United States
          Environmental Protection
          Agency
           Office of Research and
           Development
           Washington DC 20460
EPA/540/R-94/508
September 1995 '
vvEPA
J.R. Simplot Ex-Situ
Bioremediation
Technology for Treatment of
Dinoseb-Contaminated Soils

Innovative Technology
Evaluation Report
                SUPERFUND INNOVATIVE
                TECHNOLOGY EVALUATION

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                                      CONTACT

Wendy Davis-Hoover is the EPA contact for this report.  She is presently with the newly
organized National Risk Management Research Laboratory's new Land Remediation and Pollution
Control Division in Cincinnati,  OH (formerly the Risk Reduction Engineering Laboratory).  The
National Risk Management Research Laboratory is headquartered in Cincinnati, OH, and is now
responsible for research conducted by the Land Remediation and Pollution Control Division in
Cincinnati.

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                                              EPA/540/R-94/508
                                                September 1995
                   J.R. SEMPLOT
       EX-SITU BIOREMEDIATION TECHNOLOGY

                FOR TREATMENT OF
           DEVOSEB-CONTAMINATED SOILS

   INNOVATIVE TECHNOLOGY EVALUATION REPORT
NATIONAL RISK MANAGEMENT RICSEARCH LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
              CINCINNATI, OHIO 45268
                                             Printed on Recycled Paper

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                                         NOTICE
The information in this document has been prepared for the U.S. Environmental Protection Agency's
(EPA's) Superfund Innovative Technology Evaluation (SITE) Program under Contract No. 68-CO-0048.
This document has been subjected to EPA's peer and administrative reviews and has been approved for
publication as an EPA document. Mention of trade names of commercial products does riot constitute an
endorsement or recommendation for use.
                                             11

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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 meet this 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 is the  Agency's center for investigation of
technological and management approaches for reducing risks from threats to human health and the
environment.  The  focus of the Laboratory's research program is on methods for the prevention and
control of pollution to air, land, water and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites and ground water; and prevention and control of indoor air
pollution. The goal of this research effort is to catalyze development and implementation of innovative,
cost-effective environmental technologies; develop scientific and engineering information needed by EPA
to support regulatory and policy decisions; and provide technical support and information transfer to
ensure effective implementation of environmental regulations and strategies.

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.
                                            E. Timothy Oppelt, Director
                                            National Risk Management Research Laboratory
                                              ill

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                                 TABLE OF CONTENTS
 Section
Page
 NOTICE	   ii
 FOREWORD  	  iii
 LIST OF TABLES	vii
 LIST OF FIGURES	vii
 ACKNOWLEDGEMENTS	  viii

 Executive Summary	 ,,	   1

 Section 1      Introduction	   5

        .1     Background	   5
        .2     Brief Description of Program and Reports	   6
        .3     The SITE Demonstration Program	   7
        .4     Purpose of the Innovative Technology Evaluation Report (ITER)	   8
        .5     Technology Description	   8
       1.6     Key Contacts	   9

 Section 2      Technology Applications Analysis	   11

       2.1     Key Features of the J.R. Simplot Ex-Situ Bioremediation Technology	   11
       2.2     Technology Performance versus ARARs during the Demonstration  ..'..-	   12
       2.3     Operability of the Technology		   18
       2.4     Applicable Wastes	   19
       2.5     Availability and Transportability of Equipment	  20
       2.6     Materials Handling Requirements	  21
       2.7     Range of Suitable Site Characteristics	  22
       2.8     Limitations of the Technology 	  23
       2.9     ARARs for the J.R.  Simplot Ex-Situ Bioremediation Technology	  24

              2.9.1  Comprehensive Environmental Response, Compensation, and
                    Liability Act (CERCLA)	  25
              2.9.2  Resource Conservation and Recovery Act (RCRA)	  26
              2.9.3  Clean Air Act (CAA)	  28
              2.9.4  Safe Drinking Water Act (SDWA)	  28
              2.9.5  Toxic Substances Control Act (TSCA)	  28
              2.9.6  Occupational Safety and Health Administration Requirements (OSHA)  .  .  29

Section 3       Economic Analysis   	  30

       3.1     Introduction	  30
       3.2     Conclusions	 .  30
       3.3     Issues and  Assumptions   	  31
       3.4     Basis for Economic Analyses	  34

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 Section
                              TABLE OF CONTENTS (Continued)
Page
                3.4.1   Site and Facility Preparation Costs	   35
                3.4.2   Permitting and Regulatory Costs	   39
                3.4.3   Equipment Costs	   39
                3.4.4   Startup and Fixed Costs  	   40
                3.4.5   Labor Costs	   41
                3.4.6   Supplies Costs	   42
                3.4.7   Consumables Costs	   42
                3.4.8   Effluent Treatment and Disposal Costs	   42
                3.4.9   Residuals and  Waste Shipping, Handling and Transport Costs	   43
                3.4.10  Analytical Costs	   43
                3.4.11  Facility Modification,  Repair and Replacement Costs	   43
                3.4.12  Site Restoration Costs  	   44

 Section 4      Treatment Effectiveness During the SITE Demonstration	   45

        4.1    Background	   45
        4.2    Detailed Process Description	   46
        4.3    Methodology	   49
        4.4    Performance Data	   54

               4.4.1   Chemical Analysis	  54
               4.4.2   Physical Analysis	  58

        4.5    Process  Residuals	  58

Section 5      Other Technology Requirements	  61

        5.1     Environmental Regulation Requirements	  61
        5.2    Personnel Issues	   61
        5.3     Community Acceptance	   62

Section 6      Technology Status	   64

       6.1     Previous Experience	   64
       6.2     Scaling Capabilities	   64

References  	   66
                                              VI

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                            TABLE OF CONTENTS (Continued)

 Section                                                                                Page

 Appendix A    Vendors Claims		  67

        A. 1    Introduction	  67
        A.2    Process	  68
        A.3    Cost  	  69
        A.4    Technical Information  	  69
        A.5    Advantages	  70
        A.6    Limitations		  70


                                     LIST OF TABLES

 Table                                                                                  Page

 Table ES-1     Evaluation Criteria for the J.R. Simplot Ex-Situ Bioremediation Technology	  3

 Table 2-1      Federal and State ARARs for the J.R. Simplot Ex-Situ Bioremediation Technology  13

 Table 3-1      Estimated Costs for Treatment Using the J.R. Simplot Ex-Situ
               Bioremediation Technology	  32

 Table 3-2      Items Included in This Cost Estimate    	  33

 Table 3-3      Detailed Costs for Treatment Using the J.R. Simplot Ex-Situ   ,
               Bioremediation Technology	   36

 Table 4-1      Other Compounds Reduced During the Demonstration Test	  56
 Table 4-2      Compounds Unaffected by the J.R. Simplot Ex-Situ Bioremediation Technology  .  58
 Table 4-3      Summary of Pre-Treatment  Metals Data	   59


                                    LIST OF FIGURES

 Figure                                                                                 Page

 Figure 3-1     Estimated Costs for the J.R. Simplot  Ex-Siitu Bioremediation Technology ....   38
Figure 4-1     J.R.  Simplot Process Flow Diagram for the Bioremediation of Dinoseb-
              Contaminated Soil  During the  Demonstration Test	   48

Figure 4-2     Monitored Parameters during Demonstration Test	   53
                                            Vll

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                                 ACKNOWLEDGEMENTS

This report was prepared under the direction of Dr. Wendy Davis-Hoover, the EPA Technical Project
Manager for this SITE Demonstration at the National Risk Management Research Laboratory (formerly
the Risk Reduction Engineering Laboratory) in Cincinnati, Ohio.  It was prepared for EPA's Superfund
Innovative Technology Evaluation (SITE) Program  by the Process Technology Division of Science
Applications International Corporation (SAIC).  Contributors and reviewers for this report were Dr. Ron
Lewis and Mr. Robert Stenberg of the EPA-NRMRL.
                                            vm

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                                  EXECUTIVE SUMMARY


This report  summarizes  the findings  of an evaluation of the J.R. Simplot  Ex-Situ Bioremediation

Technology on the degradation of dinoseb (2-.yec-butyl-4,6-dinitrophenol) an agricultural herbicide.  This

technology was developed by the J.R.  Simplot Company (Simplot) to biologically degrade dinoseb and

other nitroaromatic contaminants in soil.  This technology is also known as the  Simplot  Anaerobic

Bioremediation (SABRE™) system.  Engineering assistance was provided to Simplot by Envirogen, Inc.

This evaluation was conducted under the U.S. Environmental Protection Agency (EPA)  Superfund

Innovative Technology Evaluation (SITE) Program.  A companion evaluation is also being performed on

this technology to determine its effectiveness in biodegrading another  nitroaromatic compound,  TNT

(2,4,6-trinitrotoluene).


Conclusions


Based on this SITE Demonstration, the following conclusions may be drawn about the applicability of

the J.R. Simplot Ex-Situ Bioremediation Technology:
              The J.R. Simplot Ex-Situ Bioremediation Technology can reduce levels of dinoseb in soil
              by >99.8% in less than 23 days at an average temperature of 18°C based on an average
              pre-treatment soil  concentration of 27.3 mg/kg (dry basis) and a final post-treatment
              concentration below the detection limits of the analytical  instrumentation.  The  95%
              confidence interval about the pre-treatment soil was 26.4 mg/kg to 28.3 mg/kg.

              Anaerobic biodegradation of dinoseb may be achieved without the identification of known
              toxic intermediates by HPLC and  GC/MS analysis.

              The preferred operating temperature range of the bioreactor is 35 to 37°C (1).  However,
              the process successfully operated during the SITE Demonstration  with an  average
              bioreactor temperature of 18°C.

              Although beyond the process design, other compounds such as 2,6-dichloro-4-nitroaniline
              (nitroaniline);  parathion; malathion; and 4,4'-DDT were estimated to be reduced  from
              parts-per-million levels in  the  pre-treatment soil  to  below their respective analytical
              detection limits in  the post-treatment slurry. Atrazine levels in the post-treatment slurry
              were estimated to be approximately half the levels found  in the pre-treatment  slurry,
              however, the negative process  control  showed a greater decrease in  the levels of this
              compound.  The  process  was estimated  to  have no  effect on compounds such as
              chlordane (alpha, gamma, and technical); and endosulfan (I  and II).

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               The cost  associated with this  technology for treatment  of 3,824 m3 (5,000 yd3)  of
               dinoseb-contaminated soil in four lined pits is approximately $127/m3 ($97/yd3). This
               does not include costs for excavating the dinoseb-contaminated soil.  Depending on site
               characteristics, an additional cost of up to $131/m3 ($100/yd3) may be assessed to the
               client by the developer for additional technical assistance, soil nutrients, a carbon source,
               and other  process enhancements.
Other conclusions that may be drawn regarding this technology, based on treatability studies and other
pertinent information include:
               The presence of heavy metals in the feed soil does not adversely affect the process.  As
               this technology  is a sulfate reducing process,  toxic metals in the feed soil, such  as:
               cadmium, lead, etc, are converted into their sulfide forms,  therefore making the metals
               less toxic (2).  Simplot claims  that this technology is less  susceptible to the effects of
               toxic metals than other bioremediation systems.

               If the feed soil contains > 1,000 mg/kg of hydrocarbons as measured by EPA Method
               418.1 (Total Recoverable Petroleum Hydrocarbons) then the hydrocarbons will be toxic
               to the microorganisms (2). However, the cloud point separation technique can be used
               to remove  the  hydrocarbons   from soil  prior  to  initiation  of  the J.R.  Simplot
               bioremediation technology.

               The Simplot system can handle most  types of soil, however, pre-processing of the  soil
               is required prior to feeding it to the bioreactor.  This pre-processing may take longer for
               soils with a high clay content  than  for  sandy  type soils,  thus  increasing the cost of
               remediation.   If the soil to be  treated contains large rocks or debris,  then this larger
               fraction must be passed through a soil washing  system to remove surface contamination
               and separate  the fine materials.  The washwater  and the  fines are then added to  the
               bioreactor for treatment.   Alternatively, the larger fraction  may be crushed and treated
               in the bioreactor.

               Treatability studies and, to a limited extent, the Demonstration Test have shown  that
               continuous mixing of the  bioreactor  is not required (3).  A  static system  can achieve
               acceptable results provided that the soil, water, and carbon source are well-mixed during
               loading of the bioreactor.
The J.R. Simplot Ex-Situ Bioremediation Technology was evaluated based on the nine criteria used for
decision-making in the Superfund Feasibility Study (FS) process. Table ES-1  presents the evaluation.

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                 Table ES-1.  Evaluation Criteria for the J.R.  Simplot Ex-Situ Bioremediation Technology (page 1 of 2)
  Overall Protection of
 Human Health and the
      Environment
    Compliance with
     Federal ARARs
       Long-Terni•
    Effect! veness|aifd
      Performance
       Short-Term
      Effectiveness
 Reduction of Toxfcity);
  Mobility, or Volume;
   through Treatment  ;
Provides both short- and long-
term protection by eliminating
exposure to contaminants in
soil.

Prevents groundwutcr
contamination and off-site
migration.

Requires measures to protect
workers and community
during excavation,  handling,
and treatment.
Requires compliance with
RCRA treatment, storage, and
land disposal regulations (for
hazardous waste).

Excavation, construction, mid
ope nit ion of on-sitc treatment
unit may require compliance
with location-specific ARARs.

Emission controls are needed
to ensure compliance with air
quality standards if volatile
compounds arc present.

Wustcwuter discharges to
POTW or surface bodies
requires compliance  with
Clean Water Act regulations.
Effectively removes
contamination.

Involves wcll-dcinonslruled
technique for removal of
contaminants.
Presents potential short-term
risks to workers and nearby
community, including noise
exposure and exposure to
airborne contaminants (e.g.,
dust, volatile organic
compounds, etc.) released-into
the air during excavation and
handling. These can be
minimized with correct
handling procedures and
borders.

Provides reduction in
conlitminntion levels; duration
of treatment determines final
contaminant levels.
Reduces toxicity and mobility;
of soil contaminants through
treatment.

Does not produce any known
toxic intermediates as a result
of biodegrudulion when
conducted properly.

If not  fully dried, increases
volume of treatment material
by addition of water to create
a slurry.
                                                                                                                                     (Continued)

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                 Table ES-1.  Evaluation Criteria for the J.R.  Simplot Ex-Situ Bioremediation Technology (page 2 of 2)
       Jmplemenlability
               Cost
    Community Acceptance
        State Acceptance
Major equipment is limited to
bioreuctor and agitation/suspension
devices.

Support equipment includes
eajj|moving equipment (for
eicavfltion, screening, and loading of
btoreuctor) and monitoring equipment
(for monitoring pH,  redox potential,
and temperature).

Once on-site, the small portable
bioreactor can be assembled and ready
to Joad within two days. The lined
pits, or larger modular bioreactor
requires approximately four days.
After excavation, biorcaclor loading
activities (soil and water) are a
function of treatment volume.

After treatment is complete, the small
bioreactor can be emptied and
demobilized in three days. Treated
soil can be placed in the excavated
area and used as nil material.  For
lined pits and erected bioreuclors,  the
integrity of the liners can be breached
when treatment is complete,  and the
liner abandoned in place.
$127/m3 (S97/yd3) for treatment in
four lined pits, remediating a total of
3,824 mj (5,000 yd3) of soil.

Actual cost is site-specific and
dependent upon:  the volume of soil,
soil characteristics, contaminants
present, and original and target
cleanup  levels. Cost data presented in
this table are for treating dinoscb-   .
contaminated soil similar to the SITE
Demonstration treatment soil.  Costs
presented are also based on a 30 day
batch treatment time.

Depending on site characteristics, an
additional cost of up to S131/m3
($IOO/yd3) may be assessed to the
client by the developer for additional
technical assistance, soil nutrients, a
carbon source, and other process
enhancements.
Minimal short-term risks presented to
the community makes this technology
favorable to the public.

Public knowledge of common
bioremedialion applications (e.g.,
wastewater treatment) eases
community acceptance for hazardous
waste treatment using this technology.

Use of naturally-selected
microorganisms makes treatment by
lliis technology a favorable option to
the community.

Low levels of noise exposure may
impact community in the immediate
vicinity.
If remediation is conducted as part of a
RCRA corrective action, Hate
regulatory agencies may require
permits to be obtained before
implementing the system.  These may
include a permit to operate the
treatment system, an air emissions
permit (if volatile compounds are
present),  a permit  to store
contaminated soil for more than 90
days, and a wastewater discharge
permit.

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                                          SECTION 1
                                       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 the J.R. Simplot Ex-Situ Bioremediation Technology.  For additional  information about the
SITE Program, this technology, and the demonstration site, key contacts are listed at the end of this
section.

1.1    Background

In 1987, the J.R. Simplot Company began working with researchers at the University of Idaho to develop
a process to  anaerobically degrade nitroaromatic compounds.  In September 1990,  the  process was
accepted  into the SITE Emerging Technologies Program.  A treatability study funded by this Program
was performed by the University of Idaho on 9,000 kg (9.9 tons) of soil contaminated with dinoseb. The
results of this treatability study showed that the process could degrade dinoseb from approximately 20
mg/kg to below the analytical detection limit in  15 days.  A transient unidentified intermediate was
formed by the process, but the concentration of this intermediate was reduced  to  near the analytical
detection limit within 45 days (3).  In April  1992, the J.R. Simplot Company applied and was accepted
into the SITE Demonstration Program.  A full-scale demonstration of the technology was performed at
an  airport where the soil was contaminated with dinoseb.  This evaluation of the J.R. Simplot Ex-Situ
Bioremediation Technology is based primarily on the results of the SITE Demonstration conducted at the
afore-mentioned airport with supporting information from the bench-scale treatability studies conducted
by  the University of Idaho.
The J.R. Simplot Ex-Situ Bioremediation Technology is a simple bioenhancement process that treats soils
contaminated  with nitroaromatic compounds by the addition  of naturally selected anaerobic soil
microorganisms.  The process is initiated under aerobic conditions, but anaerobic conditions are quickly
achieved  under designed parameters, thus  enabling  the microbes  to  degrade the  nitroaromatic
contaminants completely.  As claimed by the developer, anaerobic degradation of nitroaromatics by the
J.R. Simplot process  takes place  without the formation of any known toxic polymerization products.

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1.2     Brief Description of Program and Reports

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 Reauthorizatton 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 four major elements:

        •       the Demonstration Program,
        •       the Emerging Technology Program,
        •       the Monitoring and Measurement Technologies Program, 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 may  assess the technology'^ site-specific applicability.
Technologies evaluated are either  currently available or close to  being available for remediation of
Superfund  sites.  SITE Demonstrations are conducted on hazardous waste sites under conditions that
closely simulate full-scale remediation  conditions,  thus assuring the  usefulness and  reliability  of
information collected. Data collected are used to assess: (1)  the performance of the technology, (2) the
potential need for pre- and post-treatment processing of wastes, (3) potential operating problems, and (4)
the approximate costs. The demonstrations also allow for evaluation of long-term risks.

The Emerging Technology Program focuses on conceptually proven bench-scale technologies that are in
an  early stage of development involving pilot or  laboratory testing.   Successful technologies  are
encouraged to advance to the Demonstration Program.
Existing technologies that  improve field monitoring and site characterizations  are  identified in the
Monitoring and Measurement Technologies Program.  New technologies that provide faster, more cost-
effective contamination and site assessment  data are supported by this program.  The Monitoring and

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Measurement Technologies 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, Emerging Technology, and Monitoring and Measurement Technologies Programs through
various activities. These activities increase the awareness and promote the use of innovative technologies
for assessment and remediation at Superfund sites. The goal of technology transfer activities is to develop
interactive communication among individuals requiring up-to-date technical information.

The results of Demonstration Program are published in four basic documents: the SITE Demonstration
Bulletin,  the Technology Capsule, the Innovative Technology Evaluation Report (ITER),  and the
Technology Evaluation Report (TER).  The SITE Demonstration Bulletin provides preliminary results
of the field demonstration. The Technology Capsule provides relevant information on the technology,
emphasizing  key features of the results of the SITE field demonstration.  The ITER provides detail
information on the technology and the results of the SITE field  demonstration.  The TER contains the
raw data collected during the field demonstration and provides a quality assurance review of this data.
Both  the SITE ITER and TER are intended for use by remedial  managers making a detailed evaluation
of the technology for a specific site and waste.

1.3     The SITE Demonstration Program

Technologies are selected for the SITE Demonstration Program  through annual requests for proposals.
ORD staff reviews the proposals  to determine which  technologies show the most.promise of use at
Superfund sites.  Technologies chosen must  be at the pilot- or full-scale stage, must be innovative, and
must  have some advantage over existing technologies. Mobile technologies are of particular interest.
Once the EPA has accepted a proposal, cooperative agreements between the EPA and the developer
establish responsibilities for conducting the demonstration and evaluating the technology. The developer
is responsible for demonstrating the technology at the selected site and is expected to pay any costs for
transport, operations, and removal of the equipment.   The EPA is responsible for project planning,
sampling and analysis,  quality  assurance  and quality  control, preparing reports,  disseminating
information, and transporting and disposing of treated waste materials.

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1.4    Purpose of the Innovative Technology Evaluation Report (ITER)

This ITER provides information on the J.R. Simplot Ex-Situ Bioremediation Technology tor treatment
of dinoseb-contaminated soils and 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,
contractors, and other decision-makers carrying out specific remedial actions.  The ITER is designed to
aid decision-makers in  further evaluating specific technologies for  further consideration 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
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.  The
waste characteristics of 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

The J.R. Simplot Ex-Situ Bioremediation Technology is designed to destroy nitroaromatic compounds
without forming  any toxic intermediate  compounds.   The theory of operation behind the  Simplot
technology is that soils  contaminated with nitroaromatic compounds may be treated using an anaerobic
consortium. A consortium may be defined as a group of different populations of microorganisms in close
association that form a community  structure with  a certain  symbiosis  or interrelationship.  Each
population contributes to the general welfare of the group.   An anaerobic  consortium is a group of
different populations of microorganisms that symbolically exist without oxygen. Studies have found that
anaerobiosis with redox potential less than -100 mV promotes the establishment of an anaerobic microbial
consortium that degrades nitroaromatic compounds completely  (1).  Under aerobic or microaerophilic

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conditions, degradation of nitroaromatic compounds may form polymerization products that are potentially
toxic. Anaerobic degradation of nitroaromatics using the J.R. Simplot technology takes place without the
formation of these polymerization products.

Execution of the Simplot bioremediation technology is carried out by mixing a carbon source (a J.R.
Simplot Company potato-processing by-product) with contaminated soil and then adding water and buffers
to create a slurry. This prompts aerobic microorganisms to consume oxygen, thus creating anaerobic
conditions in the treatment slurry.  These conditions subsequently stimulate anaerobic microorganisms
to consume  toxins present in the slurry. The appropriate microorganisms are often indigenous to  the
treatment soil, however, treatment soils may also be inoculated with the necessary consortium to enhance
degradation  rates. For small soil volumes (less than 31 m3), treatment may take place in small, mobile
bioreactors.  For larger soil volumes, treatment may take place in large modular bioreactors or lined pits.

Section  4.2  provides the specific details of the process  design  used  during the  Demonstration Test.
Section  4.3 discusses the methodology behind the treatment and testing performed.

1.6     Key Contacts

Additional information on the J.R. Simplot Ex-Situ Bioremediation Technology and the SITE Program
can be obtained from the following sources:
       The J.R. Simplot Ex-Situ Bioremediation Technology
       Technical:
       Russ Kaake, PhD
       J.R. Simplot Company
       P.O. Box 912
       Pocatello, ID 83201
       Phone:  208/234-5367
       Fax:   208/234-5339
Marketing:
Tom Yergovich
J.R. Simplot Company
P.O. Box 912
Pocatello,  ID 83201
Phone: 208/238-2850
Fax:   208/238-2760

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       The SITE Program

       Robert A. Olexsey, Director
       Superfund Technology Demonstration Division
       U.S. Environmental Protection Agency
       26 West Martin Luther King Drive
       Cincinnati, Ohio 45268
       Phone:  513/565-7861
       Fax:   513/565-7620
Wendy Davis-Hoover, PhD
EPA SITE Technical Project Manager
U.S. Environmental Protection Agency
5995 Center Hill Avenue
Cincinnati, Ohio 45268
Phone: 513/569-7206
Fax:   513/569-7879
Information on the SITE Program is available through the following on-line information clearinghouses:
       •      The Alternative Treatment Technology Information Center (ATTIC) System (operator:
              301/670-6294) is a comprehensive, automated information retrieval system that integrates
              data on hazardous waste treatment technologies into a centralized, searchable source.
              This data base provided summarized information on innovative treatment technologies.

       •      The Vendor  Information System  for Innovative Treatment Technologies (VISITT)
              (hotline: 800/245-4505) data base currently contains information on approximately 231
              technologies offered by 141 developers.

       •      The OSWER CLU-In electronic bulletin board 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 contacting the Center for Environmental Research Information

(CERI), 26 West Martin Luther King Drive in Cincinnati, Ohio, 45268 at 513/569-7562.
                                              10

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                                         SECTION 2
                         TECHNOLOGY APPLICATIONS ANALYSIS

This section of the report addresses the general applicability of the J.R. Simplot Ex-Situ Bioremediation
Technology to contaminated waste sites.  The analysis is based primarily on  this SITE Demonstration,
and conclusions are based extensively on these data since only limited information is available on other
applications of the technology.  This  SITE Demonstration  was conducted on soil contaminated with
dinoseb (2-$ec-butyl-4,6-dinitrophenol).  A companion SITE Demonstration of this technology is being
performed  on soil contaminated  with TNT (2,4,6-trinitrotoluene), and another Innovative Technology
Evaluation Report will be provided at a later date.

2.1    Key Features of the J.R. Simplot Ex-Situ Bioremediation Technology

The J.R. Simplot  Ex-Situ Bioremediation Technology has several unique features that distinguish it from
most bioremediation technologies.  Bioremediation using this technology is anaerobic.  The anaerobic
consortium used for degradation of nitroaromatic  compounds is a consortium that has been naturally
selected, and not genetically engineered. For the Demonstration Test, the necessary microorganisms were
indigenous to the  local soil.
Initially, consumption of oxygen by aerobic microorganisms is promoted by the addition of a carbon
source.  This carbon source is a J.R. Simplot Company potato-processing by-product. This potato starch
mixture is made up of 42% solids: 215 mg of starch per gram; 6.7 mg of total  nitrogen per gram;
2.6 x 104 culturable heterotrophic bacteria per gram; and 8 x 103 culturable amolytic bacteria per gram.
This starch  by-product  is normally discarded  by the  potato-processing industry,  but  in this  case  is
beneficially  utilized by  the bioremediation system.  The potato-processing by-product  was used as a
carbon source for the purpose of this demonstration because it was readily available to the J.R. Simplot
Company.   Any other carbon source may also be used but only this specific starch was used during
treatability studies.

The degradation of dinoseb using this bioremediation technology is not as temperature dependent as other
biological systems.  Optimal temperatures for dinoseb degradation using the Simplot Process are 35 to
37°C.  Despite  average slurry temperatures of 18°C during the  Demonstration Test, the Simplot Process

                                              11

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was still able to degrade dinoseb to below the analytical detection limit in less than 23 days.  However,
the degradation rate can be restricted if freezing conditions exist.  This problem can be overcome by
adding heaters to the system, but at an additional cost to the remediation.  The temperature dependence
of degradation of other nitroaromatic compounds has not yet been determined for comparison with other
biological systems.

The Best Demonstrated Available Technology (BDAT) for dinoseb-contaminated soil is incineration. The
destruction and removal efficiency (DRE) for incineration is > 99.99%. This Demonstration Test has
shown that treatment by the J.R. Simplot Ex-Situ  Bioremediation Technology can attain  >99.8%
removal. Removal efficiency was determined based upon remediation of the treated soil to levels below
the  analytical detection  limits.   Treatment  by bioremediation  may  be more time-consuming  than
incineration since the  amount of contamination that is biologically degraded  is a function of time,
however, any alternative technology  that can economically compete with  incineration is of interest to
remedial managers.

The J.R. Simplot Ex-Situ Bioremediation Technology is a cost-effective treatment method.  The cost
associated with this technology for biodegradation of dinoseb is  approximately $127/m3 ($97/yd3) for
3,824 m3 (5,000 yd3) of soil treated in four lined pits.  This cost is based on a 30 day batch treatment
time. It does not include expenditures incurred for excavating the dinoseb-contaminated soil.  The J.R.
Simplot Company may also impose a cost of up to $131/mJ ($100/yd?) to these estimated costs. This
additional cost  is dependent on site characteristics and  is used for additional technical  assistance, soil
nutrients, and other process enhancements provided by the developer. The total costs for treatment using
the J.R. Simplot Ex-Situ  Bioremediation Technology  are substantially  lower than costs  for  other
technologies suitable for the destruction  of dinoseb.

2.2    Technology Performance versus ARARs  during the Demonstration

Federal and state applicable or relevant and appropriate regulations (ARARs) for the J.R. Simplot Ex-Situ
Bioremediation Technology are presented in Table  2-1.   The performance of the technology during the
Demonstration Test with respect  to ARARs is discussed below.
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               Table 2-1.  Federal and  State ARARs for the J.R. Simplot Ex-Situ Bioremediation Technology (page 1 of 3)
Process  Activity  ARAR
                         Description
                                   Basis
                                   Response
Waste characterization
(untreated waste)
RCRA 40 CFR Part 261
or state equivalent


TSCA 40 CFR Part 761
or state equivalent
Standards that apply to identification
and characterization of waste to be
treated

Standards that apply to the treatment
and disposal of wastes containing
PCBs
A requirement of RCRA prior to
managing and handling the waste


During waste characterization, PCBs
may be identified in contaminated
soil, and arc therefore subject to
TSCA regulations
Chemical and physical analyses
must be performed.

Chemical and physical analyses
must be performed.  If PCBs are
identified, soils will be managed
according to TSCA regulations.
Soil excavation
Clean Air Act 40 CFR
50.6, and 40 CFR 52
Subpart K or state
equivalent

RCRA 40 CFR  Part 262
or slate equivalent
Regulations governing the
inunitgctnenl of toxic pollutants and
particulale matter in the air
Fugitive air emissions may occur
during excavation and material
handling and transport
                                                 Standards that apply to generators of   Soils lire excavated for treatment
                                                 hazardous waste
If necessary, the waste material
should be watered down or covered
to eliminate or minimize dust
generation.

If possible,  soils should be fed
directly into the bioreuctor for
treatment.
Storage prior to
processing
RCRA 40 CFR Part 264  Standards applicable to the storage
or state equivalent     .   of hazardous waste
                                   Excavation and prc-lrcatment
                                   screening may generate hazardous
                                   wastes that ir.ua! be stored in waste
                                   piles
                                   If stored in a waste pile, the
                                   material should be placed on and  .
                                   covered with plastic, and secured  to
                                   minimize fugitive air emissions and
                                   volatilization. The time between
                                   excavation and treatment (or
                                   disposal if material is unsuitable for
                                   treatment) should be minimized.
Waste processing
RCRA 40 CFR Part 254
or state equivalent
Standards applicable to the treatment
of hazardous waste at pcnnitlcd and
interim status facilities
Treatment of hazardous waste must
be conducted in u manner that meets
the operating and monitoring
requirements; the treatment process
may occur in u small, portable
biorcactor or in a large, constructed
biorcactor.
Equipment must be maintained
daily.  Integrity of bioreaclor must
be monitored and  maintained to
prevent leakage or failure.  If
treatment standards are not met, the
bioreactor must be decontaminated
when processing is complete.

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               Table 2-1.  Federal and State ARARs for the J.R. Simplot Ex-Situ Bioremediation Technology (page 2 of 3)
Process Activity  ARAR
                         Description
                                   Basis
                                   Response
Storage after processing
RCRA 40 CFR Part 264
or slate equivalent
Standards that apply to the storage
of hazardous waste
The treated material will remain in
the biorcactor until it has been
characterized and a decision on final
disposition tins been made.
Oversize material unsuitable for
processing may be stored in a waste
pile.
Biorcactors must continue to be
well-maintained. If stored in a
waste pile, oversize material should
be placed on and covered with
plastic, and tied down to minimize
fugitive emissions and volatilization.
The material should be disposed of
or otherwise treated as soon as
possible.
Waste characterization
(treated waste)
RCRA 40 CFR Part 261
or stale equivalent
                        TSCA 40 CFR Part 761
                        or stale equivalent
Standards ihnt apply to waste
characteristics
                        Standards thai apply to the treatment
                        and disposal of wastes containing
                        PCBs
A requirement of RCRA prior to
managing and handling the waste; it
must be determined if treated
material is RCRA hazardous waste.

Treated wastes may still contain
PCBs
Chemical and physical analyses
must be performed on treated wastes
and on oversize material prior to
disposal.

Chemical and physical analyses
must be performed on treated wastes
and on oversize material prior to
disposal. A proper disposal method
must be selected if PCBs arc found.
On-siic/off-sitc disposal
RCRA 40 CFR Part 264
or state equivalent
Standards that apply to landfilling
hazardous waste
                        TSCA 40 CFR Part 761
                        or state equivalent
                        Standards that  restrict the placement
                        of PCBs in or  on the ground
Treated wastes and/or oversize
material may still contain
contaminants in levels above
required cleanup action levels and
therefore  be subject to LORs
                                  Treated wastes and/or oversize
                                  material containing less than SO ppm
                                  PCBs may be lundfillcd or
                                  incinerated.  Treated wastes and/or
                                  oversize greater than 50 ppm must
                                  be incinerated.
Treated wastes and/or oversize
material still defined as hazardous
must be disposed of at a permitted
hazardous waste facility, or approval
must be obtained from the lead
regulatory agency to dispose of the
wastes on-site.

If untreated wastes contained PCBs,
then treated wastes and oversize
material should be analyzed for PCB
concentration.  Approved PCB
landfills or incinerators must be
used for disposal.

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               Table 2-1.  Federal and State ARARs for the J.R. Simplot Ex-Situ Bioremediation Technology (page 3 of 3)
Process Activity  ARAR
                        Description
                                  Basis
                                  Response
On-sile/off-site disposal
(continued)
RCRA 40 CFR Part 268
or state equivalent
                        SARA Section I21(d)(3)
Standards that restrict the placement
of certain wastes in or on the
ground


Requirements for the off-site
disposal of wastes from a Superfund
site
The nature of the waste may be
subject to the LDRs
                                                         The waste is being generated from a
                                                         response action authorized under
                                                         SARA
The waste must be characterized to
determine if the LDRs apply.  If so,
waste must be handled in
accordance with LDRs.

Wastes must be disposed of at a
RCRA-pcrmitted hazardous waste
facility.
Transporttilion for off-
site disposal
RCRA 40 CFR Part 262
or state equivalent


RCRA 40 CFR Part 263
or stale equivalent
Manifest requirements and
packaging and labelling
requirements prior to transporting

Transportation standards
The treated waste and/or oversize
material may need to be manifested
and managed as a hazardous waste

Treated wastes and/or oversize
material mny need to be transported
as hazardous wastes
An identification (ID) number must
be obtained from EPA.
                                                                                                                  A transporter licensed by EPA must
                                                                                                                  be used to transport the hazardous
                                                                                                                  waste according to EPA regulations.
Wuslcwatcr discharge
Clean Water Act 40
CFR Parts 301, 304,
306. 307, 308, 402, and
403
Standards that apply to discharge of
wustewatcr into POTWs or surface
water bodies
The wastewatcr may be a hazardous
waste
Determine if wastewater could be
directly discharged into a POTW or
surface water body. If not, the
wastewater may need to be further
treated to meet  discharge
requirements by conventional
processes.  An  NPDES permit may
be required for discharge to surface
waters

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Prior to treatment, the soil was characterized by performing chemical and physical analyses.  The
treatment soil was analyzed for dinoseb, pesticides, chlorinated herbicides, and metals. Tests were also
performed  to characterize the soil type; particle size distribution and Atterberg limits of the soil were
determined. The soil was found to contain dinoseb, a RCRA-listed waste (P020), and high levels of other
pesticides and  herbicides including  2,6-dichloro-4-nitroaniline (nitroaniline); atrazine; and technical
chlordane.  Low levels of malathion;  parathion; endosulfan; and 4,4'-DDT were also detected. The soil
was classified as a clayey sand with gravel.  The results of these analyses indicated that, because it was
RCRA-listed, the soil was subject to RCRA regulations.  (Only soils that are defined as  hazardous by
bearing a RCRA characteristic or RCRA listing are subject to RCRA regulations).   Because of the
dinoseb contamination, the soil  was also classified  as  an extremely hazardous  soil according to the
Washington State Department of Ecology (WAC 173-303-9903). The soil did not contain PCBs, and
therefore the ARARs pertaining to materials contaminated with PCBs were not applicable to this situation.
It  is  unlikely  that soil with PCB  contamination  would be  treated by the  J.R. Simplot  Ex-Situ
Bioremediation Technology because PCBs are not amenable to remediation by this technique.

During excavation, the soil was  watered down  to minimize dust generation.  No volatile contaminants
were present in the treatment soil, therefore, volatile air emissions were not a concern during excavation.
Although it was  not possible to feed  the soils directly into the bioreactor because  of  the logistical
considerations associated with sampling during the Demonstration Test, the stockpiled excavated soil was
kept covered with plastic and fed to the bioreactor as soon as it was sampled.  During normal operation
of the J.R.  Simplot Ex-Situ Bioremediation Technology,  it is anticipated that excavated  soils may be
screened, and then homogenized with  the carbon source  and  fed directly into the bioreactor.  In the
future, Simplot will mix the carbon source directly with the slurry water before soil addition.

Before it was fed into the bioreactor, the Demonstration Test soil was screened to remove rocks and other
debris greater than 12.7 mm (0.5 in) in diameter. Because dinoseb is water-soluble, this oversize fraction
was rinsed with water to remove surface contamination.  The oversize material was kept  covered prior
to the rinsing activities. In cases where a large  portion of oversize material is present, a separate soil or
rock washing technology may be used  to treat this fraction.  In some cases, it may be possible to crush
the rocks and then feed them into the bioreactor.  It should be noted that, although soil or rock washing
reduces the volume of contaminated material, waste requiring further treatment or disposal will remain.
In some cases, the contaminated material resulting from soil or rock washing may be treated by the J.R.
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Simplot Ex-Situ Bioremediation Technology,  If stored in a waste pile, the oversize material must be kept
covered. If treated by a separate technology, the length of time that the oversize material is stored before
treatment must be minimized.

Treatment of the Demonstration Test soil took place in a bioreactor that was maintained on a regular
basis.  The integrity of the bioreactor was monitored and maintained to prevent leakage or failure.

Once treatment was complete, the post-treatment slurry was sampled and analyzed for dinoseb, pesticides,
and chlorinated herbicides.  According to a case-specific ruling by the Washington State Department of
Ecology (WADOE), the soil was no longer considered to be hazardous  if dinoseb levels were reduced
below  the specified cleanup objective.  The results of the analyses indicated  that dinoseb  in the post-
treatment slurry was below the analytical detection limit;; and below the cleanup objective specified by
the WADOE,  therefore, the post-treatment slurry was not handled as hazardous waste.

The treated material remained in the bioreactor until the results of post-treatment analyses were obtained
and verified.  The integrity of the bioreactor continued to be monitored and maintained.   The treatment
slurry was pumped from the bioreactor without the need for decontamination based on analytical results.
In cases where the cleanup objective is not met, the bioreactor must be decontaminated when processing
is complete. Oversize  material that was excavated and rinsed during the  Demonstration Test was stored
in a waste pile to be used as fill.  Oversize material that was excavated but not rinsed was stored in a
waste pile on top of plastic liners.  The pile was also covered with plastic and  tied down.  This material
will be cleaned by a rock or soil  washing technique with the washwater being remediated at a later date.
Alternatively,  the material  may be correctly disposed of at a permitted facility.

Using  a conservative  approach,  personal  protective equipment  and  debris  contaminated during the
Demonstration Test were handled as hazardous waste.  An EPA identification  number was obtained and
the waste was transported (accompanied by a hazardous waste manifest) by a licensed transporter to a
RCRA-permitted facility for disposal.  The oversize traction, if not treated on-site, must be transported
off-site for treatment or for disposal at a RCRA-permitted facility,  Wastewater generated  during the
demonstration was suitable tor discharge into the local  sewage treatment plant.
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2.3    Operability of the Technology

The J.R. Simplot Ex-Situ Bioremediation Technology is a simple system. The system consists solely of
the bioreactor equipped with agitation/suspension devices and monitoring equipment.  Support equipment
is only required  to excavate, screen,  and homogenize the soil and  to load the bioreactor  prior to
treatment.  During treatment,  support equipment is not required.  Small, portable bioreactors are mobile
and operated by trained personnel.  Large, modular bioreactors or lined pits may  be erected on-site with
minimal  effort.   The system may  operate unattended for several days at a time,  if necessary.  The
bioreactor  appeared to be free of operational problems  during the demonstration  in  Ellensburg,
Washington.

Several operating parameters influence the  performance of the J.R. Simpiot Ex-Situ  Bioremediation
Technology. These parameters are-continually monitored.  The technology is dependent on pH, redox
potential, and temperature. The pH must be  regulated by .the addition of acids and/or phosphate buffers.
For this Demonstration Test, monobasic  potassium  phosphate and 45.8 kg (100.7  Ibs) of 182.75 kg
(402.05 Ibs) of dibasic potassium phosphate were used. These buffers were selected based upon previous
treatability studies conducted  on the Bowers  Field soil.  Based on a limited parametric study, it appears
that the preferred pH range for dinoseb degradation  is between  7.5  and 8.0 (I),   However, wide
variations in the pH of the slurry at the outset of treatment during the demonstration (i.e., pH as low as
6.2 in the solid  phase and as high as 10.5 in the liquid phase) did not seem  to adversely affect the
behavior of the consortium. Small  amounts of sulfuric acid were added to the system at various intervals
to correct the pH.  The total  quantity of sulfuric acid added was not recorded since the quantities were
minor. Anaerobic conditions suitable for the microorganisms that are capable of degrading dinoseb exist
when the redox potential is less than -100 mV (I).  These anaerobic conditions are achieved when aerobic
microorganisms  consume oxygen  from the  soil and lower the redox potential.  The treatment slurry
should be  mildly agitated to  keep  the solid  fraction  in suspension during treatment.  This enables the
contaminant to pass to the liquid phase. Rigorous mixing should not be performed to avoid aerating the
slurry and recreating aerobic conditions.  Treatability studies  have shown that continuous mixing is not
required (3). A static system is known to achieve acceptable results when the  soil, water, and carbon
source are well-mixed during loading of the bioreactor.  Temperature is  a third parameter  that may
influence the performance of the J.R. Simplot Ex-Situ Bioremediation Technology. During the parametric
study  mentioned above,  it was also found that a suitable operating temperature is  between 35  and

                                                18

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37°C (1).  Successful treatment was achieved however, in 23 days during the Demonstration Test with
bioreactor temperatures at an average of 18°C.

During the demonstration, excavated soil was screened to separate rocks and debris greater than 12.7 mm
(0.5 in) in diameter.  The screening process was much more time consuming than originally anticipated,
partially due to inappropriately sized equipment. Additionally, rinsing of the resulting oversize fraction
was not completed because of poor equipment selection and difficulties in  operation.  The pug mill
utilized for homogenization of the pre-treatment soil and the J.R. Simplot Company potato-processing
by-product was undersized and proved to be a significant impediment to efficient mixing operations. This
portion of  treatment (screening, rinsing, and homogenization) was highly labor intensive.   Important
knowledge and experience about full-scale operations were gained during the Demonstration Test.

To  determine  the amount of soil treated,  the  volume of  the excavated soil  may  be  measured
geometrically, or the volume of soil fed into the bioreactor may be determined by counting the number
of loads deposited onto the conveyor.  Both techniques were employed during the SITE Demonstration.
To  determine the amount of water added, the volume of water in the bioreactor may be measured
geometrically before the addition of any soil, or the volume of water fed into  the bioreactor may be
determined by using a totalizing flowmeter.  Again, both techniques  were employed during the  SITE
Demonstration.  This information is required to ensure that a correct ratio of soil to  water is established
and maintained in the treatment slurry.  Accurate measurements of these quantities were also required
during the  Demonstration Test to facilitate calculations  for the dinoseb concentration  in the treatment
slurry.

2.4     Applicable Wastes
The J.R. Simplot Ex-Situ Bioremediation Technology is suitable for soils and liquids contaminated with
dinoseb. The medium to be treated  must be free of toxic metals or any other compounds that may be
detrimental to the appropriate microorganisms (e.g., hydrocarbons). To date, the levels of toxic metals
that affect this technology have not been determined. Simplot claims that the presence of heavy metals
in the feed soil will not adversely affect the process. Since this technology is a sulfate reducing process,
toxic metals in the feed soil, such  as: cadmium, lead,  etc are converted into their sulfide forms.  This
makes the metals innocuous. Simplot claims that this process is less susceptible to the effects of toxic

                                               19

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metals than other bioremediation systems.  J.R. Simplot claims that greater than 1,000 ppm of total
recoverable petroleum hydrocarbons (TRPH) is considered toxic to the microorganisms (2).  Although
high levels of hydrocarbons may inhibit the performance of the microorganisms, the hydrocarbons can
be removed from the soil prior  to bioremediation by using a cloud-point separation technique.  This
technique incorporates the addition of a surfactant/water solution to the waste.  Heat aids the separation
of the organic phase from the aqueous phase,  and gravity aids the separation of the solid phase.  The
hydrocarbon waste stream generated by this technique must be treated using an alternate technology or
disposed of at  a permitted facility.  The J.R.  Simplot Ex-Situ Bioremediation Technology has been
demonstrated on  dinoseb (2-jec-butyl-4,6-dinitrophenol).   It is also being  demonstrated  on another
nitroaromatic compound, TNT (2,4,6-trinitrotoluene), in a separate SITE Demonstration.

Simplot claims that any soil type can be treated, provided that the soil (or liquid) is thoroughly mixed
with the carbon source (J.R. Simplot Company potato-processing by-product).  The soil itself need not
contain the microorganisms necessary to degrade the contaminants since the bioreactor can be inoculated
with  the appropriate microorganisms.   These microorganisms  can be  obtained from previous site
remediations or treatability studies. If the soil to be treated contains large rocks or debris, then this larger
                                                         t
fraction must be passed through a soil washing system to remove surface contamination and  separate the
fine material.  The washwater and the fines may subsequently be treated in the bioreactor.  Alternatively,
the larger fraction may be crushed to  an  appropriate size and then fed into the bioreactor.   During the
Demonstration Test, the soil was screened at 12.7 mm (0.5 in) diameter.  However, Simplot claims that
rocks and  debris up to  38.1  mm (1.5 in) diameter can be remediated.   Soil washing of the oversize
fraction was attempted by Simplot during  the Demonstration Test.  Because of inadequate equipment and
lack of pertinent experience, the soil washing operations were not completed as part of the demonstration.
For future operations, it is anticipated  that, if required, this portion of treatment will be performed by
an independent rock or soil washing vendor.

2.5     Availability and Transportability of Equipment

Currently, the J.R. Simplot Company does not own any bioreactors, but rents and modifies mobile tanks
to accommodate small-scale  treatment.  The small, portable  tanks are wheel-mounted  and  can be
transported by licensed haulers.  For large-scale treatment where the treatment volume exceeds 31 m3 (40
yd3), modular, fabricated tanks  or lined pits are likely to be used.  The large tanks  are bolted together

                                               20

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on-site and rented on a case-by-case basis,  the lined pits are excavated on-site. Each large tank or lined
pit can treat up to 956 m3 (1,250 yd3) of soil.  If the treatment volume exceeds 956 m3, multiple tanks
or  lined  pits can  be  used simultaneously.   Agitation/suspension  devices  (mixers) and  monitoring
equipment can  easily  be transported by  freight.   Support equipment may be obtained locally  and
transported to the site by freight.  Once all the equipment is on-site, the small portable system can be
assembled in approximately two days.  The larger erected tanks or lined pits can be assembled in four
to six days.

Demobilization activities include emptying  the bioreactor, decontaminating on-site  equipment  (if
necessary), disconnecting  utilities,  disassembling equipment,  and  transporting  equipment  off-site.
Demobilization requires approximately three days for the small portable bioreactor.  For the larger
erected tanks or lined pits,  the bioreactor can be emptied by breaching the  integrity of the liner  and
removing the walls of erected tanks or by abandoning the lined pits in place.

2.6    Materials Handling Requirements

Before treatment can commence, the soil must be excavated, staged, screened, homogenized with the J.R.
Simplot Company potato-processing by-product, and loaded into the bioreactor. Soils should be kept
moist if fugitive emissions or airborne particulates are expected. If present in the soil, most VOCs will
volatilize into the atmosphere unless strict preventative measures are undertaken. These measures may
include covering the excavated material and/or operating in an enclosed environment.  At sites where
VOCs are the primary contaminants, treatment by the J.R. Simplot Ex-Situ Bioremediation Technology
is not recommended.

When the treatment soil contains large rocks or other debris, it must be passed through a vibrating screen
(or other size-separating device) to  remove the oversize material.  Large clumps of soil which pass
through the screen must also be broken apart to increase the surface area and thereby increase the number
of sites available for attack by the microorganisms. The oversize fraction may be crushed or washed on-
site using a separate rock or soil washing technology. The waslvwater generated by soil washing may be
treated in the bioreactor. If not treated by an alternate technology on-site, the oversize material must be
transported off-site for treatment or proper disposal at a permitted facility.
                                               21

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At some sites, water may be available from the facility or from  a local water source.  At remote
locations, water may need to be transported, to the site in water trucks.  For treatment of 30 m3 (39 yd3)
in a 75,700-L (20,000-gal) portable bioreactor, approximately 29,000 L (7,650 gal) of water are required.
For large-scale treatment, the volume of water required will vary and is based on the amount of soil
treated and the composition of the soil.  In either case, approximately one liter (0.26 gal) of water is
required for each kilogram (2.2 Ib) of soil treated.

The J.R. Simplot Company potato-processing by-product that is mixed with the treatment soil as a carbon
source for the  microorganisms  is  generally transported  to  the site  in  208-L (55-gal)  drums  or,
alternatively, in a tanker truck. When stored for extended periods of time or when exposed to heat, the
J.R. Simplot Company potato-processing by-product begins to naturally ferment, causing an increase in
pressure inside the drums.  When handling this material, particularly when opening the drums, strict
precautions must be followed to avoid ruptures of the J.R. Simplot potato-processing starch by-product
drums.  Drum lids may be pierced to  provide an escape route for gases that build up during fermentation.
The size of the hole  should  be minimized to control the  release of  foul  odors associated  with
fermentation.

The treated slurry is pumped from the bioreactor at  the conclusion of successful treatment. Wastewater
with few suspended solids may be discharged into a  publicaUy owned treatment works (POTW) or a
surface water body. The remaining sludge can be pumped into lined pits for evaporation of the  liquid
phase with the dried product being used as fill material.

2.7     Range of Suitable Site Characteristics

Locations suitable for on-site treatment using the J.R.  Simplot Ex-Situ Bioremediation Technology must
be able to accommodate utilities, support facilities, and support equipment.  These requirements are
discussed below.
Utilities required for the Simplot bioremediation system  are  limited to water and electricity.  For
treatment using a bioreactor, water is needed to create a treatment slurry in the bioreactor. As mentioned
above,  approximately one liter (0.26 gal) of water is required for each kilogram (2.2 Ib) of soil added
to the reactor.  Water is also required for cleanup and decontamination activities, if necessary.  The J.R.
                                               22

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Simplot Ex-Situ Bioremediation Technology requires a three-phase 480-voIt electrical circuit to power
the agitators, and screening and homogenization equipment.  The current needed is a Function of the size
of the equipment.  Additional power is required for on-site office trailers, if present.  Compressed air
may be required if the bioreactor is to be lanced.  During the demonstration, the bioreactor was lanced
by placing the suction end of a diaphragm pump into the settled sediment and pumping the sediment into
a more well-mixed region of the bioreactor.

Support facilities include a contaminated soil staging area, a treated slurry storage area, a drum storage
area, and an office area. The treated slurry that is generated must be stored in soil piles or in cleared
areas and allowed to dry before it is suitable for use as clean fill.   Drums containing nutrients (J.R.
Simplot Company potato-processing starch by-product) and  waste personal protective equipment (PPE)
must be stored in a drum storage area.  In addition, a tank  storage area to store water and wastewater
may be required at some sites.  These support facilities must be contained to control run-on and run-off.
Mobile trailers  may be used as office space on-site.  These office  trailers must be located outside the
treatment area.
Support equipment tor  the J.R. Simplot  bioremediation system  includes earth-moving equipment,
conveyor belts, a vibrating screen (or other  size-separating device), and homogenization equipment.
Earth-moving equipment (including backhoes, front-end loaders, and bobcats) is needed to excavate and
move soils.  Earth-moving equipment  is also needed to  load soils onto the vibrating screen  and the
conveyor belts.  Conveyor belts are required to move the screened soil into the homogenization equipment
and  the bioreactor.  The  vibrating screen is used to remove large rocks  and other  debris,  and the
homogenization equipment is utilized to blend the nutrients into the soil  (if not blended with the water)
before treatment.  A container for wastewater (if not discharged into the sewer) may also be necessary.

2.8     Limitations of the Technology

According to the developer, the scope of contaminants suitable for treatment using the J.R. Simplot Ex-
Situ  Bioremediation Technology is limited to nitroaromatic compounds.  This SITE Demonstration was
conducted to evaluate the performance of the technology with respect to dinoseb only.  The behavior of
other compounds was noted during the demonstration, and therefore data regarding the degradation (or
lack  of degradation) of these compounds are also presented in this report.
                                               23

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It has been established that high levels of hydrocarbons are toxic to the microorganisms necessary for
biodegradation of nitroaromatic compounds. However, by using a cloud-point separation technique prior
to bioremediation, hydrocarbons can be removed from the soil.  When using the cloud-point separation
technique, surfactant and water are added to the waste in designated proportions, and the mixture is
subjected to heat.  This allows the organic phase to separate from the aqueous phase (containing the
dinoseb contamination), while the solid phase simply separates by gravity.  This technique produces an
additional  organic  waste stream that  must be treated by a separate technology or disposed of at a
permitted facility.

The presence of heavy metals in the feed soil does not adversely affect the process.  As this technology
is a sulfate reducing process, toxic metals in the feed soil, such  as: cadmium, lead, etc, are converted
into their sulfide forms, therefore making the metals less toxic (2).  Simplot claims that this technology
is less susceptible to the effects of toxic metals than other bioremediation systems.

Because the performance of the technology is temperature-sensitive, cold climates may adversely affect
the rate of biodegradation.  This was not a significant consideration during treatment in Ellensburg,
Washington when  temperatures were approximately at  18°C,  below that considered  optimal  by the
parametric study (1),  but other tests  have  indicated   that treatment  with operating  temperatures
substantially below the 35 to 37°C range slows the rate of degradation, as expected.  At an additional
cost, heaters may be installed to compensate for cold temperatures.

The execution of this technology may be limited by the availability of tanks for use as bioreactors.  This
limitation  can  be overcome by purchasing or fabricating bioreactors as required.   For large-scale
treatment, space requirements may also restrict the use of this technology.
2.9     ARARS For the J.R. Simplot Ex-S5tu Bioremediation Technology

This subsection discusses specific federal environmental regulations pertinent to the operation of the J.R.
Simplot Ex-Situ Bioremediation Technology 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:
                                                24

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 (1) the Comprehensive Environmental  Response, Compensation, and Liability Act; (2) the Resource
 Conservation and Recovery Act; (3) the Clean Air Act; (4) the Safe Drinking Water Act; (5) the Toxic
 Substances Control Act; and (6) the Occupational Safety and Health Administration regulations. These
 six genera! ARARs are discussed below; specific ARARs that may be applicable to the J.R. Simplot Ex-
 Situ Bioremediation Technology are identified in Table 2-1.

 2.9.1    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 and directs EPA to do the following:
        •      use remedial alternatives that permanently and significantly reduce the volume, toxicity,
               or 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. The J.R.
Simplot Ex-Situ Bioremediation Technology is likely to be part of a CERCLA remedial action.  Between
1986 and 1992, ex-situ biorernediation technologies were selected  with increasing frequency as source
control remedies at 33 Superfund sites (4).

                                             25

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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,  pollutants, or  contaminants.   When  using  the  J.R.  Simplot Ex-Situ  Bioremediation
Technology, the total volume of material undergoing treatment is increased because water is added to the
contaminated soil to provide a treatment slurry.  Even so, the volume of identified contaminants in the
soil is reduced by biological degradation of these compounds. Some biodegradation processes form toxic
intermediates which were not previously present in the contaminated media.  The J.R. Simplot Ex-Situ
Bioremediation Technology anaerobically degrades nitroaromatic contaminants without the formation of
known toxic intermediates,  and thus reduces the volume, toxicity, and mobility of the contaminants.

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 at a particular site and demands on the Superfund for other sites.
These waiver options apply only to Superfund actions taken on-site, and justification for the waiver must
be clearly demonstrated.

2.9.2   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 and 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 J.R.  Simplot Ex-Situ Bioremediation Technology if RCRA-
 defined hazardous wastes are present.  If soils are determined to be hazardous according to RCRA (either
                                               26

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 because of a characteristic or a listing carried by the waste), all  RCRA  requirements regarding the
 management and disposal of hazardous waste must be addressed by the remedial managers.  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.   For the Demonstration Test, the
 technology was  subject to RCRA  regulations  because dinoseb is a RCRA-listed waste (P020).   RCRA
 regulations do not apply to sites where RCRA-defined hazardous wastes are not present.

 Generally, hazardous wastes listed in 40 CFR  Part 261 Subpart D 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, "clean" wastes are still classified as
 hazardous because the pre-treatment material was a listed waste.  For the SITE Demonstration Test in
 Ellensburg, Washington, the WADOE determined  that if dinoseb contamination could be  reduced to
 below a specified cleanup objective, the material would no longer be designated a hazardous waste. This
 cleanup objective was based on risk-related studies conducted by the WADOE. Because the J.R. Simplot
 Company met these cleanup objectives during the Demonstration Test, the treated material was  not
 considered a hazardous waste.  For cases where the pre-treatment waste is defined as hazardous because
 it carries a characteristic (not a listing), it is anticipated that, once the contaminated material is treated
 by  the  J.R. Simplot Ex-Situ  Bioremediation Technology, it will  no longer be a hazardous  waste.
 Contaminated PPE is subject to land  disposal  restriction (LDR) under both RCRA and CERCLA only
 if it contains more than 5% contamination per square inch.

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), 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  (partially  promulgated).   These  subparts also generally apply to
remediation at Superfund sites. Subparts F and S  include requirements tor 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

                                              27

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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.

2.9.3  Clean Air Act (CAA)

The CAA requires that treatment, storage, and disposal  facilities comply with primary and secondary
ambient air quality standards.  During the excavation, transportation, and  treatment of soils, fugitive
emissions are possible.  Fugitive emissions include (1) volatile organic compounds and (2) dust which
may cause semivolatile organic compounds and other contaminants to become airborne.  Soils must be
watered down or covered with industrial strength plastic prior to treatment to prevent or minimize the
impact from  fugitive emissions.  State air quality standards may require additional measures to prevent
fugitive emissions.  The J.R. Simplot Ex-Situ Bioremediation Technology is not designed to treat soils
contaminated with volatile compounds. However, if volatile compounds are present, the system may be
modified to include a cover, an exhaust fan, and carbon adsorbers or biotllters to treat volatile emissions
generated by excavation of the soil.

2.9.4  Safe Drinking Water Act (SDWA)

The SDWA  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 are  found  in 40  CFR  Parts  141  through  149.
Wastewater generated by the J.R. Simplot Ex-Situ Bioremediation Technology during the degradation of
dinoseb is anticipated  to be acceptable for discharge  into a  POTW. Analyses of the wastewater and
approval by  the local authorities will confirm this assumption.
2.9.5   Toxic Substances Control Act (TSCA)

The TSCA of 1976 grants the EPA  authority to  prohibit  or  control the  manufacturing, importing,
processing, use, and disposal of any chemical substance that presents an unreasonable risk of injury to

                                               28

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 human health or the environment. These regulations may be found in 40 CFR  Part 761; Section 6(e)
 deals specifically with PCBs.  Materials  with less than 50 ppm PCB are  classified as non-PCB; those
 containing between 50 and 500 ppm are classified as PCB-contaminated; and those with 500 ppm PCB
 or greater are classified as PCB.  PCB-contaminated materials may be disposed  of in TSCA-permitted
 landfills or destroyed by incineration at a TSCA-approved incinerator; PCBs must be  incinerated. Sites
 where spills of PCB-contaminated material or PCBs have occurred after May 4, 1987 must be addressed
 under the PCB Spill Cleanup Policy in 40 CFR Part 761, Subpart G. The policy establishes cleanup
 protocols for addressing such releases  based  upon the volume and concentration of the spilled material.
 The J.R.  Simplot Ex-Situ Bioremediation Technology is  not  suitable for PCB-contaminated wastes;
 alternative treatment must be undertaken to treat this type of contamination.

 2.9.6   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.

 All technicians operating the J.R. Simplot bioremediation  system  and all  workers performing on-site
 construction are  required to have completed an OSHA training course and  must be familiar with  all
 OSHA requirements relevant to hazardous waste sites. For most sites, minimum PPE for workers will
 include gloves, hard hats,  steel-toe boots, and  Tyvek® suits.  Depending on contaminant types and
 concentrations, additional  PPE may be required.  Noise levels are not expected to be high,  with the
 possible exception of noise caused by pre-treatment excavation and soil handling activities.  During this
 time, 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 be required to wear  ear protection. The levels of noise  anticipated are not expected
to adversely affect the community.
                                              29

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                                         SECTION 3
                                   ECONOMIC ANALYSIS

3.1    Introduction

The primary purpose of this economic analysis is to provide a cost estimate (not including profit) for
commercial  remediation of dinoseb-contaminated sites utilizing the J.R. Simplot Ex-Situ Bioremediation
Technology. This analysis is based on the results of a SITE Demonstration Test that utilized a small-scale
bioreactor with a soil batch capacity of 31 m3, and also information provided by Simplot on future plans
to remediate 3,824 m3 (5,000 yd3) sites. This economic analysis estimates expenditures for remediating
a total volume of 3,824  m3 of treatment  soil in four lined pits  utilizing the J.R. Simplot Ex-Situ
Bioremediation Technology.

Remediation is anticipated to be performed in four lined pits. Each of the four lined pits are assumed
to be 50 feet wide, 340 feet  long, four feet deep, and to have a one-foot berm.  They are each capable
of treating 956 m3 of soil using the J.R. Simplot Bioremediation Technology. Thus, throughout this cost
estimate they will be referred to as "956-m3" lined pits.  Each pit is double lined with 30-miI  HOPE and
has an 8-ounce geotextile underlayment beneath the liners. A hydro-mixer is used to agitate the treatment
slurry.  This is a device that Simplot has developed to mix the soil with the water.

The actual Demonstration Test treated approximately 30 m3 (39 yd3) of soil with an average dinoseb (2-
sec-butyl-4,6-dinitrophenol)  contamination level of 27.3 mg/kg (dry basis). The soil was classified as
a clayey sand  with gravel. Treatment of the soil during the Demonstration Test required 23 days.  For
the purpose of this  economic analysis batch treatment times are assumed to  be 30 days.  The total
treatment period for  treating 3,824 m3 of soil  in four lined pits is approximately two months.  This total
treatment time includes:  excavation of the pits, soil processing, and remediation.  It does  not include
excavation of the treatment soil and demobilization.

3.2    Conclusions
 Estimated  costs  for  four  956-m3  lined  pits remediating a total  volume  of 3,824 m3 of soil  are
 approximately $127/m3 ($97/yd3).  Table 3-1 breaks down these costs into categories and lists each

                                               30

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 category's cost as a percent of the total cost.   Costs that are assumed to be the obligation of the
 responsible party or site owner have been omitted from this cost estimate and are indicated by a.line (—)
 in Table 3-1.  Categories with  no costs associated with this technology are indicated by a zero (0) in
 Table 3-1.  These total costs do not include additional charges that may be imposed by the J.R. Simplot
 Company.   These additional costs may total up  to $131/m3 ($100/yd3), depending  on site-specific
 information.

 Costs presented in this report are order-of-magnitude estimates as defined by the American Association
 of Cost Engineers, with  an  expected  accuracy within  +50%  and  -30%;  however, because this is  an
 innovative technology,  the range may  actually be wider,.

 3.3     Issues and Assumptions

 The cost estimates presented  in this analysis are representative of charges typically assessed to the client
 by the vendor, but do not  include profit. As mentioned above, the total costs do not include an additional
 expense that may be charged by the J.R. Simplot Company.  Depending on site characteristics, this
 additional expense may include supplementary technical  assistance, soil nutrients and enhancements, and
 a carbon source. This could total  up to S131/m3 ($100/ydJ) to the cost of remediation.

 Many actual  or potential costs that exist were, not included as part of this estimate.  They were omitted
 because site-specific  engineering designs that are beyond  the scope  of this SITE project  would be
 required. Also,  certain functions were  assumed to be the obligation of the responsible party or site owner
 and were not included in the estimates.

 Costs that were considered to be the responsible party's (or site owner's) obligation include:  preliminary
 site preparation, excavation  of the  dinoseb-contaminated soil, permits  and regulatory requirements,
 initiation  of monitoring  and sampling programs,  effluent  treatment  and disposal,   environmental
 monitoring, and site cleanup  and restoration.  These costs are site-specific.  Thus, calculations are left
to the reader so that relevant  information  may be obtained'tor  specific cases.   Whenever possible,
applicable information is  provided on these topics so that  the reader can independently perform the
calculations required to acquire relevant economic  data.   Table 3-2 lists a summary of the expenditures
included in the total estimated costs.
                                               31

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                 Table 3-1. Estimated Costs for Treatment Using The J.R. Simplot
                            Ex-Situ Bioremediation Technology
Bioremediation Lined Pit Size
Number of Lined Pits
Total Treatment Volume
Batch Treatment Time
Approximated Total Project Period
Site Facility Preparation Costst
Permitting & Regulatory Costs
Annualized Equipment Costs
Startup & Fixed Costs
Labor Costs
Supplies Costs
Consumables Costs
Effluent Treatment & Disposal Costs
Residuals & Waste Shipping, Handling, & Transport Costs
Analytical Costs
Facility Modifications, Repair, & Replacement Costs
Site Restoration Costs
Total Costs
986 m3(I.250yd3)
4
3,824 m3 (5,000 yd3)
30 Days
2 Months
*"»' W Tot!, Cost
32.37 24.75 25.4%
—
27.18 20.78 21.3%
18.41 14.08 14.5%
12.97 9.91 10.2%
0.16 0.12 0.1%
34.28 26.21 26.9%
—
0. 12 0.09 0. 1 %
1.67 1.28 1.3%
0.22 0.17 0.2%
—
S127/m3 S97/ydJ
t       This does not include costs for excavation of the contaminated soil.  It does include excavation cost for
        constructing the lined pits.
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                       Table 3-2.  Items Included in This Cost Estimate
Cost Item
   Included in
Treatment Costs?
Costs for Site Design and Layout
Survey and Site Investigations Costs
Costs for Preparation of Support Facilities
Costs for Excavation of Contaminated Material
Costs for Excavation of Lined Pits
      NO
      NO
      NO
      NO
      YES
Costs for Construction of the Lined Pits
Costs for Screening and Loading the Contaminated Soil into the Lined Pits
Permitting and Regulatory Costs •
Equipment Costs Incurred During Treatment
      YES
      YES
      NO
      YES
      YES
Insurance, Taxes, and Contingency Costs
Costs for Initiation of Monitoring Programs
Labor Costs Incurred During Treatment
Labor Costs Incurred During Demobilization and Site Restoration
Travel Costs
      YES
      NO
      YES
      NO
      YES
Supplies Costs
Consumables Costs (Fuel, Water, and pH Adjustment Chemicals)
Costs for the J.R. Simplot Potato-Processing By-Product (Starch)
Effluent Treatment and Disposal Costs
              «.H^
      YES
      YES
      NO
      NO
      YES
Environmental Monitoring Analytical Costs
Simplot Monitoring Analytical Costs
Design Adjustments, Facility Modifications, & Equipment Replacement Costs
Maintenance Materials Costs.
Site Restoration & Demobilization Costs (Including Drying the Slurry)	
       NO
      YES
       NO
      YES
       NO
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Other important  assumptions  regarding  operating  conditions and  task responsibilities  that  could
significantly impact the cost estimate results are presented below:

        •      Operating hours during treatment are assumed to be eight hours a day, five days a week.
               Site preparation operations are assumed to be 10 hours a day for seven days a week. Site
               preparation operations will take approximately four weeks.
        •      The soil being  treated is similar to  the  dinoseb-contaminated  soil treated  during  the
               Demonstration Test.
        •      A sufficient water supply of at least 200 gpm is available on-site. Costs will significantly
               increase if wells must be constructed  and/or if water must be transported to the site..
        •      Operations take  place in mild weather. If not,  provisions for heating the bioreactor tanks
               will increase the treatment costs.
        •      The batch treatment time is 30 days.  Costs will  be directly effected if the treatment rate
               increases or decreases.
        •      Four  lined pits are used to treat the dinoseb-contaminated soil.  If Simplot scales their
               process up differently (such as using modular  erected bioreactors, or different sizes and
               numbers of lined pits), then the treatment costs will vary.
3.4     Basis for Economic Analysis
The cost analysis was prepared by breaking down the overall cost into 12 categories:
               Site and facility preparation costs,
               Permitting and regulatory costs,
               Equipment costs,
               Startup and fixed costs,
               Labor costs,
               Supplies costs,
               Consumables costs,
               Effluent treatment and disposal costs,
               Residuals  and waste shipping, handling, and transport costs,
               Analytical costs,
                                               34

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        •      Facility modification, repair, and replacement costs, and
        •      Site restoration costs.

These 12 cost categories reflect typical cleanup activities encountered on Superfund sites. Each of these
cleanup activities is defined and discussed, forming the basis for the detailed estimated costs presented
in Table 3-3. The estimated costs are shown graphically in Figure 3-L  The  12 cost factors examined
and assumptions made are described in detail below.

3.4.1   Site and Facility Preparation Costs

For the purposes of these cost calculations, "site" refers to the  location of the contaminated soil.  For
these cost estimates, it is assumed that the space available at the site is sufficient for a configuration that
would allow the J.R. Simplot Ex-Situ Bioremediation lined pits to be located near the contaminated soil.
Thus, costs for transportation of the contaminated soil  from the site to a separate facility where the Ex-
Situ Bioremediation lined pits  are located is not required for this cost estimate.

It is assumed that preliminary site preparation will be performed by the responsible party (or site owner).
The  amount of preliminary  site  preparation  required  will  depend  on  the site.   Site  preparation
responsibilities include site design and layout, surveys and site logistics, legal searches,  access rights and
roads, preparations for support and  decontamination  facilities, utility connections, excavation of the
dinoseb-contaminated soil, and fixed auxiliary buildings.  Since these costs  are site-specific, they are not
included as part of the site preparation costs in this cost estimate.
 For the purposes of these cost calculations, installation costs are limited to shipping cost for the liners,
 and construction of the four lined pits. Shipping costs for all of the liners are estimated at a total cost
 of $2,400.  Excavation costs for the lined pits is limited to rental equipment, fuel for the equipment,
 equipment operators, and labor to install the liners and geotextile underlayment for the liner. Excavation
 rental equipment includes:  five 1-yd3 excavators (each $2,100/wk). three 10-yd* box dump trucks (each
 $600/wk), and one backhoe ($700/wk) each rented  for approximately three weeks. Fuel requirements
 are approximated at 3-gals/hr for  each excavator, 2-gals/hr for each dump truck, and 3-gals/hr for the
 backhoe.  Fuel cost are estimated a  $1.00 per gallon.  Equipment operators include five excavator
 operators (each $25/hr), three dump truck operators (each $25/hr), one backhoe operator ($25/hr), and
                                                 35

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           Table 3-3.  Detailed Costs for Treatment Using the J.R Simplot Ex-Situ
                      Bioremediation Technology (page 1 of 2)
Bioremediation Lined Pit Size
Number of lined Pits
Total Treatment Volume
Batch Treatment Time
Approximated Total Project Period
986m3 (1,250 yd3)
4
3,824 m3 (5,000 yd3)
30 Days
2 Months
$/m3 $/yd3
Site and Facility Preparation Costs
        Site design and layout
        Survey and site investigations
        Legal searches, access rights & roads
        Preparations for support facilities
        Auxiliary buildings
        Excavation of the contaminated soil
        Technology-specific requirements
        Transportation of waste feed
Total Site and Facility Preparation Costs

Permitting and Regulatory Costs
        Permits
        System monitoring requirements
        Development of monitoring and protocols
Total Permitting and Regulatory Costs

Equipment  Costs
        Annual ized equipment cost
        Support equipment cost
        Equipment rental
Total Equipment Costs

Startup and Fixed Costs
        Working capital
        Insurance and taxes
        Initiation of monitoring programs
        Contingency
              and Fixed Costs
32.37

32.37
 0.46
24.88
 1.84
27.18
17.97
 0.22

 0.22
18.41
24.75

24.75
 0.35
19.02
 1.41
20.78
13.74
 0.17

 0.17
14.08
Supervisors
Health & Safety
Technicians
General'
Secretary
Rental car
Travel
Total JLabor Costs
3.44
0.71
4.79
2.51
0.52
0.37
0.63
12.97
2.63
0.54
3.66
1.92
0.40
0.28
0.48
9.91
                                                                          (Continued)
                                         36

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           Table 3-3.  Detailed Costs tor Treatment Using the J.R. Simplot Ex-Situ
                      Bioremediation Technology (page 2 of 2)
                                   Bioremediation Lined Pit Size
                                          Number of Lined Pits
                                       Total Treatment Volume
                                          Batch Treatment Time
                              Approximated Total Project Period
 986 mj( 1,250 yd3)
 4
 3,824 m3 (5,000 yd3)
 30 Days
 2 Months
Supplies Costs
       Personal protective equipment
Total Supplies Cost

Consumables Costs
       Fuel
       Water
       pH adjustment chemicals
Total Consumables Costs

Effluent Treatment and Disposal Costs
       On-site facility costs
       Off-site facility costs
               -wastewater disposal
               -monitoring activities
Total Effluent Treatment and Disposal Costs

Residuals &  Waste Shipping, Handling & Transport Costs
       Preparation
       Waste disposal
Total Residuals & Waste Shipping, Handling & Transport Costs

Analytical Costs
       Operations
       Environmental monitoring
Total Analytical Costs

Facility Modification, Repair, & Replacement Costs
       Design adjustments
       Facility modifications
       Maintenance materials
       Equipment replacement
Total 'Facility Modification, Repair, & Replacement Costs

Site Restoration Costs
       Site cleanup and restoration
       Permanent storage
Total Site Restoration  Costs
 $/mJ

 0.16
 0.16
 0.21
 0.06
34.01
34.28
 0.12
 0.12
 1.67

 1.67
 0
 0
 0.22
 0
 0.22
 S/yd-'

 0.12
 0.12
 0.16
 0.05
26.00
26.21
 0.09
 0.09
 1.28

 1.28
 0
 0
 0.17
 0
 0.17
TOTAL COSTS
 $127/m3   $97/yd3
                                          37

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                                                 $34.28/m3 (A)
S32.37/rr? (B)
                                                  $27.18/m3 (C)
                                                                                                 (G,H,&I)
                                                                                               .67/nr3 (F)

                                                                                               312.97/m3 (E)
                                                                                                $18.41/nP (D)
  ] (A) Consumables Costs ($34.28/m3)
   (B) Site Facility Preparation Costs ($32.37/m3)
   (C) Annualked Equipment Costs ($27.18/m3)
   (D) Startup & Fixed Costs ($18.4 1/m3)
   OE) Labor Costs ($12.97/m3)
*  Permitting & Regulatory Costs
                                                    (F) Analytical Costs ($1.67/m3)
                                                    (G) Facility Modifications, Repak, & Replacement Costs ($0.22/m3)
                                                    (H) Supplies Costs ($0.16/m3)
                                                    (I) Residuals & Waste Shipping, Handling. & Transport Costs (SO. 12/m3)
                                                 *  Effluent Treatment & Disposal Costs
                                                 *  Site Restoration Costs
   *.
      These costs are not included in this economic analysis.

               Figure 3-1.  Estimated Costs for the J.R. Simplot Ex-Situ Bioremediation Technology

      one supervisor ($40/hr) for 10 hrs per day for approximately 17 days.  Liner installation requires 12
      general labors at $20/hour/person for  16 hours per lined pit and liner installation equipment (estimated
      at a total of $2,700).

      Technology-specific site preparation requirements for the Ex-Situ Bioremediation Unit consist of:  soil
      screening; and soil and  water loading  into the bioreactor.

      Equipment necessary for technology-specific site preparation for treatment includes:  a vibrating screen,
      a conveyor belt, and a 50-kW diesel generator.
                                                         38

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3.4.2  Permitting and Regulatory Costs

Permitting and regulatory costs are generally the obligation of the responsible party (or site owner), not
that of the vendor.  These costs may include actual permit costs, system monitoring requirements, and
the development of monitoring and analytical protocols. Permitting and regulatory costs can vary greatly
because they are site- and waste-specific.  No permitting costs are included in this analysis; however
depending on the treatment site, this may be a significant factor since permitting activities can be very
expensive and time-consuming.

3.4.3  Equipment Costs

Equipment costs include purchased equipment, purchased support equipment,  and rental equipment.
Support equipment refers to pieces of purchased equipment and/or sub-contracted items that will only be
used for one project.

Purchased Eciuipment Costs
The purchased equipment costs are presented  as  annualized equipment costs,  prorated based on the
amount of time the equipment is used for the project. The annualized equipment cost is calculated using
a 5-year equipment life and a 10% annual  interest rate.  The annualized equipment cost is based upon
the writeoff of the total initial capital equipment cost and scrap value (5,6) (assumed  to be 10% of the
original equipment cost) using the following equation:
 Where
        V
        V.
        n
        i
                            Capital recovery - (V -
is the cost of the original equipment,
is the salvage value of the equipment,
is the equipment life (15 years), and
is the annual  interest rate (6%) (5,6).
                                                                Q"
                                                        (1 + i)"' -1
                                               39

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For this cost estimate, purchased equipment includes: four hydro-mixers (used for 7 weeks) at a total
cost of $40,000, and four data loggers (used for 7 weeks) at a total cost of $1,000. The total cost of the
purchased equipment is thus $41,000.  This total  cost is used to  calculate the prorated  annualized
purchased equipment cost.

Support Equipment Costs

For estimating purposes, support equipment includes:  double liners,  geotextile underlayment fofr the
liner, and 2 inches of sand between the liners for each pit ($22,700 per pit), a decontamination area
($300), four area lights ($245 each), and 12 probes to measure temperature,  pH, and reduction potehiial
($250 each).  This support equipment will not be used on subsequent projects, and therefore these costs
are not prorated.

Rental Equipment Costs

Rental equipment includes: a bobcat at $l,650/month for  two months, an office trailer at $330/month
for two months, a telephone at $30/month for two months,  portable toilet facilities at $30/month for two
months, and a 50-kW generator at $l,500/month for two months.

3.4.4  Startup and Fixed Costs

Working capital is based on the amount of money  currently invested  in supplies and consumables.  The
working capital cost of supplies and consumables is based on maintaining a one-month inventory of these
items.  (See  "Supplies Costs" and  "Consumables Costs" for  the  specific  amount of supplies  and
consumables  required for the operation of the system.  These  quantities were used to determine the
amount of supplies and consumables required to maintain a one-month  inventory of these items.)

Insurance and taxes are usually approximately 1 %  and 2 to 4% of the total purchased equipment capital
costs,  respectively.  The cost of insurance for a hazardous waste process  can be several times more.
Insurance and taxes together are assumed for the purposes of this estimate to  be  10% of the purchased
equipment capital costs (6).
                                               40

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The cost for the initiation of monitoring programs has not been included in this estimate. Depending on
the site and the location of the system, however, local authorities may impose specific guidelines for
monitoring programs.  The stringency and frequency of monitoring required may have significant impact
on the project costs.  Simplot does plan to monitor pH,  redox potential, and temperature within the
bioreactor using probes  and data loggers.  The cost of the data logger is  included under purchased
equipment, and the cost  of the probes is included under support equipment in the "Equipment Costs"
section.

A contingency cost of 10% of the equipment capital costs is allowed for any unforeseen or unpredictable
cost conditions, such as strikes, storms, floods, and price variations (6,7).

3.4.5   Labor Costs

Labor costs are limited to labor rates, per diem, daily  transportation, and travel.  Labor rates include
overhead  and administrative costs.  Per diem is estimated at $70/day/person.   Daily transportation
includes a rental car and fuel at $50/day.   Round trip travel costs are assumed to be $600/round
trip/person.  Only supervisors,  health and safety engineers,  and technicians  require per diem, daily
transportation to the site, and round trip air travel to the site location.   Support secretaries provide
assistance from the home office and are not required to be present on-site. Loader operators and general
operators  are assumed to  be local hires that will be trained and supervised by Simplot personnel. Thus,
loader operators and general operators do not require per diem or daily transportation to the site.

For this cost estimate, operating labor time on-site is assumed to be eight hours  a day, five days a week.
Labor requirements include:  one supervisor at $70/hour for four weeks; one health and safety engineer
at $55/hour for one week; two technicians at $45/hour/person for four weeks; two general labors at
$15/hour/person for  eight weeks;  and one secretary at $25/hour for two hours a day, five days a week
for 8  weeks.  Travel includes four round trips (one trip for the supervisor, one trip for the health and
safety engineer, and  two  trips total for the two technicians).
                                               41

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3.4.6   Supplies Costs

Supplies costs for this cost estimate are limited to personal protective equipment (PPE). The cost of PPE
is estimated at $3 per set of PPE.  It is assumed that 200 sets of PPE will be required.

3.4.7   Consumables Costs

Consumables  required for the operation of the J.R. Simplot Ex-Situ Bioremediation Technology are
limited to buffer, fuel, electricity,  and  water. For the purposes of this economic analysis it is assumed
that the cost of the buffer is $34/m3 ($26/yd3) of treatment soil.

The fuel required for the Ex-Situ Bioremediation Unit is estimated at 380 L/week (100 gal/week) for eight
weeks.

The water rate is  assumed  to be $0.05/1,000 L  ($0.20/1,000 gal).  Approximately 4,660,000 L
(1,230,000 gals) of water are required  for treatment of 3,824 m3 of soil using the J.R. Simplot Ex-Situ
Bioremediation Technology.

3.4.8   Effluent Treatment and Disposal Costs

One effluent stream is anticipated from  the J.R. Simplot Ex-Situ Bioremediation Technology. This is the
treated slurry from the Ex-Situ Bioremediation Unit.  It is anticipated that the solid phase of the treated
slurry  can be  dried and replaced within the excavated area or used as fill material. In states where
cleanup levels have not been established or when cleanup levels are not met, then disposal of the soil at
a RCRA-permitted facility may be necessary. The  liquid'phase of the slurry is anticipated to be non-
hazardous and suitable for disposal to a local POTVV.  In some cases with the proper permits it may be
possible that the integrity of the liner can be intentionally breached when treatment is complete, and the
liner abandoned in place.
                                               42

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3.4.9   Residuals and Waste Shipping, Handling and Transport Costs

Waste disposal costs including storage, transportation and treatment costs are assumed to be the obligation
of the responsible party (or site owner). It is assumed that the only residuals or solid wastes generated
from  this process will be used PPE and decontamination water.  The disposal cost tor 208-L (55-gaI)
drums of used  PPE and/or decontamination water is estimated at $225/208-L drum.  For this  cost
estimate, it is assumed that two 208-L drums of used PPE and decontamination water will be generated.
3.4.10
Analytical Costs
Only spot checks executed at Simplot's discretion (to verify that equipment is performing properly and
that cleanup criteria are being met) are included in this cost estimate. The client may elect, or may be
required by local authorities, to initiate a planned sampling and analytical program at their own expense.
The cost for Simplot's spot  checks is estimated  at $200 per sample.  For  the purposes  of this  cost
estimate, it is assumed that there will be 32 samples analyzed.

The analytical costs associated with environmental monitoring (not process monitoring) have not been
included in this estimate due to the fact that monitoring programs are not typically initiated  by Simplot.
Local authorities may,  however, impose  specific sampling and monitoring criteria  whose analytical
requirements could contribute significantly to the cost of the project.
3.4.11
Facility Modification, Repair and Replacement Costs
Maintenance costs are assumed to consist of maintenance labor and maintenance materials.  Maintenance
labor and materials costs vary with the nature of the waste and the performance of the equipment.  For
estimating purposes, the annual maintenance labor and materials cost is assumed to be  10%  of the
purchased equipment capital costs.  Costs for design adjustments, facility modifications, and equipment
replacements are not included in this cost estimate.
                                              43

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3.4.12
Site Restoration Costs
Site restoration requirements will vary depending on the ruture use of the site and are assumed to be the
obligation of the responsible party.  Therefore, no site cleanup and restoration costs are included in this
cost estimate.
                                                 44

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                                          SECTION 4
          TREATMENT EFFECTIVENESS DURING THE SITE DEMONSTRATION

This section presents the results of the SITE demonstration in Ellensburg, Washington and discusses the
effectiveness of treatment at the Bowers  Field  site by  the J.R. Simplot  Ex-Situ  Bioremediation
Technology.

4.1     Background

Bowers Field is a county-owned airport located in rural Ellensburg, Washington.   State regulatory
agencies have detected dinoseb contamination at this site.   Dinoseb (2-jt'c-butyl-4,6-dinitrophenol) is
nitroaromatic compound used as an agricultural herbicide to  defoliate potatoes and other legumes.  It is
a RCRA-listed waste bearing a P020 waste code.  It is conjectured that the airport soil was previously
contaminated with dinoseb by crop-dusting activities.

The fixed base operator at the airport contracted with the J.R. Simplot Company to clean up dinoseb-
contaminated soil at Bowers Field.  The cleanup was initiated in cooperation with the EPA under the
SITE Demonstration Program.  A partial site characterization was performed  in  November 1992 by
Science Applications International Corporation (SAIC), a contractor to the EPA.  The investigation was
not intended to fully characterize the site, but to  identify approximately 30 m3 of dinoseb-contaminated
soil for use in a SITE Demonstration Test.  The results of the site characterization indicated that the
levels of dinoseb contamination ranged from < 1 mg/kg (the analytical detection limit for these analyses)
to 292 mg/kg.   Average concentration of dinoseb in the test  soil was estimated at approximately 50
mg/kg.  Neither volatile nor semivolatile organic compounds were detected.  Other pesticides, herbicides,
and metals were identified as contaminants in the soil. Dinoseb was the only target analyte selected for
the Demonstration Test.
The only critical objective for the Demonstration Test was based on the developer's claim—that dinoseb
contamination in soil could be reduced by at least 95% using their technology.  This critical objective was
to determine the effectiveness of the J.R.  Simplot Ex-Situ Bioremediation Technology  in degrading
dinoseb in the test soil based on the concentration in the pre-treatment slurry (dry basis) and  the post-
treatment slurry (dry basis).  Results were to be reported as percent reduction in the slurry (dry basis).

                                              45

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Non-critical objectives for the Demonstration Test were:

       •       to determine if the reduction of dinoseb contamination was a result of the J.R. Simplot
               Ex-Situ Bioremediation Technology;
       •       to determine if the reduction of dinoseb contamination was a result of biodegradation;
       •       to determine the relative toxicity of the test soil before and after treatment;
       •       to determine the presence of 6-amino-4-nitro-2-j6'C-butylphenol (a previously identified
               intermediate)  in the soil before and after treatment;
       •       to determine if pesticides and herbicides other than dinoseb were present in the test soil
               and, if so, to  establish their levels of contamination;
       •       to determine the metals contamination  in the soil  before treatment;
       •       to determine the type of soil being remediated;
       •       to evaluate the effect of pH, temperature, and redox potential; and
       •       to develop operating costs.

The use and manipulation of  microorganisms for treatment of waste, particularly wastewater, has been
applied for many years.   Bioremediation, or enhanced  microbial treatment, now has  many other
applications including soils, sludges, groundwater, process water, and surface  waters.  Treatment may
take place under aerobic  or  anaerobic conditions.  Although bioremediation  has met much success,
polymerization products that  are  potentially toxic are often  formed under aerobic or  microaerophilic
conditions.  The J.R. Simplot Company has developed a simple bioenrichment procedure that achieves
anaerobic conditions under which a microbial consortium can degrade nitroaromatic compounds in soil
without the formation of known toxic polymerization products.

4.2    Detailed Process Description

The J.R. Simplot Ex-Situ Bioremediation Technology takes place in a bioreactor.  Portable tanks with
a volume of 75,700 L (20,000 gal) are used to treat up to  31 m? (40 yd3) of soil; for larger volumes of
soil, excavated, lined, in-ground pits approximately 15.2 m (50 ft) wide, 104 m (440 ft) long, and  1.2
m (4 ft) deep can be used, or, erected modular tanks with a volume of 2.84 million L (750,000 gal) are
                                               46

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used.  Both can treat up to  956 m3 (1,250 yd') of soil.  V/hen the treatment volume exceeds 956 m3,
multiple lined pits or multiple modular bioreactors may be used simultaneously.

Simplot utilized a portable tank as the bioreactor during the Demonstration Test because the volume of
test soil was small—only 30 m3 (39 yd3).  The bioreactor for these tests was 12.2 m long, 2.4 m wide,
and 2.6 m tall (40 ft x  8.0  ft x  8.5  ft).  To facilitate mixing, water was placed in the bioreactor with
the soil in a ratio of approximately I  L (0.26 gal) water to  1 kg (2.2 Ib) soil.  Nutrients  (J.R. Simplot
Company potato-processing by-product) and pH-regulating agents were added  to induce the aerobic
microorganisms to consume oxygen from the soil.  This  lowered the redox potential (EJ and created
anaerobic conditions. Tests have shown that anaerobic conditions with Eh less than -100  mV promote
the establishment of the  anaerobic microorganisms  capable of degrading dinoseb and other nitroaromatic
compounds (1).

Figure 4-1 shows the flow diagram for the Simplot process as operated during the Demonstration Test.
Initially, the  excavated  test  soil  was sent through  a  vibrating screen to remove  large rocks and other
debris greater than 12.7 mm (0.5 in)  in diameter.  Since dinoseb  is water-soluble, the rocks  and debris
at the Bowers Field site were rinsed with water  to remove dinoseb contamination from the surface.
Rinsing activities were  not  completed during the  Demonstration Test due to the  large percentage of
material that was greater than  12.7 mm in diameter.  The oversize material will be treated by a separate
soil or rock  washing technology or properly disposed of at  a later date.  The rinse water .that was
generated was combined with make-up water and placed in the bioreactor. A total  volume of 28,900 L
(7,640 gals) of make-up water was added to the bioreactor to provide the 1-L to 1-kg (0.26-gal to 2.2-lb)
ratio required for treatment.  Acids and phosphate buffers were added to the system to correct the pH.
Batches of treatment soil and J.R. Simplot Company  potato-processing by-product (2% by weight) were
mixed together in a pug mill (homogenization unit) and added  to the bioreactor by conveyor until all of
the treatment soil was  in the bioreactor.  After the soil, water,  and  nutrients  were loaded in the
bioreactor, the mixture  was  augmented  with 0.02  m3 (a 5-gallon  pail) of soil previously treated by the
Simplot process during treatability studies for this site.   This  previously-treated soil contained the
naturally selected indigenous microorganisms necessary for degradation of dinoseb using the J.R. Simplot
Ex-Situ Bioremediation Technology.   The  soil  .at Bowers Field already  contained  the necessary
microorganisms, however, the treatment slurry was augmented so that dinoseb degradation rates would
be enhanced.
                                               47

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   Contaminated Soil
oo
          Starch
         Addition
Vibrating Screen
                                      I
                                                  contaminated
                                                  soil > 12.7 mm
           contaminated
           soil < 12.7 mm
 Homogenization
(using a pug mill)
                             Augmentation Soil
Screen Overs
  Washing
                                                                                            Clean Rejects
       Water From
       Screen Overs
       Washing
     Clean rejects if contaminants in the soil are water soluble.
                      Make-up
                        Water
                         and
                        Buffer
tj-

,
A.
pH, Redox
Potential, &
Temperature
Probe
                         Figure 4-1.  J.R. Simplot Process Flow Diagram for the Bioremediation of
                                Dinoseb-Contaminated Soil During the Demonstration Test

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The bioreactor was loosely covered and equipped with three mixers for agitation.  The mixers were
installed to achieve a well-mixed slurry in the bioreactor, however,  "dead spots" (i.e. settled sediment
that did not receive agitation) occurred in the bioreactor due to insufficient mixing of the slurry by the
agitators. Although previous testing indicated that the effect of the dead spots on the J.R. Simplot  Ex-
Situ Bioremediation Technology is not significant, the bioreactor was lanced to agitate these dead spots.
This was accomplished by placing the suction end of a diaphragm pump into the settled sediment  and
pumping the sediment into a more well-mixed region of the bioreactor. The bioreactor was also equipped
with instrumentation to monitor pH, temperature, and  redox potential.  A  limited study has shown  that
suitable operating conditions are temperatures between  35 and 37°C,  pH below 8.0 (ideally between 7.5
and 8.0 for dinoseb degradation), and redox  potential <-100 mV //;.

4.3     Methodology

Prior to commencement of the Demonstration Test, SAIC determined that evaluation of the J.R. Simplot
Ex-Shu Bioremediation Technology would begin after the excavated soil was  screened.  Therefore,
sampling of the pre-treatment feed soil for all parameters occurred after the soil had been excavated  and
passed through the screening process.  For informational purposes, three composite samples of the  pre-
screened material were collected for particle size and Atterberg limits determination to evaluate the type
of soil that could be processed  by the overall system (including screening).
Excavation of the test soil was  performed by the J.R. Simplot Company, assisted by  Envirogen, Inc.
Simplot and Envirogen determined the location of the soil to be excavated based on the findings of the
site characterization previously performed by SAIC.  The soil was stockpiled until excavation activities
were complete.  Excavated soil was then passed through a vibrating screen to separate out rocks and other
debris greater than 12.7 mm (0.5 in) in diameter.  Each fraction (the screened test soil and the oversize
material) was placed in a separate lined area and covered for storage before sampling  and  processing.
The screened soil  pile was leveled and shaped into a flat, truncated pyramid-like form.  All  sides of the
pile were measured so that the total soil  volume could be geometrically determined.  Seven  soil  density
samples were collected in metal sleeves of known mass and volume.  The volume of each metal sleeve
was determined on-site using a calibrated Vernier caliper.  The mass of each metal  sleeve was also
determined on-site using a certified calibrated balance. The soil density and total soil volume were used
                                               49

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to determine the mass of treatment soil.  Three composite samples were collected from this pile for
particle size and Atterberg limits determination.

The screened soil was placed in wheelbarrows to facilitate loading of the soil into a hopper that fed the
homogenization unit (pug mill).  J.R. Simplot Company potato-processing by-product was added to the
soil prior to homogenization by the pug mill.  Soij samples were collected from each wheelbarrow before
the soil was fed to the pug mill and before the starch by-product was added.  Samples of the J.R. Simplot
Company potato-processing by-product were collected for dinoseb, pesticides, chlorinated herbicides, and
metals analyses. These samples were held for analysis, unless it was  found that the post-treatment
samples had elevated .concentrations from the pre-treatment samples for dinoseb, pesticides, chlorinated
herbicides, and/or metals. Thus, these samples would help determine if the potato-processing by-product
had introduced dinoseb, pesticides,  chlorinated herbicides and/or metals to  the bioreactor.   Since the
post-treatment samples did not have elevated concentrations from the pre-treatment samples, the potato-
processing by-product samples were not analyzed.
In order to measure the variability of dinoseb contamination in the treatment soil, a grab sample was
collected from every wheelbarrow fed into the hopper as mentioned above.  After each four grab samples,
the soil was homogenized and appropriate aliquots were collected.  A total of 61 primary samples were
collected for dinoseb analysis. Four field duplicates and four field triplicates were collected for dinoseb
analysis to measure sampling and compositing variability.  Matrix spike (MS) and matrix spike duplicate
(MSD) analyses were  performed on  aliquots of  five dinoseb samples.   Gas chromatograph/mass
spectrometer (GC/MS) confirmation of dinoseb was also performed on aliquots of four samples previously
analyzed by high  performance liquid chromatography  (HPLC).  These GC/MS scans, along with the
HPLC scans, also allowed the identification and quantification of other compounds  present.

A negative process control was  set up prior to the start  of the  Demonstration  Test as a means of
comparing naturally occurring dinoseb degradation to degradation by the Simplot process. Grab samples
were collected from each wheelbarrow  to comprise a composite sample of the entire feed stream for the
negative process control. The sample was homogenized and placed in a covered 19-L (5-gal) container
near  the bioreactor.  As microorganisms are indigenous to the site, it is  expected that some natural
degradation will occur, however, the rate of degradation is  unknown at this time.  No amino derivative
or  any other known toxic derivatives  were found in the negative control, indicating that this natural
                                               50

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process was  not similar to the process occurring within the bioreactor.  Due  to uncertainties in the
statistical evaluation, this presumed natural degradation will not be discussed further in this report and
will be left for reader interpretation.

Thirteen samples each were collected for pesticides,  chlorinated herbicides, and metals analysis.  These
samples were collected  in a manner similar to the dinoseb samples except a grab sample was obtained
from each of twelve separate wheelbarrows before the soil was homogenized and aliquots were collected.
One field duplicate each was collected for pesticides, chlorinated herbicides,  and metals analysis.  The
MS/MSD analyses were performed on aliquots of one pesticide and one chlorinated herbicide sample.
The MS and  analytical duplicate (AD) analyses were performed on aliquots of one metals sample.

Grab samples were collected from each wheelbarrow to comprise composite samples  of the entire feed
stream for toxicity tests.  These toxicity tests  included earthworm reproduction,  early seedling growth,
root elongation, and herbicide bioassay screening.   Reference samples for the toxicity tests were also
collected to compare to the toxicity of uncontaminated soil with dinoseb-contaminated soil.  Except for
having no contamination, this soil had the same characteristics and composition as the treatment  soil.
Although appropriate samples were collected, the toxicity tests were not performed.  Since there were
other toxic pesticides present in the test soil, it was determined  at the beginning of.testing that the toxicity
analysis would be misleading.  As toxicity tests are also expensive, it was decided that toxicity analysis
should not be performed.

Because dinoseb is water soluble, the  oversize material was washed with  water to remove surface
contamination.  The washwater was collected and then sampled.  Samples were analyzed for dinoseb,
pesticides, chlorinated herbicides, and metals.  Approximately 570 L (150 gal) of washwater was added
to the bioreactor.   Washing activities  were  not completed  during the Demonstration Test, and the
unwashed portion of the oversize material  must be either cleaned using a separate soil or rock washing
technology (with the washwater and fines being placed in the bioreactor for treatment  at a later date) or
properly disposed of at  a permitted facility.
Based on the amount of soil to be treated, a total of 28,900 L (7,640 gal) of make-up water was added
to the bioreactor.  This water was sampled before introducing the soil into the bioreactor. Samples were
analyzed for dinoseb, pesticides, chlorinated herbicides, and metals.
                                                51

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After the soil, water, and nutrients were added, a sterile process control was set up at the start of the
Demonstration Test by collecting slurry directly from the bioreactor.  This sample was to be sterilized
to destroy any existing microorganisms and then returned to the vicinity of the bioreactor. Degradation
of dinoseb in the bioreactor and lack of degradation in the sterile control under similar conditions would
indicate that dinoseb degradation in the bioreactor was biological. The abiotic control was analyzed and
found not to be sterile although it was exposed to 1.56 MRads of gamma radiation. Thus, it was decided
that it not be used as a control.

Monitored parameters during remediation were pH, temperature, and redox  potential. Measurements of
these parameters were taken every  15 seconds and  recorded  by computer.   During the  course of
remediation, conditions more than sufficient for anaerobic dinoseb degradation (Eh<-200 mV) were
achieved in three days, and the pH stabilized at 7.1  as seen in Figure 2. However,  due to the unusually
cool summer experienced in the Pacific  Northwest during 1993, the temperature in the  bioreactor
averaged only 18°C. This was lower than the preferred bioreactor temperature of  35 to 37°C  (1).

According to the developer, treatment time was expected to be approximately six weeks. Therefore, after
23  days (the anticipated midpoint),   10 samples  were  obtained  to  determine the progress of  the
remediation.  Analysis of these  mid-point samples indicated that  the dinoseb had been  completely
degraded.  Full post-treatment sampling of the bioreactor was then initiated.

All post-treatment slurry samples were obtained from random locations within  the bioreactor.  A total
of 39 post-treatment slurry samples were collected and analyzed for dinoseb.  Four field duplicate samples
were collected for dinoseb to measure sampling variability.  The MS/MSD analysis was performed on
aliquots of four dinoseb samples, and GC/MS confirmation was performed on aliquots of four dinoseb
samples.   These GC/MS scans, along with the  HPLC scans,  also allowed  the identification  and
quantification of other compounds present.

Six primary samples each were collected for pesticides and  chlorinated herbicides analysis.  One field
duplicate sample each was collected  to assess the sampling variability  for pesticides and chlorinated
herbicides.   The MS/MSD analysis was performed on aliquots of one pesticide and one chlorinated
herbicide sample.
                                               52

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s
 £
 CJ
 t-t
 4)
 cu
i
25



20



15



10



 5



 0
                                                                      •Temperature

                                                                      •pH
                              Day 0 to Bay 23
                                                                     •Redox
                              Day 6 to Day 23
     Figure 4-2.  Monitored Parameters during Demonstration Test



                              53

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Slurry samples were obtained for the post-treatment toxicity tests. Samples were collected for earthworm
reproduction, early seedling growth, and root elongation toxicity tests.  As stated previously, the toxicity
tests were not performed.

4.4     Performance Data

This section presents the performance data gathered by the testing methodology described above. Results
are presented and interpreted below.
4.4.1   Chemical Analyses

Dinoseb: A total of 110 primary samples (61 pre-treatment, 10 mid-point, and 39 post-treatment) were
analyzed by the SAIC Analytical Laboratory for dinoseb using a high performance liquid chromatography
(HPLC) method developed specifically for this demonstration (8).  This method is given in the SITE
Technology Evaluation Report for this demonstration. This method gave analytical detection limits of
0.03 mg/kg for the solid samples and 0.015 mg/L for the liquid samples. (Because the mid-point samples
were not concentrated in the laboratory, detection limits for these samples were 0.15 mg/kg for the solid
phase and 0.15 mg/L for the liquid phase.) The average concentration of dinoseb in the feed soil, on a
dry basis, was 27.3 mg/kg with a range of 14.0 to 34.2 mg/kg. The 95% confidence interval around this
average was 26.4 to 28.3 mg/kg. No dinoseb was found in the pre-treatment make-up water samples.
Upon arrival in the laboratory, the post-treatment slurry samples were phase separated, and the solid and
liquid phases were analyzed separately.  No dinoseb was found in either the solid phase or the liquid
phase of the post-treatment slurry samples.  Based on the average pre-treatment slurry  concentration (on
a dry basis) and the analytical detection limit for the post-treatment slurry samples (on a dry basis), the
percent reduction of dinoseb in the slurry was > 99.8% .  The concentration of dinoseb in the pre- and
post-treatment  slurries was determined, on a dry basis, using the following expression:
          \Slurry\Dry
                                         (Wet solid x Sy)  + (Liquid x L}
                                       =
where:
Wet Solid
Sr
Liquid
Concentration of the wet solid phase in mg/kg.
Weight fraction of wet solid phase.
Concentration of the liquid phase in mg/kg.
Weight fraction of liquid phase.
                                                54

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Using the pre- and post-treatment concentrations of dinoseb in the bioreactor (analytical detection limit
in the case of post-treatment samples), on a dry basis, the percent reduction was determined.
                                                       ,
                                 Percent Removal=\ 1 — '- xlOO%
                                                  I  CJ
where:
Cf
C,
Post-treatment slurry dinoseb concentration in mg/kg (dry basis).
Pre-treatment slurry dinoseb concentration in mg/kg (dry basis).
No known intermediates from the degradation of dinoseb were found by HPLC analysis. To investigate
this  further,  GC/MS  scans were run on four selected pre-treatment and four selected post-treatment
samples.  These analyses confirmed that no known intermediates had been formed during remediation.
Additionally, no new  peaks were observed on the post-treatment sample chromatograms.

Analysis of the negative process control before and after treatment  indicated that dinoseb, nitroaniline,
and  atrazine in the soil  naturally degraded  during  the treatment period.   However,  dinoseb and
nitroaniline levels in the negative process control were only reduced by,26.8% (from 28.0 mg/kg to 20.5
mg/kg, on a dry basis) and 51.0% (from  10.2 mg/kg to 5.0 mg/kg. on a dry basis), respectively. This
is lower than the reduction of dinoseb and nitroaniline levels achieved in the bioreactor: >99.8% and
>87.3%  (on a dry basis),  respectively.  The accelerated rates-of dinoseb and nitroaniline degradation
seen in the bioreactor can therefore be attributed to the J.R. Simplot Ex-Situ Bioremediation Technology.
All of the negative control data is based upon only 3 pre- and 3-post treatment measurements. Therefore,
statistical evaluations indicating degradation is somewhat uncertain. The level of atrazine in the negative
process control was reduced by 88.3% (from 55.6 mg/kg to 6.5 mg/kg, on a dry  basis) while that in the
bioreactor was only reduced by 52.5%. Degradation of atrazine is not attributed to the J.R. Simplot Ex-
Situ  Bioremediation Technology since natural degradation  rates were greater than  those seen in the
bioreactor.

Pesticides and Herbicides: Samples were analyzed  by Lockheed Analytical Laboratory for pesticides
using SW-846 Method 8080 and for chlorinated herbicides using SW-846 Method 8150.  Compounds
were also detected by the HPLC and GC/MS scans  performed by the SAIC Analytical Laboratory on
aliquots collected for  dinoseb analysis.  Table 4-1  presents a summary  of the average pre- and post-
                                              55

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               Table 4-1. Other Compounds Reduced During the Demonstration Test
 Compound
Average Pre-Treatment
 Slurry Concentration
    on a Dry Basis
       (mg/kg)
Average Post-Treatment
  Slurry Concentration
     on a Dry Basis
        (mg/kg)
Atrazine*
Nitroaniline*
Malathionf
Parathion*
53.7
11.9
1.60
2.30
25.5
<1.51
<1.51
<1.5I
       Based on high performance liquid chromatography (HPLC) analyses.
 f     Based on gas chromatography/mass spectrometry (GC/MS) analyses.

treatment slurry concentrations of the compounds reduced during the Demonstration Test.  Although not
attributed to the J.R. Simplot Bioremediation Technology (based on the results of the'negative process
control discussed above), a >52.5 percent reduction was observed for atrazine (see Table 4-1).  On a
dry basis, the average pre-treatment slurry concentration of 2,6-clichk>ro-4-nitroaniIine (nitroaniline) was
11.9 mg/kg.  Like dinoseb,  this nitroaromatic compound was also degraded to  below its analytical
detection limit in the post-treatment slurry samples.  Based on pre- and post-treatment results in the slurry
on a dry basis, nitroaniline was reduced by > 87.3% (see Table 4-1).  Further inspection of Table 4-1
does not indicate significant reductions of malathion or parathion. However, it is quite evident from the
chromatograms that these compounds were present in the pre-treatment soil.  The chromatograms for the
post-treatment solid and liquid phases did not show any indication of the presence of these compounds.
Malathion; parathion; and 4,4'-DDT were reduced from, parts-per-million levels to below their analytical
detection limits.  Quantification of atrazine. nitroaniline, malathion, and parathion was possible through
the use of standards. The 4,4'-DDT was identified in the pre-treatment samples, but no peaks could be
found for this compound in the post-treatment samples. Accurate quantification of  4,4'-DDT could not
be performed because a standard was not readily available. However, based on column manufacturer's
recommendations and  the peak height, the 4,4'-DDT concentration in the pre-treatment samples  is
estimated to be on the order of a part per million.  The data presented in Table 4-1 are from the SAIC
                                               56

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analyses alone. The methods used were not SW-846 methods, but rather methods that were specifically
developed for this particular project.   Details of the methods used can be found in Appendix A and
Appendix F of the Quality Assurance Project Plan (8).

The process had no noticeable effect on chlordane (alpha, garnma, and technical) and endosulfan (I and
II).  In each case, the change in average concentration was within the limits of analytical error, and
definitive conclusions regarding changes in concentrations cannot be made.  Table 4-2 presents a data
summary (pre- and post-treatment slurry concentrations, on a dry basis) for compounds that were detected
but appeared to be unaffected by the J.R. Simplot Ex-Situ Bioremediation Technology.  Analytical Data
listed in Table 4-2 is from SW-846  Method 8080.

Metals: Pre-treatment  soil  and make-up water samples were analyzed for ICP  metals  using SW-846
Method 6010.   Samples were also analyzed for mercury using SW-846 Method  7470/71.  Metals
concentrations in the pre-treatment soils and make-up water were at levels generally found  in natural soils
and potable water, and  were not thought to be toxic to the microorganisms.  Although the post-treatment
slurry samples were collected, they  were not analyzed for  metals. The metals concentrations were not
expected to change due to remediation.  Table 4-3 presents a summary of the pre-treatment metals data
for the soil and the make-up water.

Toxicity:  It was anticipated that the toxicity tests could be performed simultaneously on the pre- and post-
treatment  soils to determine  if the relative toxicity of the soil had  changed because of the degradation of
dinoseb.  However, it was found  that the levels of pesticides and herbicides (in addition to dinoseb) in
the pre-treatment soil negated the relevance of the analyses. To determine if the relative toxicity changes
because of this process, toxicity testing (including earthworm reproduction, early seedling growth, root
elongation, and herbicide bioassay screening) will be performed during the TNT SITE demonstration and
reported in the associated Innovative Technology Evaluation Report  (ITER).
Sterile Process  Control:  Immediately after collection, the sterile process control was shipped to the
laboratory for sterilization using gamma radiation. The process control was subjected to 1.56 MRads of
gamma radiation from a cobalt 66 source.  However, it was found, by performing biological counts, that
the control was  not sterile.  The control could not be further subjected to gamma radiation due to
mechanical problems with the radiation source.
                                               57

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     Table 4-2. Compounds Unaffected by the J.R. Simplot Ex-Situ Bioremediation Technology
Compound
Chlordane (alpha)
Chlordane (gamma)
Chlordane (technical)
Endosulfan I
Endosulfan II
Average Pre-Treatment Soil
Concentration on a Dry Basis
(mg/kg)
1.92
2.21
25.7
2.72
2.12
Average Post-Treatment
Solid Phase Concentration
on a Dry Basis
(mg/kg)
1.74
1.97
16.9
1.61
2.52
4.4.2  Physical Analyses

Prior to treatment in the bioreactor, the soil was screened to separate out material greater than 12.7 mm
(0.5 in) in diameter.  Particle size distribution was determined for the soil both  before and after the
screening process.   Atterberg limits were also determined for the soil before and after the screening
process.  The soil was determined to be a clayey sand with gravel. The density of the screened soil was
determined to be 1.22 g/cm3 (76.2 Ibs/ft?).   Density data were used to  determine the total mass of soil
treated.

4.5    Process Residuals

Three process  waste streams  were  generated  by  implementation  of the  J.R.  Simplot Ex-Situ
Bioremediation Technology.  These streams were the treated soil, wastewater, and the rocks and debris
with diameters greater than 12.7 mm (0.5  in).  Prior to the Demonstration Test  at Bowers Field, the
Washington State Department of Ecology (WADOE) established a dinoseb clean-up level below which
                                               58

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Table 4-3. Summary of Pre-Treatment Metals Data
Compound
Aluminum
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
Average Soil
Concentration on a Dry Basis
(mg/kg)
16,400
122
1.1
5,800
21.8
12.3
27.9
36,900
22.1
4,990
584
25.5
2,310
634
110
181
Average Make-Up Water
Concentration
(Mg/L)
267
200
5.0
18,600
10.0
50.0
25.0
4,490
100
10,400
24.6
40.0
2,220
9,040
50.0
51.2
                    59

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the soil no longer presented a hazard to human health and, therefore, would no longer be considered
hazardous.  After treatment in the bioreactor at Bowers Field, the dinoseb concentrations in the treated
soil and liquid were below the analytical detection limits as noted in Section 4.4.1  of this report.  The
treated soil was then replaced within the excavated area and used as fill material.  In states where clean-
up levels have not been established or when the clean-up levels are not met, then disposal of the soil at
a RCRA-permitted facility may  be necessary.   If nitroaromatic compounds other  than  dinoseb  are
remediated, then disposal of the soil at a RCRA-permitted  facility is only required if components of the
waste are listed or the material has hazardous waste characteristics.

Water was used to wash the dinoseb from the separated rocks and debris. This was performed by the
J.R. Simplot Company during the Demonstration Test; however, when the percentage of oversize material
becomes excessive, a separate soil or rock washing vendor may provide assistance in this task. The rinse
water was then added to the bioreactor with the make-up water to be remediated by the process. After
treatment in the bioreactor at Bowers  Field, the dinoseb concentration in the  water was below  the
analytical detection limit.  In most instances, the wastewater can be  disposed through a publicly owned
treatment works (POTW), assuming the appropriate permits have been obtained.

The third waste stream—the untreated rocks and  debris—may present a disposal problem.  During the
Demonstration Test, only a portion of the rocks and debris greater  than 12,7 mm  (0.5 in) in diameter
were  washed.  Logistical difficulties in executing the washing procedures left a large portion of the
oversize material untouched.   When material greater than 12.7 mm in diameter represents a high
percentage of the excavated soil, a separate soil or rock washing technology is required for clean-up of
this fraction or the material must be transported off-site for disposal at a RCRA-permitted facility.  For
the oversize material that was washed during the Demonstration Test, it was assumed that the washing
process transferred the dinoseb from the rocks to the rinse water since dinoseb is highly water soluble.
The decontaminated rocks and debris were then replaced in the excavated area as fill material. In cases
where the nitroaromatic compound is not water soluble, the soil washing  process  separates the coarse
fraction from the fine particles (where contamination is greatest) and then places the fine particles into
the bioreactor.  The oversize rocks and debris from the soil washing process may still require disposal
at a RCRA-permitted facility.
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                                          SECTION 5
                          OTHER TECHNOLOGY  REQUIREMENTS

5.1    Environmental  Regulation Requirements

Before implementing the J.R. Simplot Ex-Situ Bioremediation System, state regulatory agencies may
require a number of permits to be obtained.  A permit may be required to operate the system.  A permit
is required for storage of contaminated soil in a waste pile for any length of time and for storage in drums
on-site for greater than 90 days.  At the conclusion of treatment, permits may be required to discharge
the wastewater  into  a  publically owned treatment works (POTW).  A national pollutant discharge
elimination system (NPDES)  permit may be required to discharge into surface waters.  If air emissions
are generated, an air emissions permit will be necessary.  If off-site disposal of contaminated waste is
required, the waste must be taken off-site by a licensed transporter to a permitted landfill.

Section 2 of this report discusses the environmental regulations that apply to this technology.  Table 2-1
presents a summary of the Federal and State ARARs for  the J.R.  Simplot Ex-Situ Bioremediation
Technology.
5.2
Personnel Issues
For pre-treatment operations (excavation, assembly, and loading), the number of workers required is a
function of the volume of soil to be remediated. During the Demonstration Test, three workers and one
supervisor were required for all operations through loading of Che bioreactor.  Once the reactor is loaded,
a Simplot employee familiar with the system and any contaminant-specific requirements will fine-tune the
system to ensure that appropriate operating conditions are established and maintained.  During treatment,
only one technician  is required to operate the J.R.  Simplot  Ex-Situ  Bioremediation System.   This
technician will be trained by a Simplot supervisor.  The training will be specific to the J.R. Simplot Ex-
Situ Bioremediation System.  Treatment will take place 24 hours a day, however,  it is anticipated that
the technician will only be present for approximately one hour each day.  During this time, all system
parameters will be checked and  any required modifications will he made.  If necessary, the system may
operate unattended for several days at a time.   For the larger, modular hioreactors, eight workers are
required  for 16 hours to erect each bioreactor,  and 12  workers are required for 16 hours to install the
                                               61

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liner for each bioreactor.  For lined pits, heavy equipment operators are required to excavate the pits,
and 12 workers are required tor 16 hours to install the liner in each pit.

The health and safety issues for personnel using the Simplot system  for waste treatment are generally the
same  as those that apply to  all hazardous waste treatment facilities.  The regulations governing these
issues are documented in 40 CFR 264 Subparts B through G,  and Subpart X.

Emergency response training for operations of the J.R. Simplot Ex-Situ Bioremediation System is the
same  as the general  training required for operation of a treatment,  storage,  and disposal (TSD) facility
as detailed in 40 CFR 264 Subpart D.  Training must address fire-related  issues such as extinguisher
operation, hoses, sprinklers, hydrants, smoke detectors and alarm systems.  Training must also address
contaminant-related issues such as  hazardous material spill control  and decontamination equipment use.
                                 ^
Other issues include self-contained breathing apparatus use, evacuation, emergency response planning,
and coordination with outside emergency personnel (e.g., fire/ambulance).

For most sites, personal protective equipment (PPE) for workers will include gloves, hard hats, steel-toed
boots, and Tyvek® suits.  Depending on contaminant types and concentrations, additional  PPE may be
required.   Noise  levels  should be   monitored during excavation  and pre-treatment screening,
homogenization,  and loading activities to ensure that workers are  not exposed  to noise levels above a
time-weighted average of 85 decibels, over an 8-hour day.  If operation of the J.R. Simplot Ex-Situ
Bioremediation System increases noise levels above this limit, workers will be required to wear additional
protection.

5.3     Community Acceptance
Potential hazards related to the community include exposure to volatile pollutants (if present) and other
paniculate matter released to air during soil excavation and handling. Air emissions can be managed by
watering down the soils prior to excavation  and handling, and covering the stockpiled soil  with plastic
sheeting.  Depending on the scale of the project, the biodegradation process may require contaminated
soils to remain stockpiled on-site for extended periods of time.  This  could expose the community to
airborne emissions for several months.  Community exposure to stockpiled soils may be minimized by
excavating in stages, limiting the amount of soil excavated to the amount of soil that can be treated at once.
                                               62

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The J.R. Simplot potato-processing starch by-product used as a carbon source at the onset of treatment
may be stored in 208-L (55-gal) drums on-site. Once the drums are opened, the potato-processing starch
by-product gives off a foul odor in the immediate vicinity.  This odor intensifies over time as the starch
by-product ferments in the drums. The odor may be minimized by storing the drums in  a shaded area
to reduce the rate of fermentation. Keeping the drums sealed when not in use  will also reduce the odor
that escapes into the ambient air.

During bioremediation, the  treatment slurry may  also give off a  foul odor  caused  by  the enhanced
microbial activity.  The odor is not pervasive and only penetrates airspace in  the immediate proximity
of the treatment area;  covering  the bioreactor may minimize this odor.

Noise may be a factor to neighborhoods in the immediate vicinity of treatment.  Noise levels may  be
elevated  during excavation,  screening,  and  homogenization  since heavy  equipment is used for these
activities.  During  actual  treatment, however, the noise generated by the bioreactor and  associated
equipment  is expected to be minimal.
                                               63

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                                         SECTION 6
                                  TECHNOLOGY STATUS

This section discusses the experience of the developer in performing treatment using the J.R. Simplot Ex-
Situ Bioremediation Technology. It also examines the capability of the developer in using this technology
at sites with different volumes of contaminated soil.

6.1    Previous Experience

In addition  to the demonstration performed on  dinoseb in Ellensburg, Washington, the J.R. Simplot
Company is also participating in a second SITE Demonstration to evaluate the ability of this technology
to degrade another nitroaromatic compound. TNT (2,4,6-trinitrotoIuene). at the Weldon Spring Ordnance
Works in Weldon Spring, Missouri.  The pre-treatment  level of TNT in the test soil at this site is
approximately 1,500 mg/kg.  The treatment is being performed using a bioreactor identical  to the one
used in Ellensburg, Washington. These two bioreactors are the latest in the line of development for this
process.  Prior to these demonstrations, biodegradation of nitroaromatics using this technology had only
been achieved in treatability studies performed by the  University of Idaho.

The J.R. Simplot Company has no experience in the remediation of contaminated sites.  To overcome
this hurdle, Simplot  intends to  form partnerships with respected environmental remediation  companies
to implement this technology.  For the two SITE Demonstrations, Envirogen Inc. has  teamed with
Simplot to provide the necessary expertise in performing full-scale operations.

6.2    Scaling  Capabilities

To date, this SITE Demonstration  represents the largest scale of remediation performed using the J.R.
Simplot Ex-SStu Bioremediation Technology.  During the demonstration, a small portable bioreactor was
used to degrade 30 m3 of dinoseb contaminated soil in Ellensburg, Washington. An identical bioreactor
is currently being used  to perform the same scale of remediation  at the TNT site in  Weldon Spring,
Missouri.
                                              64

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Simplot (in cooperation with an environmental remediation company) has proposed that the remediation
of greater volumes of soil will require the use of lined, excavated pits or,  alternatively, using modular
tanks.  A scenario has been proposed by Simplot in which the remediation of up to 7,646 m3 (10,000 yd3)
could be accomplished.  This scenario involves the rotating use of four-3,800,000-L (750,000-gal) tanks
over a complete project period of  seven months.  This period includes excavation, tank erection,
remediation,  and demobilization.  Each tank would be lined with a 30-mil liner and used to remediate
two 956 m3 (1,250 yd3) batches of soil.  It is assumed that the remediation of each  batch of soil would
take approximately 30 days, similar to the remediation time required during SITE Demonstration. The
maximum rock size that could be handled would be 38.1 mm (1.5 in) in diameter; all larger rocks would
be crushed to this diameter.

This scenario is being proposed to remediate the entire Bowers Field site in Ellensburg, Washington.
In Reedley, California, excavated pits are being proposed to bioremediate dinoseb contaminated soil.  In
addition, excavated pits are being used to destroy TNT contamination at a site in Bangor, Washington.
The economic analysis given in Section 3  of this report is based on this remediation effort.
                                               65

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                                       REFERENCES
        Kaake, R.H.; Crawford, D.L.; and  Crawford, R.L.  1994.  "Optimization  of an Anaerobic
               Bioremediation Process of Soil Contaminated with the Nitroaromatic Herbicide Dinoseb
               (2-rec-Butyl-4,6-Dinitrophenol)." R.E. (ed.), Proceedings of the Second In Situ and On-
               Site Bioreclamation Symposium. Battelle, Columbus, Ohio. In press.
        Personal Communications with R.H. Kaake.
3.      Roberts,  D.J.; Kaake,  R.H.;  Funk, S.B.; Crawford,  D.L.;  and Crawford,  R.L.  1993.
               "Anaerobic Remedition of Dinoseb from contaminated Soil: An On-Site Demonstration."
               Appl. Biochem. Biotechnol. In press.


4.      U.S. Environmental Protection Agency.  1993. Office of Solid Waste and Emergency Response.
               Technology Innovation Office. Innovative Treatment Technologies: Annual Status Report
               (Fifth Ed). U.S. Government Printing Office, Washington, D.C. EPA 542-R-93-003.

5.      Douglas, J.M. Conceptual Design of Chemical Processes; McGraw-Hill, Inc. New York,  1988.


6.      Peters, M.S.; Timmerhaus, K.D. Plant Design and Economics for Chemical Engineers.  Third
               Edition. McGraw-Hill, Inc. New York, 1980.


7.      Garrett, D.E. Chemical Engineering Economics. Van Nostrand Reinhold. New York,  1989.


8.      Science Applications International Corporation. "Quality Assurance Project Plan, Superfund
              Innovative Technology Evaluation: J.R. Simplot Bioremediation Process (Dinoseb) at
              Bowers Field in Ellensburg, Washington," 1993.
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                                         APPENDIX A
                                     VENDOR'S CLAIMS

This appendix was generated and written solely by the J.R. Simplot Company. The statements presented
herein represent the vendor's point of view and summarize the claims made by the vendor,  the J.R.
Simplot Company, regarding their Ex-Situ Bioremediation Technology.  Publication herein does not
represent the EPA's approval or endorsement of the statements made in this section; the EPA's point of
view is discussed in the body of this report.

A.I    Introduction

The  Simplot Bioremediaton Process offers  a bioremediation  alternative to  cleaning soils  and  water
contaminated with nitroaromatics.  Nitroaromatics have become serious environmental contaminants at
both private and military locations nationwide. Examples of nitroaromatic contaminants include nitrotolu-
ene explosives, as well as many pesticides, including dinoseb, a herbicide banned  because of health
concerns.

The  Simplot  Process  was demonstrated to  degrade  dinoseb  (2-rcc-butyl-4,6-dinitrophenol) to non
detectable limits (15 ppb) which is less than the maximum allowable concentration specified by the
Federal government. The Simplot process is an anaerobic bioslurry for the degradation of nitroaromatic
compounds in soil or aqueous phases.  In this demonstration, the Simplot Process was used to clean soil
contaminated with the herbicide dinoseb which is a RCRA-listed waste (PO20).

The Simplot  Process was demonstrated by the J.R. Simplot Company and Envirogen, Inc.  at Bowers
Field, a former crop dusting site in Ellensburg, Washington. Dinoseb contamination had occurred at this
site,  beginning in the  1940's  until the 1970's.  At Ellensburg, Dinoseb was degraded to less than
detection limits in soils  and water, from  a beginning concentration of 28 ppm, resulting  in overall
reduction greater than 99.9%.
Other agricultural chemicals were also found in the Ellensburg soil.  These included DDT, malathion,
parathion, nitroanaline, atrazine, chlordane and endosulfan. The Simplot Process was entirely effective
in the presence of these co-contaminants.
                                              67

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Optimal temperatures for The Simplot Process have been determined to be between 35 and 37°C. The
summer of 1993 in the Ellensburg area was cold and wet, resulting in average ambient temperatures that
did not exceed 18°C.  The Simplot Process was entirely effective, even with sub-optimal temperatures,
resulting in total degradation of dinoseb within 23 days.

The Simplot Process, developed by the University of Idaho and the J.R. Simplot Company, with patents
pending, is licensed  exclusively to the J.R. Simplot Company.

A.2    Process

The Simplot Process begins when contaminated soil is placed in a bioreactor with specially prepared
water in a one-to-one ratio by weight.  Water is prepared by adding nutrients, pH buffers, and a special
carbon source (a Simplot potato starch byproduct). Addition of the excess carbon source to the reactors
results  in  the consumption  of dissolved oxygen by  aerobic bacteria, rapidly  establishing anaerobic
conditions. The process is illustrated on the next page.

Before soil is added  to the bioreactor, a consortium of enhanced dinoseb-degrading anaerobic bacteria is
introduced  to the conditioned  water, to increase the rate of nitroaromatic degradation.  The enhanced
anaerobic  bacteria are stimulated to grow  and degrade dinoseb  to  short chain  organic acids,  without
formation  of potentially toxic polymerization products.  After the treatment is complete and the soil is
returned to site,  aerobic bacteria can degrade the short-chain organic acids to C02 and water.

The Simplot Process has been demonstrated successfully on a variety of soil types,  from sandy soils to
tight clays. Rates of degradation are slightly delayed in heavier soil textures.  The Simplot Process makes
use of feasibility testing to optimize the rate of degradation for each site by  altering inputs on a site-by-
site basis.
                                                68

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                              The Simplot Process
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A.3    Cost

Cost of the Simplot Process is less than half the cost of thermal processes including incineration.  Savings
of transportation and related costs result because soil remains on site. Cost for a typical agricultural site
can be as low as $250 per cubic yard.  Costs are dependent on site characteristics and cost per cubic yard
of soil will be lower with greater quantities.

A.4    Technical Information

This technology is designed to  treat  soils contaminated with  nitroaromatic contaminants.  Anaerobic
microbial mixtures have been developed for the pesticide dinoseb and for TNT. These contaminants can
be reduced to less than one part per million in most soils. The proprietary inoculum used by the Simplot
Process consists of a variety of microbial genera, developed at  the University of Idaho through selection
of anaerobic microbes that have been  most effective in degrading nitroaromatic compounds.

Anaerobic microbial mixtures have been developed by the  University of Idaho for Simplot for both the
pesticide dinoseb (2-sec-butyl 4,6-dinitro-phenol) and trinitrotoluene (TNT).

The consortium becomes  active at redox potential of -200 mV  or lower.
                                              69

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                The initial step in the metabolism of nitroaromatic compounds is a reduction of the nitro substituents to
                amino groups, producing aminonitro compounds.  These intermediates are further degraded to simple
                organic acids, and hydroxylated aromatics, which can be subsequently mineralized by indigenous bacteria.

                A.5    Advantages

                        •       Dinoseb  concentrations have been reduced by more  than 99.9% using The Simplot
                                Process,  achieving cleanup levels below the analytical detection limit of 15 ppm.
                        •       Complete anaerobic biodegradation  of dinoseb  is achieved  without the formation
                                (accumulation) of toxic intermediates.
                        •       Breakdown of dinoseb compounds is complete, resulting in innocuous byproducts, mainly
                                CO,.
                        •       Dinoseb  is degraded using The Simplot Process at temperatures considerably lower than
                                is required for other biological remediation methods.
                        •       Periodic  mixing is sufficient for optimum degradation.
                        •       The Simplot Process has been proven  effective in the presence of other commonly found
                                contaminants  on agricultural  sites,  including  nitroanaline, parathion, malathion and
                                atrazine.
                        •       The Simplot Process is a cost-effective alternative to  traditional  technologies  for both
                                large and small sites. Costs are often  less than half of the cost to incinerate. Total costs
                                are site-specific and determined  by treatability studies.
                        •       Remediated soils are rich in organic  content and with high nutrient  value, suitable for
                                returning to the site.
                        •       Liability is reduced because contaminated soil is remediated without being transferred off-
                                site.
                        •       Treatment of any contaminated site is completed within one season.

                 A.6    Limitations

                        •       Each site must be individually assessed by treatability studies.
                        •       Presence of co-contaminants may require additional processing, or may be unsuitable for
                                the Simplot process.
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