that permanently reduce
the volume, toxicity, and mobility of hazardous substances
or pollutants.   The EcoMat BDN  and  post-treatment
systems are likely  to be part of a CERCLA remedial action
since the toxicity of the contaminants of concern is  reduced
by either denitrification or oxidation. Remedial actions are
governed by the SARA amendments to CERCLA. On-site
remedial actions  must comply  with federal and  more
stringent state ARARs. ARARs are determined on a site-
by-site basis and may be waived under six conditions: (1)
the action is an interim measure, and  the ARAR will be met
at completion; (2)  compliance with the ARAR would  pose
a  greater  risk  to health  and  the environment  than
noncompliance;  (3) it is technically impracticable to  meet
the ARAR; (4) the standard of performance  of an ARAR
can be met by an equivalent method; (5) a state ARAR has
not been consistently applied elsewhere;  and  (6) ARAR
compliance would not  provide  a balance between the
protection achieved ata particular site and demands on the
Superfund RPM for other  sites.  These waiver options
apply only  to  Superfund  actions  taken  on-site,  and
justification for the waiver must be clearly demonstrated.
                                                   10

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Table 2-1. Federal and State ARARs for the EcoMatBDN Process.
Process
Activity
Characteriza-
tion of
untreated
waste
Waste
Processing
Storage of
auxiliary
wastes
Determination
of cleanup
standards
Waste disposal
ARAR
RCRA: 40
CFR Part 261
(or state
equivalent)
RCRA: 40
CFR Part 264
(or state
equivalent)
CAA: 40 CFR
Part 50
(or state
equivalent)
RCRA: 40
CFR Part 264
Sub-part J
(or state
equivalent)
RCRA: 40
CFR Part 264
Subpart I
(or state
equivalent)
SARA:
Section
121(d)(2)(ii);
SDWA: 40
CFR Part 141
RCRA: 40
CFR Part 262
CWA: 40 CFR
Parts 403
and/or 122
and 125
Description
Standards that
apply to
identification and
characterization of
wastes.
Standards apply to
treatment of
wastes in a
treatment facility.
Regulations govern
toxic pollutants,
visible emissions
and particulate
matter.
Regulation governs
standards for tanks
at treatment
facilities.
Regulation covers
storage of waste
materials
generated.
Standards that
apply to surface &
groundwater
sources that may
be used as drinking
water.
Standards that
pertain to
generators of
hazardous waste.
Standards for
discharge of
wastewater to a
POTW or to a
navigable
waterway.
Basis
Chemical and physical properties of
waste determine its suitability for
treatment by the EcoMat BDN
Process.
Applicable or appropriate for the
EcoMat BDN Process.
During process operations, any off-
gases (i.e., from ozonation, air
stripping, etc.) must not exceed limits
set for the air district of operation.
Standards for monitoring and record
keeping apply.
Storage tanks for liquid wastes (e.g.,
decontamination waste) must be
placarded appropriately, have
secondary containment and be
inspected daily.
Potential hazardous wastes remaining
after treatment (i.e., spent biocarrier,
etc.) must be labeled as hazardous
waste and stored in containers in good
condition. Containers should be stored
in a designated storage area and
storage should not exceed 90 days
unless a storage permit is obtained.
Applicable and appropriate for the
EcoMat BDN Process used in projects
treating groundwater for use as
drinking water.
Waste generated by the EcoMat
process which may be hazardous is
limited to spent carbon, well purge
water, spent media or biocarriers,
clarification/filtration residual wastes,
and decontamination wastes.
Applicable and appropriate for well
purge water and decontamination
wastewater generated from process.
Response
Chemical and physical analyses
must be performed to determine
if waste is a hazardous waste.
When hazardous wastes are
treated, there are requirements
for operations, record keeping,
and contingency planning.
Off-gases may contain volatile
organic compounds or other
regulated substances; although,
levels are likely to be very low.
If storing non-RCRA wastes,
RCRA requirements may still be
relevant and appropriate.
Applicable for RCRA wastes;
relevant and appropriate for
non-RCRA wastes.
Remedial actions of surface and
groundwater are required to
meet MCLGs or MCLs
established under SDWA.
Generators must dispose of
wastes at facilities that are
permitted to handle the waste.
Generators must obtain an EPA
ID number prior to waste
disposal.
Discharge of wastewater to a
POTW must meet pre-treatment
standards; discharges to a
navigable waterway must be
permitted under NPDES.
                                                      11

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2.8.2   Resource  Conservation  and  Recovery Act
       (RCRA)

RCRA, an amendment to the Solid Waste Disposal Act
(SWDA),  is  the primary federal legislation  governing
hazardous waste activities.  It was passed  in 1976  to
address the problem  of  how to safely  dispose  of the
enormous volume of municipal and  industrial  solid waste
generated annually.   Subtitle  C  of RCRA  contains
requirements for generation, transport, treatment, storage,
and disposal of hazardous waste, most of which are also
applicable to CERCLA activities. The Hazardous and Solid
Waste Amendments (HSWA) of 1984 greatly expanded the
scope  and   requirements of RCRA.  RCRA  regulations
define  hazardous wastes  and  regulate  their transport,
treatment, storage, and disposal. These regulations are
only applicable to the EcoMat Biological Denitrification and
Post-Treatment processes if RCRA defined  hazardous
wastes are present.

Hazardous   wastes  that  may  be  present  include the
aqueous waste to be treated, spent media or biocarriers
from each   of the reactors, and  the residual  wastes
generated from any process included in the post-treatment
system, such as clarification and filtration. If  wastes are
determined to  be hazardous according to RCRA  (either
because  of  a  characteristic  or  a listing  carried by the
waste), essentially all RCRA requirements regarding the
management and disposal of this hazardous waste will
need to be addressed by the remedial managers. Wastes
defined as hazardous under RCRA include characteristic
and listed wastes.
Criteria for identifying characteristic hazardous wastes are
included in 40 CFR  Part 261 Subpart C.  Listed wastes
from specific  and nonspecific  industrial sources, off-
specification products, spill cleanups, and other industrial
sources are itemized  in 40 CFR Part 261   Subpart  D.
RCRA  regulations do  not apply to sites where  RCRA-
defined wastes are not present.
Unless they are  specifically delisted through delisting
procedures,  hazardous wastes listed in 40 CFR Part 261
Subpart D currently remain listed wastes regardless of the
treatment they may undergo and regardless  of the final
contamination levels in the resulting effluent streams and
residues. This implies that even after remediation, treated
wastes are still classified  as hazardous wastes because
the pre-treatment material was a listed waste.

For  generation  of any   hazardous  waste, the  site
responsible  party  must  obtain  an  EPA  identification
number.   Other applicable  RCRA requirements may
include a Uniform Hazardous Waste Manifest (if the waste
is transported off-site), restrictions on placing the waste in
land disposal units, time limits on accumulating waste, and
permits for storing the waste.

Requirements  for corrective action  at RCRA-regulated
facilities are provided in  40 CFR Part 264, Subpart F
(promulgated)  and  Subpart S.   These  subparts  also
generally  apply  to  remediation  at  Superfund  sites.
Subparts F and S include requirements for initiating and
conducting  RCRA  corrective   action,   remediating
groundwater, and ensuring that corrective actions comply
with  other  environmental regulations.   Subpart S  also
details  conditions   under  which   particular   RCRA
requirements may be waived for temporary treatment units
operating   at  corrective   action  sites   and   provides
information regarding requirements for modifying permits
to adequately describe the subject treatment unit.

2.8.3    Clean Air Act (CAA)

The  CAA  establishes national primary  and secondary
ambient air quality standards for sulfur oxides, particulate
matter, carbon  monoxide,  ozone, nitrogen dioxide, and
lead.  It also limits the emission of 189 listed hazardous
pollutants  such  as vinyl chloride, arsenic, asbestos and
benzene.  States are responsible for enforcing the CAA.
To assist in this, Air Quality Control Regions (AQCR) were
established. Allowable emission limits are determined by
the AQCR, or  its sub-unit, the Air Quality Management
District (AQMD).  These  emission limits are  based on
whether or not the region is currently within attainment for
National Ambient Air Quality Standards (NAAQS).
The CAA requires that treatment,  storage, and disposal
facilities comply with primary and secondary ambient air
quality standards. Emissions from  post-treatment systems
associated with  EcoMat's  Biological BDN may need  to
meet  current air quality standards.   For example, the
ozonation  system may be  regulated  by state  or local
agencies.   Also, State air quality  standards  may require
additional   measures  to  prevent emissions,  including
requirements to obtain permits  to install and  operate
processes (e.g., air strippers for control of VOCs).

2.8.4    Clean Water Act (CWA)

The objective of the Clean Water Act is to restore and
maintain the chemical, physical and biological integrity of
the nation's waters by establishing federal, state, and local
discharge  standards.  If treated water is discharged  to
surface water bodies or Publicly Owned Treatment Works
(POTW), CWA regulations will apply.  A facility desiring to
discharge water to a navigable waterway must apply for a
permit under the National Pollutant Discharge Elimination
System  (NPDES). When a NPDES permit is issued, it
includes waste  discharge requirements.   Discharges  to
POTWs also must  comply with  general pretreatment
regulations outlined in 40 CFR Part 403, as well as other
applicable state and local administrative and substantive
requirements.

The demonstration did have a variety of available options
for  disposal  of the water.   These  options  included
                                                    12

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discharge 1) to a 1 000 gallon septic system, 2) to a nearby
down gradient drainage network, 3) back down PWS Well
#, and 4) into the ground down gradient of PWS Well #1.
After careful review, option #1 was selected as  the most
viable.

Treated  effluent  from  the  SITE  demonstration  was
discharged to an on-site 1000 gallon septic system at a
rate of approximately 7,200 gallons per day. Permission
for septic system installation and discharge to the system
was  required by Doniphan County, KS.    The county
required  the   completion   of  a   Sewage   Facility
Application/Permit.  Approval for discharge to the septic
system was granted by the KDHE.
The  only listed option  that would have been  regulated
under the CWA and required a NPDES permit would have
been  discharge  to  a  nearby  down  gradient  drainage
network. It should be noted that depending on the levels
of contaminants and perm it limitations, additional treatment
may  be  required prior to discharge.

2.8.5    Safe Drinking  Water Act (SDWA)

The SOW A of 1974, as most recently amended by the Safe
Drinking Water Amendments of 1986, requires the EPA to
establish regulations   to  protect  human   health  from
contaminants in drinking water. The legislation authorized
national drinking water standards and a joint federal-state
system for ensuring compliance with these standards.

The National Primary Drinking Water Standards (NPDWS)
are found in 40 CFR Parts 141 through 149. Parts 144 and
145 discuss requirements associated with the underground
injection of contaminated water. If underground injection of
wastewater is selected as a disposal means, approval from
EPA or the delegated state for constructing and operating
a new underground injection well is required.

Since the actual intent of the EcoMat BDN  Process is to
render the water as drinkable (i.e., reducing nitrate-N and
nitrite-N to below their respective MCLs of 10 and 1 mg/l),
in most cases treated effluent would be discharged directly
into the commu nity water system. For example, the treated
effluent could be routed to 1) a water supply tank, 2) to an
existing  drinking  water  treatment  system,  or  3)  a
distribution system. If the final effluent of the system were
to be  used for  drinking purposes  while  providing no
additional treatment, the quality of the water would need to
meet NPDWS.

During  the demonstration elevated concentrations of both
heterotrophic bacteria and methanol were found in the
treated  effluent.  Heterotrophic  bacteria,  which  are
measured to determine how effective treatment  is at
controlling  microorganisms,  have  no  reported  health
effects.  40  CFR 141.72 of the NPDWS states that in lieu
of measuring the residual disinfectant concentration  in the
distribution system, heterotrophic bacteria, as measured by
the heterotrophic plate  count, may be  performed.   If
heterotrophic bacteria concentrations  are  found  above
500/100 ml in the distribution system, the minimum residual
disinfectant concentration is  not in compliance with the
NPDWS. There are no standards or health advisories for
methanol  in the NPDWS.   The agency delegated  for
enforcement of the NPDWS would need to  be notified  of
these elevated concentrations well before supplying this
water to customers.

The NPDWS also have turbidity standards which must be
met. A standard of 1.0 turbidity unit (NTU), as determined
by  a  monthly average  must  be  met.   During the
demonstration the calculated averages for three of the four
sampling events were above the 1.0 NTU limit.

2.8.6    Occupational Safety and Health Administration
        (OSHA) Requirements

CERCLA remedial actions and RCRA corrective actions
must  be  performed  in  accordance  with  the  OSHA
requirements detailed in 20 CFR Parts 1900 through 1926,
especially Part  1910.120, which provides for the health and
safety  of  workers at hazardous  waste  sites.  On-site
construction activities at Superfund or RCRA corrective
action sites must be  performed in  accordance with Part
1926  of  OSHA,  which  describes  safety  and  health
regulations  for construction  sites.     State   OSHA
requirements,  which  may be significantly  stricter than
federal standards, must also be met.

If working at a hazardous  waste site, all personnel involved
with  the construction  and operation of the EcoMat BDN
treatment  process  are  required to have completed an
OSHA training  course and must be familiar with all OSHA
requirements relevant to hazardous waste sites. Workers
on hazardous  waste sites  must also be enrolled in  a
medical monitoring  program.   The  elements  of any
acceptable program must include: (1) a health history, (2)
an initial exam before hazardous  waste work starts  to
establish fitness for duty and  as a medical baseline, (3)
periodic  examinations  (usually annual) to  determine
whetherchanges due  to exposure may have occurred and
to  ensure  continued fitness for the job,  (4) appropriate
medical  examinations  after  a  suspected  or  known
overexposure,  and (5) an examination at termination.

For most  sites, minimum PPE for workers will include
gloves, hard hats, steel-toe boots,  and Tyvek® coveralls.
Depending on  contaminant  types  and  concentrations,
additional  PPE may be required, including the use of air
purifying respirators or supplied air. Noise levels are not
expected to be high, except during well installation which
will involve the operation of drilling equipment.   During
these activities, noise levels should be monitored to ensure
that workers are not exposed to noise levels above a time-
weighted average of 85 decibels over an eight-hour day.
If noise  levels increase above this limit, then workers will
                                                    13

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be required to wear hearing protection. The levels of noise    community, but  this will depend  on proximity to the
anticipated are  not expected  to  adversely affect  the    treatment site.
                                                      14

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                                             Section 3.0
                                        Economic Analysis
3.1    Introduction

The purpose of this economic analysis is to estimate costs
(not  including  profits)  for  commercial  treatment  of
groundwater contaminated with elevated levels of nitrate
utilizing  the EcoMat BDN  Process.
The treatment system evaluated at Bendena was operated
in  an approximate range  of 3-8 gpm during  the SITE
demonstration.   This  pilot-scale  treatment system is
considered by EcoMat to have an extremely low capacity
for producing drinking water.  The full-scale systems  that
EcoMat  plans  to design,  own  and operate for drinking
water applications are  10  to 50 times the size of the pilot
unit used at Bendena. Therefore, this analysis will present
a cost estimate based on a 100 gpm system.
The  costs associated  with  implementing  the EcoMat
designed and operated process have been broken down
into 12 cost categories that reflect typical cleanup activities
at Superfund sites. They include:

        (1) Site  Preparation
        (2) Permitting  and Regulatory Activities
        (3) Capital Equipment
        (4) Start-up and Fixed
        (5) Labor
        (6) Consumables and Supplies
        (7) Utilities
        (8) Effluent Treatment and Disposal
        (9) Residuals Shipping, & Disposal
       (10) Analytical  Services
       (11) Maintenance and  Modifications
       (12) Demobilization

To reasonably estimate costs for the technology, some
basic assumptions have been made regarding the overall
size  of the reactors, treatment flow rate,  level  of nitrate
contamination, presence of othercontaminants (otherthan
nitrate), treatment duration, and the level of post-treatment
required to meet standard Safe  Drinking Water criteria for
general parameters.
The EcoMat BDN Process is ex-situ and is designed to
operate on a continual  pump and treat mode. Standard
sized tanks are used  as the reactors and holding tanks.
The only specialized  mechanical equipment used is the
patented mixing apparatus that is fitted into the standard-
sized reactor tank. EcoMat prefers to install and own their
treatment systems, and then service the systems with local
contractors.   EcoMat would then  bill monthly  for the
service.  However, this cost estimate assumes the site
owner  will purchase  the treatment  system and  pay for
setup, monitoring, and maintenance.
Table 3-1 presents a categorical breakdown of estimated
costs for the one year's treatment of groundwater, using a
100 gpm BDN system, atan assumed online factor of 80%
(42 million gallons treated annually). Table 3-2 projects the
first year cost estimates  to approximate costs for the same
100 gpm capacity and at the same assumed on-line factor
of 80% for multi-year treatment (e.g., 5,10, and 15 years).
Figure 3-1 graphically illustrates the  percentage of total
cost that each of the twelve cost components comprise, for
each treatment scenario.

As with all cost  estimates,  caveats  may be  applied to
specific cost values based on associated factors,  issues,
and assumptions.   The  major  factors  that  can affect
estimated costs are  discussed  in subsection 3.3. The
issues and  assumptions made regarding  the  specific
treatment system used for  this economic  analysis are
incorporated into the cost estimate.  They are discussed in
subsection 3.4.
The basis for costing each of the individual 12 categories
in Table 3.1 is discussed in detail in subsection 3.5. Much
of the  information presented in this subsection has been
derived from observations made and experiences gained
from the SITE demonstration that was conducted as four
separate  sampling   events   interspersed  over  an
approximate 7V2  month period at the location of a former
public water supply well in Bendena, Kansas.  Other cost
information  has   been   acquired  through  subsequent
discussions with EcoMat and by researching current
                                                    15

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Table 3-1. Cost Estimates for Initial Year of 100 GPM BDN System, Online 80%.
Cost Category
1 . Site Preparation
Treatment System Delivery
Heated Building Enclosure
Utility Connections
2. Permitting & Regulatory Activities
Permits
Studies and Reports
3. Capital Equipment
Biodenitrification/Post-Treatment Systems
In-line Nitrate Analyzer (two cells)
In-line Dissolved Oxygen Meter
Portable Water Quality Instrumentation
Pressure Washer
4. Startup & Fixed (10% of Capital Equipment)
5. Labor
System Design
Site Setup (EcoMat)
(Contractor)
Startup Testing (EcoMat)
Performance Monitoring/Maintenance
Remote Monitoring (EcoMat)
On-site Monitoring (Contractor)
6. Consumables and Supplies
Methanol (99% + grade)
EcoLink Biocarrier
Hypochlorite solution (for chlorination)
Post-Treatment Media
7. Utilities
8. Effluent Treatment & Disposal
9. Residuals Shipping & Disposal
10. Analytical Services
Nitrate-N/Nitrite-N in Water
Methanol in Water
Fecal Coliform
Trihalomethanes
Sample Shipments
11. Maintenance & Modifications
12. Demobilization
1 Cost value rou nded to two sign if leant digits.
2 Value increased to account for 10% QA sam pies.
Quantity

1
1
1




1
1
1
2
1


100
40
400
80
210
310

1,200
0.2
600
NA
175,000
NA
NA

27
27
27
27
54
1
NA
Units

Each
Each
Each




Each
Each
Each
Each
Each


Hours
Hours
Hours
Hours
Hours
Hours

Gallons
m3
Gallons
NA
kW-hr
NA
NA

Each
Each
Each
Each
Each
Year
NA
Unit Cost

$5,000
$60,000
$2,000




$250,000
$8,000
$2,000
$600
$2,800


$80
$80
$50
$80
$80
$50

$0.65
$6,000
$6.00
NA
$0.07
$0000.00
$0000.00

$15
$100
$15
$150
$30
$2,640
NA
Total Initial
$- 1s1 Yr.

$5,000
$60,000
$2,000

$10,000
$20,000

$250,000
$8,000
$2,000
$1,200
$2,800


$8,000
$3,200
$20,000
$6,400
$16,800
$15,500

$780
$1,200
$3,600
NA
$12,300
$0000.00
$0000.00

$405
$2,700
$405
$4,050
$1,620
$2,640
NA
Year Cost 1
$/Category
$67,000


$30,000


$264,000





$26,400
$69,900




$5,580




$12,300


$9,940





$2,640

$490,000
                                                         16

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 Table 3-2. Cost Estimates for EcoMat's BDN System for Multi-Year Treatment Scenarios.
Cost Category
1. Site Preparation
Treatment System Delivery
Heated Building Enclosure
Utility Connections
2. Permitting/Regulatory Activities
3. Capital Equipment
4. Startup & Fixed
5. Labor
System Design 2
Site Setup 2
Startup Testing 3
Pert Monitoring/Maintenance
6. Consumables & Supplies
Methanol
Hypochlorite Solution
EcoLink Biocarrier
Post-Treatment Media
7. Utilities (Electricity)
8. Effluent Treatment & Disposal
9. Residuals Shipping & Disposal
10. Analytical Services
Nitrate in water
Methanol in water
Fecal Coliform
Trihalomethanes
QA samples (10%)
Sample Shipments
11. Maintenance & Modifications
12. Demobilization
TOTAL COSTS 1
Initial Year
$67,000
$5,000
$60,000
$2,000
$30,000
$264,000
$26,400
$69,900
$8,000
$23,200
$6,400
$32,300
$5,580
$780
$3,600
$1,200
$000.00
$12,300
NA
NA
$9,940
$405
$2,700
$405
$4,050
$756
$1,620
$2,640
$000.000
$490,000
5 Years
$67,000
$5,000
$60,000
$2,000
$30,000
$264,000
$26,400
$225,000
$8,000
$23,200
$32,000
$162,000
$27,900
$3,900
$18,000
$6,000
$000.00
$61,500
NA
NA
$15,900
$645
$4,300
$705
$6,450
$1,210
$2,580
$13,200
$000,000
$730,000
10 Years
$67,000
$5,000
$60,000
$2,000
$30,000
$264,000
$26,400
$418,200
$8,000
$23,200
$64,000
$323,000
$55,800
$7,800
$36,000
$12,000
$000.00
$123,000
NA
NA
$23,500
$945
$6,300
$1,220
$9,450
$1,790
$3,780
$26,400
$000.000
$1,000,000
15 Years
$67,000
$5,000
$60,000
$2,000
$30,000
$264,000
$26,400
$612,200
$8,000
$23,200
$96,000
$485,000
$83,700
$11,700
$54,000
$18,000
$000.00
$184,500
NA
NA
$31,100
$1,250
$8,300
$1,670
$12,500
$2,370
$4,980
$39,600
$000,000
$1,300,000
1 Total costs have been rounded to two significant digits.
2 Designates a one time cost incurred for all scenarios.
3 Startup testing is assumed to be repeated once per year.
                                                              17

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IQ



I

CO
O
o
       1,500,000
       1,250,000
      1,000,000
ro

a
CD
3
5;


I
        750,000
        500,000
3

S-


CD


w
o
CD
        250,000
                                                           01
                                                                                                         Extended Treatment Scenarios

                                                                                                        •      D    •
                                                                                                        5-Yrs	10-Yrs    15-Yrs
                                                                                                          Not

                                                                                                        Applicable
                                                                                                                                      600,000
                                                                                                                                      450,000
                                                                                                                                      300,000
                                                                                                                                             0)
                                                                                                                                             a
                                                                                                                                      150,000
                                                                                                                                      75,000
                   Total Treatment
                                                            /    Permitting         Labor     \     Utilities

                                                         Site7       Etc       '              \
                                                      Preparation            Capital       Consumables
                                                                          Equipment       & Supplies
                                                                                                               Analytical
                                                                                                                                 Demobilization
                                                                                                      Effluent Treatment/

                                                                                                      Residuals Shipping

                                                                                                        & Disposal
Maintenance &
 Modifications
                                                                      Major Technology Cost Catagories

-------
estimates for specific cost items related to the technology.
Certain actual or potential costs were omitted because site-
specific engineering aspects beyond the scope of this SITE
Demonstration project would be required. Certain  other
functions were assumed  to  be  the obligation of the
responsible  parties  and/or site owners.  Although these
costs are also not included in the estimate, they are still
shown as line items  on Tables 3.1  and 3.2 to emphasize
that those costs need to be accounted for.

It should be emphasized that the cost figures provided  in
this section are "order-of-magnitude" estimates, generally
+ 50% 1-30%.

3.2    Conclusions
The  majority of the information for the costs (as well as
some actual costs) to treat groundwater using the EcoMat
BDN System at a flow rate of 100 gpm were provided by
EcoMat. These estimates, along with otherconclusions  of
the economic analysis, are presented below:

(1)    For a 100 gpm system, the  estimated cost to treat
       nitrate-contaminated groundwater over a one year
       period is $490,000, or approximately $0.012/gal.
       The cost over 5, 10,or 15  years is estimated  to
       increase to approximately $730,000 ($0.0034/gal.);
       $1,000,000   ($0.0024/gal.)  and   $1,300,000
       ($0.002/gal.), respectively.

(2)    The largest cost components for the one-year
       application of a 100 gpm EcoMat BDN system are
       capital equipment (54%),  labor  (14%),  and site
       preparation (14%); accounting for over 80% of the
       total cost.  As the treatment duration increases
       overtime, the impact of capital equipment and site
       preparation   diminish  considerably.   Shortly
       following five years of treatment, labor becomes
       the dominant cost component and the impact  of
       consumables  and   supplies   becomes   more
       significant.

(3)    The   cost   of   implementing    the    EcoMat
       Biodenitrification System may be less  or  more
       expensive than the estimate given in this economic
       analysis depending on several factors.   If water
       recovery wells are not already present at the site,
       their installation would be a significant added cost
       to the site owner, especially if the water source  is
       deep (these  costs are not directly associated with
       the EcoMat treatment process and thus  have not
       been included  in the  estimate). Other factors
       include,  but are  not  limited  to,  the nitrate
       concentration in the water  and  the presence  of
       other contaminants that would require increased
       post-treatment or pretreatment.
3.3     Factors Affecting Estimated Cost
There are a number of factors that could affect the cost of
treatment of nitrate-contaminated groundwater using an ex
situ bioremediation treatment technology.  An  important
factor for  initial  consideration  is  the  ability to supply
contaminated water at an  economically viable flow  rate
(which is dependent on aquifer characteristics).  Other
important factors include, but are not limited to, the  inlet
nitrate  concentration  (as  measured as  nitrate-N), the
presence of other contaminants in the inlet water, and the
level of pre-or post-treatment required.

The aquifer yield will affect the size and number of pumping
wells  required  to  attain  sufficient  flow  rate  to allow
treatment to be economically feasible. For aquifers that are
capable of yielding high flow rates, the numberof wells that
are required to be  installed and the depth at which  they
must be screened can significantly impact startup costs,
but this would affect any  system.

3.4     Issues and Assumptions
This  section   summarizes  the   major  issues   and
assumptions used to estimate the cost of implementing the
EcoMat BDN  Process  at full-scale.   In  general,  the
assumptions  are  based  on  information  provided  by
EcoMat and observations made during the demonstration.

3.4.1   Site Characteristics

The site characteristics used for this economic  analysis
are considered to be significantly differentfrom those found
at the  Bendena  site.  The Bendena demonstration  site
consisted of a former railroad well constructed in  the early
1900's.  Pre-demonstration pump testing of this well at just
20 gpm over a 5-day period depleted nearly 30 percent of
the well volume.  Thus, the aquifer recharge would not be
sufficient for adequately  supplying a 100 gpm treatment
system.   Also,  nitrate  levels  in  the  well  water were
measured  as high as 100 ppm.  Such levels of nitrate in a
well are uncommon and EcoMat has costed their treatment
system to be contingent on  an inlet nitrate level of 20 mg/l.
For the  purposes of this analysis, there are three major
assumptions  that  have  been  made  regarding  site
characteristics: 1) the  aquifer being treated is capable of
supplying groundwater to one or more wells at a rate equal
to or greater than 100 gpm for an extended time period; 2)
no additional wells are required, and 3) that nitrate-N levels
will be consistently above the regulatory  limit of 10 mg/l but
will not exceed 20 mg/l.

3.4.2    Design and Performance Factors

Design and performance factors would  include designing
the  properly-sized  treatment  system   and  process
parameters  to  adequately  treat  nitrate-contaminated
                                                    19

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groundwater  at  a rate of  100 gpm.  If  need  be,  a
groundwater  recovery  system  may  also  need  to  be
designed  and  would  include  locating  and  installing
groundwaterrecovery wells and theassociated pumps and
piping to route the inlet water to the treatment system. For
this cost estimate an assumption is made that sufficient
groundwaterrecovery wells and piping are already present
at the site.
The developer (EcoMat)designs the properly-sized system
anticipated fora particular site. Once designed the system
components  are  manufactured  or  purchased off-site,
usually from one or more vendors. The components are
then shipped  from the plant(s) to the site location, where
EcoMat assembles the system.
With respect to  the  pilot-scale  unit used  at  Bendena,
EcoMat has indicated that a 100 gpm  system  would be
scaled-up  in physical size by a factor of between two and
three times that of the pilot  unit.

3.4.3   Financial Assumptions
All costs are presented  in Year 2001  U.S. dollars without
accounting for interest rates, inflation, or the time value of
money.  Insurance and taxes are assumed to be fixed
costs lumped  into   "Startup  and  Fixed  Costs" (see
subsection 3.5.4). Any licensing fees passed  on  by the
developer, for using  the EcoMat  patented mixed reactor
and implementing technology-specific functions, would be
considered profit.  Therefore, those fees are not included
in the cost estimate.

3.5    Basis for  Economic Analysis
The  12 cost categories reflect typical clean-up activities
encountered at Superfund  sites.  In this section, each of
these activities will be defined and discussed. Combined,
these 12 cost categories form the basis for the detailed
estimated  costs presented in Tables 3-1  and 3-2.   The
labor costs that are continually repeated for each scenario
are grouped into two labor categories, one category for
developer  labor (i.e.,  EcoMat)  and  one  category  for
developer  contractor labor (see subsection 3.5.5).

3.5.1   Site Preparation
Site preparation forimplementing the EcoMat BDN system
technology can be subdivided into three distinct phases.
These include the initial design of the treatment (system
design), shipping  and assembly of the designed system
(site setup) and conducting  initial  shakedown/recycle
testing. The first two phases are one time occurrences. The
shakedown and recycle phase may have to be repeated if
the system stops operating for a substantial period of time
during the  treatment process.
All three of these phases are discussed in the following
subsections. However, the majority of the costs associated
with site preparation is labor (labor costs are presented in
subsection 3.5.5). Therefore, the only costs discussed in
this subsection are  non-labor costs associated with site
setup phase (see 3.5.1.2). The total non-labor cost of site
preparation for the beginning operation  of the system is
estimated to be approximately $67,000, which would be a
one time  cost.

3.5.1.1 System Design

System  design  consists of  obtaining the  anticipated
contaminant range from the prospective customer and then
selecting the proper sized system components necessary
for treating  that influent at a specified flow rate. EcoMat
does  not conduct treatability testing on  the water matrix
(i.e., influent); however, they do have  small reactors that
could be used for such a purpose. Generally speaking, the
system design does not include the means forpumpingthe
water matrix from its source  to the BDN system.

EcoMat has indicated thatthe design of a 100 gpm system
would not radically change from the design of the pilot unit
used at Bendena, however the scale-up factor would be
between  two and three. Therefore the deoxygenating tank
(R1) would have an approximate capacity of 2,600 gallons
and the EcoMat Reactor (R2) would be on the order of 5
cubic meters (the R2 unit at Bendena was 2 cubic meters).
The cost  of system design has been estimated by EcoMat
to correlate to approximately 100 hours (see  subsection
3.5.5 - Labor).

3.5.1.2 Site  Setup

The second  phase of site preparation is site setup. This
phase includes shipping the treatment system components
from one or  more of EcoMat's suppliers to the site.  The
costs of  shipping will vary  depending  on  location  and
distance  the site is from the supplier(s). EcoMat roughly
estimates shipping costs at  2% of the treatment system
capital cost.  For a  100 gpm  treatment unit, this would be
approximately $5,000 (see  subsection  3.5.3 for capital
costs).

Once at the  site the entire treatment  system  is normally
housed in a shed or building that provides security and
temperature control. Therefore, if an appropriate existing
structure does  not exist at  the  site,  one  has  to  be
assembled or built. EcoMat has estimated  that a building
twice the size of the Bendena shed would  be  required to
accommodate a 100 gpm system.  It is feasible to install a
system outside, which may be necessary for even larger
systems. In such instances, heattracing would  be installed
to provide temperature control where needed.
At the Bendena site, the KDHE provided for the 20 ft. x 15
ft.  building  and all  associated  utility  hookups  at  an
approximate cost of $40,000 (which included construction
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labor costs). The cost of a structure about twice that size
(i.e., 40  ft.  x  30 ft.),  not  including  utility  hookups, is
estimated at approximately $60,000.

At the Bendena site, electrical hookups, communications,
and water supply were also provided  by the KDHE and
incorporated into the total  cost  estimate for the  shed.
Electrical power is required for operating pumps, control
panels, etc. for the system;  lighting, etc. A water hookup
is needed for power washing equipment components (e.g.,
filters, etc.). For this cost  estimate, utility hookups  are
estimated to be a one time charge of $2,000.
It is assumed that the site used for this cost estimate is
secured and cannot be easily vandalized. The treatment
system itself would, in  most cases, be installed within a
secured  building, as previously discussed. If security
became  an  issue with  a  larger outdoor system,  then a
fence would need to be erected. Assuming  no costs  for
security, the total site setup costs for initiating the activities
are estimated  to total approximately $67,000. This cost
value represents the total non-labor cost estimated for the
Site Preparation category.

3.5.1.3 Shakedown  and Recycle

Once the full treatment system has been assembled, there
is  a period  of  time necessary to  acclimate the microbial
colony to the  biocarrier(s), and the  inlet water,  make
adjustments to methanol feed rates, and check operation
of system components. Once this steady-state is reached
the system  can continually operate effectively as long as
there are no significant shutdowns.
The overwhelming majority of the cost associated with the
shakedown  and  recycle  process  is  labor, which  is
discussed in subsection 3.5.5. The cost of consumables
specifically  associated  with conducting shakedown and
recycle activities are negligible with respect to total annual
consumables  (consumable  costs  are  discussed  in
subsection 3.5.6).

3.5.2   Permitting and Regulatory  Requirements

Several types of permits may be required for implementing
a full-scale remediation. The types of permits required will
be  dependent  on the type  and concentration  of  the
contamination,  the   regulations  covering the  specific
location,   and   the   site's  proximity   to   residential
neighborhoods.
At the Bendena site, treated water was discharged to a 300
foot  long, 1,000  gallon capacity lateral  septic system
purchased and installed for the demonstration. The KDHE
acquired  the necessary permits for discharging the treated
water to the septic system located in an adjacent field in
this manner. Although, ozone treatment and an air stripper
were used during portions of the demonstration, a permit
was not required.
The non-analytical costs incurred for ultimately receiving
approval from the regulatory agency to install the treatment
system are included under the Permitting and Regulatory
Activities  category.   These  costs  would  include  the
preparation of site characterization reports that establish a
baseline for the site contamination, the design feasibility
study for  the  pilot system,  potential meetings  with
regulators for discussing comments and supplying other
related documentation,  and for acquiring approval for
installing and implementing the treatment.
Based on past experience, permitting feesforimplementing
the full-scale treatment system are assumed  to be about
$10,000. It should be noted that actual permitting fees are
usually waived for government-conducted research type
projects (e.g., SITE Demonstrations).
Depending upon the classification of the site, certain RCRA
requirements may  have to  be satisfied  as well.  If the site
is  an  active  Superfund  site,  it is  possible  that  the
technology could be  implemented under the  umbrella of
existing permits and plans held by the site owner or other
responsible party.  Certain regions or  states have more
rigorous environmental policies  that may result in higher
costs for permits and verification of treatment performance.
Added  costs may result  from  investigating  all  of  the
regulations and policies for the location of the site, and for
conducting  a historical   background   check  for  fully
understanding the scope  of  the  contamination.   From
previous  experiences,  the associated cost with  these
studies and reports is estimated  to be $20,000.

The  total  cost of all necessary permitting and  other
regulatory requirements is estimated to  be approximately
$30,000.

3.5.3   Capital Equipment

Most of the capital equipment cost data directly associated
with  the  BDN and post-treatment  system  have  been
supplied by EcoMat. Specific capital equipment associated
with their system includes high density polyethylene tanks,
high  capacity pumps,  electronic control  systems,  a
patented  mixing  apparatus,  system piping  and valves,
rotometers, and various off-the-shelf post-treatment units.
Some of the monitoring equipment costs are based on the
SITE Program's experience during the demonstration  and
from other  similar products.   It is  assumed  that  all
equipment parts   will be  a one time  purchase and will
have no salvage value at the end of the project.

EcoMat has  provided an  approximate lump sum  cost
estimate  of $250,000 for a 100 gpm  treatment system
capable of treating a water matrix having nitrate levels of
20 mg/l.  This value does not include the installation of
groundwater wells,   groundwater pumps,  or  piping
installation  required to supply inlet water to the treatment
system  (at  the Bendena  site the groundwater  supply
delivery system consisted  of a single submersible pump
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that supplied  the BDN system with groundwater at flow
rates varying between 3 and 8 gpm). The $250,000 value
also does not include costs for disassembly, shipping and
reclaiming system components.

In addition to the main components of the EcoMat BDN and
post-  treatment systems,  in-line monitoring equipment
would be an additional capital cost. The most important
monitoring instrumentation required for a full-scale system
would be an in-line nitrateanalyzerequipped with two cells;
one for monitoring inlet water nitrate levels  and one for
monitoring either post BDN or final effluent nitrate levels.
The estimated cost for a direct read  nitrate analyzer is
$8,000.
Dissolved  oxygen  is another important  parameter that
requires  close monitoring,  as  evidenced  during  the
demonstration.  Since the time  of the  demonstration,
EcoMat has incorporated a dissolved oxygen monitoring
unit into theirsystem to immediately identify irregularities in
DO. A microprocessor-based DO meter  installed within the
BDN system is estimated to cost $2,000. Other portable
instrumentation required formonitoring parameters such as
pH, temperature, and turbidity are estimated to collectively
cost about  $1,200.

Although an industrial pressure washer could be rented on
an as-need-basis,  it will be  assumed  that  a  dedicated
pressure washer would be purchased  for EcoMat's full-
scale  unit. This would allow for quicker response to any
periodic clogging  of filters and reactor  screens (which
occurred during the demonstration) and the cost would be
relatively minor with respect to the cost of the treatment
system itself or renting the equipment over several years.
A combination steam cleaner/pressure washer is estimated
to cost roughly $2,800.
The total cost of all of the necessary capital equipment for
a  full-scale  100  gpm  system  is  estimated to  be
approximately $264,000.

3.5.4   Startup and Fixed Costs

From  past experience, the fixed costs  for this economic
analysis are assumed to include only insurance and taxes.
They  are  estimated as  10 percent of the  total capital
equipment, or $26,400.

3.5.5   Labor

Included in this subsection are the core labor costs that are
directly associated with the EcoMat BDN  System. These
costs  comprise the bulk of the labor required for the full
implementation of the technology. It is assumed for this
cost  analysis that the  treatment system  will be fully
automated  and will operate  continuously without  major
interruption at the  designed  flow rate.  Non-core  labor
costs, associated with periodic system  adjustments (i.e.,
chemical adjustments), regulatory sampling requirements,
maintenance activities, and site restoration, are discussed
in subsections 3.5.10,  3.5.11 and 3.5.12, respectively.

For the purchased EcoMat treatment system, assembly is
a  labor  intensive  operation consisting of  unloading
equipment  from  trucks  and trailers,  as well  as actual
assembly.  EcoMat will have    significant  hands-on
involvement during the site setup phase of the project and
early stages of a field project to ensure proper assembly
and startup of their technology. EcoMat's labor hours, as
specified in Tables 3-1  and 3-2, would include overseeing
and training  local contractors on the operation of the
system and making the proper adjustments to the system
during the shakedown and  recycle operation.  Once the
system is acclimated and operating ata steady state, labor
should become minimal.
The hourly labor rates presented in this subsection are
loaded, which means they include base salary, benefits,
overhead, and generaland administrative (G&A) expenses.
Travel, per diem, and standard vehicle  rental have not
been included in these figures. The labortasks have been
broken down  into four subcategories, each representing
distinct  phases  of technology  implementation.   They
include 1) System Design 2) Site Setup; 3) Startup  Testing;
and 3) Performance Monitoring & Maintenance.

3.5.5.1 System Design

System  design  consists of  obtaining   the  anticipated
contaminant range from the prospective customer and then
selecting the properly-sized system components necessary
for treating that influent at a specified flow rate.  Specific
tasks may include  preparation of design parameters and
detailed  process  flow   schematics  (including  piping
designs),  logistics for  procuring the  specific  system
components,  and  calculating feed  rates for methanol
solution and  other additives.   EcoMat has  estimated
system design labor at 1 00 hours.  Assuming a loaded rate
of $80/hr for an  EcoMat process  design engineer (or
comparable professional) to conduct this task, labor for
system design is estimated at $8,000.

3.5.5.2 Site Setup

Site setup  includes   labor costs that  are  not  already
included  in  the  system  design.   These costs would
therefore  include  the  labor  to  assemble  the  system
components and associated  monitoring equipment once at
the site;  organization  and  storage  of the initial year's
supplies  (e.g.,  methanol,  filter  cartridges,  etc.);  and
arranging for  and overseeing the  utility hookups. Due to
the importance of these initial activities, it is assumed that
the developer  will be   on-site  to  direct  and assist
subcontracted personnel.

It is assumed that the developer will supply one senior level
process engineer, billing  out at an estimated $80/hour, to
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perform oversight duties.   It is also assumed that  the
developer will contract out for supplying a local field team
consisting of two  technical staff personnel. The average
hourly  loaded rate for these two individuals is estimated to
be $50/hour. To complete the aforementioned tasks for a
100 gpm system, EcoMat has estimated 40 hours of their
time ($3,200)  and  400  contractor hours  ($20,000).
Therefore, total labor for the site setup  phase has been
estimated at approximately $23,200.

3.5.5.3  Startup Testing

The  EcoMat   process  requires  a period of  time  for
developing  the  necessary  biological  growth on  the
biocarrier in the EcoMat Reactor under a full recycle mode.
EcoMat  refers to this  startup  testing  phase  as  the
"Shakedown and Recycle Operation." The shakedown and
recycle  operation for  the  SITE  demonstration took
approximately eightweeks. EcoMat has indicated thatthis
process can be completed in about half of that time under
closer  control  and that the  time  period does  not vary
significantly with  the size of the project.  They have
estimated 80 hours of laborforcompleting this task, which
at an $80/hr rate would total $6,400. The shakedown and
recycle mode must be repeated  if the system goes down
for an extended period to re-acclimate the microorganisms
(this was necessary during the demonstration).  For this
cost it will be assumed that system startup will have to be
repeated at least  once annually.  Thus the $6,400 labor
cost will be incurred each and every year of operation.

3.5.5.4  Performance  Monitoring & Maintenance

Although the full-scale system is assumed to be fitted with
an on-line  nitrate/nitrite  analyzer and  other  automated
systems (i.e., for metering the proper amount of methanol
solution, chlorination, etc.), the full-scale system would still
require  both remote  (off-site) and on-site  monitoring  to
ensure reliable and consistent system performance.

Off-site monitoring of the full-scale treatment system would
at minimum be capable of continuously tracking inlet and
effluent nitrate and nitrite levels, dissolved  oxygen  levels,
and system disruptions as  indicated by the control panel
alarms (i.e., high  tank level alarms, pump  malfunctions,
high dissolved  oxygen levels, etc.).
Actual  on-site  observation  would also be  necessary, as
would  routine  maintenance site  visits.  Observing  the
system is required to visualize biocarrier suspension in the
EcoMat reactor. Periodic maintenance of the system is
required forfilter backflushing, adjusting methanol solution
feed rate, washing the bioballs  in  the deoxygenating
reactor, replenishing hypochlorite solution supply, etc.
With respect to a 100  gpm system, EcoMat has estimated
their off-site monitoring  labor at four hours per week and
contracted on-site labor at six hours per week. Assuming
the same labor rates of $80/hr and $50/hr for EcoMat and
contractor labor, respectively,  the weekly labor cost for
performance monitoring is estimated at $620/week. This
weekly cost would equate to $32,300 annually.

Total labor costs for the first year of treatment operation
would  total  approximately   $69,900.  Although  labor
comprises only about 14% of the  total first year treatment
costs, laboris projected to become the highestannualcost
category over time. Labor costs at five, ten and 15-years
of operation are estimated to comprise roughly 30%, 42%,
and 47% of the total annual costs, respectively.

3.5.6    Consumables &  Supplies

Due to the higher initial capital costs, consumables and
supplies  comprise a  relatively  small  initial year cost
component (i.e., slightly more than 1 % of the first year total
cost) for the EcoMat system. As  the capital cost impact
diminishes over time, the consumables and supplies costs
gradually increase in significance. Potential consumables
and  supplies  costs  for  the EcoMat  Biodenitrification
process can be associated  with  four subcategories:  1)
Nutrients and growth  substrate;  2) Biocarrier media;  3)
Post-treatment consumables; and 4) Equipment rentals.

3.5.6.1  Nutrients and Growth Substrate

Growth substrate includes any consumable supply that is
added  to  the  BDN  system  to  specifically  sustain  or
enhance the viability of microbes  used  to degrade nitrate
and nitrite.  The  primary  substrate is  a 50%  aqueous
methanol solution thatis added to  both the de-oxygenating
reactor tank and the EcoMat reactor.
During the demonstration, the methanol solution feed rate
roughly  ranged from 7-10 liters  per day.  EcoMat has
indicated that three times that feed rate would be required
for a 100  gpm system.   Therefore,  a  high range of 30
liters/day  of  "solution" would provide  a  conservative
estimate. That daily feed  rate would total approximately
8,800 liters of "solution" consumed per  year for a system
on-line 80%. Thus, approximately 4,400 liters (about 1,200
gallons) of methanol would be consumed annually.
EcoMat has  indicated that  they have  a supplier  that
provides bulk purchases of methanol at a cost of $0.65 per
gallon. Using that value,  the annual cost of the methanol
would be $780. The remainder of the methanol "solution"
consists mostly of water.
Nutrient supplements are also sometimes used. For the
demonstration, a small amount of food  grade  phosphoric
acid was added to the methanol solution to achieve a
phosphorus concentration of about 0.75 ppm. The cost of
the non-methanol  portion of the solution is considered
negligible and therefore is not included.
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In some cases, additional substrates may be utilized. For
example, during the demonstration, molasses was added
to "kick start" the system. However, supplements such as
molasses are notalways needed and its cost is considered
negligible and is not included here.

3.5.6.2  Bio carrier Media
The "EcoLink" biocarrier material is not replaced as long as
it remains in  suspension.   Overloading  does  occur,
therefore,  after a  significant period of time the EcoLink
must  be replaced before  they sink and clog  screens.
EcoMat has indicated that a  100 gpm  system requires
about two m3of EcoLink, which presently costs $6,000 per
cubic  meter.  The developer has  also  estimated that
approximately ten percent of the volume of EcoLink used
in any sized system needs "refreshing" on an annual basis.
Therefore, an annual cost of $1,200 for EcoLink biocarrier
is assumed for this cost estimate.
The bioballs used in the deoxygenating reactor tank are
also a type of biocarrier. However, they can last indefinitely
if periodically washed.  For this  reason, they  are not
considered as consumable. The labor cost of maintaining
the bioballs is included in subsection 3.5.5.4

3.5.6.3  Post-Treatment Consumables
Post-treatment consumables would potentially include any
chemical treatment added to the post-BDN effluent.  Also
included would be absorption and filtration media that
would be spent over an indefinite time period and need
replacement.   Examples of such post-treatment media
would be sand (used  in sand filtration),  spent activated
carbon, spent filter cartridges, etc.
It is assumed for this cost estimate that chlorination would
likely be required when implementing the EcoMattreatment
system  for  drinking   water  applications.  EcoMat  has
indicated that they would  use a 25% solution  of liquid
hypochlorite for full-scale chlorination post-treatment. For
a 100 gpm  system,  they  have  estimated hypochlorite
consumption  at  2  gallons  per  day  at  a  cost  of
approximately $6 pergallon. This daily rate would correlate
to approximately 600  gallons of  hypochlorite consumed
annually at an estimated cost of $3,600.
During the demonstration, EcoMat replaced the paperfilter
cartridges being  used  with cleanable metal  cartridges.
Activated carbon was  used for one event only,  and the
sand filter was periodically flushed. For this cost estimate,
it will  be assumed the cleanable metal  filter cartridges
would also be used for a larger 100 gpm system.  It will
also be assumed that activated carbon will not be required
and thatthecostof replacing sand filtration media would be
negligible. Thus the cost of post-treatment consumables
would consist solely of the hypochlorite cost, about $3,600
annually.
3.5.6.4  Equipment Rentals

Equipment rentals would be an alternative to purchasing
dedicated equipment for the full-scale treatment system.
For example,  a pressure  washer  could  be  rented for
flushing out  metal cartridge filters  and reactor screens
during periodic maintenance. A conservative costestimate
for renting a heavy duty pressure washer is $300/week.
Assuming that pressure  washing  would be  required
quarterly, the annual rental charge would be approximately
$1,200 per year. Since this annual  cost exceeds 40% of
the  estimated  purchase price, purchase  of a pressure
washer  is the more economical choice.

It should be  noted that other equipment listed in the cost
estimate as a capital expense may also be rented. During
the demonstration, the SITE Program rented a colorimeter,
pH/conductivity meter, a temperature/DO meter, a turbidity
meter, and water level meter. However, as is the case with
the  pressure washer, the rental costs  of these items for
indefinite periods is not cost effective, especially when the
periodic shipping charges are included.

Since equipment that could be rented have been included
as capital cost items, no rental costs are included in the
cost estimates on Tables 3-1 and 3-2.

The total estimated cost of consumables and supplies for
the initial year of treatment is $5,580. The cost is estimated
to increase proportionately with treatment duration.

3.5.7    Utilities

The main utility required for the EcoMat treatment system
is electricity.  Atthe Bendena site the electrical hookup and
service  were provided by the State  of Kansas.   The
electricity  provided  the  power needed to operate  the
system pumps and control  panels, the submersible pump
in the well, and outlets used forthe building heaterand the
telephone/facsimile machine. The SITE Program recorded
electric  meter  readings  before,  during,  and  at  the
conclusion of the demonstration.  During the approximate
7%  month  period  of time encompassed by the  four
sampling events, a total of approximately 26,400 kW-hr
was used. Power usage rates varied in a range of 5.0-1 0.4
kW. EcoMat has projected a  100 gpm system to utilize
approximately  2.5  times the  power of the  pilot-scale
system; which would correlate to a range of 12.5 - 26 kW
of power. Conservatively using 20 kW as the power usage
fora 100 gpm system, the numberof  kW-hrs used annually
would be approximately 20 kW x 24  hr/day x 7 days/wk. x
52 wk./yr or approximately 175,000 kW-hrs. Assuming a
utility charge of $0.07/kWh,  the cost of operation of the 100
gpm treatment  system  for a year would thus be about
$12,300. (Note: It is assumed  that electric  usage  will
continue when the system  is off-line for testing and other
maintenance activities.) It should  be noted that electricity
cost can vary greatly depending on geographical location.
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There is also a need for a water line to operate a pressure
washer for maintenance activities.   However,  the water
usage  is sporadic and is not expected to be substantial.
Therefore,  water  usage  is  considered  negligible  for
estimating utility costs.

3.5.8   Effluent Treatment and Disposal

For this technology successful treatment will mean that the
effluent will become  drinking water.  Therefore, it is
assumed  that there  will  be no effluent treatment  and
disposal expense. It is assumed that the minimal amount
of wastewater generated from periodic power washing of
metal filter cartridges  and reactor filter screens can be
discharged either to a land septic system (as was the case
at Bendena), or to a local POTW.

3.5.9   Residuals Shipping and Disposal

The only residuals generated during the demonstration
were spent filter media (cartridges and carbon) and spent
biocarrier media. Since levels of residual methanol are low
in these wastes, most if not all of this  material would be
classified as non-hazardous  and can be disposed of as
such.

It should be noted that if carbon is used  to treat hazardous
organic contaminants, any spent carbon could be classified
as a  hazardous waste,  and thus  require  disposal as
hazardous waste.
For this cost estimate, it is assumed that no hazardous
waste  will be generated  during treatment.   Residuals
would  be  discarded  as  non-hazardous  solid  waste.
Disposal costs are, therefore, considered negligible for this
cost estimate.

3.5.10  Analytical Services

Although nitrate and  nitrite  levels  would  be  monitored
continuously by an on-line nitrate analyzer, the state or
local regulatory agency  would still require independent
analysis of effluent samples at some specified frequency.
Based  on  discussions with the Public Works Supply
Section of the KDHE, the required monitoring fora water
treatment  system such as EcoMat's would include four
specific drinking  water criteria.  These four  criteria would
include nitrate-N/nitrite-N (which is conducted as a single
analysis),  methanol, Fecal Coliform, and trihalomethanes
(THMs). A likely monitoring schedule fora nitrate treatment
system producing drinking  water  would   include  the
following final effluent analyses at the indicated frequency:

(1)     Nitrate and nitrite quarterly;
(2)     Methanol quarterly;
(3)     Trihalomethanes (THM) quarterly; and
(4)     Fecal Coliform twice a month.
The required monitoring would be conducted quarterly for
the duration of the life of the treatment system, but would
be at an increased level for the first 8 weeks of operation.
For estimating the cost of the analytical services category,
it is assumed  that the treatment system effluent will be
sampled  three times  a  week for the first 8 weeks  of
operation (for a total of 24 samples)  and then a  total of
three times for the remainder of the first year of operation
in  accordance with  a   quarterly  sampling  schedule.
Therefore, a total of 27 effluent samples will be collected
during the initial year of system operation and four effluent
samples will be collected for each successive year.
The resulting first year total of 27 water samples, analyzed
for nitrate-N/nitrite-N at  an estimated cost  of $15  per
sample, methanol at an estimated cost of $100 per sample,
Fecal Coliform atan estimated $15 persample, and THMs
at  an  estimated  $150  per  sample  would  total  to
approximately $7,560. Assuming an  increase of sample
cost of 10 percent to cover QA samples, the total cost for
the first year samples is estimated at $8,320. The total cost
for each subsequent year of quarterly monitoring would be
around $1,120. Again, assuming a 1 0 percent increase in
costs  to  cover QA  samples,  the total  cost for each
subsequent year is estimated at about $1,230.

It is anticipated that the VOC (methanol) and biological
analyses  would  be  conducted  at  separate   off-site
laboratories. The holding time requirements for  nitrate-
N/nitrite-N analyses and Fecal Coliform would necessitate
near immediate shipments to those off-site laboratories,
allowing for no holdovers. Therefore, separate shipments
would be required for each. As a result there would be 54
overnight shipments to the offsite laboratories during the
first year  of  operation  and  eight shipments for each
successive year. At an estimated  $30/shipment for these
small  sample  sets,  the   total cost of sample  shipping
services is estimated to be about $1,600 the first year and
$240 each successive year.

It should  be noted that the stringency and frequency of
monitoring required may  have a significant impact on this
cost category.

3.5.11  Maintenance and Modifications

Once the treatment system is in full operation (following the
shakedown and recycling phase) monitoring and periodic
maintenance are necessary to maintain the required level
of  the treatment.

For this cost estimate it will be assumed that most of the
system operation will be  monitored remotely from off-site.
Based  on  the observations made during  the  SITE
demonstration, the mostly likely  maintenance problems
would involve system disruptions due  to clogged filters or
screens.   The cost associated  with  these problems is
mostly  labor  and   did  not  involve  the  purchase  of
                                                    25

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replacement  parts   during  the  demonstration  (see
subsection 3.5.5.4). It is assumed that system components
having high replacement  costs  (such  as pumps) will
operate for the full  duration of treatment if maintained
properly.  Components  that were  replaced  during the
demonstration included those having a relatively low cost
(such as malfunctioning switches and level sensors).

EcoMat has estimated non-labor cost of maintenance  to
be approximately 1 percentof the treatment system capital
cost annually, which  is roughly $2,600.

3.5.12 Demobilization

In general,  EcoMat believes that much of the equipment
comprising the biodenitrification treatmentsystem (if notall)
will be reusable. The end use of the equipment would be
determined  on  a  case-by-case basis.  Demobilization
would be performed at the conclusion of the entire project,
which is dependent on the total treatment time.  It  is
possible that treatment would be indefinite or would be of
long enough  duration that  the  equipment components
would be fully depreciated, thus essentially making the cost
of disassembly  and  shipment  to  a second   location
prohibitive. In eithercase, this cost estimate assumes that
the responsible party owns the system through their capital
cost investment. Therefore, demobilization is not an issue,
and all equipment has zero salvage value.
                                                    26

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                                             Section 4.0
                                     Demonstration Results
4.1    Introduction

4.1.1   Project Background

EcoMat's BDN  Process was evaluated  under the SITE
Program at the former PWS Well #1 in Bendena, Kansas.
The primary contaminant  in the well water is nitrate-N,
which historically  has  been measured at concentrations
rangingfrom approximately 20 to 130 ppm, wellabovethe
regulatory limit of 10 mg/l. VOCs, notably  CCI4, have been
a secondary problem.  The overall goal of EcoMat was to
demonstrate the ability of their process to reduce the levels
of nitrate-N in the groundwaterand restore the public water
supply well as a drinking water source.
The  SITE demonstration  occurred between  May  and
December of 1999 and  was conducted in cooperation with
the KDHE. The study consisted of four separate sampling
events interspersed over a 7/4 month time period. During
these four events EcoMat operated its  system at flows
between three and eight  gpm.  During  this  same  time
period well water nitrate-N  levels varied from greaterthan
70 mg/l to approximately 30 mg/l.

During the   four sampling events,  the  SITE Program
collected  water from  four specific sample taps  located
along EcoMat's   process.    Sampling  rounds  were
scheduled at pre-specified  intervals,  and consisted  of
collecting the water samples from the four sample locations
atthe approximate same time. By following this procedure
the data collected simultaneously from the four  sample
locations could be compared to one another. A total of 119
samples from each of the four sampling locations were
collected for the four field  events (28 for Event 1; 31 for
Event 2; and 30 each for Events 3 and 4).

The four sample points, as shown on Figure 4-1,  are:

1.     An untreated ("InletWater")sample pointlocated
       between PWS Well #  1 and the Deoxygenating
       Tank(S1);

2.     A "Partial BDN Treatment"sample point located
       between the  Deoxygenating Tank and  EcoMat
       Reactor (S2);

3.      A "Post BDN" sample point located between the
       EcoMat Reactor and post-treatment system (S3);

4.      A   "Final   Effluent"  sample   point  located
       downstream of the post-treatment system (S4).

4.1.2   Project Objectives

Specific objectives  for this  SITE demonstration  were
developed and defined prior to the initiation of field work.
These  objectives were subdivided into  two  categories;
primary and secondary. Primary objectives are those goals
of  the  project  that  need to  be achieved to  adequately
compare demonstration results to the claims made by the
developer. The field measurements required for achieving
primary  objectives  are  referred  to  as     critical
measurements.  Critical measurements were  formally
evaluated   against   regulatory limits  using  statistical
hypothesis tests (which are detailed in the TER).

Secondary  objectives  are  other  goals  of the project
developed for acquiring additional  information of interest
about the technology,  but  are  not  directly related to
validating  developer claims.  The field  and laboratory
measurements required forachieving secondary objectives
are considered to be noncritical. Therefore, the analysis of
secondary objectives was more qualitative in nature and
involved observations made by summarizing data  in tables
and graphs.

Table 4-1 presents the one primary and seven secondary
objectives of the  demonstration,  and  summarizes  the
method(s) by which each was evaluated. Except for the
cost estimate (Objective 8), which  is discussed in Section
3,  each ofthese objectives is  addressed in this section.

4.2    Detailed Process Description
A  process flow diagram of the EcoMat treatment  systems
used for the demonstration is  presented in Figure 4-1. As
illustrated, there are two majorcomponents comprising the
                                                   27

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                    INLET WATER     MeOH
                     (FROM PWS # 1)     (50%Aqueous
                                    Solution)
              (S) = Sample
              v?^y Collection
                  Point
                       R1
                   Deoxygenating
                       Tank
                                             EcoMat Reactor \ /perforated piat»
                                                             -^Downcomer
                       Biodenitrification
                       Post-Treatment
            Figure 4-1. Flow Diagram Showing EcoMat's Treatment System and Sample Collection Points
process: a BDN system and a post-treatment system. The
BDN system is a type of fixed film bioremediation in which
specific biocarriers and  bacteria are used  to convert
nitrates in the groundwater to nitrogen, thus reducing
nitrate-N  concentrations to  acceptable levels. The post-
treatment system is designed to either destroy or remove
any intermediate compounds potentially generated  during
the biological  breakdown of nitrate, and to remove small
amounts  of bacteria and suspended solids that are not
attached  to the biocarrier.  The post-treatment system
shown in Figure 4-1  is a compilation of the  different
combinations that were used during the demonstration. As
illustrated, the post-treatment system can incorporate
traditional methods for treating other contaminants (e.g.,
VOCs) that may be present in the influent. Both the BDN
and post-treatment systems are discussed in greater detail
in the following subsections.

4.2.1   BDN System

EcoMat's BDN system is designed to allow for rapid and
compact  treatment of nitrate with  minimal byproducts.
Unique to EcoMat's process is a patented mixed reactor
that is designed to retain the biocarrier within the system,
thus minimizing solids carryover. A detailed schematic of
the EcoMat denitrification reactor flow pattern is shown in
Figure 4-2.

A 50 percent aqueous methanol (MeOH) solution is added
to the system to provide an oxygen scavenger for BDN and
a source of carbon for cell growth. The resulting oxygen-
deficient environment encourages the bacteria to consume
nitrate. Methanol is  also  important to  assure  that
conversion of nitrate proceeds to the production of nitrogen
gas rather than to  the intermediate nitrite, which  is
considered to be more toxic.

The  mechanism for  anoxic biodegradation of nitrate
consists of an initial reaction for removal of excess oxygen
followed by two  sequential denitrification reactions.  This
mechanism can be expressed as three separate equations
as follows:

Oxygen Removal

CH3OH + 1.502	> C02 + 2H20             (1)

Denitrification Step 1:
CH3OH + 3NO3-	> 3NO2- + CO2 + 2H2O      (2)

Denitrification Step 2:

CH3OH + 2NO2-	> N2 + CO2 + 2OH' + H2O   (3)
                                                  28

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Table 4-1.    Demonstration Objectives.
    Objective
Description
                                                                                                  Method of Evaluation
  Primary Objective
  Objective 1        Evaluate the performance of the EcoMat BDN and post-treatment
                   process components, separately; with respect to the following
                   performance estimates:


                   I.        With incoming groundwater having nitrate-N concentrations of 20
                            mg/l or greater, and operating at a flow through rate of 3-1 5 gpm,
                            the BDN u nit would red uce the combined nitrate-N and nitrite-N
                            (total-N) concentration  from PWS Well #1  groundwater to at or
                            below a total-N concentration of 10 mg/l.

                   II.        The post treatment unit(s) will produce treated groundwater that
                            will meet applicable drinking water  standards with respect to
                            nitrate-N, nitrite-N, and the combined nitrate-N plus nitrite-N.

                   III.       Coupled with  planned or alternative post-treatment, the product
                            water will consistently meet drinking water requirements, except
                            for residual chlorine.  Specifically it will not contain turbidity of
                            greater  than 1 NTU, detectable levels  of methanol (1  mg/l), or
                            increased  levels of biological material or suspended solids, and
                            will have a pH in the acceptable 6.5-8.5 range.
                                      Collect post BDN effluent and final effluent samples from
                                      two critical outfalls, interspersed over a period of  four
                                      events.  Determine nitrate-N and nitrite-N concentrations
                                      in  those effluent samples via EPA Standard Method
                                      300.0.

                                      Note: Forthe purpose of performance evaluation, effluent
                                      nitrate-N (and similarly the  total-N) concentrations  of
                                      10.49 mg/l were to be rounded  down to  10 mg/l  and
                                      therefore considered as meeting the MCL and 10.50 mg/l
                                      were to be rounded up to 11 and therefore considered as
                                      failing the MCL.   Similarly, nitrate-N concentrations  of
                                      1.49 mg/l were  to be rounded  down to 1  mg/l  and
                                      therefore considered as meeting the MCL and 1.50 mg/l
                                      were to be rounded up to 2 mg/l and therefore considered
                                      as failing the MCL.  These decisions were  based on
                                      discussions  with the  KDHE  and  reflect its current
                                      practices.<10.5 mg/l when rounded to three significant
                                      digits).   The  detailed   statistical   equations   and  data
                                      analysis  procedures  used   for   evaluating   the
                                      demonstration data are included in the TER.
  Secondary Objectives
  Objective 2       Evaluate the performance of EcoMat's combined BDN and post-
                   treatment system components with respect to influent nitrate-N
                   concentration and with respect to time and/or water flow.
                                      Plot  the  Objective  1  data  versus   1)   the  influent
                                      concentration from PWS Well # 1 and 2) the average flow
                                      rate for each event.
  Objective 3       Demonstrate that at least  90% of the final effluent samples
                   (downstream of post-treatment) analyzed during the demonstration
                   period for  methanol, turbidity,  and biological materials  meet
                   drinking water requirements or at least do not provide cause for
                   concern where numerical values cannot be used for guidance.
                                      Collect samples for methanol, total heterotrophs, fecal
                                      coliform,  and  facultative  anaerobes  analyses  at  a
                                      frequency of one  per day  from all four outfalls and
                                      conduct daily turbidity measurements collected at inlet
                                      water, post BDN, and final effluent sample streams.
  Objective 4       Evaluate the percent mass removal of nitrate-N during each
                   sampling period over the course of the demonstration.
                                      Calculate the total inlet and final effluent nitrate-N masses
                                      in  grams;   determine  mass removed as a  total  and
                                      percentage.
  Objective 5       Evaluate  the  effectiveness of the  post-treatment system in
                   removing suspended solids, biologically active materials, methanol,
                   and VOCs of  interest (e.g., carbon tetrachloride, benzene and
                   tetrachloroethylene).
                                      Collect daily samples at all four outfalls for TSS analysis.
                                      Collect inlet water, post-BDN, and final effluent samples
                                      for VOC analysis at a frequency of three per event, and
                                      conduct PLFA analysis at least once at all four outfalls.
  Objective 6       Evaluate  the  necessity  of   the  post-treatment  system for
                   contributing to nitrate and nitrite mass removal.
                                      Compare nitrate-N and nitrite-N mass results before and
                                      after post-treatment.
  Objective 7       Evaluate the effectiveness of each post-treatment system used
                   during the demonstration for removing suspended solids, bacterial
                   material, methanol and other VOCs.
                                      Compare the data acquired for Objective 3 on an inter-
                                      event basis.
  Objective 8       Collect and compile information and data pertaining to the cost of
                   implementing the  EcoMat  BDN  Process  and necessary  post-
                   treatment for the removal of excessive levels of nitrate in drinking
                   water supplies.
                                      Acquire cost estimates from past SITE experience and
                                      from developer.  Cost treatment for a full-scale system
                                      similar in design to the pilot unit used at Bendena.  Break
                                      down estimates into 12 cost categories that reflect typical
                                      cleanup activities at Superfund sites. (See Section 3)
                                                                   29

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                                                                             Injector
                                                                                     Perforated
                                                                                 y Plate-
                                                                                     Downcomer
   TUV-3
           CIRC
           PUMP

Figure 4-2. Detailed Schematic of the EcoMat Denitrification Reactor.
                                                30

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Overall Denitrification Reaction:
5CH3OH + 6NO3-
3N  + 5CO  + 6OhT
                                      7H2O   (4)
Note: The subsequent discussion refers to nitrate-N and
nitrite-N  values,  in  which  each  mg/l of nitrate-N  is
equivalent to 4.4 mg/l of nitrate and each mg/l of nitrite-N
is equivalent to 3.2 mg/l of nitrite.
In  the first  step,  aerobic/facultative bacteria  consume
oxygen in the process of metabolizing methanol for energy
and biomass production.  For the first denitrification step
(Equation 2) to occur,  it is essential that the  dissolved
oxygen  (DO) concentration be  less than 1 mg/l.  Under
these anoxic  conditions, the  bacteria  are  forced to
substitute the  nitrate as  the  electron  acceptor and the
nitrate is reduced to nitrite. In the third equation, the nitrite
is further reduced to nitrogen gas. Nitrite production is an
intermediate step and there is no apr/or/reason to assume
that the  second reaction  (Equation 3) is  at least as fast as
and/or favored over the  first reaction (Equation 2) in the
presence of a specific bacterial population. Consequently,
any evaluation scheme  must establish that there is no
buildup of nitrite, particularly since the nitrite-N maximum
contaminant level (MCL)  is only 1 mg/l, one tenth that of
nitrate-N.    High  concentrations  of  nitrate  and high
nitrate/methanol ratios tend to increase  the concentration
of residual nitrite-N.
BDN is conducted in two reactors, identified as R1  and R2
on Figure 4-1. The majority  of the oxygen removal step
(Equation 1 ) is conducted within R1, which EcoMat refers
to  as the "Deoxygenating Tank". Inside this tank are
bioballs (a standard type of biocarrier)  which have been
loaded  with  de-nitrifying bacteria purchased  from  a
commercial vendor. These aerobic bacteria initially reduce
DO levels of the contaminated  influent.   A 50 percent
aqueous MeOH  solution is metered  to  the  tank to
encourage the bacteria to begin consuming nitrate in the
resulting oxygen deficient water.
The de oxygenated water is pumped from the bottom of R1
to the bottom of R2, which is  referred to by the developer
as the "EcoMat Reactor".  R2 is packed with a synthetic
polyurethane biocarrier called "EcoLink", which serves as
the biocarrier for a colony of additional  bacteria that are
also cultured for degrading nitrate. The EcoLink media are
1-cm3 cubes of sponge-like material that  provide  a large
surface area for growing  and sustaining  an active bacteria
colony.  The cubes have  contiguous holes  so that bacteria
can populate them and nitrogen  gas can  exit.  A special
additive to the polyurethane makes the surface more
hospitable to the bacteria.

Specially designed mixing apparatus within R2 directs the
inflowing water into a circular motion,  which keeps the
suspended media circulating and enablesthe contaminated
waterto have intimate contactwith the bacteria. Perforated
plates at the bottom and top of R2 retain the EcoLink
biocarrier within the reactor, while permitting passage of
the water. Before the production of nitrogen gas starts the
specific gravity of EcoLink is slightly greater than that of
water. Within R2, the majority of denitrification (Equations
2  and  3) is conducted  by the  established  anaerobic
bacteria  colonies that are continually fed methanol as a
carbon  source.  After  a  sufficient retention  time  the
denitrified water  drains by gravity to an overflow tank,
which allows for a continuous and smooth transfer to the
post-treatment system.

4.2.2    Post-Treatment System

The  post-treatment system can  be comprised  of  two
primary treatment components; an oxidation component
and a filtration component. The oxidation  component is
intended to oxidize residual nitrite back to nitrate,  oxidize
any residual methanol, and destroy bacterial matterexiting
the EcoMat  Reactor (R2). The  oxidation  component may
consist of chlorination,  ozonation, or UV treatment; or a
combination  of  the  three.  During  the demonstration,
chlorination was used fortwo events, UV was used forone
event, and an ozone/UV  combination was used for  one
event.

The  filtration component usually consists  of a clarifying
tank and  one  or  more filters  designed  to  remove
suspended  solids  generated  from the BDN  process.
During the demonstration, a variety of filter combinations
were used, including a sand filter, and a series of variable-
sized cartridge filters. The cartridge filters that were used
included   "rough filters" (20um),  "high efficiency  filters"
(Sum), and "polishing filters" (1um). Carbon cartridge filters
and  an  air stripper were  used during Events  3  and 4,
respectively, to remove small amounts  of CCI4.


4.3     Field Activities
4.3.1    Pre-Demonstration Activities

To  confirm  contaminant   concentrations  for  the
demonstration and  assist in  sizing the  system,  pre-
demonstration samples were taken from PWS Well # 1
over a nine-day period (September 22-30,1998). Since the
pilot-scale system was expected to be operated within the
3-15gpm range, it was decided to pump ground water from
the well at 10 gpm during  the nine-day period. To provide
an indication of the variation in nitrate-N concentrations,
one sample was collected  every two hours over a four-hour
period, at the same times each day. It was also realized
during the pre-demonstration activities that pumping  at a
rate  of 20 gpm over a five-day period  lowered the water
level in the well by about 10 feet, over 20 percent of the
water column. When the pumping rate  was reduced to
about 10 gpm, there was little drawdown  in the well.
                                                     31

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4.3.2   Sample Collection and Analysis

The sampling strategy for evaluating the effectiveness of
EcoMat's BDN Process was developed around comparing
the post BDN and final effluent (after post-treatment) data
to applicable regulatory limits. This comparison addresses
the project Primary Objective as presented in Table 4-1.

As was explained previously, there were four  separate
treatment events during the demonstration. These events
were partially determined based on anticipated changesto
the post-treatment system.  The events were spread out
over several  months to allow for evaluating the EcoMat
technology over a longer time duration.
The goal of the sampling strategy was to collect sufficient
samples at each critical outfall during each event so that
statistical hypothesis tests could be conducted with an a
error rate = O.IOand a (3error rate = 0.10. (The method for
calculating the number of samples  is presented in more
detail in the TER).  Using 5.5  mg/l as an estimate of the
population variance in the final effluent nitrate-N + nitrite-N
(total-N)  measures,  the  number  of  sampling  rounds
required per event was found to be 29.
The SITE Program  conducted  on average ~ 30 sample
sampling rounds for each event. Since the samples were
collected at each of the four locations at the same time, the
resulting sample sets were comparable for evaluating the
EcoMat process at different points of the process; either on
a "per sample round" or "per  event" basis. In order to
achieve some I eve I of "flushing" between sampling rounds,
the daily sampling  frequency  during  each  event was
dependent on the water  flow  rate  through the system.
Because the flow rate was varied  for each event,  the
number of daily sampling rounds for collecting sample sets
varied from 3 to 5 per day.

The effectiveness of the  post-treatment  systems for all
events was evaluated by collecting  samples immediately
downstream  of  the BDN  system  ("post BDN"),  and
immediately  downstream of the  developer-selected post-
treatment components ("final effluent"); then comparing the
sample  results from the  two  outfalls with respect to a
variety of microbial and water quality parameters. These
parameters included, but were not  limited to,   residual
methanol,  total suspended solids (TSS),  turbidity,  total
culturable heterotrophs (TCH), Fecal Coliform (FC), and
facultative anaerobes (FA). Phospholipid fatty acids (PLFA)
were analyzed for on a very limited  basis. Since these
limited PLFA  results do not impact any developer claims,
those results  are presented  in the TER only.
Table 4-2 presents a summary  of the laboratory analyses
conducted on samples collected from each of the four
sampling points monitoring the EcoMattreatment process,
and for the   methanol  feed  (the main  additive  for the
process). All samples collected were grab samples.
4.3.3    Process Monitoring

Process monitoring was conducted on a routine daily basis
during  all four sampling events.  Table 4-3 presents  the
type  of process   monitoring  conducted  during   the
demonstration,  the  frequency   and  location  of  that
monitoring, and  the instrumentation  used.  Details  are
provided in the following subsections.

4.3.3.1  Nitrate-N and Nitrite-N Colorimeter Testing

Although daily samples were being collected during each
event   for laboratory nitrate-N  and  nitrite-N analyses,
colorimeter  testing  was  also  conducted   daily   to
approximate real time values forthose critical parameters.
These  measurements  aided  the developer in making
adjustments  to  its system and aided the  analytical
laboratory  in determining calibration ranges. An on-line
nitrate  monitor was also installed to provide a continuous
record  of nitrate entering and leaving the treatment system,
but the unit could not be operated  routinely and  no useful
records were obtained.

4.3.3.2  Process Flow Rate

Flow measurements were taken  from  a totalizer meter to
ensure that sampling rounds were  being conducted atthe
properly-spaced  time  intervals  (i.e.,  the treated water
correlated to the previous sampling round had exited the
entiretreatmentsystem).The flow  measurements were also
used  for later calculation of flow rates that could be
correlated to analytical results for each  sampling round
conducted. A calibration  check  of the Neptune  totalizer
gauge  was conducted for each event to assure accuracy
of the meter.

4.3.3.3  General Water Quality Parameters

Daily measurements of general water quality parameters
were taken at all four outfalls to  monitor parameters that
either  could directly  affect  biological  activity  (e.g.,
temperature and DO) or were  to be used to  evaluate
system performance with respect to secondary objectives
(e.g., pH and turbidity).  All water quality parameters were
measured with field instrumentation thatwas calibrated per
manufacturer  instructions    prior   to  taking   the
measurements.

4.3.4    Process Residuals

During the demonstration  the developer was responsible
for disposing of process residuals. These mostly included
spent cartridge filters, spent biocarrier, and spent carbon.

Due to the fact that nitrate and nitrite are non-hazardous
with respect to   RCRA   regulations,  and  that  VOC
concentrations were negligible,  all  residuals from  the
process were considered non-hazardous. Thus the spent
                                                    32

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Table 4-2. Summary of Laboratory Analyses Conducted for the Demonstration.
PARAMETER
Test
Method
SAMPLE LOCATION POINTS
INLET
WATER
PARTIAL
BDN
POST
BDN
FINAL
EFFLUENT
METHANOL
FEED
Chemical Analyses
Nitrate-N
Nitrite-N
TSS
Methanol
VOCs
Total Metals
Sulfate
Alkalinity
Total Solids
Phosphate
Ammonia
Total Organic Carbon
EPA 300.0
EPA 300.0
EPA 160.2
SW 801 5
SW 8260
SW 301 0/6020
EPA 300.0
EPA 310.1
EPA 160.3
EPA 300.0
EPA 350.2
SW 9060
Each Round 1
Each Round 1
1 per day
1 per day
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
Each Round 1
Each Round 1
1 per day
1 per day
—
—
—
—
—
—
—
—
Each Round 1
Each Round 1
1 per day
1 per day
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
Each Round 1
Each Round 1
1 per day
1 per day
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
3 per Event
—
—
—
—
2 per Demo.
—
—
—
—
—
—
—
Microbial Analyses
Total Heterotrophs
Fecal Coliform
Facultative Anaerobes
PLFA
SOP
SOP
SM9215M
SOPGCLIP
1 per day
1 per day
1 per day
1 for Event 1
1 per day
1 per day
1 per day
1 for Event 1 ;
1 for Event 4
1 per day
1 per day
1 per day
1 for Event 1 ;
1 for Event 4
1 per day
1 per day
1 per day
1 for Event 1
—
—
—
—
1 Refers to a round of samples collected from the process sample location points (Figure 4-1) at approximately the same time.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-3. Summary of Field Measurements Conducted for the Demonstration.
PARAMETER
Nitrate-N
Nitrite-N
Flow Rate
PH
Conductivity
Dissolved Oxygen
Temperature
Turbidity
INSTRUMENTATION
Hach DR-890 Colorimeter
Hach DR-890 Colorimeter
Neptune Totalizer
YSI Mod. 63 pH/Cond. meter
YSI Mod. 63 pH/Cond. meter
YSI M95 DO meter
YSI M95 DO meter
LaMotte 2020 Turbidmeter
SAMPLE LOCATION POINTS
INLET
WATER
1 per day
—
Each Round
1 per day
1 per day
1 per day
1 per day
1 per day
PARTIAL
BDN
—
—
Each Round
1 per day
1 per day
1 per day
1 per day
1 per day
POST
BDN
1 per day
1 per day
Each Round
1 per day
1 per day
1 per day
1 per day
1 per day
FINAL
EFFLUENT
—
—
Each Round
1 per day
1 per day
1 per day
1 per day
1 per day
1 In addition, daily water levels of PWS Well #1 were recorded and electric usage was periodically recorded during each Event.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                             33

-------
filter cartridges,  carbon,  biocarrier,  etc.  were  simply
collected in a trash container and  disposed of in  a solid
waste dumpster.

The  final  effluent was deemed non-hazardous  by the
KDHE, who arranged for a permitto discharge the treated
water to a septic system installed  in an agricultural field
downgradient of  the  EcoMat treatment  shed  and  PWS
Well#1.


4.4     Performance and Data Evaluation
This  subsection  presents  in   summary  form  the
performance  data  obtained during the  EcoMat SITE
Demonstration conducted from May to December, 1999.
The  data are presented in two ways. Subsections 4.4.1
through 4.4.4 evaluates each sampling event (i.e.,  Events
1 through  4, respectively),  independently, with respect to
the objectives listed in Table 4-1. Subsection 4.4.5, on the
other hand, compares all four events. The latter inter-event
comparison  may  provide  the reader with  a  better
understanding of the overall demonstration.  Subsection
4.4.6 summarizes data quality assurance  aspects of the
demonstration.

Since the post-treatmentsystemwas varied foreach event,
the data from the four events were  initially  analyzed
separately.  Then  a comparison  between events was
performed. The level  of significance (LOS) or a error rate
was  set to 0.10 for the various statistical tests  performed.
These tests  included  the Shapiro-Wilk tests of Normality
followed by either the Wilcoxon Signed  Rank test or the
Student's t-test. The Wilcoxon Signed Rank (WSR) test is
a non-parametric, one-sample test, used to test the median
against a fixed threshold such as a regulatory limit. The
one-sample Student's t-test is a para metric test which tests
the mean against a fixed threshold.
Within each of these subsections, the following discussions
are presented in sequence:

•       a  summary of the  effectiveness of the EcoMat
        BDN  and post-treatment systems at the various
        sampling points.
•       results  of the  statistical  analysis  that were
        conducted to  compare post  BDN and final effluent
        data to the appropriate regulatory limits.
•       an evaluation ofthe BDN system.

•       post-treatment system performance.

•       a summary on the mass removal of nitrate.

•       a discussion ofthe possible relationship between
        system performance and flow rate.

To evaluate  the post  BDN  and final effluent data against
regulatory limits, the following analytical strategy was used.
For each separate event, an  Exploratory Data Analysis
(EDA) was conducted forthe post BDN combined nitrate-
N/nitrite-N (total-N), the final effluent nitrate-N, the final
effluent nitrite-N, and the final effluent total-N.  The EDA
consisted  of  graphing  the data in  several formats and
calculating summary statistics (i.e.,  mean, median, and
standard deviation).  These graphs and summary statistics
were used to make preliminary assumptions  about the
shape ofthe distributions ofthe variables. This information
was needed  in order to identify the appropriate statistical
hypothesis tests forthe data.

After  reviewing  the graphs  and  summary  statistics,
Shapiro-Wilk tests of Normality were performed. Based on
the results of these tests,  either  the  WSR test  or the
Student's t-test was chosen as the appropriate hypothesis
test (i.e., the non-parametric WSR test was chosen when
the data did not fit either a normal or log-normal distribution
and the Student's  t-test was chosen when  the  data
resembled a  normal distribution). When  the WSR test was
used the mean of the variable was evaluated against the
appropriate demonstration criterion. When the Student's t-
test was used the median of the variable was  evaluated
against the appropriate  demonstration criterion.
The demonstration criterion was the regulatory  limit when
rounded to a whole  number. The post BDN  total-N was
tested against the demonstration criterion of < 10.5 mg/l
(i.e., regulatory  limit = 10 mg/l), using  an a error  rate of
0.10.  The final  effluent had to meet a combined criteria
where the mean or median nitrate-N was < 10.5 mg/l (i.e.,
regulatory limit = 10 mg/l), the mean or median nitrite-N
was < 1.5 mg/l (i.e., regulatory limit = 1 mg/l), and the mean
or median total-N was below 10.5 mg/l (i.e., regulatory limit
= 10 mg/l).  All  three of these criteria  had to be met in
order  for the technology to be considered  successful.
Therefore, a family-wise a error rate was set at 0.10 for
these three tests.

4.4.1 Event 1

4.4.1.1  Summary

Event 1  was  an  11-day  sampling episode conducted May
5-15, 1999. During Event 1 a total of 28 sampling rounds
were   conducted  and  -42,000   gallons  of  nitrate-
contaminated  well  water  passed  through  EcoMat's
treatment system at an average flow rate of 3 gpm.  Based
on average flow rate and an estimated  retention capacity
of 1,300 gallons for the reactor tanks, the sample rounds
were conducted  three times per day and approximately
seven hours  apart.

Figure 4-3 separately illustrates the  effectiveness  of the
EcoMat BDN and post-treatment systems evaluated during
Event 1, on an averaged basis (Note: the term average is
also referred to  as the mean in subsequent discussions).
The top illustration shows BDN effectiveness for reducing
nitrate in the  well water as a step-by-step  process. As
                                                    34

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       80
       60
    °E
    Oi-
        40
        20
               INLET
              WATER
              (from PWS
               Well#1)
PARTIAL BDN
TREATMENT
N (R1 Effluent)
                      R1
                       De-
                    Oxygenating
                      Tank
                               46
   (43/3)
       Event   1
           Flow @ 3 gpm
              Legend
46  = Total-N concentration (mg/l)
(43/3) = Nitrate-N / Nitrite-N concentration (mg/l)
BDN = Biodenitrification
ND = Not detected > detection limits
         R2
      EcoMat
      Reactor
                                              POST BDN
                                             TREATMENT
                                               (R2 Effluent)

                                                  1.9
                                                 (0.9/1)
                                     POST
                                  TREATMENT
                                   (see below)
                        FINAL
                      EFFLUENT

                         2.1
                     >  (1.7/0.4)
                     Event 1 Post-Treatment Effectiveness
Post BDN
MeOH = 5.8 	 |\ ^
TSS = 12 I \ /
Turbidity = 2.8 ) ( C
TCH = 2.4x106 / V^
FC = 0 /
FA = 3.6x106
Final
^- 	 — -^ [\ MeOH
\ I 	 \ TSS =
Effluent
= 15
10
Jhlorination ) } Turbidity = 4.4
/ / TCH =
^- 	 — ^ I/ FC = 0
v FA = 3
2.7x10b

.4x105
  Figure 4-3. Event 1 - Treatment Effectiveness for Averaged Test Results.
illustrated, the nitrate-N concentration in PWS Well #1 was
in excess of 70 mg/l during the first event in May of 1999.
This high level of nitrate-N was reduced  by about 38%
during the partial BDN treatment process that occurred in
the first reactor (R1).  A small amount of nitrite, 3 mg/l,
remained from the nitrate-nitrite conversion. Subsequent
treatment in the EcoMat Reactor (R2) further reduced the
mean nitrate-N concentration from 43 mg/l to 0.9 mg/l and
reduced  the mean nitrite-N level from 3 mg/l  to 1 mg/l.
                        Thus, a  mean total-N concentration  of  1.9 mg/l was
                        attained by BDN treatment for Event 1 effluent samples.

                        Post-BDN and final effluent samples had essentially the
                        same total-N concentration. Mean total-N concentrations
                        for post-BDN and final effluent sam pies were 1.9 mg/l and
                        2.1  mg/l, respectively.  However,  the mean nitrate-N
                        concentration increased  approximately twofold  and the
                        mean nitrite-N concentration decreased by more than half.
                                                 35

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At these low levels, variability in laboratory analyses may
be an explanation, although continued biological activity
between the BDN and post-treatment processes may also
be a contributing factor.  Alternatively, the post-treatment
chlorination  may  simply  be re-oxidizing  nitrite  back to
nitrate.
As shown in the bottom illustration of Figure 4-3, the only
post-treatment conducted during Event 1 was chlorination.
The  addition  of chlorine  had  little  effect  on  mean
concentrations  of methanol.  The  mean  methanol and
turbidity levels actually increased following post-treatment,
while mean TSS concentrations remained essentially the
same.  As a disinfecting agent, the chlorination may have
had  a  modest impact on  residual biological material.
Although  TCH remained essentially the same, FA counts
were measured on average to decrease  by one order of
magnitude.  There was no growth for FC, thus there was
no measured post-treatment effect for that parameter.

4.4.1.2 Event 1 Statistical Analysis

The summary statistics for the critical measurements are
presented in Table 4-4.   The nitrate-N, the nitrite-N, and
the total-N results for the four sampling locations,  for all 28
tests comprising Event 1 are shown in Table 4-5. The
average (i.e., mean) values from these data were used in
generating Figure 4-3. These data were  also  used to
evaluate the Primary Objective (Objective 1).
Table 4-4. Event 1 - Summary Statistics.
Critical
Measurement
Post BDN Total-N
Final Effluent
Nitrate-N
Final Effluent
Nitrite-N
Final Effluent
Total-N
Mean
(mg/l)
1.917
1.654
0.410
2.064
Median
(mg/l)
1.270
1.600
0.113
1.676
Standard
Deviation (mg/l)
1.474
1.509
0.424
1.445
The EDA showed that the data for all four measurements
from Event 1  more closely resembled a lognormal than a
normal distribution.  However, normality and lognormality
were rejected for all measurements, using an a error rate
of 0.10.  (In other words, at the selected or error rate of
0.10, these data did not fit either a normal or a lognormal
distribution).  Therefore, the  non-parametric WSR  was
chosen foranalyzing the data and the median was used as
the appropriate measure of central tendency.

Statistical hypothesis tests that we re conducted yielded the
following results:
•       Part I: Post BDN median total-N of 1.27 mg/l was
        significantly below the criterion of 1 0.5 mg/l.

•       Part II:  Final Effluent met the combined criterion.
        The median total-N of 1.68 mg/l was significantly
        below the criterion of 10.5  mg/l.

Based on the results  of these 2 hypothesis tests, Event 1
was shown to be successful in reducing levels of nitrite-N
and nitrate-N to below regu latory limits, with a LOS of 0.10.
A more detailed explanation ofthese results is presented
in the TER.

4.4.1.3  General Evaluation of BDN System

Table 4-6 presents a summary of all performance criteria
results for Event 1. This includes the post-BDN and final
effluent nitrate-N, nitrite-N, and total-N data for each ofthe
28 Event 1 tests. Also included are the additional analytical
and field measurement data for specific outfalls that were
used for evaluating other performance criteria. As shown,
the objectives regarding reductions in nitrate-N, nitrite-N,
and total-N in final effluent were attained for all 28 sample
sets. However, other performance criteria results indicated
the need for more substantial post-treatment, especially for
treating residual methanol and removing microbial matter.

The  daily  DO  measurements in Table  4-7 are  key
indicators   for  evaluating  the   effectiveness  of  the
deoxygenating step  required for triggering  the anaerobic
BDN  process. The  data  show that  the  deoxygenating
process was  effective in reducing  an average inlet water
DO of 10 mg/l to approximately 1 mg/l in partially treated
water exiting the Deoxygenating Tank.

4.4.1.4  General Evaluation of Post-Treatment System

Presented  in  this subsection are the field  and laboratory
measurement data that were used  primarily for evaluating
the post-treatment component of EcoMat's process during
Event 1 (Objective 5). Parameters  included pH, turbidity,
TSS,  microbial analyses,  methanol, and "supplemental
analyses" which included a variety of parameters sampled
and analyzed on a limited basis.
The daily  pH measurements in Table 4-8 show a  slight
increase in pH to occur following BDN treatment. The post-
treatment chlorination that followed BDN may have caused
a very slight upward shift in the pH  range. This negligible
effect was expected since  chlorination is not a pH-altering
post-treatment (i.e., as opposed to ozone).

The  daily  turbidity  measurements  in Table 4-9  are
considered a  gross indicator measurement for evaluating
the production of solids in the BDN  system  and a measure
of the  effectiveness  of  the post-treatment  system in
removing solids carryover.  Since  there is a  secondary
criteria drinking water standard associated with turbidity,
each day of sampling was  evaluated independently to
                                                     36

-------
Table 4-5. Event 1 - Nitrate-N and Nitrite-N Results (mg/l).
Sample Inlet Water
Round 1
Nitrate-N Nitrite-N Total-N2
1 77.9 <0.076 77.9
2 77.7 <0.076 77.7
3 79.2 <0.076 79.2
4 79.3 <0.076 79.3
5 79.5 <0.076 79.5
6 79.2 <0.076 79.2
7 79.7 <0.076 79.7
8 78.6 <0.076 78.6
9 74. 3 J <0.076 74. 3 J
10 73. 7 J <0.076 73. 7 J
11 73.7 <0.076 73.7
12 72.4 <0.076 72.4
13 73.4 <0.076 73.4
14 71.4 <0.076 71.4
15 72.2 <0.076 72.2
16 73.6 <0.076 73.6
17 72.4 <0.076 72.4
18 69.8 <0.076 69.8
19 71.0 <0.076 71.0
20 72.2 <0.076 72.2
21 71.0 <0.076 71.0
22 71.5 <0.076 71.5
23 69.7 <0.076 69.7
24 69.6 <0.076 69.6
25 68.9 <0.076 68.9
26 69.1 <0.076 69.1
27 69.2 <0.076 69.2
28 67.9 <0.076 67.9
Mean3 74 J ND 74 J
Partial BDN
Nitrate-N Nitrite-N Total-N2
34.9 4.8 39.7
47.9 2.9 50.8
50.0 2.6 52.6
47.7 3.3 51.0
50.5 2.9 53.4
49.7 3.6 53.3
43.3 J 3.8 47.1 J
49.1 3.3 52.4
38. 7 J 4.6J 43. 3 J
46.1 J 2.9 J 49.0 J
48.5 2.9 51.4
42.0 3.7 45.7
42.2 2.9 45.1
43.0 2.5 45.5
39.9 2.8 42.7
45.2 2.5 47.7
41.6 2.9 44.5
41.3 2.8 44.1
43.8 2.4 46.2
43.3 2.5 45.8
41.1 2.6 43.7
42.8 2.6 45.4
43.0 2.5 45.5
39.8 3.6 43.4
39.1 2.7 41.8
40.9 2.7 43.6
19.3 1.4 20.7
42.4 2.5 44.9
43 J 3.0J 46 J
Post BDN
Nitrate-N Nitrite-N Total-N2
1.2 1.3 2.5
1.2 0.67 1.87
4.7 1.1 5.8
3.7 1.4 5.1
0.63 0.64 1.27
2.4 1.4 3.8
0.76 0.74 1.5
1.3 0.82 2.12
0.65J 0.42J 1.07J
0.72J R NC
3.7 2.3 6.0
0.77 0.92 1.69
0.47 0.87 1.34
0.92 0.86 1.78
0.22 0.77 0.99
0.14 1.0 1.14
0.21 0.79 1.0
0.27 0.91 1.18
0.084 0.97 1.05
0.068 0.69 0.76
0.14 0.93 1.07
0.07 1.1 1.17
0.22 1.3 1.52
0.23 1.0 1.23
0.085 1.1 1.19
0.057 1.2 1.26
< 0.056 0.88 0.88
0.14 1.3 1.44
0.9J 1.0J 1.9J
Final Effluent
Nitrate-N Nitrite-N Total-N2
2.5 <0.15 2.65
2.2 <0.15 2.35
5.3 0.26 5.56
3.8 1.3 5.10
2.1 < 0.076 2.18
2.9 1.0 3.90
1.2 0.51 1.71
0.087 < 0.076 0.16
1.7J < 0.076 1.78
1.6J < 0.076 1.68
6.2 < 0.076 6.28
2.2 < 0.076 2.28
1.6 < 0.076 1.68
1.7 < 0.076 1.78
1.5 < 0.076 1.58
0.57 0.83 1.40
0.097 0.78 0.88
0.14 0.83 0.97
< 0.056 0.86 0.92
< 0.056 0.67 0.73
1.4 < 0.076 1.48
1.8 < 0.076 1.88
1.8 < 0.076 1.88
1.6 < 0.076 1.68
0.13 1.1 1.23
< 0.056 1.1 1.16
1.46 < 0.076 1.54
0.57 0.88 1.45
1.7J 0.4 2.1
 1  Represents a sample set in which samples from all four locations were collected at the approximate same time.
 2  Represents combined Nitrate-N and Nitrite-N in which values < the detection limit were considered zero for summing totals.
 3  Means are rounded to two significant digits.  Values < detection limit considered zero for calculating means.
 J = Estimated value.   R  = Value rejected by  QC.  NC = Not calculated.  ND = Not  detected at or above MDL
                                                              37

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Table 4-6.  Event 1  - Summary of Treatment Effectiveness.
Nitrate-N/Nitrite-N Results (mg/l)
Post BDN Final Effluent
Sample
Round1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Mean5
Total-N 2

2.5
1.87
5.8
5.1
1.27
3.8
1.5
2.12
1.07 J
R
6.0
1.69
1.34
1.78
0.99
1.14
1.0
1.18
1.05
0.76
1.07
1.17
1.52
1.23
1.19
1.26
0.88
1.44
1.9 J
Nitrate-N
2.5
2.2
5.3
3.8
2.1
2.9
1.2
0.087
1.7 J
1.6 J
6.2
2.2
1.6
1.7
1.5
0.57
0.097
0.14
< 0.056
< 0.056
1.4
1.8
1.8
1.6
0.13
< 0.056
1.46
0.57
1.7J
Nitrite-N
<0.15
<0.15
0.26
1.3
< 0.076
1.0
0.51
< 0.076
< 0.076
< 0.076
< 0.076
< 0.076
< 0.076
< 0.076
< 0.076
0.83
0.78
0.83
0.86
0.67
< 0.076
< 0.076
< 0.076
< 0.076
1.1
1.1
< 0.076
0.88
0.4
Total-N 2

2.65
2.35
5.56
5.10
2.18
3.90
1.71
0.16
1.78
1.68
6.28
2.28
1.68
1.78
1.58
1.40
0.88
0.97
0.92
0.73
1.48
1.88
1.88
1.68
1.23
1.16
1.54
1.45
2.1
Final Effluent - Other Performance Criteria
Flow
(gpm)
—
3.2
3.1
3.1
3.1
0.024
5.3
—
—
2.6
2.8
3.1
2.9
3.5
3
3
3.1
2.8
2.8
2.9
3
3
3.2
2.9
3
2.9
2.9
3
3
MeOH TSS Turbidity
(mg/l) (mg/l) (NTU)
91 9 8.6
—
—
<0.23 9 3.1
—
— —
<0.23 6 3.1
—
—
5 10.5 5.2
—
3.4 10 4.8
—
7.8 11.5 5.0
—
—
<0.23 10 2.0
—
—
<0.23 11.3 2.8
—
—
27 10.5 6.2
—
—
<0.23 14.2 2.8
—
26 1 1 4.8
14.6 10.3 4.4
pH 3 Total Heterotrophs
(SU) (CFU/ml)3
7.7/8.6 1,300/NG
—
—
7.7/8.2 2,300/2,000,000
—
— —
7.5/7.5 NG/ 4,500,000
—
—
8.1/8.2
—
8.1/7.7
—
7.7/8.2 NG/670
—
—
7.8/8.1 3,200/3,200,000
—
—
7.8/8.3 1,000/7,200,000
—
-
7.7 / 8.2 1 ,800 / 1 ,300
—
—
—
—
—
7.5-8.6 1,400/2,700,000
 Represents a sample set in which samples from all four locations were collected at the approximate same time.
 Total-N is equal to the combined  Nitrate-N + Nitrite-N concentration.
3 The first value represent the inlet  water and the second value represents the final effluent.
4 Flow rate value represents a likely interruption in the system followed by increased flow to compensate.
5 All values, except for pH, are means, rounded to two significant digits. Values < detection limit considered zero when calculating means.
R = Value rejected  by QC. J = Estimated value. Dashed line indicates that samples collected at that location were not analyzed for that param eter.
                                                                           38

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Table 4-7. Event 1 - Dissolved Oxygen Measurements (mg/l).
DATE
5-5-99
5-5-99
5-6-99
5-7-99
5-8-99
5-9-99
5-1 0-99
5-1 1 -99
5-1 2-99
5-1 3-99
5-1 4-99
5-1 5-99
TIME
INTERVAL
1000-1100
1600-1625
0930
1130
1000
1630
0930
2030
0945
0900
0945
-0730
Associated
Round Nofs.)1
1
2-3
4-6
7,8,9
10-11
12-13
14,15,16
17,18,19
20,21,22
23,24,25
26-27
28
Mean 2
SAMPLE POINT
Inlet Water
9.76
9.78
10.68
8.91
11.40
10.98
12.04
9.66
9.52
9.48
9.67
9.61
10
Partial BDN
2.34
1.10
1.10
1.02
0.92
0.95
1.05
0.65
1.28
1.00
0.91
0.72
1.1
Post BDN
6.17
4.65
5.70
5.30
5.80
6.35
5.65
4.50
4.50
4.90
4.85
4.92
5.3
Final Effluent
7.00
6.78
6.35
6.90
5.90
7.95
7.15
4.52
4.20
5.35
5.02
5.90
6.1
1 Sample rounds conducted closest in time to the measurement are bolded. 2 Mean values are rounded to two significant digits.
Table 4-8. Event 1 - pH Measurements.
DATE
5-5-99
5-5-99
5-6-99
5-7-99
5-8-99
5-9-99
5-1 0-99
5-1 1 -99
5-1 2-99
5-1 3-99
5-1 4-99
5-1 5-99
TIME
INTERVAL
1000-1100
1445-1500
0727-1100
1315-1330
0758-081 0
1455-1510
0837-0850
0805-0825
0832-0859
0942-0955
...
...
Associated
Round Nofs.)1
1
2-3
4-6
7,8,9
10-11
12-13
14,15,16
17,18,19
20,21,22
23,24,25
26-27
28
Range 2
SAMPLE POINT
Inlet Water
7.74
7.67
7.66
7.50
8.10
8.07
7.70
7.79
7.79
7.65
...
...
7.5-8.1
Partial BDN
7.81
7.73
7.66
7.5
7.58
7.5
7.79
7.75
7.78
7.74
...
...
7.5-7.8
Post BDN
8.43
8.24
8.21
7.2
8.20
7.5
8.0
8.05
8.15
8.12
...
...
7.2 -8.4
Final Effluent
8.61
8.45
8.21
7.5
8.23
7.7
8.20
8.12
8.25
8.21
...
...
7.5 -8.6
1 Sample rounds conducted closest in time to the measurement are bolded.   2 Range values are rounded to two significant digits.
Dashed line indicates that samples collected at the locations were not analyzed for that parameter.
                                                            39

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    Table 4-9. Event 1- Turbidity Measurements (NTU).
DATE
5-5-99
5-6-99
5-7-99
5-8-99
5-9-99
5-10-99
5-11-99
5-12-99
5-13-99
5-14-99
5-15-99
TIME
INTERVAL
1 000-1 1 00
0727-1 1 00
0941 -0950
0835-0844
1555-1610
0752-0800
0758-0820
0847-0855
0847-0855
1005-1010
0715
Associated
Round No(s.)1
1
4-6
7,8,9
10-11
12-13
14,15,16
17,18,19
20,21,22
23,24,25
26-27
28
Mean3
SAMPLE POINT
Inlet Water
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Partial BDN
...
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Post BDN
4.4
3.4
2.95
1.69
2.14
2.68
2.31
2.85
2.62
2.61
3.63
2.8
Final Effluent
8.6
3.10
3.13
5.15
4.81
5.03
2.00
2.82
6.18
2.75
4.82
4.4
Pass/
Fail2
F
F
F
F
F
F
F
F
F
F
F
0/11
     Sample rounds conducted closest in time to the measurement are bolded.
     A sample round is considered passing ifthe final effluent value is <_ 1 NTU. In the last row, the number of passing values is shown in
     the numerator; the total number of values (pass + fail, minus any blankvalues) is shown in the denominator.
    3Mean values are rounded to two significant digits.
    Dashed line indicates that sam pies collected at that location were not analyzed for that parameter.
determine  if  final  effluent  met the goal of £ 1  normal
turbidity units (NTU) (Objective 3). The readings indicate
turbidity to be   measured consistently above that goal
each day ofsampling and to average 4.4 NTU.
The TSS data  in Table 4-10 provide information on the
amount of solids added to the  inlet water by  the  BDN
process during  Event 1.  More importantly, the laboratory-
derived TSS data can be used in conjunction with the field
turbidity measurements to assess the effectiveness of the
post-treatment system for removing those solids.  The data
show the in let water to be essentially free of TSS  (i.e., only
one value was  above the MDL).  As would be expected,
the post-treatment chlorination used during Event 1 had no
effect on the increased TSS levels  produced during  BDN.
The average post  BDN and final effluent values  were
essentially  the same (12 mg/l and  10 mg/l,  respectively).
On a per round  basis, all final effluent values were greater
than their paired inlet water values.

The Event 1  microbial  results  presented in Table  4-11
include data  for the three  separate types of  microbial
analyses conducted: TCH, FA,  and FC. Inlet water, post
BDN,  and  final effluent  outfalls were sampled  for these
parameters.

The results of the TCH analyses can  be used to measure
the additional bacteria produced by EcoMat's BDN process
(relative to inlet water) and to determine how effective the
post-treatment  system was for  removing the increased
level  of  bacteria.    The data  indicated  that the  TCH
population associated with the BDN process effluentwas,
on average, three  orders of magnitude higher than TCH
levels in the well water. The carryover of this bacteria from
the BDN process to the final effluent was measured,  on
average, to exceed 100 percent. Final effluent TCH values
were measured to  be less than  corresponding inlet water
TCH values in only two ofthe seven sampling rounds.
The  FA  analyses provide  a  useful  measure  of the
production of active biodenitrifying bacteria during the BDN
process. The concentration of these bacteria in inlet water
gives some  indication of the character and quality of the
well water. Their numbers would  be  expected to  greatly
increase  in  the   post-BDN  effluent  and then  greatly
decrease in final effluent due to  post-treatment.
The FA data followed the expected pattern onlyto a certain
degree.  The average ofthe FA plate count mean in inlet
water was increased by three orders of magnitude in post
BDN effluent. However, the post-treatment effectiveness
for reducing  FA in final effluent was inconsistent.  Final
effluent plate count means  for individual samples  ranged
from < 1000 cfu/ml to > 800,000 cfu/ml. The final effluent
                                                      40

-------
    Table 4-10. Event 1- TSS Results (mg/l).
Sample Round
No.
1
4
7
10
12
14
17
20
23
26
28
Mean 2
SAMPLE POINT
Inlet Water
<5
<5
< 5
5.5
< 5
<5
< 5
<5
< 5
<5
< 5
<5
Partial BDN
—
—
—
—
—
—
—
—
—
—
—
—
Post BDN
15.2
7.5
8
14.7
9.5
12.7
12
13.3
14
12.7
14
12
Final Effluent
9
9
6
10.5
10
11.5
10
11.3
10.5
14.2
11
10
Pass/
Fail1
F
F
F
F
F
F
F
F
F
F
F
0/11
    1 A sample round is considered passing if the final effluent value is <_the inlet water value. In the last row, the number of pass ing
     values is shown in the numerator; the total numberofvalues(pass+ fail, minusanyblankvalues) isshown in the denominator.
     Mean values are rounded to two significant digits. Values < detection limit are considered zero when calculating means.
mean value was less than the inlet water mean value for
only one sample round.

A possible contributing factorto the high variability of post-
treatment performance on FA could have been the lack of
controlled chlorination. At least on  one occasion during
Event 1, the chlorine tablets being used were completely
depleted without being replenished for an  indefinite time
period. This lapse was recorded to occur a couple of hours
after round #20 samples were collected and almost a day
before round #23 samples were collected.  Round #20 and
the preceding round #17 had the two poorest results with
respectto large percentage increases in FA as  measured
from post-BDN to final effluent (i.e., > 100 % carryover from
BDN);  whereas for  round  #23  the  final effluent was
measured to have had less than 6% of the post-BDN plate
count mean.

TheFCanalysescanbeusedtocomparethequalityofthe
inlet water  with final effluent.  Ideally, there should  be no
increase.  Since fecal coliform  are  aerobic, they  could
become dormant during the  BDN process  and  difficult to
measure among the other bacteria. For Event 1, there was
no growth of FC measured in inlet water, nor was there any
growth for the post-BDN and final effluent streams.

Table 4-12 presents the Event 1 laboratory results for
methanol analyses conducted on inlet water,  post-BDN
effluent,  and final effluent.  There were small detectable
concentrations  of methanol  in three of the eleven inlet
watersamples. Round #1 results indicate that initially there
may have been a larger than expected imbalance  in the
methanol-nitrate  ratio,  causing excess methanol in the
post-BDN effluentto carry overto the final effluent. For all
subsequent test samples, methanol was not detectable in
the post-BDN effluent,  indicating that most of the carbon
source had been used up in the BDN process.  There is no
explanation why detectable concentrations of methanol
were  measured  in five of the  final effluent  samples
corresponding to the  post-BDN samples showing  no
detectable concentrations of methanol. The post-treatment
chlorination was  primarily  used  as a disinfectant and
should not have impacted methanol  concentrations.
Table 4-13 presents the results of supplemental analyses
that were carried  out on a  limited number of  samples to
obtain general background information on the technology.
These  analyses  included  VOCs,  total  metals,  sulfate,
alkalinity, total  solids,  phosphate,  ammonia, and  total
organic carbon (TOC).

CCI4, which had been historically detected in PWS Well#1
water, was not detected in the  inlet water sample nor in
effluent  samples. A  small  concentration  of the  VOC
chloroform, which is a also a trihalomethane (THM), was
detected in the final effluent. It is possible that chloroform
is  a reaction  by-product of CCI4  and   chlorine in  the
presence of organic matter.

The majority ofthe supplementalanalyses results indicates
the BDN and post-treatment systems to  have little to  no
effect on the measured parameters.  The increase in TOC
                                                     41

-------
Table 4-11.  Event! - Microbial Results.
Sample
Round
No.
1
4
7
14
17
20
23
Avg.
TOTAL CULTURABLE HETEROTROPHS - Plate Count Mean (cfu/ml)2
Inlet
Water 2
1,300
2,300
NG
NG
3,200
1,000
1,800
1,400









Post
BDN2
90,000
29,800
28,000
15,000
4,500,000
11,300,000
680,000
2,400,000









Final
Effluent 2
NG
2,000,000
4,500,000
670
3,200,000
7,200,000
1,300
2,700,000
% Carryover
from BDN
0%
6,700 %
16,000%
4.5%
71 %
64%
0.2 %
113%
% Change from
Inlet Water
- 100 %
+ 870 %
NC
NC
+ 1 ,000 %
+ 7,200 %
-28 %
+ 19,000%
Pass/
Fail3
P
F
F
F
F
F
P
2/7
FACULTATIVE ANAEROBES - Plate Count Mean (cfu/ml)2
1
4
7
14
16
17
20
23
Avg.
23,000
4,600
3,500
250
—
280
260
440
4,600









150,000
17,000,000
5,300,000
810,000
—
380,000
360,000
1 ,300,000
3,600,000









6,600
620,000
350,000
...
330
810,000
480,000
76,000
335,000
4.4%
3.6%
6.6 %
...
NC
213%
133%
5.8%
9.3 %
-71 %
+ 13,000%
+ 9,900 %
...
NC
+ 290,000 %
+ 190,000 %
+ 17,000%
+ 7,300 %
P
F
F
...
—
F
F
F
1/6
FECAL COLIFORM (Fecal coliforms/100ml)
1
4
7
14
17
20
23
Avg.
NG
NG
NG
NG
NG
NG
NG
NG








NG
NG
NG
NG
NG
NG
NG
NG








NG | NC
NG | NC
NG | NC
NG | NC
NG | NC
NG | NC
NG | NC
NG | NC
NC
NC
NC
NC
NC
NC
NC
NC
...
—
...
—
...
—
...
...
1 Post-treatment for Event 1 consisted solely of chlorination.
2 Plate count mean = average of three separate analyses, reported in colony forming units per milliliter.
3 A sample round is considered passing if the final effluent value is £ the inlet water value. In the last row for each parameter, the number
of passing values is shown in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the
denominator.
NG = No growth; for purposes of percent change calculations, it is assumed that this value is zero.
NC = Not calculated; when the initial reading to be used in a calculation indicated no growth, no calculation was performed.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                            42

-------
Table 4-12. Event 1- Methanol Results (mg/l).
Sample
Round
N"
1
4
7
10
12
14
17
20
23
26
28
Mean 2
SAMPLE POINT
Inlet Water
1
<0.23
	
2.5
< 0.23
<0.23
< 0.23
3.9
< 0.23
<0.23
< 0.23
0.7
Partial BDN
	
	
	
	
	
	
	
	
	
	
	
...
Post BDN
64
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
5.8
Final Effluent
91
<0.23
<0.23
5
3.4
7.8
<0.23
<0.23
27
<0.23
26
15
Pass/
Fail 1
F
P
P
F
F
F
P
P
F
P
F
5/11
1 A sample round is considered passing if the final effluent value is < 1 mg/l. In the last row, the number of passing values is shown
  in the nu merator; the total number of values (pass + fail, minus any blankvalues) is shown in the denominator.
 Mean values are rounded to two significant digits. Values < detection limit are considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-13. Event 1 - Supplemental Analyses Results (mg/l).1
Sample
Round
N"s
7,14,20
7,14,20
7,14,20
7,14, 20
7,14,20
7,14, 20
7,14,20
7,14, 20

7,14, 20
7,14,20
7,14,20
7,14,20
7,14, 20
7,14,20
Analyte 2
CCL
Chloroform
Total Solids
Ammonia
Total Organic Carbon
Sulfate
Phosphate
Alkalinity
SAMPLE POINT
Inlet Water
< 0.001
< 0.001
855
< 0.8
1.2
106*
< 0.082*
166
Partial BDN
	
—
	
—
	
—
	
—
Post BDN
< 0.001
< 0.001
602
<0.8
6.47
102
1.21
373
Final Effluent
< 0.001
0.006
635
< 0.8
6.07
104
	
367
Metals
Barium
Calcium
Potassium
Magnesium
Sodium
Phosphorus
0.08
150
1.8
42
12
<0.37
—
	
—
	
—
	
0.074
130
1.8
42
13
0.61
0.073
130
1.8
42
14
0.65
 Values are the mean of the three test results (except where indicated) and are rounded to a maximum three significant digits.
2Exceptfor CCI4 onlyThe SW-846 Method 8260 contaminants with mean values above detection limits are reported.
 Metals analyzed for included Ag, Al, Ba, Be, Ca, Cd, Co, Cr, Cu, Fe, K,  Mg, Mn, Mo, Na, Ni, P, Sb, and Zn.
Dashed line indicates that samples collected at that location were not analyzed for that parameter; and no pass/fail determination was made.
* Two samples collected only.
                                                                        43

-------
following BDN  is likely attributable to the carryover  of
biological material and methanol. The increased alkalinity
following BDN is consistent with the slight increase in pH
(refer to  Table 4-8). The small amount of phosphate and
phosphorus measured in the effluent samples is residuum
from the 50% methanol solution, which contains food grade
phosphoric acid.

4.4.1.5  Mass Removal of Nitrate

The  percent mass  removal of nitrate, as measured as
Nitrate-N, was estimated for Event 1 (Objective 4). A total
of approximately 42,000 gallons, or about 160,000 liters of
well water was treated during Event 1. Each mg/l of nitrate-
N  is equivalent to 4.4 mg/l of nitrate. Since the mean
nitrate-N concentration for Event 1  inlet water was 74 mg/l,
the total  mass of nitrate treated during Event 1 would be
(74x4.4) mg/lx 160,000liters= 52,000,000  mg. The mean
nitrate-N concentration  for Event 1 final effluent was 1.7
mg/l.  The total mass of nitrate in the final effluent  = (1.7 x
4.4) mg/l x  160,000 liters = 1,200,000 mg.  Therefore, the
mass  removal of  nitrate  during  Event  1  would  be
approximately 52,000,000 mg-1,200,000 mg = 51,000,000
mg (a 98% reduction in nitrate).  This would correlate to
51,000 grams or 112 pounds. However, the contribution of
nitrite should  not  be  discounted  since it  can be  re-
converted to nitrate. Including the nitrite that remains in the
final effluent, the mass  removal would be  111 pounds.

4.4.1.6  System Performance Vs. Flow Rate

The performance of  EcoMat's combined  BDN and  post-
treatment system components were evaluated with respect
to  water flow through  the system (Objective 2).   The
variation in  inlet water flow rate  during  Event 1 was
compared with the  total-N  concentrations  in  the final
effluent.   Figure  4-4  directly  compares the  Event 1
fluctuation for inlet water flow rate to the Event 1 fluctuation
in total-N final effluent concentrations forthe same sample
rounds. There is a similar pattern to both of the plots that
suggests  a  relationship between flow rate and  BDN
effectiveness (i.e., lower flow rates corresponding to more
effective BDN).  This is evident where the somewhat sharp
decrease in flow rate occurred about one quarter the way
  I
      2-
      1-
  Sample
Round No.
                                                    Final Effluent
                                                    Total-N(mg/l)
                                        28
Figure 4-4.  Event 1 - Comparison of Flow Rate Fluctuations and Final Effluent Total-N Concentrations.
                                                     44

-------
through the event correlates to a sharp reduction in total-N
concentration. However, elsewhere during the event there
are variations  in  the total-N  values  that cannot be
correlated with fluctuations in flow; these may correspond
to upsets in the treatment process.  The plots in Figure 4-
4 also indicate  that  once  the system was  kept  at a
consistent flow rate (i.e., the average event flow rate of 3
gpm), the BDN performance remained  stable  and quite
effective.

4.4.2 Event 2

4.4.2.1 Summary

Event 2 was a 10-day sampling episode conducted August
3-12, 1999. During Event 2, a total of 31  sampling rounds
were  conducted  and  ~  45,000   gallons of  nitrate-
contaminated  well  water  passed  through  EcoMat's
treatment system at an average flow rate of  3.5 gpm.
Based  on this average flow rate,  and on  an  estimated
retention capacity of 1,300 gallons for the reactor tanks,
sampling rounds were normally  conducted four times per
day at approximately QVz  hour intervals.

Figure 4-5 separately illustrates the  effectiveness of the
EcoMat BDN and post-treatment systems evaluated during
Event 2. The nitrate-N  in   PWS Well #1  had a mean
concentration of 68 mg/l during  the second event.  This
mean inlet water concentration was slightly less than for
Event 1  (74 mg/l), possibly due to inflow of clean water into
the aquifer as contaminated water was removed.  During
the partial BDN treatment process that occurred in the first
reactor  (R1), the nitrate-N levels were reduced by about
40%, with a small amount of nitrite remaining from the
nitrate to nitrite conversion.  Subsequent treatment in the
EcoMat  Reactor  (R2)  further  reduced  the  nitrate-N
concentration from a mean of 41 mg/l to a mean of 4.6
mg/l.  The mean nitrite-N concentration  increased  from
1mg/l to 1.5  mg/l  between  partial BDN and  post-BDN
samples.  A mean total-N concentration of 6.1  mg/l was
attained by the  BDN treatment for Event 2 samples.

During  Event 2 post-treatment consisted of  an initial
separation  of suspended   solids  in  a  clarifying  tank
("clarification"), followed by sand and cartridge filtration and
finally by UV oxidation. The post-treatment had no effect on
nitrite-N concentrations and only a  minimal  effect on
nitrate-N concentrations. The mean  values  for  total-N
concentrations for post-BDN and final effluent samples
were 6.1 mg/l and 5.6 mg/l, respectively.
                          20
                                          PARTIAL BDN
                                          TREATMENT
                                            (R1 Effluent)
                                            42
                                           (41/1)
        Event  2
          Flow @ 3.5 gpm
             Legend
    42 = Total-N concentration (mg/l)
   (41/1) = Nitrate-N / Nitrite-N concentration (mg/l)
   BDN = Biodenitrification
   ND = Not detected > detection limits
R2
EcoMat
Reactor


POST BDN
TREATMENT
(R2 Effluent)
	 — _ 6.1
                                                         (4.6/1.5)
                                                                                   FINAL
                                                                                 EFFLUENT
                                    Event 2 Post-Treatment Effectiveness
                  Post BDN

                  MeOH = 88
                  TSS = 13
                  Turbidity = 4.7
                  TCH = 2.9x10"
                  FC = 51
                  FA = 8x106
                      Final Effluent

                      MeOH = 98
                      TSS = < 5
                      Turbidity = 1.8
                      TCH = 1.8x107
                      FC = 42
                      FA = 3.2 X 10s
                  Figure 4-5. Event 2 - Treatment Effectiveness for Averaged Test Results.
                                                     45

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4.4.2.2  Event 2 Statistical Analysis

The summary statistics for the critical measurements are
presented in Table 4-14. Nitrate-N,  nitrite-N, and total-N
results for the four sampling locations for all 31 sample
rounds comprising Event 2 are shown in Table 4-15. The
mean values from this data were used in generating Figure
4-5.  This data was also used to evaluate  the Primary
Objective (Objective 1).
Table 4-14. Event 2 - Summary Statistics.
Critical
Measurement
Post BDN
Total-N
Final Effluent
Nitrate-N
Final Effluent
Nitrite-N
Mean
(mg/l)
6.145
4.132
1.459
Median
(mg/l)
4.600
2.220
1.200
Standard
Deviation
(mg/l)
3.781
4.237
1.155
The EDA indicated that the data from Event 2 more closely
resembled a lognormal than a normal distribution. When
Shapiro-Wilk   tests  were   run,   both  normality   and
lognormality were rejected forall measurements exceptthe
final   effluent  nitrite-N  data,   which  fit  a  lognormal
distribution.  However, the presence of one extreme  point
may   have  biased  the  results.   Therefore, the  non-
parametric WSR was chosen for analyzing  all of the data
and the median was used as the appropriate measure of
central tendency.
Statistical hypothesis tests that we re conducted yieldedthe
following results:

•       Part I: Post BDN median total-N of 4.60 mg/l was
        significantly below the criterion of 1 0.5 mg/l.

•       Part II: Final Effluent met all criteria. The  median
        nitrate-N, nitrite-N,  and total-N concentrations
        were  2.22,  1.20,  and  3.61  mg/l,  respectively.
        These values were below their respective criterion
        of 10.5, 1.5, and 10.5 mg/l.
Based on the results of these 2 hypothesis tests, Event 2
was shown  to be successful in reducing levels of nitrite-N
and nitrate-N to below regulatory limits.

4.4.2.3  General  Evaluation of BDN System

Table 4-16 presents a summary of all performance criteria
results for Event 2. This includes the post-BDN and final
effluent nitrate-N, nitrite-N, and total-N data for each ofthe
31 Event 2 tests. Also included are the  additional analytical
data  and field measurement results  that were used for
evaluating other performance criteria.  On  a per round
basis, the objectives  regarding reductions  in  nitrate-N,
nitrite-N, and total-N in the final effluent were attained for
17 of the 31 sample rounds.  Other performance criteria
results shown in Table 4-16 indicate the need for more
substantial post-treatment, especially for treating residual
methanol and removing microbial matter.

The daily DO measurements in Table 4-17 show that for
approximately the first half of the event (i.e.,  rounds 1-14)
the daily measured DO in the partially treated  BDN effluent
was consistently above 1 mg/l. Then, for the  remainder of
the event,  DO  was  consistently below  1  mg/l.  The
deoxygenating process was effective in reducing the mean
inlet water   DO  of  approximately  9  mg/l  down  to
approximately 1 mg/l in partially treated water exiting the
Deoxygenating Tank.

4.4.2.4  General Evaluation of Post-Treatment System

The field and laboratory measurements  used primarily for
evaluating the  post-treatment component  of  EcoMat's
Process during Event2 (Objective 5) included pH; turbidity;
TSS; microbial  analyses;  methanol; and "supplemental
analyses".
The daily pH measurements in Table 4-18 indicate a very
slight increase in  alkalinity from inlet water  to post BDN
effluent.  However, there was essentially no change in pH
range in the  final effluent following  post-treatment.

The daily turbidity measurements  in Table 4-19 indicate
turbidity to be consistently above the secondary drinking
water criterion of 1 NTU.  However, the  mean NTU of 1.8
was much improved over the Event 1 turbidity results.
The TSS data  in Table 4-20 show that the inlet water
contain no detectable levels of TSS and post  BDN effluent
to contains, on average, 13 mg/l of TSS. The final effluent
data indicated the post-treatment  system had a positive
effect on reducing TSS levels, on  average to less than 5
mg/l, most likely due to filtration. Six of  nine final effluent
values were less than their paired  inlet water values.
Table 4-21 presents the laboratory results for Total TCH,
FC, and FA at each  of the four  outfalls. An additional
sample  was collected immediately upstream of the UV
oxidation unit and analyzed for TCH and FC to evaluate
that  unit independently  of the  remainder  of the post-
treatment system (refer back to Figure 4-5).

The results ofthe TCH analyses indicated that the TCH
population  associated with the BDN  process was, on
average, three orders of magnitude higherthan TCH levels
in the well water. On average, approximately 6 percent of
this bacteria carried over from the BDN process to the final
effluent. This marked a substantial improvement from the
first Event when no filtration was used. However, all seven
final effluent TCH values were measured to be above the
                                                     46

-------
Table 4-15. Event 2 - Nitrate-N and Nitrite-N Results (mg/l).
Sample Inlet Water
Round1
Nitrate- Nitrite- Total-
N N N2
1 71.5 < 0.076 71.5
2 71.3 < 0.076 71.3
3 71.4 < 0.076 71.4
4 72.0 < 0.076 72.0
5 71.5 < 0.076 71.5
6 72.9 < 0.076 72.9
7 73.1 < 0.076 73.1
8 73.1 < 0.076 73.1
9 67.0 < 0.076 67.0
10 65.6 < 0.076 65.6
11 66.5 <1.9 66.5
12 69.3 < 0.076 69.3
13 68.7 < 0.076 68.7
14 68.5 < 0.076 68.5
15 69.8 < 0.076 69.8
16 69.8 < 0.076 69.8
17 67.5 < 0.076 67.5
18 67.5 < 0.076 67.5
19 66.7 < 0.076 66.7
20 64.4 < 0.076 64.4
21 65.2 < 0.076 65.2
22 63.2 < 0.076 63.2
23 64.0 < 0.076 64.0
24 65.7 < 0.076 65.7
25 66.1 < 0.076 66.1
26 66.2 < 0.076 66.2
27 67.0 < 0.076 67
28 65.7 < 0.076 65.7
29 67.2 < 0.076 67.2
30 67.6 < 0.076 67.6
31 66.4 < 0.076 66.4
Mean3 68 ND 68
Partial BDN
Nitrate- Nitrite- Total-
N N N2
54.1 0.29 54.4
58.7 0.17 58.9
32.4 0.73 33.1
42.6 0.22 42.8
53.4 0.21 53.6
27.1 1.7 28.8
49.1 0.69 49.8
45.4 0.74 46.1
41.2 0.85 42.1
42.8 0.99 43.8
36 <1.9 36
43.3 0.86 44.2
47.2 1.16 48.4
38.1 1.37 39.5
41.4 1.3 42.7
49.3 0.99 50.3
47.2 0.99 48.2
41 1.5 42.5
38.3 1.3 39.6
38.4 1.4 39.8
37.8 1.5 39.3
41.3 1.3 42.6
37.8 1.3 39.1
39.1 1.1 40.2
37.8 1.1 38.9
35.6 1.4 37.0
38.4 1.1 39.5
36.2 1.2 37.4
35.7 1.4 37.1
35.3 1.3 36.6
34.5 1.4 35.9
41 1.0 42
Post BDN
Nitrate- Nitrite- Total-
N N N2
6.6 0.34 6.9
14.4 0.52 14.9
6.8 0.72 7.5
11.9 0.19 12.1
12.5 0.88 13.4
12.3 6 18.3
4.6 1.5 6.1
4 0.94 4.9
2.7 0.82 3.5
1.8 0.77 2.6
3 1.6 4.6
3.34 1.52 4.9
4.8 2.11 6.9
2.42 0.813 3.2
2.9 1.6 4.5
6.3 2.6 8.9
5.8 2.9 8.7
4 2.1 6.1
3.1 1.8 4.9
2.8 1.5 4.3
2 1.4 3.4
3.7 1.9 5.6
2.2 1.2 3.4
2.7 1.4 4.1
2.7 1.5 4.2
2.5 1.6 4.1
2.5 1.5 4.0
2.2 1.3 3.5
2.4 1.4 3.8
2.2 1.4 3.6
2.2 1.3 3.5
4.6 1.5 6.1
Final Effluent
Nitrate- Nitrit Total-
N e-N N2
5.2 0.37 5.6
13.2 0.48 13.7
10.8 0.94 11.7
9.6 0.28 9.9
11.1 0.79 11.9
18.6 6.7 25.3
4.1 1.7 5.8
2.8 0.81 3.6
1.2 0.74 1.9
1.5 0.76 2.3
2.2 1.6 3.8
1.7 0.95 2.7
2.54 1.8 4.3
1.34 0.73 2.1
3.5 1.9 5.4
6.0 2.8 8.8
6.1 2.9 9.0
3.5 2.1 5.6
3.1 1.9 5.0
2.1 1.4 3.5
1.1 0.99 2.1
3.1 1.8 4.9
1.5 1.0 2.5
1.7 1.3 3.0
1.5 1.3 2.8
2.1 1.5 3.6
1.7 1.4 3.1
1.6 1.1 2.7
1.5 1.2 2.7
0.9 1.0 1.9
1.2 0.98 2.2
4.1 1.5 5.6
 Represents a sample set in which samples from all four locations were collected at the approximate same time.
2 Represents combined Nitrate-N and Nitrite-N.  Values < the detection limit were considered 0.0 when summing totals.
3 Means are rounded to two significant digits. Values < detection limit are considered zero when calculating means.
ND = Not detected at or above MDL.
                                                                       47

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Table 4-16.  Event 2 - Summary of Treatment Effectiveness.
Nitrate-N/Nitrite-N Results
Sample
Round1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Mean 2
Post
Total-N1
6.9
14.9
7.5
12.1
13.4
18.3
6.1
4.9
3.5
2.6
4.6
4.9
6.9
3.2
4.5
8.9
8.7
6.1
4.9
4.3
3.4
5.6
3.4
4.1
4.2
4.1
4.0
3.5
3.8
3.6
3.5
6.1
Nitrate-
5.2
13.2
10.8
9.6
11.1
18.6
4.1
2.8
1.2
1.5
2.2
1.7
2.5
1.3
3.5
6.0
6.1
3.5
3.1
2.1
1.1
3.1
1.5
1.7
1.5
2.1
1.7
1.6
1.5
0.9
1.2
4.1
(mg/l)
Final Effluent
Nitrite-N Total-N1
0.37
0.48
0.94
0.28
0.79
6.7
1.7
0.81
0.74
0.76
1.6
0.95
1.8
0.73
1.9
2.8
2.9
2.1
1.9
1.4
0.99
1.8
1.0
1.3
1.3
1.5
1.4
1.1
1.2
1.0
0.98
1.5
5.6
13.7
11.7
9.9
11.9
25.3
5.8
3.6
1.9
2.3
3.8
2.6
4.4
2.1
5.4
8.8
9.0
5.6
5.0
3.5
2.1
4.9
2.5
3.0
2.8
3.6
3.1
2.7
2.7
1.9
2.2
5.6

Flow
(qpm)
2.9
2.5
3.1
3.9
4.4
3.4
2.9
2.7
2.7
3.2
3.5
1.6
2.6
3.3
4.7
4.5
—
—
4
3.7
—
4
3.9
4
3.9
3.9
3.6
3.8
3.8
3.8
3.5
Final Effluent - Other Performance Criteria
MeOH TSS Turbidity pH 2 Total Heterotrophs 2
(mg/l) (mg/l) (NTU) (SU) (CFU/ml)
—
34 5.6 2.7 7.8/7.6 5,000/380,000
—
—
—
70 6 2.6 8.2/7.9 27,000/3,300,000
—
—
7.4/7.8
180 <5 2.3 — 17,000/250,000
—
110 <5 2.4 7.5/7.8
—
—
39 < 5 1 .6 7.5 / 8.2 28,000 / 620,000
—
94 <5 1.2 7.6/8.4 33,000/130,000
—
—
7.6/7.7
100 <5 1.1 — 370,000/25,000,000
—
—
—
77 9 1.2 7.4/8.3 230,000/97,000,000
—
—
—
180 <5 1.5 7.4/8.2
...
98 <5 1.8 7.4-8.4 100,000/18,000,000
 Total-N is equal to the combined Nitrate-N + Nitrite-N concentration.
2The first value represent the inlet water and the second value represents the final effluent.
 All values, except for the pH range, are means rounded to two significant digits. Values < detection limit are considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                                            48

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Table 4-17. Event 2 - Dissolved Oxygen Measurements (mg/l).
DATE
8-4-99
8-5-99
8-6-99
8-7-99
8-8-99
8-9-99
8-1 0-99
8-1 1 -99
8-1 2-99
TIME
INTERVAL
0945-1015
1000-1054
0900- 1 000
0820-0842
1440-1523
0830-0955
0845-0950
0800-0837
0830
Associated
Round No(s.)1
2-3,4,5
6-7,8,9
10-11,12
13,14
15,16
17-18,19,20
21-22,23,24
25,26,27,28
29-30,31
Mean 2
SAMPLE POINT
Inlet Water
—
8.70
8.74
9.45
8.85
9.33
8.8
9.09
8.81
9.0
Partial BDN
1.65
1.78
1.14
1.45
0.72
0.61
0.5
0.5
0.67
1.0
Post BDN
5.88
5.90
5.89
5.61
6.14
6.30
5.90
6.30
5.40
5.9
Final Effluent
2.11
4.55
0.51
1.03
5.9
4.30
4.64
3.55
0.5
3.0
1 Sample rounds conducted closest in time to the measurement are bolded.
2 Mean values are rounded to two significant digits.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
 Table 4-18. Event 2 - pH Measurements.
DATE
8-4-99
8-5-99
8-6-99
8-7-99
8-8-99
8-9-99
8-1 0-99
8-1 1 -99
8-1 2-99
TIME
INTERVAL
0920-1016
0956-1054
0919-1006
0821-0843
1445-1524
0855-0956
0921-0934
0804-0830
0915-0925
Associated
Round No(s.)1
2-3,4,5
6-7,8,9
10-11,12
13,14
15,16
17-18,19,20
21-22,23,24
25,26,27,28
29-30,31
Range 2
SAMPLE POINT
Inlet Water
7.76
8.18
7.35
7.45
7.48
7.56
7.64
7.44
7.39
7.4-8.2
Partial BDN
7.5
7.72
7.57
7.25
7.39
7.75
7.67
7.61
7.58
7.4-7.8
Post BDN
7.62
7.72
8.01
7.91
8.19
8.46
8.39
8.36
8.25
7.6-8.5
Final Effluent
7.61
7.91
7.82
7.84
8.19
8.38
8.38
8.32
8.2
7.6 -8.4
 1 Sample rounds conducted closest in time to the measurement are bolded.
 2 Range values are rounded to two significant digits.
                                                         49

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   Table 4-19. Event 2 -Turbidity Measurements (NTU).
DATE
8-4-99
8-5-99
8-6-99
8-7-99
8-8-99
8-9-99
8-10-99
8-11-99
8-12-99
TIME
INTERVAL
0931-1018
1003-1056
0925-1008
0825-0845
1448-1526
0855-0958
0921-0953
0804-0843
0915-0925
Associated
Round Nofs.)1
2-3,4,5
6-7,8,9
10-11,12
13,14
15,16
17-18,19,20
21-22,23,24
25,26,27,28
29-30,31
Mean3
SAMPLE POINT
Inlet Water
0.45
0.30
0.15
0.0
0.45
0.0
0.05
0.00
0.00
0.16
Partial BDN
0.95
0.35
0.85
0.9
0.25
0.3
0.4
0.25
0.5
0.53
Post BDN
8.3
4.7
7.2
7.6
2.7
5.0
4.5
2.2
0.5
4.7
Final Effluent
2.7
2.6
2.3
2.4
1.6
1.2
1.1
1.2
1.5
1.8
Pass/
Fail2
F
F
F
F
F
F
F
F
F
0/9
   1 Sample rounds conducted closest in time to the measurement are bolded.
   2 A sample round is considered passing if the final effluent is <1 NTU.  In the last row, the number of passing values is shown in the
   numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
   3 Mean values are rounded to two significant digits. Values < detection limit considered zero when calculating means.
Table 4-20. Event 2 - TSS Results (mg/l).
Sample
Round No.
3
7
11
13
16
18
22
26
30
Mean 2
SAMPLE POINT
Inlet Water
<5
<5
<5
< 5
<5
< 5
<5
< 5
<5
<5
Partial BDN
...
—
...
—
...
—
...
—
...
—
Post BDN
23
17.1
11
8
10.4
12
13.3
17.8
<5
13
Final Effluent
5.6
6
<5
< 5
<5
< 5
<5
9
<5
<5
Pass/
Fail 1
F
F
P
P
P
P
P
F
P
6/9
1 A sample round is considered passing if the final effluent value is < the inlet water value. In the last row, the number of passing values
is shown in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
2 Mean values are rounded to two significant digits. Values < detection limit considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                            50

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Table 4-21.  Event 2 - Microbial Results.1
Sample
Round
No.
3
7
11
16
18
22
26
Avg.
TOTAL CULTURABLE HETEROTROPHS - Plate Count Mean (cfu/ml)2
Inlet
Water 2
5,000
27,000
17,000
28,000
33,000
370,000
230,000
101,000









Post
BDN2
7,300,000
117,000,000
33,000,000
880,000,000
420,000,000
470,000,000
97,000,000
289,000,000









Final H % Carryover
Effluent ' 1 from BDN
380,000 | 5.2 %
3,300,000 | 2.8 %
250,000 | 0.8 %
620,000 | 0.7 %
130,000 | 0.03%
25,000,000 | 5.4 %
97,000,000 | 100%
18,100,000 | 6.3%
% Change from
Inlet Water
+ 7,600 %
+ 12,000%
+ 1 ,500 %
+ 2,200 %
+ 390 %
+ 6,800 %
+ 42,000 %
+ 18,000%
Pass/
Fail3
F
F
F
F
F
F
F
0/7
FACULTATIVE ANAEROBES - Plate Count Mean (cfu/ml)2
3
7
11
16
18
22
26
Avg.
2,900
3,100
320
220
520
2,400
3,400
1,840








360,000
760,000
320,000
1 1 ,000,000
9,600,000
19,000,000
15,000,000
8,000,000








85,000 | 24 %
70,000 | 9.2 %
150,000 | 53%
37,000 | 0.3 %
3,600,000 | 38 %
1 1 ,000,000 | 58 %
7,400,000 | 49 %
3,190,000 | 40 %
+2,800 %
+ 2,200 %
+ 47,000 %
+ 17,000%
+ 690,000 %
+ 460,000 %
+ 220,000 %
+ 170,000%
F
F
F
F
F
F
F
0/7
FECAL COLIFORM (Fecal coliforms/100ml)
3
7
11
16
18
22
26
Avg.
232
190
335
278
27
73
62
170








135
22
2
62
2
28
105
51








NG | 0 %
1 73 | 790 %
28 | 1 ,400 %
88 | 1 40 %
NG | 0 %
3 | 11 %
3 | 2.9 %
42 | 82 %
-100%
-9.1 %
-92%
-32 %
-100%
-96 %
-95%
- 75 %
P
P
P
P
P
P
P
7/7
1 Post-treatment for Event 2 consisted of clarification, followed by sand filtration, cartridge filtration, and UV oxidation.
2 Plate count mean = average of three separate analyses, reported in colony forming units per milliliter.
3 A sample round is considered passing if the final effluent value is £ the inlet water value. In the last row, the number of passing
values is shown in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
NG = No growth.
NC = Not calculated.
                                                           51

-------
corresponding inlet water  values.  Thus, the secondary
criterion was not met for TCH. The pre-UV oxidation mean
value for TCH was two orders of magnitude lowerthan the
final effluent plate count mean average, indicating thatthe
clarification and filtration preceding UV oxidation may have
been the only effective post-treatment. Based on the limited
results,  UV  was,  at best,  non-effective and, at worst,
detrimental with  respect to TCH treatment.  It  is not clear
whether the UV  oxidation system was correctly sized for
the role or whether other factors adversely affected its
utility.

As was  the case with Event 1, the FA data followed the
expected pattern to a certain degree.  The average ofthe
FA plate count means  for inlet water increased by three
orders  of magnitude  in  post  BDN effluent.  The post-
treatment effectiveness was improved  over Event 1, but
was inconsistent.  Final effluent plate  count  means for
individual  sample  rounds ranged from 37,000 cfu/ml to
11,000,000 cfu/ml.  None ofthe final effluent mean values
was less  than the inlet water mean  value. Thus,  the
secondary criterion was not  met for FA.   The sharp
increase (i.e., two orders of magnitude) for final effluent FA
values, starting midway through Event 2, could have been
the result of filter breakthrough.

For Event 2, the FC values in final effluent were below inlet
watervalues, both on a  per round and total average basis.
Thus, the secondary criterion was met for FC. The pre-UV
oxidation sample indicated UV oxidation to have no positive
    Table 4-22. Event 2- Methanol Results (mg/l).
effect on FC (refer back to Figure 4-5).
The methanol results in Table 4-22 indicate that methanol
was not detected in inlet water samples, but was detected
in  all  post BDN and  final  effluent samples.  The mean
methanol concentrations in  post BDN and final effluent
were 88 and 98 mg/l, respectively.  The post BDN and final
effluent values were alsoverysimilaron a per round basis,
indicating that  the UV oxidation post-treatment had no
effect on reducing residual methanol concentrations. The
secondary criterion of < 1 mg/l was, therefore, not met for
any of the sample rounds.
Table 4-23 presents results of supplemental analyses for
all outfalls sampled. The majority of these results indicate
thatthe BDN and post-treatment systems to had little to no
effect  on  the  measured  parameters.  The  mean
concentration of CCI4 detected  in  the inlet water during
Event 2 was small (i.e., 1.4 ug/l). CCI4 was not detected in
effluent samples.  This indicates that the compound  was
either volatilized or biodegraded during the BDN process.
The only other VOC detected was chloroform, which was
measured at a low concentration in the final effluent.
The somewhat  significant increase in TOC following BDN
can be attributed  to the  carryover of biological  material
and/or methanol. The increased alkalinity following BDN is
consistent with  the slight increase in pH (refer to Table 4-
18). The  small amounts of phosphate and  phosphorus
measured in  effluent  samples is residuum from the 50%
Sample Round
No.
3
7
11
13
16
18
22
26
30
Mean2
SAMPLE POINT
Inlet Water
<0.23
<0.23
<0.23
<0.23
< 0.23
<0.23
< 0.23
<0.23
< 0.23
<0.23
Partial BDN
...
—
—
...
—
...
—
...
—
...
Post BDN
46
73
160
90
21
60
100
68
170
88
Final Effluent
34
70
180
110
39
94
100
77
180
98
Pass/
Fail 1
F
F
F
F
F
F
F
F
F
0/9
     1 A result is considered passing if the final effluent value is < 1 mg/l. In the last row, the number of passing values is shown in the
     numerator; the total number of values is shown in the denominator.
     2 Mean values are rounded to two significant digits. Values < detection limit considered zero for calculating means.
     NG = No growth.
     Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                     52

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   Table 4-23. Event 2 - Supplemental Analyses Results (mg/l).
SAMPLE
ROUND NOs.
7, 16, 26
7,16,26
7, 16, 26
7, 16, 26
7, 16, 26
7, 16, 26
7, 16, 26
7, 16, 26

7, 16, 26
7, 16, 26
7, 16, 26
7, 16, 26
7, 16, 26
7. 16. 26
Analyte 2
CCI4
Chloroform
Total Solids
Ammonia
Total Organic Carbon
Sulfate
Phosphate
Alkalinity
SAMPLE POINT
Inlet Water
< 0.001 4
< 0.001
877
< 0.8
1.1
80
< 0.082
162
Partial BDN
	
	
	
	
	
	
	
	
Post BDN
< 0.001
< 0.001
612
< 0.8
47
77
1.2
374
Final Effluent
< 0.001
0.002
600
< 0.8
45
76
	
370

Barium
Calcium
Potassium
Magnesium
Sodium
Phosphorus
0.078
130
1.8
37
12
<0.35
	
	
	
	
	
	
0.073
123
1.7
37
13
1.3
0.072
123
1.6
38
13
1.3
    Values are the Mean of the three test results and are rounded to a maximum three sign if leant dig its.
   2Exceptfor CCI4 only SW-846 Method 8260 contaminants with mean values above detection limits are reported.
    Metals analyzed for included Ag, Al, Ba, Be, Ca, Cd, Co, Cr, Cu, Fe, K, Mg, Mn, Mo, Na, Ni, P, Sb, and Zn.
   Dashed line indicates that sam pies collected at that location were not analyzed for that parameter.
methanol solution, which contains food grade phosphoric
acid.

4.4.2.5  Mass Removal of Nitrate

The percent mass removal of nitrate, measured as Nitrate-
N, was estimated for Event  2  (Objective 4). A total of
approximately 45,000 gallons, or about 170,000 liters of
well water was treated during Event 2. Each mg/l of nitrate-
N  is equivalent to  4.4 mg/l of nitrate.  Since the  mean
nitrate-N concentration forEvent2 inlet waterwas about68
mg/l, the total mass of nitrate treated during Event 2 would
be (68 x 4.4)mg/l x 170,000 liters = 51,000,000 mg. The
mean nitrate-N concentration for Event 2 final effluent was
4.1 mg/l. The total mass of nitrate in the final effluent = (4.1
x 4.4) mg/l x 170,000  liters = 3,000,000 mg. Therefore the
mass  removal  of  nitrate  during  Event  2  would  be
approximately52,000,000 mg-3,000,000 mg = 49,000,000
mg (a 94% reduction  in nitrate).  This correlates to 49,000
grams or 108  pounds.  Adding  the  nitrite-N  in the final
effluent would reduce the removal by 2 pounds.
4.4.2.6  System Performance Vs. Flow Rate

The  performance of EcoMat's  combined  BDN and post-
treatment system components were evaluated with respect
to water flow  through the system  (Objective 2). The
variation in inlet water flow  rate  during Event  2 was
compared  with the total-N concentrations  in  the final
effluent.  Figure 4-6  directly  compares the  Event  2
fluctuation for inlet water flow rate to the Event 2 fluctuation
in total-N  final effluent concentrations  throughout  the
duration of Event 2. As was the case with the first event
the flow rate  and  final effluent  total-N  concentrations
patterns are similarto one another; although there was a
lot more variability during the first half of the eventtesting.
Nonetheless, the inverse relationship showing lower flow
rates consistent with increased BDN  effectiveness is still
apparent.  Similarto Event 1 a rather sharp decrease  in
flow  rate occurred about one quarter the way through the
event  and  correlated  to  a  sharp reduction  in  total-N
concentration.  The  plot in figure 4-6 also indicates that the
system became stabilized past the halfway point of Event
2. Once again, other operating  factors  may mask  the
expected correlation of flow and denitrification.
                                                       53

-------
      5-1
      4 —
      3 -
      2-
      1 -
  Sample
 Round No.'
                                                                             Inlet Water
                                                                             Flow (gpm)
                                                                                                   -20
                                                                                                   - 16
                                                                                                   — 8.0
                                                                                                   -4.0
12
           16
                      20
                                                                           24
                                             28
Figure 4-6. Event 2 - Comparison of Flow Rate Fluctuations and Final Effluent Total N-Concentrations.
4.4.3 Events

4.4.3.1 Summary

Event 3 was a 9-day sampling episode conducted October
20-28,1999. During Event 3, a total of 30 sampling rounds
were   conducted and  ~  49,000  gallons  of  nitrate-
contaminated  well  water  passed  through    EcoMat's
treatment system at an average flow rate of 4 gpm. Flow
rates   among  the  individual  sampling  rounds varied
considerably, ranging  between ~2 and 7 gpm.  Based on
the average flow rate, and an estimated retention capacity
of 1,300 gallons forthe reactor tanks, the sampling rounds
were normally conducted three times per day.  However,
due to the high variability in flow rate, the sample rounds
were conducted at intervals anywhere between  3-7 hours
apart.

Figure 4-7 illustrates the effectiveness of the EcoMat BDN
and post-treatment systems used for Event 3. The mean
nitrate-N  concentration in PWS Well #1 during   Event 3
was 38 mg/l. This concentration was significantly less than
              that measured for Event 2, which occurred approximately
              21/2 months  earlier. During  the partial  BDN  in  the first
              reactor (R1), the mean nitrate-N levels were  reduced  by
              about 47%, with a small amount of nitrite generated by the
              nitrate to nitrite conversion.  Subsequent treatment in the
              EcoMat reactor (R2) further reduced the mean nitrate-N
              concentration from of  20  mg/l to 7.7 mg/l. The average
              nitrite-N concentration  increased from 1.3 mg/l to 2.9 mg/l
              between  partial and post-BDN samples.  Mean total-N
              effluentconcentrationofapproximatelyl 1 mg/l was attained
              by the  BDN  treatment for Event 3 samples.

              Event 3 post-treatment consisted of ozone followed by UV
              oxidation followed by clarification. Clarification was followed
              by "rough" filtration,  "high  efficiency" filtration,  carbon
              adsorption, and "polishing" filtration. The  post-treatment
              system had no effect on nitrate-N or nitrite-N levels. When
              rounded  to  two  significant digits,  the  mean  total-N
              concentrations for post-BDN and final effluent samples
              were -11 mg/l and 9.9 mg/l, respectively.
                                                     54

-------
              60 i—
              40
              20
INLET
WATER
(from PWS
Well#1)


38
(38/ND)




	







	



^
f


PARTIAL BDN
7 TREATMENT
	 v (R1 Effluent)


R1
De-
Oxygenating
Tank

> 	
A


Event 3


Flow© 4.1 gpm



Legend
21 = Total-N concentration (mg/l)
(20/1 .3) = Nitrate-N / Nitrite-N concentration (mg/l)


BDN = Biodenitrification
Nn = Nnt Hetarterl > Hatertinn limits
_21_r>( __ A POST BDN
(20/1. 3K

	 '
KZ
EcoMat
Reactor
L J
TREATMENT
(R2 Effluent)
11 ,. Post
(7.7/2.9) Treatment
(See below)
FINAL
EFFLUENT
	 ^ g_g
^ (8.3/1.6)
               0 —
                             Event 3 Post-Treatment Effectiveness
      Post BDN
      MeOH = 41
      TSS = < 5
      Turbidity = 1.3
      TCH = 6.7x106
      FC = 50
      FA = 6x105
                        Final Effluent

                        MeOH = 41
                        TSS = < 5
                        Turbidity = 1.2
                        TCH = 6.9x105
                        FC = 5
                        FA = 1.7 x 10s
      Figure 4-7. Event 3 - Treatment Effectiveness for Averaged Test Results.
4.4.3.2 Event 3 Statistical Analysis

The summary statistics for the critical measurements are
presented in Table 4-24. Nitrate-N, nitrite-N, and total-N
results for the four sampling locations for all 30 Event 3
sample rounds are shown in Table 4-25. The mean values
from these data were to evaluate the  primary objective
(Objective 1) and for generating Figure 4-7.
Table 4-24. Event 3 - Summary Statistics.
Critical
Measurement
Post BDN Total-N
Final Effluent
Nitrate-N
Final Effluent
Nitrite-N
Final Effluent
Total-N
Mean
(mg/l)
10.613
8.347
1.545
9.897
Median
(mg/l)
10.950
8.350
1.400
9.825
Standard
Deviation (mg/l)
3.706
2.854
0.851
2.978
The  EDA indicated  that the data from Event 3 closely
resembled a normal distribution, except for the post BDN
data. When Shapiro-Wilk tests  were run, normality was
accepted for all variables except the  post BDN data. For
these data neither the normal nor lognormal distribution
was  shown to fit the  data. Therefore, the non-parametric
WSR was chosen for analyzing the post BDN data and the
median was used as the appropriate measure of central
tendency. The Student's t-test was chosen for analyzing
the otherthree measurements (i.e., final effluent nitrate-N,
final  effluent nitrite-N, and final effluent total-N), thus the
mean was used as the appropriate  measure of central
tendency.

Statistical hypothesis tests thatwere conducted yielded the
following  results:

       Part I: For the  Post BDN total-N  data, both the
       mean of 10.613 mg/l and the median of 10.950
       mg/l were above the criterion of 10.5 mg/l. Thus,
       no statistical test was needed  to determine thatthe
       Post BDN data did not meet that criterion.
                                                    55

-------
   Table 4-25. Event 3 - Nitrate-N and Nitrite-N Results (mg/l).
Inlet Water
Sample
Round1 Nitrate- Nitrite- Total-
N N N2
1 43.9 < 0.076 43.9
2 41.8 < 0.076 41.8
3 44.1 < 0.076 44.1
4 45.7 < 0.076 45.7
5 45.3 < 0.076 45.3
6 41. 8 J < 0.076 41 .8 J
7 41.1 <0.076 41.1
8 41.8 < 0.076 41.8
9 40.3 < 0.076 40.3
10 40.4 < 0.076 40.4
11 38.5 < 0.076 38.5
12 40.3 < 0.076 40.3
13 38.9 < 0.076 38.9
14 39.0 < 0.076 39.0
15 38.7 < 0.076 38.7
16 36.9 < 0.076 36.9
17 36.8 < 0.076 36.8
18 37.3 < 0.076 37.3
19 36.8 < 0.076 36.8
20 37.1 < 0.076 37.1
21 36.6 < 0.076 36.6
22 35.4 < 0.076 35.4
23 35.5 < 0.076 35.5
24 35.3 < 0.076 35.3
25 34.8 < 0.076 34.8
26 34.7 < 0.076 34.7
27 33.7 < 0.076 33.7
28 33.6 < 0.076 33.6
29 32.7 < 0.076 32.7
30 31.4 < 0.076 31.4
Mean2 38 J ND 38 J
Partial BDN
Nitrate- Nitrite- Total-
N N N2
10 1.4 11.4
22.3 1.7 24
19.9 1.4 21.3
23.7 1.8 25.5
22.4 1.8 24.2
18.7 1.7 20.4
21.6 1.5 23.1
7.6 1.8 9.4
17.3 3.0 20.3
23.9 0.74 24.6
26.9 0.96 27.9
27.1 1.1 28.2
26.3 1.1 27.4
24.6 1.1 25.7
23.7 0.88 24.6
22.3 0.89 23.2
22.5 0.77 23.3
14.4 0.76 15.2
24.1 0.66 24.8
25 0.63 25.6
23 0.69 23.7
22.4 0.88 23.3
21.8 0.78 22.6
20 0.91 20.9
14.1 2.9 17
10 3.0 13
13.3 1.9 15.2
15.2 1.7 16.9
7.5 0.99 8.49
19 0.8 19.8
20 1.3 21
Post BDN
Nitrate- Nitrite- Total-
N N N2
3.9 4.0 7.9
6.4 2.6 9.0
6.4 3.0 9.4
6.6 2.0 8.6
12 3.0 15
6.7 3.2 9.9
10.1 2.8 12.9
7.2 3.4 10.6
10.5 2.8 13.3
7.5 2.5 10
12.5 2.9 15.4
12.2 3.7 15.9
12.1 3.7 15.8
11.4 3.7 15.1
9.2 1.8 11
8.8 3.3 12.1
8.5 3.1 11.6
<.056 0.19 0.19
8.7 2.2 10
10.1 2.9 13
9.6 3.2 12.8
8.9 3.7 12.6
8.3 3.4 11.7
7.0 3.2 10.2
4.5 2.5 7.0
2.5 2.6 5.1
8.0 3.0 11
4.8 3.3 8.1
0.15 1.2 1.35
7.4 3.0 10.4
7.7 2.9 11
Final Effluent
Nitrate- Nitrite- Total-
N N N2
1.7 0.44 2.14
5.3 0.85 6.15
8.9 0.95 9.85
7.6 <0.076 7.6
13.3 1.1 14.4
9.4 1.1 10.5
9.9 1.1 11
11 1.4 12.4
8.2 1.3 9.5
7.4 1.1 8.5
12.2 1.3 13.5
12.6 2.5 15.1
12.7 2.4 15.1
11.8 2.1 13.9
9.1 3.5 12.6
8.6 1.8 10.4
7.8 2.0 9.8
5.4 1.5 6.9
8.4 0.84 9.24
11.1 1.1 12.2
6.6 1.4 8.0
9.1 1.6 10.7
8.3 <0.076 8.3
9.4 0.38 9.78
5.5 3.0 8.5
2.5 2.6 5.1
7.8 2.6 10.4
5.2 2.5 7.7
5.6 1.9 7.5
8.0 2.0 10
8.4 1.5 9.9
1  Represents a sample set in which samples from all four locations were collected at the approximate same time.
2 Represents combined Nitrate-N and Nitrite-N. Values below the detection limit were considered 0.0 when summing totals.
3 Means are rounded to two significant digits. Values < detection limit considered zero when calculating means.
J = Estimated value. ND = Not detected at or above MDL.
                                                                   56

-------
•       Part II: Final Effluent did not meet its performance
        estimate since the nitrite-N mean was above the
        1.5 mg/l criterion.

Based on the results of these 2 hypothesis tests, Event 3
was not shown to be successful in reducing levels of nitrite-
N and nitrate-N to below  regulatory limits.

4.4.3.3  General Evaluation of BDN System

Table 4-26 presents the post-BDN and final effluent nitrate-
N; the nitrite-N; and total-N results for the four sampling
points for each of the  30 Event 3 sampling rounds.  Also
included in  Table 4-26 are additional analytical data and
field  measurement results that were used for evaluating
other performance criteria. A total of 11 of the 30 sample
rounds showed reductions in nitrate-N, nitrite-N, and total-
N in  the final effluent to  below the respective regulatory
criteria (when the results  are rounded to the nearest whole
number). Results for other performance  criteria indicated
a steady  improvement  in  mean  turbidity values  with
substantially less biological carryover than in the first two
events.  However, those same results indicated thatneither
the ozone nor the  UV oxidation treatment was effective in
reducing mean residual methanol concentrations to below
1 mg/l.

The daily DO measurements in Table 4-27 showed DO in
the partially treated BDN  effluent to be consistently above
1 mg/l and  to  average slightly over 2 mg/l for  the entire
event. Although the deoxygenating process was effective
in reducing  mean inlet  water DO of 9.5 mg/l down to ~ 2
mg/l,  the  elevated DO   values  are  an  indicator  that
anaerobic processes were not optimized. This was a likely
contributing  factor  to the poorer performance of Event 3
with respect to nitrate-N  and nitrite-N reduction. Also, the
addition of  ozone as  a  post-treatment  step  did  not
significantly increase the  DO of the final effluent.

4.4.3.4  General Evaluation of Post-Treatment System

The field and laboratory measurements used primarily for
evaluating the post-treatment component of the EcoMat's
Process during Events (Objective 5) included pH, turbidity,
TSS,   microbial  analyses,   residual  methanol,   and
"supplemental analyses".
The daily pH measurements in Table 4-28 showed little to
no change between all four sample points. Potential pH-
altering  post-treatment units used during  Event 3, such as
ozone, apparently had  no impact on pH.

The daily turbidity  measurements in Table 4-29 indicate
that although just two  of nine final effluent values were
measured below the secondary drinking water criteria of 1
NTU,  the  1.2  mean value of NTU in  the final effluent
showed continued improvement from Events  1 and 2.

The TSS data in Table 4-30 showed that  the inlet water
contained no detectable levels of TSS and the post BDN
effluent to contain detectable levels of TSS in six of the
nine rounds. The final effluent data indicated that the post-
treatment system  had a positive effect on reducing TSS
levels in  all but one  of those  rounds, and that the  final
effluent mean TSS value was below the detection limit.
Two of nine final  effluent values were higher than their
paired inlet water value. Thus, the secondary criteria was
met for seven of nine  rounds. Therefore, the combination
of filters used for Event 3 was, for the most part, effective.
Table 4-31 presents the laboratory results for Total TCH,
FC, and  FA at each of the four outfalls. An additional
sample was collected immediately upstream  of the  UV
oxidation unit and analyzed for TCH and FC to evaluate
that  post-treatment  system  independently  of  ozone
treatment (refer to Figure 4-7).

The  results of the  TCH  analyses  indicated the TCH
population  associated  with the BDN process was, on
average,  two orders of magnitude higher than TCH levels
in the well water. On average, approximately 10 percent of
this bacteria carried over from the BDN process to the final
effluent (similar to that measured for Event 2).  And,  like
Event2, all seven final effluentTCH values were measured
to  be above their paired inlet water values.  Thus,  the
secondary criterion was not met for TCH.

The pre-UV oxidation mean value for TCH (obtained from
the added sample  point upstream of the UV oxidation unit)
was the same  order of magnitude  as the average of the
mean inlet water values. Therefore, the ozone treatment
may not have had any effect on TCH. The post-treatment
train downstream of the ozone unit may have had all of the
impact for reducing TCH levels in final effluent.

Like the  two previous events, the FA data generally
followed the expected pattern of greatly  increasing in  the
post-BDN effluent and then greatly decreasing in  final
effluent due to post-treatment  (the values for round # 23
were an  exception). The average  of the FA plate count
mean values in inlet water was increased by one order of
magnitude  in  post  BDN  effluent. The post-treatment
effectiveness was improved over both previous events, but
the results were skewed by the unexplainable final effluent
mean value for round # 23. Only one of the final effluent
mean values was less than the corresponding  inlet water
mean value. Thus, the criterion was  not met for FA. (It
should also be noted that the  inlet water in  round #19
exhibited an unusually high FA).
For Event 3, a small amount of FC  was measured in final
effluent of round 1 only. There was no FC measured in the
paired inlet water sample for round 1. Conversely, there
was FC measured in  the last inlet water sample collected
(round 30). A similar number of colonies was measured in
the corresponding post BDN sample,  but no FC  was
measured in the final  effluent. On a per round basis the
                                                    57

-------
Table 4-26.  Event 3 - Summary of Treatment Effectiveness.
Nitrate-N/Nitrite-N Results
Sample
Round1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Mean4
Post BDN
Total-N

7.9
9.0
9.4
8.6
15
9.9
12.9
10.6
13.3
10
15.4
15.9
15.8
15.1
11
12.1
11.6
0.19
10
13
12.8
12.6
11.7
10.2
7.0
5.1
11
8.1
1.35
10.4
11
Nitrate-N

1.7
5.3
8.9
7.6
13.3
9.4
9.9
11
8.2
7.4
12.2
12.6
12.7
11.8
9.1
8.6
7.8
5.4
8.4
11.1
6.6
9.1
8.3
9.4
5.5
2.5
7.8
5.2
5.6
8
8.4
(mg/l)
Final Effluent
Nitrite-N Total-N2

0.44
0.85
0.954
<0.076
1.1
1.1
1.1
1.4
1.3
1.1
1.3
2.5
2.4
2.1
3.5
1.8
2.0
1.5
0.84
1.1
1.4
1.6
<0.076
0.38
3.0
2.6
2.6
2.5
1.9
2.0
1.5

2.14
6.15
9.85
7.6
14.4
10.5
11
12.4
9.5
8.5
13.5
15.1
15.1
13.9
12.6
10.4
9.8
6.9
9.24
12.2
8
10.7
8.3
9.78
8.5
5.1
10.4
7.8
7.5
10
9.9

Flow
(gpm)
—
3.9
4.4
2
5
3.6
5
4.3
4.9
3.6
4.6
4.9
4.7
5.7
4.3
4.7
4.3
2.3
4.8
5
4.6
4.5
4.5
7.2
3.3
4
5
5.2
3.3
4.8
4.2
Final Effluent - Other Performance Criteria
MeOH TSS Turbidity pH 3 Total Heterotrophs 3
(mg/l) (mg/l) (NTU) (SU) (CFU/ml)
59 <5 1.4 8.1/7.9 46,000/310,000
—
—
32 <5 1.1 8.1/8.2
42,000/360,000
—
—
—
62 <5 1.0 8.1/8.0 18,000/110,000
—
—
—
27 <5 0.64 8.2/8.0
—
—
—
35 5 1.0 8.1/8.0
—
34 7 1.8 8.2/8.0 180,000/630,000
—
—
—
54 <5 1.1 — 17,000/49,000
—
—
—
30 <5 1.9 8.1/8.1 14,000/240,000
—
—
33 <5 0.84 8.2/8.1 120,000/3,200,000
41 <5 1.2 7.9-8.2 63,000/690,000
1 Represents a sample set in which samples from all four locations were collected at the approximate same time.
2Total-N is equal to the combined Nitrate-N + Nitrite-N concentration.
3 The first value represent the inlet water and the second value represents the final effluent.
4 All values, except forthe pH range, are means rounded to two significant digits. Values < detection limit considered zero for calculating means.
Dashed line indicates that sam pies collected at that location were not analyzed for that param eter.
                                                                        58

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Table 4-27. Event 3 - Dissolved Oxygen Measurements (mg/l).
DATE
10-20-99
10-21-99
10-22-99
10-23-99
10-24-99
10-25-99
10-26-99
10-27-99
10-28-99
TIME
INTERVAL
1300
1100
0800
0900
1400
1045
1630
1130
0800
Associated
Round No(s.)1
1,2,3
4,5,6,7
8,9,10,11
12-13,14
15,16,17
18-19,20,21
24,25
26,27,28,29
30
Mean
SAMPLE POINT
Inlet Water
9.20
9.18
9.18
9.25
10.0
9.62
—
9.37
10.3
9.5
Partial BDN
1.90
1.91
1.91
2.56
2.59
2.62
—
1.66
1.66
2.1
Post BDN
3.9
3.24
0.6*
4.1
3.74
2.10
—
2.65/0.2*
2.22
3.1/0.4
Final Effluent
4.88
8.67
7.90
1.23
0.44
6.51
—
3.21
3.68
4.6
1 Sample Rounds conducted closest in time to the measurement are bolded.
2 Mean values are rounded to two significant digits.
3 Average of two readings.
* Measurement taken inside R2 tank due to air bubbles in hose.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-28. Events - pH Measurements.
DATE
10-20-99
10-21-99
10-22-99
10-23-99
10-24-99
10-25-99
10-26-99
10-27-99
10-28-99
TIME
INTERVAL
1300
1100
0800
0900
1400
1045
1630
1130
0800
Associated
Round No(s.)1
1,2,3
4,5,6,7
8,9,10,11
12-13,14
15,16,17
18-19,20,21
24,25
26,27,28,29
30
Range
SAMPLE POINT
Inlet Water
8.08
8.05
8.09
8.22
8.10
8.19
—
8.11
8.15
8.1 -8.2
Partial BDN
8.09
7.94
8.03
8.12
8.06
8.03
—
8.14
8.06
7.9 -8.1
Post BDN
8.15
8.15
8.16
8.17
8.17
8.15
—
8.21
8.18
8.2 -8.2
Final Effluent
7.93
8.17
8.03
8.00
7.98
8.02
—
8.10
8.06
7.9-8.2
1 Sample rounds conducted closest in time to the measurement are bolded.
2  Range values are rounded to two significant digits.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                            59

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 Table 4-29. Event 3 - Turbidity Measurements (NTU).
DATE
10-20-99
10-21-99
10-22-99
10-23-99
10-24-99
10-25-99
10-26-99
10-27-99
10-28-99
TIME
INTERVAL
1300
1100-1400
0800-0900
0900
1400
1045
1630
1130
0800
Associated
Round(s)1
1,2,3
4,5,6,7
8,9,10,11
12-13,14
15,16,17
18-19,20,21
24,25
26,27,28,29
30
Mean3
SAMPLE POINT
Inlet Water
—
0.13
0.10
0.32
0.18
0.65
0.17
0.21
0.15
0.24
Partial BDN
—
0.38
0.65
0.39
1.38
...
1.60
—
4.25
1.4
Post BDN
—
1.20
2.14
0.86
1.10
1.51
1.09
1.67
0.95
1.3
Final Effluent
1.4
1.07
1.03
0.64
1.02
1.82
1.06
1.86
0.84
1.2
Pass/
Fail2
F
F
F
P
F
F
F
F
P
2/9
 1 Sample rounds conducted closest in time to the measurement are bolded.
 2 A round  is considered passing if the final effluent is < 1 NTU.  In the last row, the number of passing values is shown in the numerator;
  the total  number of values (pass + fail, minus any blank values) is shown in the denominator
 3 Mean values are rounded to two significant digits.
 Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-30. Event 3 -TSS Results (mg/l).
Sample
Round No.
1
4/5
9
13
17
19
23
27
30
Mean2
SAMPLE POINT
Inlet Water
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
Partial BDN
—
...
—
...
—
...
—
...
—
...
Post BDN
6
5
6
<5
<5
5
5.3
8
<5
<5
Final Effluent
<5
<5
<5
<5
5
7
<5
<5
<5
<5
Pass/
Fail1
P
P
P
P
F
F
P
P
P
7/9
1 A round is considered passing if the final effluent value is < the inlet water value. In the last row, the number of passing values is
shown in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
2 Mean values are rounded to two significant digits. Values < detection limit considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                           60

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Table 4-31.  Events - Microbial Results.1
Sample
Round
No.
1
5
9
19
23
27
30
Avg.
TOTAL CULTURABLE HETEROTROPHS - Plate Count Mean (cfu/ml)2
Inlet
Water 2
46,300
42,000
17,700
183,000
17,300
14,200
120,000
62,900









Post
BDN2
3,100,000
7,550,000
3,370,000
5,150,000
4,230,000
21,300,000
1,970,000
6,670,000









Final H % Carryover
Effluent2 | from BDN
305,000 I 9.8 %
362,000 | 4.8 %
113,000 I 3.4%
632,000 | 12%
49.0004 I 1 .2 %
240,000 | 1.1 %
3,160,000 I 160%
694,000 | 10%
% Change from
Inlet Water
+ 660 %
+ 860 %
+ 640 %
+ 350 %
+ 280 %
+ 1 ,690 %
+ 2,600 %
+ 1,100%
Pass/
Fail3
F
F
F
F
F
F
F
0/7
FACULTATIVE ANAEROBES - Plate Count Mean (cfu/ml)2
1
5
9
19
23
27
30
Avg.
2,300
3,300
2,000
350, OOO4
470
1,000
2,100
51,600








240,000
1,100,000
430,000
1,900,000
190,000
65,000
290,000
602,000








16,000 | 6.7%
3,500 I 0.3 %
7,100 | 1.7%
1,5004 I 0.1 %
12,000,000" | 6,300%
2,200 I 3.4 %
8,400 | 2.9 %
1,720,000 | +290%
+ 700 %
+ 6.1 %
+360 %
- 99 %
+ 2,500,000 %
+ 220 %
+ 400 %
+ 3,300 %
F
F
F
P
F
F
F
1/7
FECAL COLIFORM (Fecal coliforms/100ml)
1
5
9
19
23
27
30
Avg.
NG
NG
NG
NG
NG
NG
378
54








NG
NG
NG
NG
NG
NG
348
50








33 I NC
NG | NC
NG I NC
NG | NC
NG I NC
NG | NC
NG I 0 %
5 | 10%
NC
NC
NC
NC
NC
NC
-100%
- 91 %
F
—
—
—
—
—
P
1/2
1 Post-treatment for Event 3 consisted of chlorination, ozonation, UV treatment, a clarifying tank, high efficiency filtration,
 carbon filtration,  and polishing filtration.
2 Plate count mean = average of three separate analyses, reported in colony forming units per milliliter.
3 A round is considered passing if the final effluent value is < the inlet water value. In the last row, the number of passing values is
shown in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
4 Anomalous results indicate potential problems with sampling or labeling. No corrective action is required. Data are suspect
 and should be used with extreme caution.
NG = No growth. NC = Not calculated.
                                                              61

-------
criterion for FC was met for one of two rounds for which
any FC growth occurred; no growth occurred in the inlet
water, post-BDN, orfinaleffluentforthe otherfive tests. No
FC was  detected  in the single analysis of the sample
collected between  the ozone and UV oxidation treatment
units during the 3rd round of Event 3 (refer to Figure 4-7).
Thus, no evaluation of UV oxidation  effectiveness can be
made with respect to FC based on these limited data.

The laboratory results in Table 4-32 indicate that methanol
was  not detected in inlet water samples, but was detected
in  all post  BDN and final effluent samples.  The mean
concentration of methanol in post BDN and final effluent
were both 41 mg/l. The post BDN and final effluent values
were very similar on a per round basis,  indicating that the
combined ozone and UV oxidation post-treatment had no
effecton reducing residual methanol concentrations. Thus,
the secondary criterion of achieving  a final effluent with  <
1 mg/l  methanol was not met.
Table 4-33 presents the results of supplemental analyses
for all outfalls sampled. The majority of the supplemental
analyses results indicates  the BDN and post-treatment
systems  to have  little  to  no  effect on the  measured
parameters. As was the case with the  previous event,  a
small average  concentration of CCI4 (i.e.,  19 ug/l) was
detected in  the inlet water during Event 3. Based on a post
BDN mean  value of 10 ug/l and a final effluent estimated
mean value of  1ug/l for CCI4, the post-treatment system
(likely  the  UV  oxidation)  may have contributed  to  the
   Table 4-32. Event 3 - Methanol Results (mg/l).
reduction of that VOC contaminant.
The increase in TOC following BDN can  be attributed to
the carryover of biological material and/or methanol. The
increased alkalinity following BDN is consistent with the
slight increase in pH  (refer to Table  4-28). The small
amounts of phosphate and phosphorus measured in the
effluent samples  is  residuum from  the  50% methanol
solution, which contains food grade phosphoric acid.

4.4.3.5  Mass Removal of Nitrate
The percent mass removal of nitrate, measured as Nitrate-
N, was estimated for  Event 3  (Objective 4). A total of
approximately 49,000 gallons, or about 185,000 liters of
well water was treated during Event 3. Each mg/l of nitrate-
N  is equivalent to 4.4  mg/l of nitrate. Since the  mean
nitrate-N concentration for Event 3 inlet water was 38 mg/l,
the total mass of nitrate treated during Event 3 final effluent
was (38 x 4.4) mg/l x 185,000 liters = 31,000,000 mg. The
mean nitrate-N concentration for Event 3 final effluent was
8.3 mg/l. The total mass of nitrate in the final effluent = (8.3
x4.4) mg/l x 185,000 liters =  6,800,000 mg. Therefore the
mass  removal of   nitrate   during  Event  3 would  be
approximately 31,000,000 mg-6,800,000 mg = 24,000,000
mg (a 77% reduction in nitrate).  This correlates to  24,000
grams or 53 pounds. Considering the residual nitrite-N in
the final effluent, the nitrate-N reduction would decrease to
51 pounds.
Sample
Round No.
1
4/5
9
13
17
19
23
27
30
Mean2
SAMPLE POINT
Inlet Water
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
Partial BDN
...
...
...
...
...
...
...
...
...
...
Post BDN
83
33
34
38
42
31
49
35
26
41
Final Effluent
59
32
62
27
35
34
54
30
33
41
Pass/
Fail1
F
F
F
F
F
F
F
F
F
0/9
  1 A round is considered passing if the final effluent value is < 1 mg/l. In the last row, the number of passing values is shown
    in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
  2 Mean values are rounded to two significant digits. Values < detection limit considered zero when calculating means.
  Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                     62

-------
   Table 4-33. Event 3 - Supplemental Analyses Results (mg/l).1
Sample
Round No.
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27

4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
4/5,17,27
Analyte *
CCI4
Total Solids
Ammonia
Total Organic
Sulfate
Phosphate
Alkalinity
SAMPLE POINT
Inlet Water
0.019
582
<0.8
1.1
59
< 0.082
157
Partial BDN
...
—
...
—
...
—
...
Post BDN
0.01
459
<0.8
24
55
1.4
252
Final Effluent
o.oou
467
<0.8
21
56
1.4
250
Metals
Barium
Calcium
Potassium
Magnesium
Sodium
Phosphorus
0.069
103
1.4
28
13
<0.37
—
...
—
—
...
—
0.068
103
1.2
29
15
1.6
0.067
102
1.2
30
16
1.6
   1 Values are the mean of the three test results and are rounded to a maximum three significant digits.
   2 Except for CCI4 only SW-846 8260 contaminants with mean values above detection limits are reported.
    Metals analyzed for included Ag, Al, Ba, Be, Ca, Cd, Co, Cr, Cu, Fe, K, Mg, Mn, Mo, Na, Ni, P, Sb, and Zn.
   J = Estimated average value. Dashed line indicates that samples collected at that location were not analyzed for that parameter.
4.4.3.6  System Performance Vs. Flow Rate

The  performance of EcoMat's  combined BDN and post-
treatmentsystem components wereevaluated with respect
to water  flow  through  the  system  (Objective  2).  The
variation  in inlet water flow rate  during  Event  3  was
compared with the total-N  concentrations in the  final
effluent.    Figure  4-8  directly  compares  the Event 3
fluctuation for inlet water flow rate to the Event 3 fluctuation
in total-N final effluent concentrations on a perround basis.
The patterns for both plots reflect the high variability in flow
rate for Event 3, but still do suggest an inverse correlation
with system performance.  Again, a relationship between
lowerflow rate and increased BDN effectiveness is evident
where the somewhat sharp decrease in flow rate occurred
about one  quarter the  way through the  event, which
correlates with a  reduction in total-N concentration.  The
plots in  Figure 4-8 also indicate that the system was never
really stabilized which in large part  was due to system
perturbations that disrupted Event 3.
                                                       63

-------
       5-
      4-
      3-
      2 -
      1 -
 Sample
Round No.
                     Event 3
                                          12
                                                      16
                                                                 20
 I
24
                                                                                       28
                                                                                                   1-28
                                                                                                    -24
                                                                                                    • 20
                                                                                                      16
                                                                                                    -12
                                                                                                    -8.0
                                                                                                    -4.0
Figure 4-8. Event 3 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N Concentration.
                                                      64

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4.4.4 Event 4

4.4.4.1 Summary

Event  4  was  an  8-day  sampling episode  conducted
December 7-14, 1999. During  Event 4  a  total  of 30
sampling rounds were conducted and • »61,000 gallons of
nitrate-contaminated well water passed through EcoMat's
treatment system at an average flow rate of 6 gpm.  The
flow rate  among the 30 sampling rounds ranged between
4.7and 8.3 gpm. Based on an estimated retention capacity
of 1,300 gallons for the reactor tanks, the sampling rounds
were conducted • »2 to 3/4 hours apart and from three to
five times per day.

Figure 4-9 illustrates the effectiveness of the EcoMat BDN
and post-treatment systems evaluated during Event 4. The
mean  nitrate-N  concentration in PWS   Well  #1  had
continued to drop in the six-week period since the Event 3
testing in  October. The mean concentration of nitrate-N in
the well water during the fourth event was 34 mg/l. During
the partial BDN in the first reactor (R1), the mean nitrate-N
levels were reduced by about 44% to 19 mg/l, with a small
amount of nitrite  left over from  the  nitrate  to nitrite
conversion. Subsequent treatment in the EcoMat reactor
(R2) further reduced the mean nitrate-N concentration from
19  mg/l to 8  mg/l.  The mean  nitrite-N  concentration
increased from 1.3 mg/l to 3.2 mg/l between partial BDN
and post-BDN samples. A mean total-N concentration of
approximately 11 mg/l was attained by the BDN treatment
for Event 4 samples.
Event 4 post-treatment consisted of chlorination followed
by clarification, "high efficiency" filtration, air stripping, and
"polishing" filtration. The  post-treatment system  had no
effect on nitrite-N levels;  mean nitrate-N concentrations
were  reduced from 3.2 to 0.81 mg/l. The mean total-N
concentrations for post-BDN and final  effluent samples
were 11.2 mg/l and 11.9 mg/l, respectively.
            60 t—
             40
             20
INLET
WATER
(from PWS
Well#1)


J4
(34/ND)






PARTIAL BDN
•\7 TREATMENT
. 	 ^ (R1 Effluent)

R1
r\ i
De-
Oxygenating
Tank

V J

s~ ^s.
20 t>
(19/1)



R2
EcoMat
Dp9f*t/\r


POST BDN
TREATMENT
(R2 Effluent)
11 r.
(8/3) V

Event 4
Flow @ 6.2 qpm


20 = Total-N

Legend
concentration (mg/l)
(19/1) = Nitrate-N / Nitrite-N concentration (mg/l)
BDN = Biodenitrification
ND = Not detected > detection limits


Post
Treatment
(See below)
V S

FINAL

— D> 12
(11/0.8)

                           Event 4 Post-Treatment Effectiveness
    Post BDN
    MeOH = 27
    TSS = < 5
    Turbidity = 1.1
    TCH = 3.5x106
    FC = >7
    FA=1.9x105
                      Final Effluent

                      MeOH = 42
                      TSS = < 5
                      Turbidity = 0.96
                      TCH = 4.5x105
                      FC = 9
                      FA = 2x104
    Figure 4-9. Event 4 - Treatment Effectiveness for Averaged Test Results.
                                                    65

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4.4.4.2  Event 4 Statistical Analysis

The summary statistics for the critical measurements are
presented in Table 4-34.  Nitrate-N,  nitrite-N, and total-N
results for the four sampling locations  for all 30  tests
comprising Event 4 are shown in Table 4-35.  The mean
values from these data were used in generating Figure 4-9.
Table 4-34. Event 4 - Summary Statistics.
Critical
Measurement
Post BDN Total-N
Final Effluent
Nitrate-N
Final Effluent
Nitrite-N
Final Effluent
Total-N
Mean
(mg/l)
11.197
10.63
0.870
1 1 .993
Median
(mg/l)
10.550
11.750
0.076
12.076
Standard
Deviation (mg/l)
5.079
5.023
1.523
5.324
These data were also used  to  evaluate  the  Primary
Objective (Objective 1).

The  EDA showed that the  data  from Event 4  closely
resembled a normal distribution, exceptforthe finaleffluent
nitrite-N data which had a large percentage of non-detects.
When Shapiro-WiIk tests were run, normality was accepted
forall measurements except the final effluent nitrite-N data.
Forthesedata neitherthe normal norlognormal distribution
was shown to fit. Therefore, the non-parametric WSR was
chosen foranalyzing the final effluent nitrite-N data, butthe
Student's t-test was chosen for analyzing the post BDN
total-N, final effluent nitrate-N, and final effluent total-N.

Statistical hypothesis tests thatwere conducted yielded the
following results:

        Part I: For the Post BDN total-N data, both the
        mean and median were above 10.5 mg/l, so  no
        statistical test was needed to  determine that the
        Post BDN data did not meet the regulatory limit.

•       Part II: Final Effluent did not meet its performance
        estimate criteria since both the nitrate-N mean and
        median concentrations were >  10.5 mg/l.

Based on the results of these 2 hypothesis tests, Event 4
was not shown to be successful in reducing levels ofnitrite-
N and nitrate-N  to below regulatory limits.

4.4.4.3  General Evaluation of BDN System

Table 4-36 presents the post-BDN and final effluent nitrate-
N; nitrite-N and total-N results for the four sampling points
for each of the 30 Event4 sampling rounds. Also included
in  Table 4-36 are  additional  analytical data  and field
measurement  data  that were  used  for evaluating other
performance criteria. A total of 11 of the 30 sample rounds
showed reductions in nitrate-N, nitrite-N, and total-N in the
final effluent to below the respective  regulatory criteria
(when  rounding  results to the nearest whole  number).
Other performance results indicated that, on average, the
Event 4 filtration  achieved the best removal of  biological
carryover among all four events, although the levels were
still well above inlet water levels.  The  secondary criteria
results also indicated  that the air stripping treatment was
not effective in reducing residual methanol  levels to near
the desired level  of 1 mg/l.

The daily DO measurements in Table 4-37  show that DO
in the partial BDN effluent was  consistently  above 1 mg/l,
averaged close to 3 mg/l,  and was  highly variable over the
entire event. System disruptions, including  unexplainable
shut-offs of the methanol feed pump,  contributed to the
erratic DO levels. Elevated DO values are an indicator that
anaerobic  processes  were  not  optimized and likely
contributed to the poor performance of Event 4 with respect
to nitrate-N and nitrite-N removal.

4.4.4.4  General Evaluation of Post-Treatment System

The field and  laboratory  measurements that were used
primarily for evaluating the post-treatment  component of
EcoMat's process during Event 4  (Objective 5) included
pH, turbidity, TSS,  microbial analyses,  methanol, and
"supplemental  analyses".
The daily pH measurements in Table 4-38 indicated a
continued increase for the inlet water from PWS Well # 1,
as compared to previous  events. However, the  pH range
appears to decrease following BDN treatment.

Although two final effluent pH values  were slightly outside
of the acceptable drinking water standard  range  of 6.5  -
8.5, the pH values forfinal  effluentwere improved over inlet
water values.
The final effluent turbidity measurements  in Table 4-39
were consistently the  lowest of all four events,  indicating
improved  post-treatment effectiveness with respect to
turbidity. Five  of seven final effluent measurements, and
the mean of the seven measurements, were below the
criterion of 1 NTU.

Table 4-40 presents the Event 4 laboratory results for TSS.
As was the case for Event 3, the data show that the inlet
water and post BDN effluent contain detectable levels of
TSS in just two of the eight samples. The final effluent data
indicated that  the post-treatment  system had a positive
effect on reducing TSS levels in  both  of  those  sample
rounds, and that the final effluent  mean TSS value was
below the detection limit. One of eight final effluent values
was higher than the paired inlet water value. Thus, the
                                                     66

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Table 4-35. Event 4 - Nitrate-N and Nitrite-N Results (mg/l).
Sample Inlet Water
Round1
Nitrate- Nitrite- Total-
N N N2
1 34.8 < 0.076 34.8
2 35 < 0.076 35
3 35 < 0.076 35
4 34.8 < 0.076 34.8
5 34.6 < 0.076 34.6
6 35.3 < 0.076 35.3
7 35.3 < 0.076 35.3
8 33.9 < 0.076 33.9
9 34.5 < 0.076 34.5
10 34 < 0.076 34
11 33.5 < 0.076 33.5
12 33.5 < 0.076 33.5
13 33.6 < 0.076 33.6
14 33.6 < 0.076 33.6
15 33.2 < 0.076 33.2
16 34 < 0.076 34
17 33.9 < 0.076 33.9
18 33.8 < 0.076 33.8
19 33 < 0.076 33
20 33.9 < 0.076 33.9
21 33.1 < 0.076 33.1
22 33 < 0.076 33
23 33.3 < 0.076 33.3
24 33 < 0.076 33
25 32.8 < 0.076 32.8
26 33.2 < 0.076 33.2
27 33.3 < 0.076 33.3
28 32.8 < 0.076 32.8
29 33.6 < 0.076 33.6
30 33.6 < 0.076 33.6
Mean3 34 < 0.076 34
Partial BDN
Nitrate- Nitrite- Total-
N N N2
25.4 0.68 26.1
27 0.43 27.4
26.8 0.39 27.2
25.6 0.48 26.1
27.4 0.48 27.9
26.6 0.5 27.1
18.3 1.4 19.7
19.8 1 20.8
19.1 0.92 20.0
21.1 1.1 22.2
17.1 1.5 18.6
20.3 0.65 21
20.7 1.5 22.2
20.6 1.6 22.2
21.3 1.4 22.7
13.5 2.4 15.9
15.3 2.5 17.8
22.3 1.3 23.6
10.8 <0.076 10.8
17.8 1.8 19.6
29.2 0.1 29.3
32.4 <0.076 32.4
15 <0.076 15
15.4 <0.076 15.4
9.4 <0.076 9.4
14.5 <0.076 14.5
13.4 2.3 15.7
14 2.3 16.3
7.9 1.4 9.3
7.9 1.2 9.1
19 0.98 20
Post BDN
Nitrate- Nitrite- Total-
N N N2
13.9 4 17.9
15.5 3.7 19.2
13 4.4 17.4
12.1 4.2 16.3
14.8 3.9 18.7
14 3.9 17.9
7 4 11
9.1 3.1 12.2
8.4 3.3 11.7
9.1 3.5 12.6
4.5 2.9 7.4
5.6 3.5 9.1
8 3.4 11.4
8.3 3.8 12.1
14.1 2.7 16.8
3 2.5 5.5
5.8 3.1 8.9
7 3.1 10.1
2.5 2.4 4.9
5.7 2.6 8.3
6.4 2.2 8.6
16.5 4.4 20.9
9.4 4.4 13.8
5 3.3 8.3
2.3 3.4 4.7
5.8 3 8.8
5.5 3.3 8.8
4.4 3 7.4
1.4 1.4 2.8
1.3 1.1 2.4
8.0 3.2 11
Final Effluent
Nitrate- Nitrite- Total-
N N N2
14.6 3.8 18.4
15.8 3.7 19.5
19.4 <0.076 19.4
16.8 <0.076 16.8
18.9 <0.076 18.9
18.6 <0.076 18.6
15.3 <0.076 15.3
12 <0.076 12
12.8 <0.076 12.8
13.8 <0.076 13.8
8.8 <0.076 8.8
10.6 <0.076 10.6
12 <0.076 12
12.1 0.73 12.8
17 <0.076 17
5.0 <0.076 5.0
7.6 <0.076 7.6
9.0 <0.076 9.0
5.1 <0.076 5.1
9.3 <0.076 9.3
12.5 <0.076 12.5
16.6 4.5 21.1
11.5 4.6 16.1
4.9 3.6 8.5
2.3 2.4 4.7
7.2 1.1 8.3
9.0 <0.076 9.0
7.6 <0.076 7.6
3.3 <0.076 3.3
2.5 <0.076 2.5
11 0.81 12
1  Represents a sample set in which samples from all four locations were collected at the approximate same time.
2 Represents combined Nitrate-N and Nitrite-N. Values below the detection limit were considered 0.0 when summing totals.
3  Means are rounded to two significant digits. Values < detection limit considered zero when calculating means.
                                                                   67

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Table 4-36.  Event 4 - Summary of Treatment Effectiveness.
Nitrate-N/Nitrite-N

Sample
Round
No.
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Mean3
Post BDN
Total-N1
17.9
19.2
17.4
16.3
18.7
17.9
11
12.2
11.7
12.6
7.4
9.1
11.4
12.1
16.8
5.5
8.9
10.1
4.9
8.3
8.6
20.9
13.8
8.3
4.7
8.8
8.8
7.4
2.8
2.4
11
Results
(mg/l)
Final Effluent
Nitrate-N
14.6
15.8
19.4
16.8
18.9
18.6
15.3
12
12.8
13.8
8.8
10.6
12
12.1
17
5
7.6
9
5.1
9.3
12.5
16.6
11.5
4.9
2.3
7.2
9
7.6
3.3
2.5
11
Nitrite-N
3.8
3.7
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
0.73
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
<0.076
4.5
4.6
3.6
2.4
1.1
<0.076
<0.076
<0.076
<0.076
0.81
Total-N1
18.4
19.5
19.4
16.8
18.9
18.6
15.3
12
12.8
13.8
8.8
10.6
12
12.8
17
5.0
7.6
9.0
5.1
9.3
12.5
21.1
16.1
8.5
4.7
8.3
9.0
7.6
3.3
2.5
12


Flow
(gpm)
7.9
7.9
6.7
7.7
7.7
7.5
7.1
7.9
8.3
5.9
5.5
7.7
7.4
8
5
6.2
5.5
5.2
6.8
6
5.3
6
5.9
5.4
6.7
6.1
6.2
4.7
4.7
6.2
Final Effluent - Other Performance Criteria

MeOH TSS Turbidity pH 2 Total Heterotrophs 2
(mg/l) (mg/l) (NTU) (SU) (CFU/ml)
<0.23 <5 0.85 9.0/6.8 22,000/1,400,000
—
—
—
33 <5 1.3 9.0/8.4
—
34,000/8,300
—
—
—
43 6 1.7 8.7/8.9 600,000/2,000
—
—
—
—
38 <5 0.95 9.2/8.2 9,800/1,200,000
—
—
20 <5 0.77 9.1/8.1
—
—
29 <5 0.77 9.1/8.3 5,200/1,300,000
—
—
43 <5 0.40 8.3/8.6 480,000
—
—
—
91 <5 — 9.0/8.2 5,200 / NG
37 <5 0.96 6.8-9.1 97,000/450,000
1 Total-N is equal to the combined Nitrate-N + Nitrite-N concentration.
2 The first value represents the inlet water and the second value represents the final effluent.
3 All values, except for the pH range, are means rounded to two significant digits. Values < detection limit considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                                68

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Table 4-37.  Event 4 - Dissolved Oxygen Measurements (mg/l).
DATE
12-7-99
12-8-99
12-9-99
12-10-99
12-11-99
12-12-99
12-13-99
12-14-99
TIME
INTERVAL
Not Available
1200
0915
Not Available
Not Available
Not Available
Not Available
Not Available
Associated
Round No(s.)
1-5
6-10
11-15
16-18
19-21
22-24
25-29
30
Mean1
SAMPLE POINT
Inlet Water
9.55
9.55
9.51
9.66
10.32
9.56
9.70
10.1
9.7
Partial BDN
5.65*
3.70
1.50
1.87
2.10
4.56**
1.34
1.28
2.8
Post BDN
—
4.89
—
3.88
3.65
—
—
...
4.1
Final Effluent
9.55
9.60
9.75
9.55
9.58
9.61
9.60
9.56
9.6
1  Mean values are rounded to two significant digits.
*  Discovered methanol feed pump off. Turned on 1 hour later.
** Discovered methanol feed pump off. Turned on 2 hours later.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-38.  Event 4 - pH Measurements
DATE
12-7-99
12-8-99
12-9-99
12-10-99
12-11-99
12-12-99
12-13-99
12-14-99
TIME
INTERVAL
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Not Available
Associated
Round No(s.)
1-5
6-10
11-15
16-18
19-21
22-24
25-29
30
Range1
SAMPLE POINT
Inlet Water
9.04
9.04
8.65
9.20
9.10
9.05
8.31
9.04
8.3 -9.2
Partial BDN
7.48
8.59
8.47
8.19
8.32
8.38
8.10
7.96
7.5 -8.6
Post BDN
—
8.25
8.40
8.13
8.33
8.45
8.88
8.30
8.1 -8.9
Final Effluent
6.79
8.37
8.93
8.15
8.10
8.27
8.63
8.17
6.8 -8.9
1 Range values are rounded to two significant digits.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                            69

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Table 4-39. Event 4 - Turbidity Measurements (NTU).
DATE
12-7-99
12-8-99
12-9-99
12-10-99
12-11-99
12-12-99
12-13-99
12-14-99
TIME
INTERVAL
1330
1000-1500
0815
0830
0715-1110
1445
0705
0830
Associated
Round No(s.)
1-5
6-10
11-15
16-18
19-21
22-24
25-29
30
Mean2
SAMPLE POINT
Inlet Water
0.05
0.00
0.00
0.03
0.00
0.05
0.00
0.05
0.02
Partial BDN
—
—
—
...
...
—
—
...
...
Post BDN
—
2.3/1.3
2.2/1.7
1.9/1.0
0.9/1.0
0.9/0.75
1 .3/0.9
...
1.6/1.1
Final Effluent
0.85
1.3
1.7
0.95
0.77
0.77
0.40
...
0.96
Pass/
Fail1
P
F
F
P
P
P
P
...
5/7
1 A round is considered passing if the final effluent is < 1 NTU. In the last row, the number of passing values is shown
  in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
2 Mean values are rounded to two significant digits.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
Table 4-40. Event 4 -TSS Results (mg/l).
Sample
Round No.
2
6
12
17
20
23
26
30
Mean
SAMPLE POINT
Inlet Water
<5
<5
<5
<5
<5
<5
<5
<5
<5
Partial BDN
—
...
—
...
—
...
—
...
...
Post BDN
<5
<5
12
<5
<5
6
<5
<5
<5
Final Effluent
<5
<5
6
<5
<5
<5
<5
<5
<5
Pass/
Fail1
P
P
F
P
P
P
P
P
7/8
1 A round is considered passing if the final effluent value is < the inlet water value.  In the last row, the number of passing values is shown
  in the numerator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
2 Mean values are rounded to two significant digits.  Values < detection limit considered zero when calculating means.
Dashed line indicates that samples collected at that location were not analyzed for that parameter.
                                                             70

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secondary drinking water criterion  was met for seven of
eight rounds, which indicated that the filter combination
used for Event 4 was, for the most part, effective.

Table 4-41 presents the laboratory results for TCH,  FA,
and FC, at each of the four outfalls. The data indicated the
TCH population associated with the BDN process was, on
average, two orders of magnitude higher than  TCH levels
in the well water. On average, approximately 13 percent of
this bacteria carried over from the BDN process to the final
effluent. This carryover was similar to that measured for
Events 2 and 3, which also had  filtration incorporated into
the post-treatment system.   However,  unlike the previous
two events, four of the seven  final effluent TCH values
were measured to be below  the corresponding inlet water
values on a per-round basis.  Thus, the secondary criteria
for TCH was met for those tests,  but not on an overall
average basis.
Like the previous three events, the FA data for Event 4
followed the expected pattern of greatly increasing in the
post-BDN effluent and then greatly decreasing in the final
effluent. The average of the FA plate count mean in the
inlet water was increased by three orders of magnitude in
post BDN  effluent. The  post-treatment  was  effective in
reducing the average mean post BDN effluent by one order
of magnitude. The average mean carryover for the seven
tests measured was 11 percent and four of the seven final
effluent mean values were less than the inlet water mean
value.  Thus, the secondary criterion for  FA was met for
those sample rounds, but not met on  an  overall average
basis.
For Event 4, FC was detected in six of the  seven  inlet
water samples collected. Of  these six samples FC carried
over to final effluent in only the first sample  (although the
FC in this sample was measured at a concentration above
that of the inlet water). The secondary criterion for FC was
met for five of six sample rounds. Comparable to Event 3,
results showed that on  average, the majority of FC  was
removed during Event 4 post-treatment.

Table 4-42  presents the Event 4 laboratory results for
methanol analyses conducted on inlet water, post-BDN
effluent, and final effluent. Methanol was  detected in  two
of  eight  inlet  water   samples   at  low   (estimated)
concentrations. Methanol was also detected in all  post
BDN and final effluent samples (many concentrations were
estimated values).  The  mean methanol concentrations in
post BDN  and final  effluent  were  27  and 42  mg/l,
respectively. With the exception of sample rounds 12 and
17, the post BDN and final effluent values were similar on
a per round basis. This indicates thatthe air stripping post-
treatment  did not have  a measured  effect on  reducing
residual methanol  concentrations,  except possibly  for
round 2, where an estimated 1mg/l of methanol in  post
BDN effluent was not detected  in the paired final effluent
sample. Thus, the secondary criteria of achieving  a  final
effluent with < 1 mg/l methanol was not met as a mean,
nor for 7 of the 8 sampling rounds.

Table 4-43 presents the results of supplemental analyses
for  all  outfalls sampled.  Most of the results of these
supplemental analyses indicate that the  BDN  and post-
treatment systems had little to no effect on the  measured
parameters. The only VOC detected in the inlet water was
a small amount of CCI4.  Since CCI4 was not detected in
either the  post BDN or final effluents, it is likely  that the
0.007 mg/l of that compound was volatilized or degraded
during  the BDN process.

The increase in TOC following BDN  can  be attributed to
carryover  of biological material  and/or  methanol.  The
subsequent drop  in  TOC in final effluent  may be an
indication  of a  positive  post-treatment impact  (e.g.,
filtration). The increased alkalinity following BDN, unlike the
other  three  events, does  not correlate  with  the  slight
decrease  in  pH  measurements  recorded for the  final
effluent (refer to  Table 4-38). The  small amounts  of
phosphate  and phosphorus  measured  in  the  effluent
samples is  residuum from  the 50%  methanol solution,
which contains food grade phosphoric acid.

4.4.4.5 Mass Removal of Nitrate

The percent mass removal of nitrate, measured as Nitrate-
N, was estimated  for Event 4 (Objective 4). A total of ~
61,000 gallons (-230,000 liters) of well water was treated
during  Event 4. Each  mg/l of nitrate-N is equivalent to 4.4
mg/l of nitrate. Since the mean nitrate-N concentration for
Event 4 inlet water was about 34 mg/l, the total  mass of
nitrate treated during Event 4 was (34 x 4.4) mg/l x 230,000
liters = 34,000,000 mg. The mean nitrate-N concentration
for  Event 4 final effluent was  11.4 mg/l. The total  mass of
nitrate  in the Event 4 final  effluent = (11 x 4.4) mg/l x
230,000 liters = 11,000,000 mg.  Therefore,  the  mass
removal of  nitrate would be  about 34,000,000  mg  -
11,000,000  mg = 23,000,000  mg (a 68% reduction  in
nitrate). This correlates to 23,000 grams or 51 pounds.
4.4.4.6 System Performance Vs. Flow Rate

The performance of EcoMat's combined  BDN  and post-
treatmentsystem components were evaluated with respect
to water flow through  the  system  (Objective  2).  The
variation  in  inlet water  flow  rate during Event  4  was
compared  with the total-N concentrations  in the  final
effluent.   Figure  4-10 directly compares the Event 4
fluctuation for inlet water flow rate to the Event 4 fluctuation
in total-N final effluent concentrations on a  perround basis.
As was the case with third event, Event 4 was typified by
rather high variability in flow rate and system performance.
The pattern for both of the plots reflects a very close
relationship  between flow rate  and system performance.
There is also an obvious trend of steady flow rate reduction
coupled with a steady BDN improvement from start to
                                                    71

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Table 4-41. Event 4 - Microbial Results.1
Sample
Round
No.
2
8
12
17
23
26
30
Avg.
TOTAL CULTURABLE HETEROTROPHS - Plate Count Mean (cfu/ml)2
Inlet
Water 2
21,500
33,500
600,000
9,800
5,200
4,000
5,200
97,000









Post
BDN2
7,500,000
5,800,000
3,800,000
1,950,000
1,970,000
1,800,000
1,700,000
3,500,000









Final
Effluent 2
1,370,000
8,300
2,000
670
1,300,000
480,000
0
450,000
% Carryover
from BDN
18%
0.14%
0.05 %
0.03 %
66%
27%
0%
13%
% Change from
Inlet Water
+ 6,400 %
- 75 %
- > 99 %
- 93 %
+ 25,000 %
+ 12,000%
- 100 %
+ 460 %
Pass/
Fail3
F
P
P
P
F
F
P
4/7
FACULTATIVE ANAEROBES - Plate Count Mean (cfu/ml)2
2
8
12
17
23
26
30
Avg.
180
190
260
180
1,200
440
340
400








88,000
90,000
440,000
130,000
380,000
120,000
80,000
190,000








9,200
58
28
6
130,000
440
2,400
20,300
10%
0.06 %
0.01 %
0.01 %
34%
0.4 %
3%
11 %
+ 5,100%
- 70 %
- 89 %
- 97 %
+ 11,000%
0.0 %
+ 700 %
+ 5,100%
F
P
P
P
F
P
F
4/7
FECAL COLIFORM (Fecal coliforms/100ml)
2
8
12
17
23
26
30
Avg.
40
94
158
210
38
55
NG
85








48
TNC
NG
NG
NG
NG
NG
>7








62
NG
NG
NG
NG
NG
NG
9
130%
0%
0%
0%
0%
0%
NC
NC
1.6
-100%
- 100%
-100%
- 100%
-100%
NC
- 89 %
F
P
P
P
P
P
—
5/6
1 Post-treatment for Event 4 consisted of chlorination, clarification, high efficiency filtration, air stripping, and polishing filtration.
2 Plate count mean = average of three separate analyses, reported in colony forming units per milliliter.
3 A result is considered passing if the final effluent value is < the inlet water value.
NG = No growth. NC = Not calculated.  TNC = Too Numerous to Count.
                                                                72

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Table 4-42. Event 4 - Methanol Results (mg/l).
Sample
Round No.
2
6
12
17
20
23
26
30
Mean2
SAMPLE POINT
Inlet Water
2.8 J,
<0.23
<0.23
<0.23
<0.23
<0.23
<0.23
0.3 J,
0.4 J
Partial BDN
—
—
—
—
—
—
—
—
...
Post BDN
1 J
14
4.1 J,
5.1 J2
37 J2
32 J2
43 J2
79 J2
27
Final Effluent
<0.23
33
43 J2
38
55 J2
29 J2
43
91
42
Pass/
Fail1
P
F
F
F
F
F
F
F
1/8
1 A round is considered passing if the final effluent value is < 1 mg/l. In the last row, the number of passing values is shown
  in the nu merator; the total number of values (pass + fail, minus any blank values) is shown in the denominator.
2  Mean values are rounded to two significant digits. Values < detection limit considered zero when calculating means.
J1 These values should be considered estimates due to the uncertainty in the low end of the curve.
J2 These values should be considered estimates due to the possibility of peak interferences from a second peak.
Dashed line indicates that sam pies collected at that location were not analyzed  for that param eter.
Table 4-43. Event 4 - Supplemental Analyses Results (mg/l).1
Sample Round
Nos.
6,17,27
6, 17,27
6,17,27
6, 17,27
6,17,27
6, 17,27
6,17,27

6,17,27
6,17,27
6, 17,27
6,17,27
6, 17,27
6,17,27
Analyte 2
CCI4
Total Solids
Ammonia
Total Organic Carbon
Sulfate
Phosphate
Alkalinity
SAMPLE POINT
Inlet Water
0.007
365
<0.8
< 1
54.8
< 0.082
147
Partial BDN
—
—
—
—
—
—
—
Post BDN
< 0.005
437
<0.8
49.8
54.8
1.4
225
Final Effluent
< 0.003
495
<0.8
16.2
54.7
0.84*
229
Metals
Barium
Calcium

Magnesium
Sodium
Phosphorus
0.061
82
Potassium
23
13
<0.37
—
—
1.1
—
—
—
0.055
91
—
25
15
1.5
0.052
87
1.21.1
25
33
1.5
1 Values are the mean of the three test results and are rounded to a maximum three significant digits.
2 Except for CCI4 only SW-846 Method contaminants with mean values above detection limits are reported.
 Metals analyzed for included Ag, Al, Ba, Be, Ca, Cd, Co, Cr, Cu, Fe, K, Mg, Mn, Mo, Na, Ni, P, Sb, and Zn.
                                                                   73

-------
    10 -I
     8 —
     6 —
     4 —
     2 —
 Sample
Round No."
                                       Final Effluent
                                       Total-N (mg/l)
                                                                                         Inlet Water
                                                                                         Flow (gpm)
 \
12
                                                           -20
                                                                                                     - 16
                                                                                                     -12
                                                                                                     -8.0
                                                                                                     -4.0
16
           20
                                                                             24
                                  28
Figure 4-10. Event 4 - Comparison of Flow Rate Fluctuation and Final Effluent Total-N Concentration
 finish. The only exception to this pattern is an abrupt sharp
 increase in the total-N levels about 3/4 of the way through
 the event. This anomalous peak is believed to be the result
 of an inadvertent shut off of the methanol feed pump that
 disrupted the treatment system.

 4.4.5   Inter-Event Comparison

 This   section  evaluates  the   overall  demonstration
 performance of the EcoMat BDN treatment system with
 respect to nitrate-N, nitrite-N, total-N and several key field
 and analytical parameters.  Direct comparisons are made
 among the  four events in order to investigate possible
 reasons for variable performance.

 4.4.5.1 BDN Performance

 Figure 4-11 shows the mean total-N concentrations for
 each individual event plotted against one another.   The
 mean  nitrate-N and nitrite-N  concentrations for all  tests
 conducted during a particular event are presented as data
 pairs in boxes. Several observations can be made from this
 figure. First, for all four events, the concentration of nitrate-
 N in the untreated inlet water  from PWS Well # 1 was well
 in excess of both the 10 mg/l  MCL and  the 20 mg/l
                threshold set for the demonstration. The inlet water nitrate-
                N concentrations were considerably higher for Events 1
                and 2, as compared to Events 3 and 4. Based on daily
                water level measurements taken during all four events,
                there was a significant water level drop of approximately 14
                feet in PWS Well # 1 between Events 2 and 3. Thus, there
                may  have been a corresponding drop  in the amount of
                nitrate being flushed into the well during  the dryer months
                preceding Events 3 and 4.

                Figure 4-11 also illustrates that, during the initial stages of
                BDN, the nitrate-N concentrations were reduced by similar
                percentages for all four events (i.e., 52-60%), while at the
                same time small amounts of nitrite-N were being generated
                from the  reduction of  nitrate. Following  BDN, the mean
                nitrate-N concentrations were further reduced to below 10
                mg/l, and mean nitrite-N concentrations increased forthree
                of the four events.  Following  post-treatment the  mean
                nitrite-N concentrations were reduced forallevents, except
                for Event 2, where the  mean nitrite-N level  remained
                essentially  the  same.  As  expected,   there   was  no
                appreciable difference  in the mean final  effluent nitrate-N
                concentration, following post-treatment.
                                                       74

-------
             60
       Combined
       NCV/NCV
      Concantration
        (mg/l)
                         INLET
                        WATER
                                                                                LEGEND
                                                                       43/3   = N03-N/N02-N Concentration in mg/l
                                                                             (Rounded to two significant digits)
                                                                      BDN = Biodenitrification
                                                                      ND = Not detected at or above detection limits
PARTIAL BDN
TREATMENT
                                                                                        FINAL
                                                                                      EFFLUENT
      Figure 4-11. Inter-Event Comparison - Treatment Effectiveness for Nitrate-N/Nitrite-N
4.4.5.2  Final Effluent Water Quality

Table  4-44 summarizes  relevant criteria-oriented final
effluent data  collected  during the  demonstration  as
averages  for  all  four  events. Except  for the  relevant
process parameters, all values represent final effluent
means. The  mean  DO  levels  for  water  exiting  the
deoxygenating tank have been  included  due  to  the
importance of that field measurement in determining proper
anoxic conditions. In general terms, the final effluent mean
nitrate-N concentrations increased when the DO was not
maintained near the desired 1 mg/l level.

The increased post-treatment following the first event had
less  impact than anticipated  (e.g.,  neither  the  carbon
filtration employed during  Event 3  nor  the air stripping
employed  during Event4 appears to have had a significant
impact on  methanol levels in the final  effluent).  Although
             TSS  and  turbidity  improved  to  or  near  acceptable
             concentrations when filtration was employed, carryover of
             biological material from the EcoMat reactor  to the final
             effluent remained considerable.

             None of  the oxidation  post-treatments (chlorination, UV
             oxidation, or ozone)  appeared  to  have  any beneficial
             effects on residual bacterial matter, methanol destruction,
             or re-oxidation of nitrite to nitrate. It is not known whether
             this was due to inappropriate sizing, variability in feed rate
             or other,  unknown factors. There also was  some question
             whether  ongoing  biodegradation was occurring in some
             sample containers between collection and  analysis. This
             could have taken place in BDN samples, resulting in lower
             methanol results before post-treatment, but would have
             been  inhibited in oxidized samples.  The overall EcoMat
             process appears to have little impact on pH.
                                                      75

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  Table 4-44. Inter-Event Comparison of Demonstration Criteria for Final Effluent.1
Parameter
Criterion
SAMPLING EVE NT
Event 1
(May 6-1 5)
Event 2
(August 3-12)
Event 3
(October 20-28)
Event 4
(December 7-14)
Process Parameters
Flow (dom)
Total Gallons Treated
DO in Partial BDN Effluent (mq/l)
3-15
...
...
3.0
42,000
1.1
3.5
45,000
1.0
4.2
49,000
2.1
6.2
61,000
2.8
Biodenitrification Parameters
Nitrate-N (mg/l)
Nitrite-N (mg/l)
Total-N (mg/l) 2
< 10
<1
< 10



4.1
1.5
5.6
8.3
1.5
9.9
11
0.8
12
Post-Treatment Parameters
Post-Treatment System
Residual Methanol (mg/l)
Turbidity (NTU)
Total Suspended Solids 3
pH Range (min-max)
Total Heterotrophs (% change)
Fac. Anaerobes (% change)
Fecal Coliform (% change)

< 1 mg/l
<1 NTU
< inlet water
6.5-8.5
< inlet water
< inlet water
< inlet water
>• Chlorination
>• Clarification
>• Sand Filtration
>• Rough Filtration
- UV Oxidation
15 98
4.4
<5/ 10
7.5-8.6
+ 19,000
+ 7,300
NC
1.8
<5/<5
7.6-8.4
+ 18,000
+ 170,000
-75
>• Ozone
- UV Oxidation
-Clarification
>• Rough Filtration
- High Eff. Filtration
>• Carbon Filtration
>• Polishing Filtration
41
1.2
<5/<5
7.9-8.2
+ 1,100
+ 3,300
-91
>• Chlorination
>• Clarification
- High Eff. Filtration
>• Air Stripping
>• Polishing Filtration
37
0.96
<5/<5
6.8-8.9
+ 460
+ 5,100
-89
  1 Values are means that have been rounded to a maximum two significant digits. Bolded values meet criteria;  shaded boxes denote best result of
   the four events.
  2 Total-N is equal to the combined Nitrate-N + Nitrite-N.
4.4.6   Data Quality Assurance

This section of the ITER contains a review of the critical
sample  data  and associated  QC  analyses  that  were
performed to determine whether the data collected were of
adequate  quality to provide  proper evaluation of the
project's technical objectives.  A more detailed summary
and  discussion  of quality  assurance/quality  control
information regarding the EcoMat SITE  demonstration is
included in  the TER.    The  results  of  the critical
measurements  designed  to  assess  the data quality
objectives are summarized in the following subsections.

4.4.6.1  Accuracy

Accuracy  objectives for  nitrate-N  and  nitrite-N  were
assessed  by  the evaluation  of 46  spiked  duplicates
analyzed in the same manner as the samples.  Recovery
values for the critical compounds were well within project
objectives, with two  exceptions.  Two of the samples
contained sufficient chemical (intentionally introduced into
the EcoMat treatment stream for this same purpose)  to
convert the nitrite spike added  to nitrate.  The chemicals
added, or treatments, were  done to convert the nitrite  to
nitrate and assist in meeting the 1 ppm concentration limit
for nitrite. The following adjustments were done:
        Event 1- Chlorination-calcium hypochlorite-
                pool filter chlorine tablets
        Event 2 - UV oxidation
        Event 3 - Ozone and UV oxidation
        Event 4 - Chlorine liquid
                                                      76

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Oxidation of the  nitrite to  nitrate  likely continued  after
sample  collection.  This oxidation  reaction is part of the
treatment process.  Any residual  nitrite  in the samples
would be considered more hazardous in  terms of health
effects  and  therefore  the oxidation  reaction  which is
considered  beneficial,  would convert residual nitrite to
nitrate, with total nitrate levels still expected to be below 10
ppm. Chemicals added in the final stage of treatment were
specifically designed for this purpose. This explains  poor
recoveries  of  some  of the  matrix  spikes  for nitrite.
Therefore, this is not believed to be an analytical problem.

It is likely that residual chemicals (e.g..chlorine and ozone)
continued to react with samples after spike addition and
prior to analysis. Low recoveries for matrix spikes in these
samples should therefore be treated as a "matrix problem"
due to a continued oxidation reaction.  LCS  results are
therefore considered as the "analytical indicator" showing
reasonable recovery of nitrite for these particular sample
batches.  The  preceding  text explains the rationale for
addition of oxidizing agents.

The  two spike recovery values (one from each of the
chemically treated Events 1 and 4)  are not included in the
statistical evaluation of the spikes;  therefore, a total of 44
of the 46 matrix spike/matrix spike duplicate (MS/MSD)
sample   sets  are  used  in  the  statistical  evaluation.
Recovery for nitrate-N averaged 95.4% and for nitrite-N the
average recovery was 95.8% (Tables 4-45 and 4-46).

4.4.6.2  Precision

Precision was assessed through the analysis of  44
duplicate spikes.  Again, 46 MS/MSD were performed by
the laboratory; however, due to the  conversion of nitrite to
nitrate  by the sample only 44 are  statistically evaluated.
Data quality objectives forprecision, established as relative
percent difference (RPD) values less than 15%, were met
with one exception.  Nitrate-as-nitrogen RPDs averaged
2.7% and nitrite-as-nitrogen  RPD values  averaged 2.1%
(Tables 4-47 and 4-48).
4.4.6.3  Detection Limits

Detection limits were established so as to be sufficiently
below  the  concentration  of interest (established  by
regulatory  limits) for  nitrite and  nitrate.    Nitrite had  a
detection limit of 0.076 mg/l with a concentration of interest
(decision point) of 1 mg/l.  Nitrate had a detection limit of
0.056 mg/l with a concentration of interest (decision point)
of 10 mg/l.  The concentration of interest for methanol was
established by the project since there is no regulatory level
for methanol in drinking water. The methanol concentration
of interest was established as 1.0 mg/l with a detection limit
of 0.23 mg/l.

4.4.6.4  Comparability

Comparability  was achieved through the use of QAPP
approved EPA protocols and verified by the validation of
analytical data, which indicated that QAPP and method-
specified criteria were met.

4.4.6.5  Completeness

Sufficient samples  were collected  to satisfy statistical
completeness  requirements. A minimum of 28 sample sets
were collected for each event for evaluating nitrate and
nitrite treatment effectiveness.

4.4.6.6  Representativeness

Representativeness refers  to the degree  with which  a
sample exhibits average properties of the waste stream at
the particular time being evaluated.  This is assessed in
part by the analysis of field duplicates, which also provide
insight into  the  homogeneity,  or heterogeneity, of the
matrix. Field duplicate samples have, inherent in the result,
combined field and analytical variability. For this project,
the primary sample and duplicate sample were collected
immediately after each other. These indicated reasonable
agreement in results, with RPD values for field duplicates
from all four events generally less than 25%. The average
RPD for nitrate was  10.9% and for nitrite 4.3% (Tables 4-
49 and 4-50).
                                                      77

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 Table 4-45.  Nitrate Matrix Spike Percent Recovery Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
Recovery Range
87.8% to 103.1%
86.9% to 105.4%
86.8% to 107.6%
89.4% to 108.1%
86.8% to 107.6%
Number of Duplicate Pairs
n=14
n=10
n=12
n=8
n=44
Percent Recovery Average
95.3%
93.7%
96.8%
95.7%
95.4%
 Table 4-46. Nitrite Matrix Spike Percent Recovery Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
Recovery Range
83.1% to 104.8%
92.0% to 103.4%
91. 6% to 107.1%
95.6% to 107.8%
83.1% to 107.8%
Number of Duplicate Pairs
n=14
n=10
n=12
n=8
n=44
Percent Recovery Average
90.8%
96.5%
99.0%
98.7%
95.8%
Table 4-47. Nitrate MS/MSD Relative Percent Difference Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
MS/MSD RPD Range
0.0% to 9.7%
1.4% to 4.9%
0.0% to 24.2%
0.2% to 3.8%
0.0% to 24.2%
Number of Duplicate Pairs
n=14
n=10
n=12
n=8
n=44
Average MS/MSD RPD
2.6%
2.9%
3.6%
1.5%
2.7%
Table 4-48. Nitrite MS/MSD Relative Percent Difference Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
MS/MSD RPD Range
0.4% to 7.1%
0.3% to 5.9%
0.0% to 6.5%
0.0% to 8.3%
0.0% to 8.3%
Number of Duplicate Pairs
n=14
n=10
n=12
n=8
n=44
Average MS/MSD RPD
2.1%
1 .4%
2.1%
3.1%
2.1%
                                                               78

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Table 4-49.  Nitrate Field Duplicate Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
RPD Range
0.0% to 108%
0.0% to 4. 7%
0.0% to 3.2%
0.0% to 23.9%
0.0% to 108%
Number of Field Duplicates
n=7
n=6
n=5
n=7
n=25
Average RPD
31.9%
0.8%
1 .5%
5.4%
10.9%
Table 4-50. Nitrite Field Duplicate Summary.
Event
Event 1 (May 99)
Event 2 (August 99)
Event 3 (November 99)
Event 4 (December 99)
Overall Demonstration
RPD Range
3.4% to 16.0%
0.0% to 3.5%
0.0% to 5.8%
0.0% to 5.9%
0.0% to 16.0%
Number of Field Duplicates
n=7
n=5
n=4
n=4
n=20
Average RPD
7.7%
1 .0%
3.5%
3.4%
4.3%
                                                                  79

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              Section 5.0
Other Technology Requirements
   Regu lation
5.1    Environmental
       Requirements
State and local regulatory agencies may require permits
prior to implementing  a  BDN technology.  Most federal
permits will be issued by the authorized state agency. An
air permit issued  by  the state Air Quality Control Region
may be required if an air  stripper is utilized as part of the
post-treatment system (i.e., if the air emissions are of toxic
concern or anticipated to be in excess of regulatory
criteria). Wastewater discharge permits may be required if
any such wastewater were to be discharged to a POTW.
If remediation is conducted at a  Superfund  site, federal
agencies, primarily the U.S.  EPA, will provide regulatory
oversight.  If off-site disposal of contaminated  waste is
required, the waste must be taken to the disposal facility by
a licensed transporter. Section 2 of this report discusses
the environmental regulations that may apply to the EcoMat
Inc. BDN treatment process.

5.2    Personnel Issues
The number of personnel required to operate the EcoMat
Biodenitrification technology  should be small and is not
critically dependent on  the size of the treatment system.
Large systems  may,  however,  require extensive  site
preparation and assembly operations that may require
several individuals (inclusive of contractors), especially if
there are constraints  on time.   For smaller  treatment
systems, requiring minimal site preparation, as few as one
person may be needed  to assemble and conduct the initial
startup testing of the system.

During the demonstration EcoMat, in most instances, had
one company employee at the pilot unit. They  also had
one local person  to  periodically monitor the system and
collect  samples  in  their absence.    Estimated  labor
requirements  for  a full-scale  100  gpm  system  are
discussed in detail in Section 3 of this report.
During the demonstration sampling events, two SITE team
members were required to conduct field measurements
and to collect and prepare samples.  Personnel present
during sample collection activities at a hazardous waste
site  must  have  current  OSHA health   and  safety
certification.  Although the BDN technology targets nitrate
and other inorganic contaminants, gas detection tubes
should be used to  monitor the air in the vicinity of the
treatment system to monitor for sulfide, chlorine, ozone,
and  other  potential  gases.   Respiratory   protective
equipment may be needed  in rare instances, but are not
anticipated.

At sites  with greater complexity  and  risk, the  personnel
protective equipment (PPE) for workers will include steel-
toed shoes or boots,  safety glasses,  hard  hats,  and
chemical resistant gloves.   Depending on contaminant
types,  additional PPE  (such as  respirators) may be
required.  Noise levels would usually not be a concern.
However,  loud pumps for  larger systems  could create
appreciable noise. Thus, noise levels should be  monitored
to ensure  that workers are not exposed to  noise levels
above the time weighted average of 85 decibels over an 8-
hour day. If this level is exceeded and  cannot be reduced,
workers would be required to wear  hearing protection.

5.3    Community Acceptance
Potential hazards to a surrounding community may include
exposure to air emissions of VOCs, if those contaminants
are also present in the water stream (along with the
nitrates). Ozone and chlorine  emissions are also possible
if such post-treatment is incorporated.
Overall,   there  are  few   environmental  disturbances
associated with the BDN processes. No appreciable noise
is anticipated beyond that generated by the short term use
of power washing  equipment  (used during  general
maintenance), or by  excessively loud pumps. Since most
units are contained  in a secured building,  disturbances
from the system are  kept within the building confines.
                    80

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                                             Section  6.0
                                        Technology Status
6.1    Previous Experience

The pilot-scale treatment system that was set up at the
Bendena, Kansas site was EcoMat's first application of
their BDN  technology  for treatment of contaminated
groundwater. Prior to this project, EcoMathas applied their
technology  to the commercial aquarium industry where
health of the fish is a prime economic concern.  EcoMat is
presently the only company to provide the denitrification
technology for the aquarium industry. EcoMat's systems
are applied  at the following aquariums.

       The John G. Shedd Aquarium (Chicago)
       The Albuquerque Biological Park Aquarium
       Biodome de Montreal
       New Jersey State Aquarium
       Sea World of Florida
       Large Aquarium System
       Colorado's Ocean Journey (Denver)

Based  on  their experience  gained during  the  SITE
Demonstration   in  Bendena,  EcoMat  has  improved
dissolved oxygen monitoring  by  inserting  a  dissolved
oxygen meter into their system.
Currently, EcoMat has installed a small reactor to remove
perchlorate from a  Department of Defense  facility  in
Southern California (see Appendix A). To treat perchlorate,
the process operates on the same principle as for  nitrate
treatment. In the absence of both dissolved oxygen and
nitrate, the bacteria take oxygen from perchlorate and yield
a simple chloride ion.
In-house research is being conductedforthe nitrification of
ammonia.  EcoMat has slightly  modified  their pilot-scale
reactor to permit the  addition of large amounts of air into
the reactor.  The bacteria used for  nitrification are very
differentfrom denitrification bacteria, in that they are highly
sensitive to a number of parameters.  EcoMat uses an on-
line fermentation process to continually produce them.
6.2    Ability to Scale Up
EcoMat has sold systems treating less than one gpm to
aquariums and has supplied  reactors as  large as three
cubic meters.  They currently have a single reactor design
that would treat influent at a flow rate of 200 gpm. EcoMat
has also indicated that there is no upper limit to capacity to
their technology. For very large systems multiple reactors
would be used.
                                                   81

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                                            Section 7.0
                                            References
EcoMat Inc. Internet Web Site, www.ecomatinc.com

Evergreen Analytical Laboratory. June3,1999; September
5, 1999; November 23, 1999; January 5, 2000; Analytical
Results (Data Packages) for samples submitted for SAIC
Project - EcoMat  Inc.'s  Biological Denitrification  and
Removal of Carbon Tetrachloride.
Hall, P.J. August, 2000. Perchlorate Remediation ata DOD
Facility (not published).

MicrobacLaboratories, Inc. -BioRenewal Division. May 27,
1999; September 1,1999; November 16, 1999; December
28,  1999. Results from Anaerobic Plate Count Analyses in
Connection with the EcoMat site located in Bendena,  KS.
Microbial  Insights,  Inc.  May  3,  1999.    Microbial
Characterization for EcoMat Inc.'s Biological Denitrification
Process: Analysis of Water  Samples  by  PLFA, Total
Culturable Heterotrophs, and Fecal Coliforms.

SAIC. April  1999. Quality Assurance  Project  Plan for
EcoMat  Inc.'s Biological  Denitrification  and  Removal of
Carbon  Tetrachloride at the  Bendena  site, Doniphan
County,  Kansas.
Shapiro, J.L., P. Hall, and R. Bean. January 2000. Ground
Water Denitrification  at a Kansas Well.  Presented at the
Technology Expo and International Symposium on  Small
Drinking  Water  and Wastewater  Systems,  Phoenix,
Arizona.
                                                   82

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         Appendix A
Developer Claims and Discussion

-------
Note:  Information  contained  in  this  appendix  was
provided   by  EcoMat,  Inc.  and  has   not  been
independently verified  by the U.S. EPA SITE Program

A.1     Case Study - Perchlorate Remediation
        at a DOD  Facility

The  site is a Department of Defense facility located in
Southern  California.   Under the Installation  Restoration
Program (IRP),  Earth Tech,  Inc. has a contract to provide
environmental  services,  including   evaluating   the
perchlorate levels in shallow groundwaterunderthe facility.
The  test  water that  they  pump   from  this activity is
temporarily stored in Baker tanks on the  site. The major
contaminant in this water is perchlorate, at concentrations
varying from 300 ppb to  1000 ppb.  Beginning in  October
1999 Earth Tech evaluated  EcoMat's ability to remediate
perchlorate and in December 1999 they  contracted with
EcoMat to  provide a small system forremoving perchlorate
from the test water.

A.1.1   Project Activity

EcoMat designed a system to  achieve  the  removal of
perchlorate from the Bakertanks within a period of several
months.   At  the  beginning there was not sufficient
information to determine the hydraulic residence time for
removal of perchlorate down to non-detectable levels, so
the  system  was designed for a residence   time  of
approximately one-half hour with an active volume of 200
liters. Given average tank volumes  of 20,000 gallons this
would enable complete reduction in a period of seven  days
after the bacteria are firmly established.

EcoMat had designed and built an  identical system  and
installed it  in the John G. Shedd Aquarium  in Chicago. The
design is described in the following section. It was built on
a single skid in our Hayward facility. Denitrification  bacteria
which had  been exposed to perchlorate were placed in the
reactors and then the entire  skid was loaded onto a panel
truck and driven down to Southern California.  At  the site,
it was lifted off the truck and placed in a temporary shelter
near the Baker tanks, and started up. Within a few days it
was  functioning and reducing perchlorate. After the first
few days the system's operation was transferred  to Earth
Tech, with telephone contact and advice from  EcoMat.

After several  months during which various operating
problems were dealt with, the tanks were completely clean
of perchlorate, below the detectable concentration.   The
system was then moved to  a similar site on the base,
where  it remains in operation.

A.1.2   System Design

The  system is best described using a flow diagram  (see
Figure A-1).  Water is drawn from the Baker tank into the
top of the deaeration reactor.   This reflects  a  basic
understanding by EcoMat that a two-stage process works
best for biological oxygen removal. In the deaeration tank
there is a large number of ordinary bio-balls that provide
surface for bacterial growth. The reactor is designed to
reduce the dissolved oxygen concentration from saturation
down  to  a  concentration  of 0.5-1.0 ppm.  This is the
optimum   concentration   for either  denitrification  or
perchlorate  remediation.    If  the dissolved  oxygen
concentration  rises  above one ppm, the remediation is
ineffective, and if itdrops to near-anaerobic concentrations,
the threat ofsulfate attack arises.  Hydrogen sulfide can be
injurious to the bacteria, stopping  the remediation activity.
Although  the  bacteria  can  be   revived  very easily  by
restarting the process, time is wasted if oxygen levels are
not monitored.

From the bottom of the deaeration reactor, water is then
drawn  into the bottom of the Hall reactor. This patented
reactor is the key element of EcoMat's process.  It is
designed to hold a mass of floating  media and maintain
continuous circulation of the media along with the water in
the reactor.  This mixing is attained without any internal
moving parts, but rather,  by external pump re-circulation
(as shown  in  Figure 4-2 of the  ITER).   Continuous
circulation is extremely important as it provides for uniform,
low concentrations of the contaminant under ALL influent
contaminant concentrations. This  factor is key to EcoMat's
success  in  both  denitrification  as well as  perchlorate
remediation  as it puts no upper limit on  the allowable inlet
concentrations.

At this  point we must say more about the EcoLink media
(see ITER cover). This is a polyurethane-based sponge
that is cut into one-centimeter cubes. The media last for a
very long time— up  to  several  years.  They  are  kept
reasonably  clean and capable  of  supporting bacteria
colonies by virtue of their gentle collisions with each other
and with  the walls of the reactor.  When functioning to
produce  a  gas, as  in  denitrification,  the  size  of the
interstitial spaces within the sponge is designed to permit
passage of gas out, as well as passage of water into, these
spaces.  At  the same time, the surface area involved is
sufficiently   great  to   provide   for   large  bacteria
concentrations and high interaction efficiency.
The overflow from the Hall reactor is recycled back into the
deaeration  reactor  during the  startup  period to  form
colonies  of bacteria. In normal operation the effluent is
discharged from the system.  In cases where  drinking
water purity is desired, a post-treatment system can  be
added  to the  process to control the  small  amount of
biosolids  that leaves the system.  This is the only residual
stream that  results from the process.  In case of upset
conditions, water can be returned to the Baker tanks.

Both reactors  require feed of a carbon source (electron
donor)  to feed the bacteria. EcoMat has studied a variety
of available sources and we find  that the  best one is
methanol.   Methanol residual of less  than  2  ppm is
                                                    A-1

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    BflKER
    TANK
  /~\ U-1   *»-!   I


-S«   *   >

s


fi-1 '
j

,

TUU-2
^ TtUl-1
i .- r~

DR1


                  mtat
                   M
  Figure A-1.  EcoMat Perchlorate Removal System.
considered non-hazardous and EcoMat's systems normally
run at undetectable concentrations  (below 0.5 ppm).
Methanol is notonly the lowestcostcommercially available
carbon source but it also  maintains the lowest level of
biosolids.  Alternative carbon  sources, such as ethanol,
tend to "gum up" the works.  The major requirement for
methanol  is  for removal  of  dissolved  oxygen  in  the
deaeration reactor, as oxygen  levels are so much greater
than perchlorate levels in the first stage of the process.  For
fire safety reasons, the methanol is  dissolved in water
(generally 50%).  The rate of feed of methanol is so small
that even if it were to exit unused, the concentration would
not reach hazardous levels.

It should be  noted that while the bacteria involved in
denitrification are hardy, best operations are realized when
temperatures are controlled between limits of 8 °C and 35
°C.  During  normal flow,  the influent  water  maintains
adequate  temperature  control.   During  startup, when
recirculation is 100% care should be taken to turn on the
circulation pump in the  Hall reactor for a relatively small
time period each day.

The way the system works is that the bacteria can "eat" a
constant rate of contaminant. Thus, the flow rate of water
through  the  system isn't  a significant parameter in  the
design.  The most significant system size factor, which
determines the basic system size, is the total amount of
material that is to be removed per day. This number is the
product of the flow times the concentration. For example,
for a system that will remediate 1000 gpm of water having
a concentration of 10 ppm, the amount of contaminant to
be removed is  120 pounds per day.   For  this example,
EcoMat estimates that it can build, own and operate this
system, at the  currently demonstrated sizing criteria, at
total cost to the customer of $.50 per thousand gallons.
A.1.3  Operations

The system was built on a skid that is four feet by four feet
in size. Startup operations involve continuously recycling
the water through the reactors while feeding methanol and
assuring that there is adequate perchlorate in the water.
This  recirculation  need  not be  constant, and in  warm
weather, when the bacteria might overheat, it is best to
circulate for  no more than a few hours per day. Periodic
measurements are made of the dissolved oxygen  levels
leaving the  de-aeration reactor.  When the dissolved
oxygen level is below 1.0 ppm  the system can be opened
in stages, until it is wide open.  After start-up, operations
remain continuous, and it is only necessary to check the
system once daily to be sure that no spurious upset has
taken place. The  methanol source  only needs  to be
replenished every few weeks.

At this  DOD  site  there  were  a  number  of upsets,
particularly during the early operating days. First, someone
driving by pulled the main power plug! A few days passed
before the operators realized  that there  was something
                                                    A-2

-------
wrong.  During  that time, the bacteria used up all of the
oxygen and perchlorate and started producing hydrogen
sulfide.     The  system  turned   black  and   smelled
characteristically of that material.  The system was re-
started and within  a  few days  it  returned  to  normal
operation.

Importantly, Earth Tech (the contractor  using  EcoMat's
system at the site) was not concerned with optimizing the
time for performing the remediation of the water from the
Baker tanks. With a retention time of one  half-hour, the
remediation proceeded sufficiently rapidly.   However,
based  upon EcoMat's denitrification experience, much
shorter retention times may be feasible for perchlorate
remediation, further reducing the cost of new systems.
EcoMat is pursuing this possibility.

A.1.4   Results

Measurements  were made by Earth Tech on  a  regular
basis.  As a result  of the  "closed loop" feature,  it was
possible to control the outlet so that only when the  effluent
perchlorate concentrations were below the allowable level
(ND) would water be discharged to a cleaned water baker
tank.   Initial results during  the startup  period were  as
follows in Table A-1  (in micrograms per liter):

A.1.5   Future  Plans

Reactors  15 times the  size of the subject reactor are
currently  in operation, and  EcoMat has designed reactors
as large  as 100 cubic  meters.   The reactors  may  be
ganged together to provide adequate volume for any flow
rate.  EcoMat  plans to offer its perchlorate remediation
process to customers  as  a  build-own-operate  package,
Table A-1
DATE
2/17
2/18
2/21
3/06
3/07
3/08
3/09
3/10
3/15
3/23
INLET
350
390
390
350
370
340
320
320
260
300
OUTLET
210
160
410*
ND
ND
9
ND
19
24**
ND
     * Power loss
     ** New Tank. When the Baker tanks were emptied, the
     system was moved to another location at the DOD site,
     where it is presently in operation.
with pricing in the range of $.50/1,000 gallons.

A.1.6   Conclusions

It appears to EcoMat that this system is one of the most
inexpensive ways to remediate perchlorate from water. For
very  large systems it  would be cost effective to implement
on-line measurement capabilities with SCADA systems to
transmit data to a remote operations center, facilitating
satisfactory operations.
                                                    A-3

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