EPA/540/R-94/520
                                              March 1995
        Geosafe Corporation In Situ Vitrification
INNOVATIVE TECHNOLOGY EVALUATION REPORT
         Risk Reduction Engineering Laboratory
          Office of Research and Development
         U.S. Environmental Protection Agency
                Cincinnati, Ohio 45268
                                                    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 not constitute
an endorsement or recommendation for use.

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                                         FOREWORD

The Superfund  Innovative Technology Evaluation (SITE) Program was authorized by the Superfund
Amendments and Reauthorization Act (SARA) of 1986. The Program is administered by the EPA Office
of Research and Development (ORD). The purpose of the SITE Program is to accelerate the development
and use of innovative  cleanup technologies applicable to Superfund and other hazardous waste sites.  This
purpose is accomplished through technology demonstrations designed to provide performance  and cost
data on selected technologies.

This project consisted of a demonstration conducted under the SITE Program to  evaluate the In Situ
Vitrification Technology developed by the Battelle  Memorial Institute and  exclusively licensed to Geosafe
Corporation for treatment of soils  contaminated with organic and inorganic materials. The Battelle
Memorial Institute developed the ISV  technology for the U.S.  Department of Energy, Environmental
Management  Division,  Office of Technology Develpment at Pacific Northwest Laboratory. The
technology Demonstration was conducted at the former site of Parsons Chemical Works, Inc.  in Grand
Ledge, Michigan. This Innovative Technology Evaluation Report presents an interpretation of the
performance and cost  data gathered  during the demonstration and discusses the potential  applicability of
the  technology.

A limited number of copies of this report will be available at no charge from the EPA's Center for
Environmental  Research  Information,  26  West Martin  Luther King Drive, Cincinnati, Ohio, 45268.
Requests  should include the EPA document number found  on the report's  cover.  When the limited supply
is exhausted, additional copies can be purchased from the National Technical Information Service (NTIS),
Ravensworth Building, Springfield, Virginia, 22161,  (703) 487-4600.  Reference copies will be  available
at EPA libraries in the Hazardous Waste Collection. You can also call the  SITE Clearinghouse Hotline
at (800)  424-9346 or (202) 382-3000  in Washington, D.C. to inquire about the  availability  of other
reports.
E. Timothy Oppelt, Director
Risk  Reduction  Engineering Laboratory
                                               111

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                                          ABSTRACT

       The Geosafe In Situ Vitrification (ISV) Technology is designed to treat soils, sludges,
sediments,  and mine tailings  contaminated with organic, inorganic, and radioactive compounds.  The
organic compounds are pyrolyzed and reduced to simple gases which are collected under a treatment
hood and processed prior to their emission to the atmosphere.  Inorganic  and radioactive contaminants
are incorporated into the molten soil which solidifies to a vitrified mass similar to volcanic obsidian.

       This mobile technology was evaluated under the SITE Program on approximately 330 yd3 of
contaminated soil at the Parsons site. Demonstration results indicate that the cleanup levels specified
by EPA Region V were met and that the vitrified soil did not exhibit teachability characteristics in
excess  of regulatory guidelines.  Process emissions  were also within regulatory limits.

       The Geosafe ISV Technology was evaluated based on seven criteria used for decision-making
in the Superfund Feasibility Study (FS) process.

       This report was  submitted in fulfillment of Contract No. 68-CO-0048 by  SAIC under the
sponsorship of the U.S. Environmental Protection Agency. This report covers a period  from March
1994 to April  1994, and work was completed as of April 1994.

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                                TABLE OF CONTENTS
                                                                                   Page
NOTICE   	                                        • "
FOREWORD   	                                         i'i
ABSTRACT  	                                         lv
LIST OF  TABLES  	                                        ™
LIST OF  FIGURES  	                                         lx
ACRONYMS, ABBREVIATIONS, AND SYMBOLS                                         x
CONVERSIONS   	                                        x111
ACKNOWLEDGEMENTS  	

EXECUTIVE SUMMARY .                                                             !

SECTION 1    INTRODUCTION                                                       .  7

       1.1     Background	                        -7
       1.2     Brief Description of Program and Reports  	                          8
       1.3     The SITE Demonstration Program  	                          9
       1.4     Purpose of the Innovative Technology  Evaluation Report                       '10
       1.5     Brief Technology  Description  	                        10
       1.6     Key Contacts	                         11

SECTION 2    TECHNOLOGY APPLICATIONS  ANALYSIS                               13

       2.1     Key Features 	                         '13
       2.2     Operability of the Technology  	                         '14
       2.3     Applicable Wastes   	                         ,15
       2.4     Availability and Transportability of the Equipment ,                         '17
       2.5     Materials  Handling Requirements  	                         '18
       2.6    Site Support Requirements   	                         '18
       2.7    Ranges  of Suitable Site  Characteristics  	                         '19
       2.8     Limitations of the Technology  	                         '21
       2.9    ARARS for  the Geosafe ISV Technology  	                           22

              2.9.1   Comprehensive  Environmental  Response,  Compensation  and  Liability
                     Act(CERCLA)   	     .23
              2.9.2   Resource Conservation and  Recovery Act (RCRA)  	    •  27
              2.9.3   Clean Air Act (CAA)  	    ,  29
              2.9.4   Clean Water Act (CWA)   	    .  29
              2.9.5   Safe Drinking Water Act (SDWA)   	    •  30
              2.9.6   Toxic Substances Control Act  (TSCA)  	    •  30
              2.9.7   Occupational Safety and Health Administration (OSHA)
                     Requirements   	    -31
              2.9.8   State Requirements   	32

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                             TABLE  OF CONTENTS  (Continued)
SECTION 3   ECONOMIC ANALYSIS .
                                                                                          Page
                                                                                     33
       3.1     Conclusions and Results of the Economic Analysis                          ...  33
       3.2    Issues and Assumptions ..................                         ...  39
       3.3    Basis   of  Economic  Analysis   ...............                         ...  42

              3.3.1    Site and Facility Preparation Costs  ................... ' ......  43
              3.3.2   Permitting  and Regulatory  Requirements  Costs   .................  44
              3.3.3    Equipment Costs  ....................................  45
              3.3.4    Start-up and Fixed Costs  ....... ........................  47
              3.3.5    Labor Costs   .......................................  48
              3.3.6    Consumables  and Supplies  Costs   ..........................   49
              3.3.7   Utilities  Costs  ......................................  51
              3.3.8    Effluent Treatment and Disposal Costs  .......................  52
              3.3.9   Residuals and Waste Shipping and Handling Costs   ...............  53
              3.3.10 Analytical Service  Costs ................................  54
              3.3.11  Maintenance and Modifications Costs   .......................  55
              3.3.12 Site  Demobilization Costs ...............................  56

SECTION 4   TREATMENT EFFECTIVENESS                                            57

       4.1     Site History  and Contamination  ................................  57
       4.2    Treatment Approach  .......................................  57
       4.3    Treatment  Objectives .......................................   59
       4.4    Detailed Process  Description                                                    59
       4.5     Testing Methodology ...................... :  ...............   65
       4.6    Perfomance Data  .........................................   71

                      Test  Soil                                                     ......  71

                      4.6.1.1         Pre-Treatment  Test  Soil  Chemical  Characteristics  .....   71
                      4.6.1.2        Post-Treatment  Test Soil Chemical  Characteristics  .....  77
                      4.6.1.3        Pre-Treatment Test Soil Physical Characteristics .......  79
                      4.6.1.4        Post-Treatment  Test Soil Physical  Characteristics  ......  79

                      Scrubber    Liquor     ................ , . . . .                       . .  80

                      4.6.2.1         Pre-Treatment Scrubber Liquor  .................  80
                      4.6.2.2        Scrubber Liquor During and After  Treatment   ........  84

              4.6.3    Stack Gas ........................................ 85
              4.6.4   Limitations of the Data Results   .......................... 88
              4.6.5    Process Operability and Performance at the Parsons Site   ..........  90
4.7    Process Residuals
                                                                                            95
                                              Vi

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                           TABLE OF CONTENTS (Continued)

Section                                                                               2^

SECTION 5   OTHER  TECHNOLOGY  REQUIREMENTS                                   "

       5.1    Environmental  Regulation  Requirements                                       99
       5.2    Personnel    Issues    	                                       100
       5.3    Community   Acceptance   	                                       100

SECTION 6 TECHNOLOGY STATUS                                                  102

       6.1    Previous/Other  Experience                                                  102
       6.2    Scaling  Capabilities ....                                                   HO

REFERENCES                                                                         m

APPENDIX A VENDOR'S CLAIMS                                                     113

       A.I    Summary  	               us
       A.2   Introduction  	              114
       A.3   Applicability to Contaminated Soil  and  Other Earth-Like Materials               115
       A.4   Application  Configurations	              116
       A.5   Contaminant Treatment  Effectiveness  and Permanence	              116
       A.6   Residual  Vitrified Product	              118
       A.7   Air Emissions and Other ARARs  	                119
       A.8   Application  Limitations 	                119

             A. 8.1  Media Melting  Characteristics                                        119
             A. 8.2 Vitrified Product Quality  ...                                       120
             A. 8.3 Water Recharge	                                       120
             A.8.4 Processing Depth   	                                       121
             A.8.5 Total Organic Content	                                       121
             A.8.6 Debris Content  	                                       122
             A.8.7 Sealed Containers	                                       122
             A. 8.8 Media Gas-Phase Permeability                                       123

       A.9   cost 	                          123
       A. 10  Regulatory  and Public Acceptance  	                         124
       A. 11  Development  Status  and Commercial Implementability                         125
       A. 12  Review of Parsons Chemical Site Experience	                         126

             A. 12.1 Unusual Challenges .                                              126
             A. 12.2 Performance Results                                              127
             A. 12.3 Notable Achievements                                              128

       A. 13   Review of SITE Demonstration Results                                       130
       A.14   Acknowledgement  	                                       131
                                            VM

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LIST OF TABLES
Table
Table ES-1
Table 2-1
Table 3-1
Table 3-2
Table 4-1
Table 4-2
Table 4-3
Table 4-4
Table 4-5
Table 4-6
Table 4-7
Table 4-8
Table 4-9
Table 4-10
Table 4-1 1
Table 6-1
Table 6-2
Table 6-3
Table 64

Evaluation Criteria for the Geosafe In Situ Vitrification Process
Federal and State Applicable or Relevant and Applicable (ARARs) for the
Geosafe ISV Technology 	 	
Summary of Economic Analysis Results for Three Treatment Scenarios
Detailed Summary of Results for Case 2 (3,200 Cubic Yards of Contaminated
Soil) 	
Results of Analysis of Pre-Treatment Screening Samples Collected from
Cell 8 	
Performance Data During Demonstration Test Versus ARARs
Geosafe Test Soil Pesticides and Metals Data Summary ,.
Geosafe Test Soil Dioxins/Furans Data Summary
Geosafe Soil TCLP Pesticides and Metals Data Summary
Geosafe Pre-Treatment Test Soil Conductive Cations and Ultimate Analysis
Data 	
Geosafe Scrubber Water Organics Analysis Summary Data
Geosafe Scrubber Water Metals Analysis Summary Data
Geosafe Scrubber Water Dioxins/Furans Analysis Data
Geosafe Organic Stack Emissions Summary Data
Geosafe Metal Stack Emissions Summary Data
Region V Geosafe Stack Volatile Organic Compound Emissions Summary
Data 	
Region V Geosafe Stack Semivolatile Organic Compound Emissions Summary
Data
Region V Geosafe Stack Metals Emissions Summary Data
Region V Geosafe Typical CEM Emissions
Page
2
24
34
35
. 68
72
73
74
75
76
81
82
83
86
87

105


      Vlll

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                                LIST  OF  TABLES (Continued)

Table

Table 6-5      Region V Geosafe HEPA Filter Analysis

Table 6-6      Region V Geosafe Hood  Deposit Analysis                                      108

Table 6-7      Region V Geosafe Neutron Activation Analysis on Treated Soil                   109

Table 6-8      Region V Geosafe Melt 1 Excavation Soil Analysis                            .  110

Table A-l     Off-Gas  Emission  Performance                                                129



                                      LIST OF FIGURES

Figure

Figure 3-1     Graphical Representation of 12 Cost Categories for Case 2                        38

Figure 4-1     Plan View of Treatment  Cells                                                  58

Figure 4-2     Cut-Away View of Treatment Cells                                             59

Figure 4-3     Geosafe  In Situ Vitrification Process                                             60

Figure 4-4     Typical ISV  Process Conditions for the Geosafe Technology                       62

Figure 4-5     Approximate Location of Actual ISV Melts at the Parsons Site                    92

Figure 4-6     Power Input  to Cell 8 During the  Demonstration Test                             95

Figure 4-7     Treatment Time Versus Electrode Depth During the Demonstration
              Test    (Cell   8)    	                  96

Figure A-l     Various Configuration Options for ISV Processing                               117
                                              IX

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                      ACRONYMS,  ABBREVIATIONS, AND SYMBOLS
 •tg            Microgram
 ug/kg         Microgram s pe r kilogram
 ug/L          Micrograms per liter
 Hg/m3         Micrograms per cubic meter
 AQCR        Air Quality Control Regions
 AQMD        Air Quality Management District
 ARAR        Applicable or relevant and appropriate requirement
 ATTIC        Alternative Treatment Technology  Information Center
 BOAT        Best Demonstrated Available Technology
 BLS           Below land surface
 CAA        Clean Air Act
 CEM          Continuous emission  monitors
 CERCLA      Comprehensive Environmental Response, Compensation, and Liability Act
 CERI         Center for Environmental Research Information
 CFR           Code of Federal  RegulFR
 CO            Carbon  monoxide
 CO2           Carbon  dioxide
 CWA         Clean Water Act
 DDT          Dichlorodiphenyltrichlorethane
 DRE          Destruction removal  efficiency
 EPAU.S.      Environmental Protection Agency
 EPA-BREL   EP A Risk   Reduction Engineering Laboratory
 HEPA         High efficiency particulate air
 HSWA        Hazardous and Solid  Waste  Amendments
 ICP          Inductively coupled plasma
 ISV           In Situ Vitrification
 ITER         Innovative  Technology Evaluation  Report
 kg             Kilogram
 Ib/hr           Pounds per hour
LDR           Land Disposal Restriction
MCL           Maximum contaminant levels

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               ACRONYMS, ABBREVIATIONS,  AND SYMBOLS  (Continued)
MCLG        Maximum  contaminant  level  goals
MDNR        Michigan Department of Natural  Resources
mg/kg         Milligrams per kilogram
mg/L          Milligrams per liter
mg/rn3        Milligrams per cubic meter
MW          Megawatt
MWh         Megawatt hour
NAAQS       National Ambient Air Quality Standards
NaOH        Sodium  Hydroxide
NCP          National Oil  and Hazardous  Substances  Pollution Contingency  Plan
ND           Not detected
ng/kg          Nanograms per kilogram
NIST          National Institute Standards  Technology
NO           Nitrogen  oxides
NPDES        National Pollutant  Discharge Elimination System
NTIS          National Technical Information Service
OD           Outside  diameter
ORD          EPA Office of Research and Development
OSHA        Occupational  Safety and Health Act
OSWER       Office of Solid Waste and Emergency Response
OVA          Organic vapor analyzer
PAH          Polynuclear aromatic  hydrocarbon
Parsons        Parsons Chemical Works, Inc.
PCB          Poly chlorinated  biphenyl
POTW        Publically-owned  treatment  works
PPE          Personal protective  equipment
ppmv          Parts per million by volume
PVC          Polyvinyl  chloride
QA           Quality  Assurance
QAPP        Quality Assurance Project Plan
RCRA        Resource Conservation  and  Recovery Act

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              ACRONYMS, ABBREVIATIONS, AND SYMBOLS (Continued)
MCLG       Maximum contaminant level goals
MDNR       Michigan Department of Natural Resources
mg/kg        Milligrams per kilogram
mg/L        Milligrams per liter
mg/m3        Milligrams per cubic meter
MW         Megawatt
MWh        Megawatt hour
NAAQS      National Ambient Air Quality Standards
NaOH        Sodium Hydroxide
NCP         National Oil and Hazardous Substances Pollution Contingency Plan
ND          Not detected
ng/kg        Nanograms  per kilogram
NIST        National Institute Standards Technology
NO,         Nitrogen oxides
NPDES       National Pollutant Discharge Elimination System
NTIS        National Technical Information  Service
OD          Outside diameter
ORD         EPA Office of Research and Development
OSHA        Occupational Safety and Health  Act
OSWER      Office of Solid Waste and Emergency Response
OVA        Organic vapor analyzer
PAH         Polynuclear aromatic hydrocarbon
Parsons       Parsons Chemical Works, Inc
PCB         Polychlorinated biphenyl
POTW       Publically-owned treatment works
PPE         Personal protective equipment
ppmv        Parts per million by volume
PVC         Polyvinyl chloride
QA          Quality Assurance
QAPP        Quality Assurance Project Plan
RCRA        Resource Conservation and Recovery Act
                                           XI

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               ACRONYMS, ABBREVIATIONS, AND SYMBOLS (Continued)

RREL         Risk Reduction Engineering Laboratory
SAIC         Science  Applications  International Corporation
SARA         Superfund  Amendments  and Reauthorization Act
SDWA        Safe Drinking Water Act
SITE         Superfund  Innovative  Technology Evaluation
SOX           Sulfur oxides
SWDA        Solid Waste  Disposal  Act
TCDD        Tetrachlorodibenzo-p-dioxin
TCLP         Toxicity Characteristic Leaching Procedure
THC         Total Hydrocarbons
tons/yd3        Tons per cubic yard
TSCA         Toxic Substances Control Act
VISITT       Vendor  Information System for Innovative Treatment Technologies
yd3           Cubic yards
                                             xn

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                                      CONVERSIONS
 Mass
 1 pound (Ib) = 0.4536 kg
 1 ton = 2,0001b = 907.18
 1 kilogram (kg)  = 2,20 Ib
 Volume
 1 cubic inch (in3)  = 5.78E-04 ft3  = 2.14E-05 yd3  - 0,0164 L = 1.64E-05 m3 = 4.33E-03 gal
 1 cubic foot (ft3) = 1,728 in3 = 0.0370 yd3 = 28.32 L = 0,0283 m3  = 7.48 gti
 1 cubic yard (yd3) = 46,656 in3 = 27 ft3  = 764,55 L =  0.7646 in3  = 201.97 gal
 1 cubic meter (m3) = 61,023 in3 =  35,31 ft3 =  1.31 yd3  =  1,000 L = 264,17 gal
 1 liter (L) = 61.02 in3 = 0.0353  ft3 = 1.30E-03 yd3 -  l.OOE-03 m3 = 0,2642 gal
 1 gallon (gal) = 231 in3  - 0.1337 ft3  = 4.95E-03 yd3 = 3,7854 L =  3.79E-03
m3
Length

1 inch  (in) - 0,0833 ft  - 0.0278 yd = 0.0254 m
1 foot (ft) = 12 in = 0.3333 yd = 0.3048 m
1 yard  (yd) = 36 in  = 3 ft = 0.9144 m
1 meter (m)  = 39,37 in =  3.28 ft = 1.09 yd

Temperature

1 degree Fahrenheit (°F) = 0.5556°C  [x°C=0.5556*(y°F-32)]
1 degree Celsius (°C) =  1.8°F        [x°F=1.8*(y°C) + 32]
                                            XIII

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                                CONVERSIONS (Continued)
Pressure
1 pound per square inch (psi) = 27.71 in H2O = 6894.76 Pa
1 inch of water (in H2O) = 0.0361 psi = 248.80 Pa
1 Pascal (Pa) = 1.45E-04  psi = 4.02E-03 in H2O

Viscosity

1  poise = . 1 kg/m-see = 2.09E-03 Ib/ft-sec
1 kg/m-set =10.00 poise = 2.09E-03 Ib/ft-set
1  Ib/ft-sec = 478.70 kg/m-set

Rate

1 Ib/hr = 2.20 kg/hr
1 kg/hr = 0.4536 Ib/hr
                                            xiv

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                                ACKNOWLEDGEMENTS

This report was developed under the direction of Ms. Teri Richardson, the EPA Technical  Project
Manager for this SITE Demonstration at the Risk Reduction Engineering  Laboratory (RREL) in
Cincinnati, Ohio. It was prepared by the Process Technology Division of Science Applications
International  Corporation (SAIC), San Diego, California under the direction of Mr. Raymond J.
Martrano, the SAIC Work Assignment Manager. Contributors to the report were: Ms. Jamie Sue
Winkelman,  engineering and technical writing; Mr. Jonathan E. Rochez, engineering and data evaluation;
and Ms. Ruth  D. Alfasso, technical writing.  Technical reviews were provided by Mr. Randy Parker and
Ms. Laurel Staley of EPA-RREL and Dr. Victor S. Engleman, Mr. Joseph D. Evans, and Mr. Kyle R.
Cook of SAIC. Special thanks are extended to Mr. Leonard N. Zintak, Jr. of EPA Region V for his
technical review  and assistance throughout this project.
                                           xv

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                                    EXECUTIVE SUMMARY

This report summarizes the findings associated with a Demonstration of the Geosafe Corporation
(Geosafe) .In Situ Vitrification (ISV) Process. The Geosafe ISV technology was evaluated under the EPA
Superfund  Innovative Technology  Evaluation (SITE) Program in conjunction with remediation activities
associated  with an EPA Region V removal action.  The technology was assessed regarding its  ability to
treat pesticides (specifically chlordane,  dieldrin, and  4,4'-DDT) and mercury to below Region V
mandated limits. It was evaluated against the nine criteria for decision-making in the Superfund Feasibility
Study  process. Table ES-1 presents the results  of this evaluation.

The ISV technology uses electric power to heat  contaminated soil past its melting point and thus thermally
destroy  organic contaminants in the soil. Once the entire treatment volume is molten, power is
discontinued. As the molten mass solidifies, it incorporates inorganic contaminants within a glass and
crystalline  vitrified material. Off-gases that  are  generated during  treatment  are collected in a containment
hood that  is placed over the treatment area. The off-gases are processed by a treatment train which
typically consists of a quencher, a wet scrubber, a demister, a  heater, particulate filters, and activated
carbon to process the gas before discharge to the atmosphere. In certain applications,  a thermal oxidizer
is used to  polish the treated gases before release to the atmosphere. As part of the Region V removal
action, Geosafe  performed a total of eight melts which covered nine pre-staged treatment  cells at the
Parsons  Chemical Works,  Inc.  (Parsons) site  located in Grand Ledge,  Michigan. The SITE Program
studied one of these  treatment settings (Cell 8)  in detail to determine the technology's  ability to meet the
Region V  removal criteria and to  obtain cost and performance  data on the technology. This Innovative
Technology Evaluation Report focuses on  the  findings  associated  with the SITE Demonstration.

Results presented in this report for the treated  soil are based on post-treatment sampling just below the
surface of the melt alone.  Complete post-treatment sampling of the solidified  melt cannot be safely
performed until at least one year after treatment  at which time sampling of the melt core will take place.
Because  the technology is already  being used in commercial  applications, this report has been published
prior to obtaining treated soil samples from the center of the  study area. In this manner, the community
may be provided with the information currently available regarding the operability and effectiveness  of
the technology.  Results  of the post-treatment  soil  samples collected from the core  of  Cell  8 will be
reported  at a later date in a published Addendum.

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Table  ES-1. Evalutation  Criteria for the  Geosafe In  Situ Vitrification Process
Overall Protection of
Human Health and the
Environment
Compliance with
ARARS
Long-Term
Effectiveness and
Performance
Short-Term
Effectiveness
Reduction of Toxicity,
Mobility, or Volume
through Treatment
 Provides both short- and long-
 term protection by  destroying
 organic contaminants and
 immobilizing   inorganic
 material. Developer  also
 claims  the technology can
 treat radioactive compounds.

 Remediation can  be performed
 in  situ,  thereby reducing the
 need for excavation.

 Off-gas treatment system
 reduces airborne  emissions.
 System is flexible and can be
 adapted for a variety of
 contaminant types and  site
 conditions.

 Technology can
 simultaneously treat  a  mixture
 of  waste types. Technology is
 applicable to  combustible
 materials,  but  the
 concentration of such
 materials in the treatment zone
 must be carefully controlled
 and treatment prudently
 planned.
Requires compliance  with
RCRA treatment, storage, and
land disposal regulations (for a
hazardous waste). Successfully
treated waste may be  delisted
or handled as non-hazardous
waste.

Operation of on-site treatment
unit may require  compliance
with  location-specific
applicable or relevant
appropriate  requirements
(ARARs).

Emission control  may be
needed to ensure compliance
with air quality  standards
depending upon local  ARARs
and test soil components.

Scrubber water will  likely
require secondary treatment
before discharging to
publically owned  treatment
works (POTW) or surface
bodies.  Disposal  requires
compliance with Clean Water
Act regulations.
Effectively  destroys  organic
contamination  and  immobilizes
inorganic  material.  Developer
also claims the technology can
treat radioactive compounds.

Reduces the likelihood of
contaminants leaching  from
treated soil. ISV glass  is
thought to have a stability
similar to  volcanic obsidian
which is estimated to remain
physically  and  chemically
stable for thousands to
millions of years.

Allows potential re-use of
property after  treatment.
Treatment of a site using  ISV
destroys organic compounds
and  immobilizes  inorganic
contaminants.

Vitrification of a  single
treatment setting may be
completed  in  approximately
ten days. This treatment time
may vary depending on site-
specific conditions.

Presents potential short-term
chemical exposure  risks to
workers operating process
equipment.  High voltage and
high temperatures require
appropriate safety precautions.

Some short-term  risks
associated  with air emissions
are dependent upon test
material composition and off-
gas treatment system design.

Staging,  if  required, involves
excavation  and construction of
treatment areas. A  potential
for fugitive  emissions and
exposure exists during
excavation  and construction.
Significantly reduces toxicity
and mobility of soil
contaminants through
treatment.

Volume reductions of 20 to 50
percent are  typical after
treatment.

Some  inorganic contaminants,
especially volatile metals,  may
be  removed by  the vitrification
process,  and require
subsequent treatment by the
off-gas treatment  system.

Some treatment residues may
themselves be treated during
the next  vitrification  setting.
Residues from the final
setting, including  expended  or
contaminated processing
equipment, may  require
special disposal requirements.

Volume of scrubber  water
generated is highly dependent
upon soil moisture content.

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Table ES-1 (Continued)
          Itnplcmentability
                Cost
    Community Acceptance
        State Acceptance
  Equipment is mobile and can be
  brought to a site using conventional
  shipping methods. Weight restrictions
  on tractors/trailers may vary from state
  to state.

  Support equipment  includes earth-
  moving equipment for staging
  treatment  areas (if required) and
  covering treated areas with clean soil.
  A crane is required for off-gas
  containment hood placement and
  movement.

  Chemical  characterization  of
  contaminated soil is required for
  proper  off-gas  treatment system
  design.

  A suitable source of electric power is
  required to  utilize this technology.

  Technology not recommended for sites
  which contain  organic content greater
  than 7 to  10%  (by weight), metals
  content in excess of 25% (by weight),
  and inorganic contaminants greater
  than 20% (by volume).  Sites with
  buried drums may only be treated if
  drums are not intact or sealed.
The cost for treatment when the soil is
staged into nine 15-foot  deep cells is
approximately 1770/yd1  ($430/ton).

Treatment is most economical when
treating large sites to the maximum
depth.

Electric power is generally the most
significant cost associated with ISV
processing. Other factors (in order of
significance) include labor costs,
startup and fixed costs,  equipment
costs,  and facilities  modifications and
maintenance costs.

Moisture content of the  media being
treated directly influences the cost of
treatment since electric energy must be
used to vaporize water before soil
melting occurs.

Sites that require staging and extensive
site preparation will have higher
overall costs.
Technology is generally accepted by
the public because it provides a
permanent  solution and because it is
performed  in situ.

Potential reuse of land after treatment
provides an attractive alternative to
property  owners.

A public nuisance could be created if
odorous emissions from the soil
constituents are not properly controlled
by the off-gas system.
State ARARs may be more stringent
than federal regulations.

State acceptance of the technology
varies depending upon  ARARs.

The ISV system (especially the off-gas
treatment portion) is  somewhat
modular, such that it may be modified
to meet state-specific criteria.

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CONCLUSIONS BASED ON  CRITICAL OBJECTIVES

The studies conducted by the SITE Program suggest the following conclusions regarding the technology's
performance at the Parsons site  based on the critical objectives stated for the Demonstration:

       The treated soil  met  the EPA Region  V cleanup criteria for the target pesticides and mercury.
       Dieldrin  and  4,4'-DDT  were reduced to levels below their analytical  reporting detection limits
       (< 16 Mg/kg) m the treated soil. Chlordane was below its detection limit (80  /^g/kg) before
       treatment commenced. Mercury, analyzed by  standard SW-846 Method 7471 procedures, was
       below the specified cleanup level before treatment began, averaging 3,800 ^ig/kg.  It was reduced
       to an average of less  than 33 ng/kg in  the treated soil.

       Stack gas samples were collected during the  Demonstration to characterize  process  emissions.
       There were no target pesticides detected in the  stack gas samples. During the Demonstration,
       mercury  emissions  averaged  1.2 x  10"  Ib/hr  (16ftg/m3). The emissions were below the
       regulatory requirement of  5.93 x lO^lb/hr (88 jtg/m3) at all times. Other metal emissions in the
       stack gas (particularly arsenic, chromium, and lead) were of regulatory concern during process
       operations, but were found  to be in  compliance with  the Michigan state applicable or relevant and
       appropriate requirements (ARARs).

       Emissions of total hydrocarbons (as propane) and carbon monoxide were'regulated at 100 parts
       per million by volume (ppmv) and  150 ppmv, respectively. Throughout the Demonstration, vapor
       emissions of these gases (measured  downstream from the thermal oxidizer) were well below the
       regulatory guidelines. Total hydrocarbon and carbon monoxide emissions both averaged below
       10 ppmv.

CONCLUSIONS BASED ON  SECONDARY OBJECTIVES

The studies conducted  by the SITE Program suggest  the following conclusions regarding the technology's
performance at the Parsons site based on the secondary objectives stated for the Demonstration:

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The technology successfully treated the soil in Cell 8, completing the test cell melt in ten days
with only minor operational problems. During this time, approximately 330 yd3 (approximately
600 tons) of contaminated soil were vitrified,   according to Geosafe melt summaries.
Approximately 610  MWh of energy was applied to the total  soil volume melted (estimated to be
480 yd3) during vitrification of Cell 8;  power applied to the actual contaminated soil volume
could not be independently measured because clean fill and surrounding uncontaminated soil are
vitrified as part of each melt. Based on the total soil treated in Cell 8, the energy consumption
was approximately  0.72 MWh/ton, System operation was  occasionally interrupted briefly for
routine maintenance such as electrode segment  addition  and adjustment.

The solid vitrified material collected was subjected to  TCLP  analysis for the target pesticides  and
mercury. Test results indicate that no target pesticides were detected in the post-treatment
leachate.  Chlordane was not detected in either the pre- or post-treatment leachate, so no definitive
conclusions can be  drawn about the technology's impact on the teachability of this  compound
based on this Demonstration. Levels of teachable mercury  in both pre- and post-treatment soil
leachates  were well below the  regulatory limit of 200 ^g/L (40  CFR $261.24). Several other
metals were also found to have passed the TCLP leaching test.

Scrubber water generated during the Demonstration contained volatile organics, partially oxidized
semivolatile organics  (phenolics),  mercury,  and other metals. The scrubber water  underwent
secondary treatment before ultimate disposal, and data suggest that secondary treatment of this
waste stream will probably be required in most cases.

Pre-treatment soil dry density averaged 1.5 tons/yd3, while post-treatment soil dry density
averaged  2.1 tons/yd 3. Accordingly, a volume reduction of approximately 30 percent was
observed for the test soil on a dry  basis.

The cost for treatment when the  soil is staged into nine  cells is approximately $1 ,300/yd3
($740/ton) for 5-foot  deep cells, $770/yd3 ($430/ton)  for 15-foot deep cells (like those at the
Parsons site), and $660/yd3 ($370/ton) for 20-foot deep cells. The costs presented are  calculated
based on the number of cubic yards of contaminated soil treated. Because clean fill and
surrounding uncontaminated soil are treated as  part of each melt, the       amount of material

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       treated is higher than the amount of contaminated soil treated. Costs per cubic yard based on total
       soil treated would, therefore, be lower than the costs per cubic yard based on contaminated soil
       treated presented in this report.

       Treatment is  most economical when  treating large cells to the maximum depth.  The primary cost
       categories  include utilities, labor, and startup  and fixed costs.

The following sections of this report contain the  detailed information which supports the items
summarized in this Executive  Summary.  The site studied during this Demonstration was Geosafe's first
large-scale commercial project, and the results presented in this report are based primarily on this
application. Valuable lessons learned at this site have  been  put  into practice in  subsequent  applications.

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                                           SECTION 1
                                       INTRODUCTION

This section provides background information about the Superfund Innovative Technology Evaluation
program, discusses the purpose Of this  Innovative Technology Evaluation  Report, and  briefly  describes
the Geosafe In Situ Vitrification 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

ISV has been under development since 1980. When it was first researched  by  Battelle Memorial Institute
(Battelle), ISV was designed to treat radioactive (transuranic) contaminated  soil in situ to avoid  problems
associated with excavation or transportation of these soils. A successful pilot-scale demonstration of the
technology on radioactive wastes was performed in 1983.  It was soon recognized that the technology had
applicability towards  other wastes, including hazardous  chemical contamination and mixed  (chemical and
radioactive) wastes. The Geosafe Corporation (Geosafe) was formed in the spring of 1988 and
subsequently negotiated a sublicense from Battelle for the purpose  of establishing ISV in the commercial
marketplace. From this point  forward in this report, Geosafe will be considered to be the technology
developer.

In October 1990, EPA began a cleanup of the soil contamination at the former Parsons  Chemical Works,
Inc. site (currently occupied by ETM Enterprises) in Grand Ledge, Michigan. The site, designated as a
Super-fund site by the EPA, is located approximately ten  miles west of Lansing. Parsons operated at this
location from 1945 until its closure in  1979. Parsons  was engaged in the mixing,  manufacturing, and
packaging of agricultural chemicals including pesticides, herbicides, solvents, and mercury-based
compounds. Prior to  any remedial action, the site contained approximately  3,000 ydj (5,400 tons) of
contaminated soil. The depth of contamination on-site was relatively shallow, five  feet or less;  therefore,
contaminated soils from three target areas were excavated, consolidated, and staged on-site for treatment.

ISV was the cleanup technology selected for the Parsons  site, and Geosafe Corporation of Richland,
Washington was the EPA contractor selected to perform the ISV treatment (I). During remediation of
the Parsons site, a SITE Demonstration of the full-scale Geosafe system was performed. Although

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Geosafe Corporation applied and was accepted into the SITE Program in the late 1980s, they had to wait
approximately two years for the signing  of a remediation contract with EPA Region V.  Geosafe also
encountered some developmental problems such that the actual SITE Demonstration of this technology
was delayed until March 1994.

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 Reauthorization Act of  1986 (SARA). The SITE Program promotes the development,
demonstration, and use of new or innovative technologies to  clean up Superfund  sites  across the country.

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

       •      the  Emerging Technology Program,
       •      the  Demonstration  Program,
       •      the  Monitoring and Measurement  Technologies Program, and
       •      the  Technology  Transfer  Program

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.

The Demonstration Program develops reliable  performance and cost data on  innovative technologies  so
that potential users  may  assess  the technology's 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 full-scale remediation conditions  or 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

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problems, and (4) the  approximate costs. The Demonstrations also allow for evaluation of long-term risks
and operating  and maintenance  costs.

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
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
Emerging Technology Program, the Demonstration Program,  and the Monitoring  and Measurements
Technologies Program 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,

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 for 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 and in situ 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 responsible for 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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The results of this evaluation of the  Geosafe In  Situ Vitrification Technology are published in two basic
documents: the SITE Technology Capsule  and this Innovative Technology  Evaluation Report (ITER).  The
SITE  Technology Capsule provides relevant information  on the  technology, emphasizing key features of
the results of the SITE field Demonstration while the ITER provides an in-depth evaluation of the overall
performance and applicability  of the  technology.

1.4     Purpose of the Innovative Technology Evaluation Report

This ITER provides information on the Geosafe In Situ Vitrification Technology for treatment of
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
performance, particularly  as evaluated during the Demonstration. 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     Brief  Technology  Description

In situ vitrification uses electrical power to heat and melt soil and other earthen materials (e.g., dewatered
sludge,  mine tailings, buried waste, and sediments) contaminated with  organic,  inorganic, and radioactive

                                                10

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compounds. Due to the intense heat of the process, organic contaminants within the treatment volume
undergo pyrolysis (thermal decomposition in the  absence of oxygen). The pyrolysis products then migrate
to the surface of the treatment  zone where they  are oxidized under a collection hood. Large amounts of
ambient air are used to cool the collection hood and to sweep the off-gases to the treatment system. An
air pollution control system treats the off-gases  generated  prior to discharge.  The remaining molten
material cools to form a monolithic glass-like product that incorporates the thermally stable inorganic
compounds present within the  treatment zone. The glass material is claimed to  have very low leaching
characteristics (2,3,4)

The Geosafe ISV technology uses a square array of four graphite electrodes that  allows a melt width of
approximately 20 to 40 feet and a potential treatment depth of up to 20 feet.  Multiple settings may be
used for remediation of a larger contaminated area Electric power is supplied to the electrodes through
flexible conductors.  Initially, the electrodes are inserted one to two feet below  the  soil  surface,  and a
conductive starter path is laid between them. An electric potential  is applied to the electrodes to establish
an electrical current in the starter path. Upon melting (at temperatures in the vicinity of 2,000 to
2,500°F),  the soil  becomes electrically conductive.  As the soil  surrounding the  electrodes becomes
molten, the electrodes can be lowered until the  desired treatment depth is attained.

In a single setting, the process  can remediate contaminated soil at an estimated rate  of four to six tons
per hour until a  maximum mass of 800 to 1,200 tons has been treated. After treatment, the vitrified mass
is typically left in place, although it can be removed if necessary after cooling.  Subsidence, resulting from
the elimination of void volume and removal  of humus and organic contaminants, is remedied by
backfilling  over  the melt with  clean material.

A more in-depth description of  the process  may  be found in Section 4.4 of this report, "Detailed Process
Description." Appendix A,  "Vendor's Claims," provides some additional information.

1.6    Key Contacts

Additional  information about the Geosafe In Situ Vitrification Technology  and the SITE Program can be
obtained from the following  sources
                                                11

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       The Geosafe In Situ Vitrification Technology

       Mr. James E. Hansen
       Geosafe  Corporation
       Director of  Business Development and Communications
       2950  George Washington Way
       Richland,  Washington 99352
       Phone: 509/375-07  10
       Fax: 509/375-7721

       The SITE Program

       Ms.  Teri  L. Richardson
       EPA SITE Technical Project Manager
       U .  S Environmental Protection Agency
       Risk  Reduction  Engineering  Laboratory
       26 West Martin Luther King Drive
       Cincinnati, OH 45268
       Phone: 5  13/569-7949
       Fax: 5 13/569-7620
Information on the SITE  Program is  available through the following on-line information clearinghouses


       •      The Alternative Treatment Technology Information Center (ATTIC) System (operator:
               703/908-2  137) is a comprehensive,  automated information retrieval system that integrates
               data on hazardous waste treatment technologies into a centralized, searchable source.  This
               database provides  summarized  information  on  innovative  treatment technologies.

       •      The Vendor Information System for Innovative Treatment Technologies (VTSITT)
               (hotline: 800/245-4505)  database currently contains information on approximately 23 1
               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 301/589-8368.


Technical reports may be obtained by contacting the Center for Environmental Research Information

(CERI), 26 Martin Luther King Drive in Cincinnati, OH, 45268 at 513/569-7562.
                                               12

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                                          SECTION 2
                         TECHNOLOGY APPLICATIONS ANALYSIS

This section of the report addresses the general applicability of the Geosafe ISV technology to
contaminated  soil sites. The analysis is based primarily on this SITE Demonstration, and conclusions are
based exclusively on these data since only limited information is available on full-scale applications of
the technology. This SITE Demonstration was conducted on approximately 400 cubic yards of soil,  of
which  an estimated 330 cubic yards were contaminated with low levels of pesticides,  dioxins/furans,
mercury, and other  metals,

2.1     Key Features

The Geosafe ISV system is an in situ technology that  allows on-site treatment of contaminated wastes
without excavation and with only limited site preparation. The technology is unique in that it can
effectively treat a wide variety of contamination including hazardous chemical (both organic and
inorganic), radioactive, and mixed  (chemical  and radioactive)  wastes. ISV can treat sites that would
otherwise require two  or  more technologies to handle the same range of contaminants. Although the
application of this technology to radioactive and mixed wastes was not studied  as  part  of the
Demonstration, full-scale testing for this type of treatment has been successfully conducted.

In situ treatment is  advantageous, especially when  volatile organic compounds  are present or when large
quantities of contaminated soils are present since soil handling activities may be minimized. If the
contamination is shallow or scattered, the  soil may be excavated,  consolidated,  and  staged for treatment.

Operation utilizes electric energy  to melt the soil, driving off and decomposing organic contaminants and
immobilizing  thermally stable  compounds  in a matrix claimed to be relatively non-leachable. The residual
product has very stable geological characteristics,  similar to volcanic  obsidian. Contaminants that are
diffkult to treat using other techniques can be bound into this glass and  crystalline vitrified material. The
vitrified mass is typically left in place, and thus the need for disposal of the treated material can be
eliminated. The developer claims that the vitrified material is non-hazardous  and can be delisted. Delisting
procedures are very site-specific  and could vary significantly from state to state.
                                               13

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Treatment by ISV effectively reduces the mobility of the contaminants and the toxicity  and volume of the
contaminated media. The mobility of contaminants is diminished when teachable constituents are
incorporated into a non-leachable mass. The toxicity of the soil is reduced by the destruction and removal
of organic contaminants and volatile  metal compounds. The potential  for lateral migration is restricted
through the use of refractory walls  when using staged treatment. Compounds that are vaporized but not
destroyed by the vitrification process are passed through an off-gas treatment system. The removal of
materials that can be vaporized and void space between soil particles as a result of the vitrification process
produces a 20 to 50 percent volume reduction according to the developer.

2.2     Operability  of  the Technology

The Geosafe ISV technology operates using  electrical energy to heat and melt soil, destroying organic
contaminants by means  of pyrolysis and  oxidation,  thermally decomposing some inorganic contaminants,
and immobilizing thermally  stable contaminants.  The most important operational parameter for this
technology is the electrical input to the melt. A maximum of 1.75 MW of power is supplied through each
of the two phases of the electrical system (A and B), such that maximum total power to the electrodes
during treatment is  about 3.5 MW.  Initially, the current applied to the soil is low (100 to 200 amps per
phase) and the voltage is quite  high (up to 4,000 volts per phase).  However, as the melt progresses, the
voltage is decreased and the current is increased as the molten soil becomes more conductive. The voltage
applied to each of the two phases during full power operation averages  only 600 volts while the current
for each phase averages 2,900 amps. Treatment of a typical  15-foot deep single cell requires up to 1,200
MWh  of energy; however,  the cell treated during the Demonstration required only 610 MWh
(approximately 0.72 MWh/ton),  much less than other cells at the Parsons site. According to the vendor,
normal energy consumption  is approximately  1  MWh/ton.  The high rates  of consumption dictate that
electricity is a primary  factor when considering costs and availability of resources.

Although ISV can  treat saturated soils, the presence of large amounts of  water or a high water table
hinders operation of the ISV technology. When water is present,  electrical energy is  initially used  to
vaporize this water instead of melting the contaminated soil, thus prolonging treatment time and
increasing costs. The resulting water vapors must be handled by the off-gas  treatment system and further
increases project costs. An overabundance of  water does not preclude treatment with ISV, but may make
it prohibitively expensive. As with most thermal technologies, the cost of treatment increases with the

                                                 14

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amount of water that has to be removed; therefore,  it is economically wise to keep the treatment zone
as dry as possible prior to treatment

Weather is another factor which affects the operability of the Geosafe system. Rain or snow at the
treatment site increases the amount of water in the soil and can lead to the difficulties discussed above.
High humidity increases the amount of liquid handled by the off-gas treatment system. Moving the hood
becomes more difficult in windy conditions, but may still be accomplished safely. Temperature is not a
critical factor.  Cold ambient temperatures may increase the amount of initial  heating required but once
the soil is in a molten state, the surrounding area stays warm due to the thermal insulating properties of
the soil. Extreme temperatures (hot or cold) make working conditions less favorable for  personnel and
equipment. The  ISV process was successfully operated at the Parsons site during a typical Michigan
winter season.

When contaminated soil volumes are shallow or scattered, the soil can be excavated, consolidated, and
staged in a treatment area. This was illustrated at  the Parsons site where the contaminated soil was
excavated from three  selected areas and placed in nine pre-constructed treatment cells. The cell walls
were constructed of concrete; a layer of cobble was placed outside of the concrete, and a sheet of
plywood was  used to separate  the treatment  cells from  the surrounding uncontaminated soil. The bottom
of the cells were constructed of cobble covered with a plastic liner. Some aspects of the  cell structure
used at the Parsons site proved unsuitable for effective implementation of the technology. This issue is
further discussed in Section 4 of this  report, "Treatment Effectiveness."

For the SITE Demonstration,  one of the nine treatment cells was vitrified.  This cell contained
approximately 400 cubic yards of soil, 330 of which was estimated to be  contaminated. During the
removal action supervised by EPA Region V at the Parson Chemical site, all nine cells (approximately
3,000 cubic yards of contaminated soil) were treated.  Because of the way the melts grew during
treatment, remediation of the nine cells was accomplished in eight melts  rather than nine

2.3     Applicable Wastes

The ISV technology can treat a wide range  of waste matrices  contaminated with a variety  or mixture of
contaminant types. The technology can be used on  soils,  sludges, sediments,  mine tailings, and similar

                                               15

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assembly and shakedown) is approximately three weeks. If a more rapid  setup is required, more than one
shift of workers may be utilized per day.

2.5     Materials Handling Requirements

The  amount of materials handling required depends  mainly on whether the contaminated soil is staged
or treated in situ. Treatment of soils that are not moved, and that do not require pre-treatment, does not
necessitate much additional  equipment. Earth-moving equipment (such as  a backhoe and/or a dump truck)
is  required to backfill the subsidence of treated areas.

If soils are to be staged, or if mixing of wastes is required, soil excavation equipment is needed.  The
actual  equipment used depends  on the amount and  characteristics of the  contaminated soil.  A backhoe is
commonly used to move soil on a site, with or without an accompanying dump  truck. A conveyor belt
or similar device can be used to transport soil from a temporary staging area to treatment cells. Special
equipment or modifications  to existing equipment may be recommended for excavation of soils containing
volatile contaminants in order to reduce volatilization and  exposure of personnel  or the community.

Sampling of soils before and after treatment may also require the use of materials handling equipment.
Soil  in situ can be sampled using a drill rig, a backhoe,  a shovel, or another device depending on the
characteristics of the soil and the depths to be sampled.  After treatment, samples of the solidified matrix
may need to be collected using a specially-equipped drill  rig or jackhammer

During both setup and  treatment, a crane and other support equipment  are required. The crane is used
to erect the hood during assembly, to move the hood over each melt before treatment, and to add
electrodes during treatment.  Other equipment, such as  a forklift, may  be needed to move  drums and
miscellaneous supplies  on the site.

2.6     Site Support Requirements

The  main site requirement  for  use of ISV is the availability of electricity. For the unit used during the
Demonstration, 4 MW are required at  a voltage of either 12,500 or 13,800 volts. These voltages are
standard grid voltages  available in the United States. Power can be supplied through trailer-mounted

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diesel generators in situations where building a connection to the power grid would be unfeasible. The
costs of using diesel-generated power are generally higher than that for grid electricity.

If a thermal oxidizer is part of the treatment train, then a source of natural gas or fuel oil is required.  A
natural  gas connection to the local utility was made at the Parsons site to supply natural gas during the
Demonstration.  It may be possible to obtain an electric secondary combustion device that provides the
necessary off-gas treatment. Although this would eliminate the need for fuel, the use of natural gas or
fuel oil would probably be more economical if it is available.

Other utilities required for the use of ISV include water for cleaning, for use in the scrubber, and for
personnel  needs.  Only small amounts  of potable water are  required. Phone service to the site is required
for general communications and to summon  emergency assistance. A connection to the sewer may also
be needed to  discharge  scrubber water or diverted groundwater. Portable toilets may be used as toilet
facilities.

Access  to  the site must be provided over roads suitable for travel by heavy equipment. The trailers can
travel over regular roads,  but may not be allowed on low capacity  bridges  or  especially  steep grades.
Personnel must also be able to reach the  site  without difficulty, since three shifts  of personnel are utilized
during treatment. Auxiliary facilities are needed for storage of supplies and tools,  and for office and rest
areas. Mobile  trailers and  storage containers can be brought on-site for these purposes. Because the ISV
process is  operated continuously, the  top  of the hood is equipped with floodlights which illuminate the
work areas after dark. Additional site lighting may be required in other  areas for nighttime operation.

When the  ISV  equipment  is utilized in  an inhabited  area, site security  measures are required both to
protect  the public  from accidental exposures and to prevent accidental or intentional  damage to the
equipment. A fence surrounded the Parsons  site to provide additional security.

2.7     Ranges of Suitable Site Characteristics

Because ISV can operate on soils  in  situ, applicable waste characteristics (discussed in Section 2.3) and
suitable site characteristics overlap somewhat. The site characteristics described in this section provide
additional information about items which require consideration before treatment of a site.

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Apart from  appropriate  soil types discussed previously, the required geological  conditions include  stable
formations which can support the treatment equipment.  The treatment surface must be level  to  allow
placement of the ISV equipment and facilitate effective sealing of the soil/hood interface to prevent escape
of fugitive emissions. Groundwater present in the treatment area makes treatment more time consuming
and costly (as described earlier).  Diverting groundwater around the  treatment area may  make remediation
more  efficient.

The  treatment area  cannot contain utility lines  or  other underground facilities,  since these would be
destroyed by the  treatment and may pose a safety hazard (e.g., buried gas lines). If the treatment soil or
adjacent  areas contain highly permeable natural or artificial conduits in the less permeable matrix, special
precautions may need to be taken to prevent  the  melt from extending outside the planned treatment zone
and to prevent fugitive emissions of toxic or odorous gases. These precautions may include removal  of
the more permeable  material, mixing it with the other soil, or the construction of restraining walls, such
as the refractory  concrete walls used during the  Demonstration.

The use  of ISV requires space for placement of the process equipment, auxiliary equipment and buildings,
and waste staging (when required). The process trailers occupy an  area of approximately 10 feet by 120
feet.  The off-gas hood is 60  feet in diameter, while the area treated in a single melt measures
approximately 27 feet by 27 feet; therefore,  sufficient space must  be available around the perimeter of
the treatment area to place  and seal the hood. An extra buffer of space between the contaminated soil and
any areas that are not a part of the site is  also required so that unexpected melt growth does not have an
adverse  off-site impact.

The  Geosafe equipment can operate in nearly any climate. Since soil is a good insulating material, very
cold climates do not inhibit treatment other than  perhaps slowing its initiation. Equipment can be
climatized to  prevent damage due to exposure to hot, cold, or wet conditions.

The ISV process  can be used in fairly  close proximity to inhabited areas, so long as appropriate  measures
are taken to prevent off-site emissions, odors,  or noise. The presence of lights and noise may preclude
use in some residential areas, since the system must be operated continuously for effective application.
Heavy equipment must be  transported  to and from the site on occasion, however, once the equipment is
                                                20

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operating, there is little additional traffic generated to the site. The small crew size limits the number of
vehicles  on-site.

2.8     Limitations of the Technology

The size of a melt which can be generated is limited to  approximately 40 feet by 40 feet and a maximum
depth of about  20 feet (800 to 1,200 tons) with the current ISV technology. For treatment of deeper
contamination, Geosafe has proposed using a multi-layered staged approach in which the upper portion
of contaminated soil may be excavated while the deeper portion of contaminated  soil is treated in situ.
The excavated soil would then be replaced and treated  in situ atop the  previously vitrified material. This
would, however, increase the complexity of treatment and the cost per cubic yard.  Demonstrations of this
approach have not yet been performed.

Because the ISV  process operates in situ, it may not  be appropriate for sites where contaminated soil
exists directly  adjacent to buildings, other structures, or  the property line. Staging or the use of insulating
refractory walls can be used in some cases, but will probably increase the costs.

Costs per cubic yard are minimized when a sufficient amount of waste is treated at the site to distribute
the costs of mobilization.  Small amounts of contaminated soil may be more efficiently treated with other
methods or at an off-site facility. ISV may not be the least expensive method to treat a waste with only
one type of contamination  (e.g., volatile  organics  or metals), but it may be favored  when in situ treatment
is desired. ISV also offers unique opportunities and potential cost savings when treating sites with
multiple types of  contamination-sites that would normally require the  use of two or more  technologies
or a treatment train to  accomplish  treatment goals. In some instances,  ISV may be the  most cost-effective
treatment alternative

After treatment  with ISV, the soil is molten and very hot. The molten mass may  take more than  a year
to fully cool. Although the surface of each completed melt is  covered with  a thick layer of clean fill, the
heat may prevent  re-use of the site until  complete cooling has occurred. The monolith  of  solidified
material  is dense  and  hard, which minimizes leaching and breakdown. If required,  the cooled vitrified
mass may be removed from the site. Intentional rapid cooling of the  melt may induce  shrink-cracking of
the surface, a  desirable effect if the solidified block is  to be  broken  apart and removed. Activities such

                                                 21

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as drilling through the treated material to install a building foundation or monitoring wells require state-
of-the-art technology, but  can  be accomplished using appropriate techniques.

Limits on the amounts of contaminants which can be present in media suitable for treatment by ISV are
determined by  the heat removal capacity of the off-gas treatment system. The treatment soil  is  limited to
a maximum of seven to ten percent organics by weight for effective remediation using the  current  off-gas
treatment  equipment. Additional or modified off-gas treatment  components could allow treatment  of a
waste with a higher organic content.

Previous experience has indicated that safe, effective treatment  becomes more difficult when pockets of
flammable  liquid or vapor in sealed containers  exist beneath the soil surface. Combustible materials  may
also present treatment difficulties since the sudden release of gases may exceed the heat load and
volumetric capacity of the off-gas treatment system, resulting in a loss of hood vacuum and a potential
for fugitive emission releases. The sudden gas release may also  cause bubbling and spattering  of molten
material which can damage the hood and may carry molten material away from the melt, creating a
potential safety hazard.  The most effective means of treatment exists  when contaminants are  evenly
distributed throughout the soil and so will not cause sudden overload of gas-processing and other
equipment. Buried drums also present potential problems if they are sealed and contain significant
amounts  of liquid

Metals in their reduced chemical state may sink to the bottom of the melt,  concentrate there,  and cause
the electrodes  to short-circuit.  This metal-induced shorting may be encountered in soils that have high
amounts of iron (or other similar metals). The developer claims that most metals are not reduced in an
ISV melt and that short-circuiting of the electrodes can be  prevented through use  of the feeding
mechanism which can retract the electrodes temporarily when a large metal object is encountered or when
shorting  is experienced

2.9     ARARS for the Geosafe ISV Technology

This  subsection discusses specific federal environmental regulations  pertinent to  the operation of the
Geosafe ISV technology including  the transport, treatment, storage, and disposal of wastes  and treatment
residuals. Federal and state  applicable or relevant and appropriate regulations  (ARARs) are presented in

                                               22

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Table 2-1   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.
ARARs  include  the  following:  (1)  the  Comprehensive  Environmental Response, Compensation,  and
Liability Act;  (2) the Resource Conservation and Recovery Act; (3) the Clean Air Act;  (4) the Safe
Drinking Water Act; (5) the Toxic Substances Control Act; and (6) the Occupational Safety and Health
Administration regulations.  These six general ARARs are discussed below.

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 innovative  technologies that 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)].
Geosafe's ISV technology meets each of these requirements.  Volume, toxicity, and mobility of
contaminants in the waste matrix are all reduced as a result of treatment. Organic compounds are
removed and destroyed; the  vitrified  product permanently immobilizes  inorganic  constituents.  The need
                                              23

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Table 2-1.  Federal and State Applicable or Relavant and Applicable Regulations  (ARARs)  for the Geosafe ISV Technology
PROCESS ARAR
ACTIVITY
DESCRIPTION OF
REGULATION
GENERAL
APPLICABILITY
SPECIFIC
APPLICABILITY
TO ISV
  Waste
  characterization of
  untreated waste
RCRA: 40 CFR Part
261 (or state
equivalent)
Standards that apply to
identification and
characterization of wastes
Chemical  and physical
analyses must be performed
to determine if waste is a
hazardous waste .
Chemical  and physical
properties  of waste
determine  its
suitability for
treatment  by ISV.
  Soil  excavation
CAA: 40 CFR Part
50 (or state
equivalent)
Regulation  governs toxic
pollutants,  visible  emissions
and  particulates
If excavation is performed,
emission of volatile
compounds or dusts may
occur.
Only  applies  to staged
treatment.  Handling
practices should
minimize  volatilization
and dust production.
Waste  processing
RCRA: 40 CFR Part
264 (or state
equivalent)
                            CAA: 40 CFR Part
                            50 (or state
                            equivalent)
Standards that apply to
treatment of wastes in a
treatment facility
When hazardous wastes are
treated,  there are
requirements for  operations,
recordkeeping,  and
contingency planning.
                         Regulation  governs  toxic       Stack gases may contain
                         pollutants,  visible  emissions    volatile  organic  compounds
                         and particulates             or other regulated gases.
Applicable  or
appropriate for ISV
operations.
                                                            During ISV treatment,
                                                            stack gases must not
                                                            exceed limits  set for
                                                            the air district of
                                                            operation.  Standards
                                                            for monitoring and
                                                            recordkeeping   apply.

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    Table 2-1. (Continued)
                ACTIVITY   ARAR
                       DESCRIPTION OF
                       REGULATION
                            GENERAL
                            APPLICABILITY
                            SPECIFIC
                            APPLICABILITY TO
                            ISV
     Storage of auxiliary
     wastes
to
Ut
RCRA: 40 CFR Part
264 Subpart J (or state
equivalent)
Regulation governs
standards for tanks at
treatment facilities
                             RCRA: 40 CFR Part
                             264 Subpart I (or state
                             equivalent)
                       Regulation covers storage of
                       waste materials generated
If storing non-RCRA
wastes, RCRA requirements
may still be relevant and
appropriate.
                            Applicable for RCRA
                            wastes; relevant and
                            appropriate for non-RCRA
                            wastes
Storage tanks for liquid
wastes (e.g., scrubber
water) must be
placarded properly,
have secondary
containment and be
inspected daily.
Containers of process
stream residuals (e.g.,
filters) need to be
labeled as hazardous
waste. The storage area
needs to be in good
condition, weekly
inspections are
required, and storage
should not exceed 90
days unless a storage
permit is acquired.
     Determination of
     cleanup standards
SARA: Section
                             SDWA: 40 CFR Part
                             141
Standards that apply to
surface and groundwater
sources that may be used as
drinking water
Remedial actions of surface
and groundwater are
required to meet maximum
contaminant level goals
(MCLGs) or maximum
contaminant levels (MCLs)
established under SDWA -
No specific-
applicability to ISV
unless groundwater
treatment is specified as
part of the cleanup
criteria.

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Table 2- (Continued)
 PROCESS ACTIVITY    ARAR
 Waste  disposal
RCRA: 40 CFR Part
262
                          CWA: 40 CFR Parts
                          403 and/or 122 and
                          125
                          RCRA: 40 CFR Part
                          268
DESCRIPTION OF
REGULATION

Standards that pertain to
generators of hazardous
waste
                       Standards  for discharge of
                       wastewater to a publically
                       owned treatment works
                       (POTW) or to a navigable
                       waterway
                       Standards  regarding land
                       disposal of hazardous wastes
GENERAL
APPLICABILITY

Generators must dispose of
wastes at facilities that are
permitted to  handle the
waste.  Generators  must
obtain an EPA ID number
prior to waste disposal.
Discharge of wastewaters to
a POTW must meet pre-
treatment standards;
discharges to a navigable
waterway must be permitted
under national  pollution
discharge elimination system
(NPDES).
Hazardous wastes  must meet
specific  treatment  standards
prior to land disposal, or
must be treated using
specific  technologies.
SPECIFIC
APPLICABILITY TO
ISV
Waste generated may
include filters or other
solid wastes  not
consumed in a melt.
                                                         Wastewater disposal
                                                         most applicable to
                                                         scrubber water
                                                         discharge.
                                                         May be applicable for
                                                         off-site disposal of
                                                         auxilliary wastes. May
                                                         also be applicable to
                                                         the  solidified vitrified
                                                         soil, if materials were
                                                         staged for treatment.
                                                         ISV may  be a best
                                                         demonstrated  available
                                                         technology (BOAT) for
                                                         some wastes

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for off-site transportation and disposal of solid waste is eliminated by in situ treatment.  Scrubber water
generated during  the SITE Demonstration required secondary treatment before ultimate disposal  at a
permitted facility, and off-gas emissions were treated prior to  release to the atmosphere. The developer
claims that secondary wastes, including scrubber water, may be recycled to subsequent  melts. In some
cases,  according to the developer, this  may accomplished by filtering and discharging the water and
treating the filter in a subsequent melt

In general, two types of responses are possible under CERCLA: removal and remedial action. Between
1986 and 1992, in situ vitrification was selected as the source  control remedy at four Superfund sites in
one  removal action (the Parsons  site)  and three remedial actions (1).  Superfund removal actions are
conducted in response to an immediate threat caused by a release of hazardous substances. Removal
action decisions are documented in an action memorandum. Many removals involve small quantities  of
waste or immediate threats requiring quick action to alleviate the hazard. Remedial actions  are governed
by the SARA  amendments  to  CERCLA. As stated above, these amendments promote remedies  that
permanently reduce the volume,  toxicity and mobility of hazardous substances,  pollutants, or
contaminants.

On-site removal and remedial actions must comply with federal and often more stringent state ARARs.
AFURs are determined on a site-by-site basis and may be waived under six conditions:  (I) 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 AR4R 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 municipal and industrial solid waste. Subtitle C of RCRA contains requirements for generation,

                                               27

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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 Geosafe ISV Technology if RCRA-defined hazardous wastes
are present. If soils are determined to be hazardous according to RCRA (either 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 this Demonstration, the technology was subject to RCRA  regulations
because the Parsons  site is  a Superfimd site contaminated with RCRA-listed wastes including
dioxins/furans, chlordane, dieldrin, 4,4'-DDT,  mercury, and arsenic.  RCRA regulations do not apply to
sites where RCRA-defined hazardous wastes are not present.

Unless they  are specifically delisted through delisting  procedures,  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, treated wastes are still classified as hazardous because the pre-treatment material was a listed
waste.

For generation of any hazardous  waste, the site responsible  party  must obtain an EPA identification
number. Other applicable RCRA requirements may include a Uniform Hazardous  Waste Manifest (if the
waste is transported), 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  for  initiating  and  conducting
RCRA corrective action, remediating groundwater, and ensuring that corrective actions comply  with other
environmental  regulations. Subpart S  also details conditions under which  particular RCRA requirements

                                               28

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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 establishes national primary and secondary ambient air  quality standards for sulfur oxides,
particulate matter, carbon monoxide, ozone, nitrogen dioxide, and lead.  It also limits the emission of  189
listed hazardous pollutants such as arsenic, asbestos, benzene, and vinyl chloride.  States are responsible
for enforcing the CAA. To assist in this, Air Quality Control Regions (AQCR) were established.
Allowable emissions  are determined by the AQCR,  or its sub-unit, the Air Quality Management District
(AQMD). These emission limits are  determined based on whether or not the region is currently within
attainment for National Ambient Air Quality Standards (NAAQS).

The CAA requires that treatment, storage, and disposal  facilities comply with primary and secondary
ambient air quality standards. Fugitive emissions from the ISV technology may come from (1)  the
untreated soil during sampling or staging (volatile organic compounds or dusts), (2) the area around the
hood during treatment,  (3) the treated air exhaust  stack during treatment, or  from (4) the still-molten
treated soil.  Under the CAA, the ISV treatment must not exceed the current standards for  any pollutant
that may be present in the waste soil or formed during treatment. Because of the thermal  nature of the
ISV process, the potential for generating  regulated  compounds exists. The off-gas treatment system must
be  designed to meet the current emission standards. State air quality standards may require additional
measures  to prevent  emissions

2.9.4 Clean Water Act  (CWA)

The objective  of the CWA is to restore and maintain the chemical,  physical, and biological integrity of
the nation's  waters.  To achieve this objective,  effluent limitations  of toxic pollutants from  point sources
were established. Publically owned treatment works  (POTWs) can accept waste water with toxic
pollutants; however the facility discharging the waste water must meet pre-treatment  standards and may
need a discharge permit. A facility desiring to discharge  water to a navigable  waterway must apply for
a permit under the National Pollutant Discharge Elimination System  (NPDES).  When  an NPDES permit
is  issued, it includes  waste  discharge requirements  for volumes  and contaminant concentrations

                                               29

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The only waste water from the ISV process which may need to be managed is the scrubber water that
is used to cool the off-gas and remove particulates and acid gases. The volume of waste water generated
includes the original charge of liquid to the scrubber  and water condensed from the gas stream. The
amount of waste water to be managed depends on the water content of the soil undergoing treatment and
the moisture content of the  gas stream. Because of the presence of mercury in the soil, the waste water
generated from the  scrubber during the ISV Demonstration was not treated and discharged on-site, but
was transported to an off-site facility for disposal. The CWA was therefore not an ARAR for the
Demonstration site,  but it could be in other applications where discharge to a POTW is performed.

       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. These
drinking  water standards are expressed as maximum contaminant levels (MCLs)  for some constituents,
and maximum contaminant level goals (MCLGs) for others. Under CERCLA (Section 121(d)(2)(A)(ii)),
remedial actions are required to meet the  standards  of the MCLGs when relevant. For the ISV
Demonstration, treatment of contaminated groundwater was not a part of the removal actions. Leaching
tests such as the toxicity characteristic leaching procedure (TCLP) or state-specific tests are often  used
to determine whether water may be impacted by contaminated soils. ISV immobilizes or encapsulates
contaminants in a glass and crystalline structure. The TCLP is frequently used after treatment by  ISV to
determine the final  teachability of contaminants within a vitrified mass.

       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
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

                                              30

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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.

TSCA may be relevant or appropriate for use of ISV, since the technology is capable of treating wastes
containing or contaminated  with PCBs. TSCA was not  an ARAR at the ISV Demonstration at the Parsons
site because no PCBs were detected in the treated waste

2.9.7   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  $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 Geosafe ISV 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.  Workers on hazardous waste sites must also be enrolled in a medical
monitoring program. The elements of any acceptable program must include: (1) a health history, (2) an
initial exam before hazardous waste work starts to establish fitness for duty and a medical baseline, (3)
periodic (usually annual) examinations to determine whether changes  due to exposure may have occurred
and to ensure continued  fitness for the job, (4) appropriate medical examinations after a suspected or
known overexposure, and (5) an examination at termination.

For most sites, minimum PPE for workers will include gloves, hard  hats, safety glasses, and steel-toe
boots.  Depending  on contaminant types and  concentrations, additional  PPE,  including respirators or
supplied  air may be required. Additional requirements  for protective clothing are  dictated by the use of

                                               31

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high power electricity on the site, and these requirements should be used to specify the types of boots,
gloves and hard hats which are used during operation.

The vapor hood of the Geosafe ISV system may be considered a confined space. If workers are required
to enter beneath the hood while it  is on the ground,  the actions must comply with the recently
promulgated OSHA requirements for  confined spaces (29 CFR  §1910.146),  including  requirements for
stand-by personnel, monitoring, placarding, and protective equipment. If  excavation  of the waste is
required on the  site, trenches and excavations may be considered additional confined spaces (based on
type and depth) and the same requirements would have  to be met. Other construction- or  plant-related
OSHA standards may also  apply during ISV operations, including shoring of trenches, and  lock-out/tag-
out procedures  on powered equipment.

Noise levels are not expected to be high, with the possible exception  of noise caused by soil handling
activities. During these activities, noise levels should be monitored to ensure that workers are not exposed
to noise levels above a time-weighted average of 85 decibels over an eight-hour day. If noise levels
increase above this limit, workers will be required to wear ear protection. The levels of noise  anticipated
are not expected to adversely affect the community, depending on its proximity to the treatment site.

2.9.8 State Requirements

In many cases,  state requirements supersede the corresponding Federal program, such as OSHA or
RCRA, when the state program is Federally approved and the requirements are more strict. The state of
Michigan had other regulatory  requirements which are not covered under the major Federal programs
including special requirements for operating on  a  floodplain.
                                               32

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                                          SECTION 3
                                    ECONOMIC  ANALYSIS

The primary purpose of this economic analysis is to provide a cost estimate (not including profit) for full-
scale  application and use of the Geosafe ISV system. The costs associated with this technology are
identified in  12 cost categories  defined by  EPA that  reflect typical cleanup activities encountered on
Superfund sites. Each of these categories is defined  and discussed, thus forming the basis for this cost
analysis,

Costs estimated in this economic analysis  are largely based on actual  conditions experienced at the
Parsons site.  The vendor claims to have made  substantial improvements relative to these numbers and
should be contacted for current cost estimates.  Appendix A of this report presents the vendor's claims
in detail.

3.1    Conclusions and Results of the Economic Analysis

This economic analysis estimates the cost of using the Geosafe ISV system for three cases-Case 1, Case
2, and Case 3 corresponding treatment of  approximately 970, 3,200, and 4,400 cubic yards (1,700,
5,700, and 7,900 tons) of contaminated soil in nine staged treatment cells. This represents three different
cell depths (5, 15, and 20 feet) for the same size site. The costs for Case 1, Case 2, and Case 3 are
estimated to  be $1,300, $770, and $660 per cubic yard ($740, $430,  and $370  per ton), respectively.
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 a new
technology, the range may actually be wider. Table 3-1 presents a summary of the 12 cost categories for
each case. Table 3-2 presents a detailed summary for the cost associated with Case 2 (3,200 cubic yards)
which most closely parallels conditions observed at the Demonstration site. Figure 3-1 shows  a graphical
representation of the contributions of each of the categories to the total cost  for Case 2.

The economic analysis for the case most similar to the conditions experienced at the Parsons site (Case
2) shows that the primary cost categories  include utilities, labor, and startup and fixed costs, each
contributing roughly 20% to the total cost (utilities slightly  higher). Equipment costs  and facilities and
maintenance  costs are each  responsible for roughly 10% of the total treatment cost. The other two cases

                                               33

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Table 3-1. Summary of Economic Analysis Results for Three Treatment Scenarios
Case 1

Cost Category

1. Site and Facility 'Preparation
2. Permitting and Regulatory Requirements
3. Equipment
4. Startup and Fixed
5. Labor
6. Consumables and Supplies
7, Utilities
8. Effluent Treatment and Disposal
9. Residuals .and Waste Shipping and Handling
10. Analytical Services
11. Facility Modifications and Maintenance
12. Site Demobilization
TOTAL COST PER CUBIC YARD
TOTAL COST PER TON*
970


$/yd3
51
27
190
260
250
80
180
0
34
52
170
37
1,300
740
yd3


%
4
2
15
20
19
6
14
0
3
4
13
3
100

Case
3,200


$/yd3
18
9
98
130
150
61
170
0
26
19
86
13
770
430
2
yd3


%
2
1
13
17
19
8
22
0
3
2
11
2
100

Case
4,400


$/yd3
13
7
83
no
130
52
160
0
23
14
69
9
660
370
3
yd3


%
2
1
13
17
20
8
24
0
3
2
10
1
100

 * Assuming wet soil density of 1.8 tons/yd3 based on SITE Demonstration results.
 Note:  All costs arc based on contaminated soil treated.
    Total costs are rounded to two significant figures and based on the sum of the individual costs before
    rounding. For this reason, the sum of the numbers presented in this table may not match the total
    precisely.
                                              34

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Table 3-2. Detailed Summary of Results for Case 2 (3,200 Cubic Yards of Contaminated Soil)


                                                                             Case 2
                                                                             3,200 yd3
                                                                      $/yd3*
1  SITE AND  FACILITY PREPARATION
    Site Design and Layout
    Survey and  Site Investigations
    Legal Searches
    Access Rights and Roads
    Preparations for Support Facilities
    Auxiliary Buildings
    Utility  Connections
    Transportation of Waste Feed
    Technology-Specific  Requirements
    Transportation
    Assembly
    TOTAL

2. PERMITTING AND REGULATORY REQUIREMENTS
    Permits
    Environmental  Monitoring  Requirements
    Development of Monitoring Protocols
    Stand-Down
    TOTAL

3. EQUIPMENT
    Major Equipment (to estimate other costs)
    Annualized  Equipment (prorated)
    Equipment  Rental
        100-Ton Crane
        25Ton  Crane
        Forklift
        Front-End  Loader
        Dump Truck
        Storage  Tank
        Thermal Oxidizer
        Trailers
        Toilets
    TOTAL
0.00
0.00

0.00

4.81
12.95
17.76
 9.50
 9.50
78.68

 4.05
 0.85
 2.10
 1.24
 0.43
 1.76
 8.25
 0.71
 0.24
98.31
       0
       0

       0

   15,400
   41,400
   30,400
   30,400
4,000,000
  251,800

    13,ooo
    2,700
    6,700
    4,ooo
    1,400
    5,600
    26,400
    2,300
      800
  314,700
                                                                                  (Continued)

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Table 3-2.  (Continued)
Case 2
3,200 yd3
$/yd3* $
4.






5.






6.












7.




STARTUP ANTI FIXED
Startup
Working Capital
Insurance and Taxes
Initiation of Monitoring Programs
Contingency
TOTAL
LABOR
Total Melt Labor
Total Move Labor
Per Diem
Rental Cars
Airfare
TOTAL
CONSUMABLES AND SUPPLIES
Consumables
Electrodes
Graphite and Glass Frit
Insulating Blanket
"Refractory Concrete
NaOH
HEPA Filters
Scrub Solution Bag Filters
** Carbon Filters
Office Supplies
Health and Safety Supplies
TOTAL
UTILITIES
Natural Gas
Water
Electricity
TOTAL

8.62
14.61
53.72

53.72
130.67

75.95
25.93
23.88
9.95
10.61
146.33


22.79
0.15
4.23
7.83
1.28
11.04
0.57
11.97
0.24
1.13
61.23

1.02
0.02
166.05
167.10

27,600
46,800
171900
	
171900
418^00

243,100
83jOOO
76,400
31,800
34,000
468300


72900
500
13^00
25,100
4,100
35300
1,800
38300
800
3,600
195,900

3,300
100
531,400
534^00
                                                                                      (Continued)
                                                36

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Table  3-2. (Continued)
                                                                            Case 2
                                                                           3,200 yd3
                                                                     $/yd3*
8.  EFFLUENT TREATMENT AND DISPOSAL
    On-Site Facility
    Off-Site  Facility
    TOTAL

9.  RESIDUALS AND  WASTE SHIPPING AND HANDLING
    Preparation
    Waste Disposal
      Scrubber/Decontamination  Water
      Solid Waste
    TOTAL

 10. ANALYTICAL SERVICES
    Soil  Samples
    Gas  Samples
    Scrubber  Samples
    Glass Samples
    Operational Monitoring
    TOTAL

 11. FACILITY MODIFICATIONS AND MAINTENANCE
    Design Adjustments
    Facility  Modifications
    Scheduled Maintenance  (materials)
    Equipment Replacement  (hood panels)
    TOTAL

 12.  SITE DEMOBILIZATION
    Disassembly
    Site  Cleanup  and Restoration
    Permanent Storage
    TOTAL

 TOTAL
  0.00
  1.77

 19.04
  4.86
 25.67
  4.27
  4.27
  4.27
  4.27
  1.42
 18.52
 35.81
 50.56
 86.38
  12.95
  0.00
  0.00
  12.95

774.40
   5,700

   60SCO
   15,500
   82400
   13,700
   13,700
   13,700
   13,700
   4,500
   59,300
  114,600
  161,800
  276,400
   41,400
        0
        0
   41,400

2,478,000
 *Costs presented are per ydj of contaminated soil treated.
   Costs presented in the body  of the report have been rounded to two significant figures.  Additional
   significant figures have purposely  been retained in this detailed table.
 **May not be required at every site.
                                             37

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                            Coat Breakdown by Category for Can 2 (3,200 Yd' Contaminated Soil)
     2 PERMITTING & REGULATORS
          REQUIREMEUTS
               1%
 1  SITE 4 FACILITY
  PREPARATION
      2%
12  SITE DEMOBILIZATION
         2%
                              11. FACttJTY MOOVCATIONS A
                                        HE!**
                                        11%
         10 ANALYTICAL SERVICES
                  2*
                              9 RESIDUALS A WASTE
                              SHIPPING A HANDLING
                                      3%
  3-2. Co*» (of Efflu*n(
            •>• z«Q for
w«i 'Swvfoni net, slxwm ix- th
  Figure 3-1. Graphical Representation of 12 Cost Categories for Case 2
                                                      38

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show  similar cost distributions.  Treatment is most economical when treating large soil volumes to the
maximum depth, particularly since down-time between melts is minimal compared to actual treatment
time. A high ratio of down-time to melt time results in increased costs per cubic yard for some categories
(e.g.,  labor)  because total treatment time  is not linearly  related to total treatment volume. On a per cubic
yard basis, the contribution of utilities (as a percentage of total cost) increases  markedly with increased
treatment volume. As expected,  the contributions of labor costs and consumables and supplies costs also
increase with increased treatment volume. The contributions of all other cost categories as a percentage
of total cost decrease with increased  treatment volume.

3.2     Issues and Assumptions

This economic analysis was developed based  primarily on information  collected during the  treatment of
Cell 8 at the Parsons site. Costs have been extrapolated where necessary, and when treatment of Cell 8
did not yield representative data, information was obtained from Geosafe so that  a fair estimate of typical
treatment could be generated.

This cost analysis provides estimates for the three treatment scenarios described  below.  In each case,
staged treatment is assumed to take place in nine treatment cells measuring 27 feet by 27 feet. Preliminary
analysis indicated little variation in cost  per cubic yard when treatment depth remained constant and the
number of cells was varied. The contributions of categories such  as site and facility preparation costs,
startup and  fixed costs, and, site demobilization costs (on a per cubic yard basis) decrease, as expected,
when the number of cells is increased because their contributions  can be amortized  over a longer
treatment period. However, the  impact of varying the number of treatment cells appeared to have little
effect  on the overall cost per cubic yard of contaminated soil treated. Therefore, the three cases present
data for treatment in which the  number of cells remains constant and the treatment depth  (and thus total
volume) is varied. The depth of treatment is assumed to exceed the depth of contaminated  soil by one
foot. Although included in this cost estimate, the layer  of clean fill on top of the contaminated soil may
be less than specified or not required  at all in some cases. If clean fill is not required,  the overall
treatment volume (and therefore treatment cost) may be reduced.  The three cases presented in this report
are as follows:
                                                39

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        •      Case 1: Cell depth of 5 feet with a 0.5foot layer of clean fill on top of the contaminated
               soil such that the depth of contaminated soil is 4.5 feet and the total treatment depth is
               6 feet.
        •      Case 2: Cell depth of 15 feet with a 2-foot layer of clean fill on top of the contaminated
               soil such that the  depth of contaminated  soil  is 13 feet and the  total treatment depth is  16
               feet.
        •      Case 3: Cell depth of 20 feet with a 2-foot layer of clean fill on top of the contaminated
               soil such that the  depth of contaminated soil is 18 feet and the total treatment depth is 21
               feet.

Case 1  was selected to present information representative of what  may be considered to be a minimum
treatment depth for economically feasible application of ISV. Case 2 was selected to present economic
data representative of conditions  observed during the Demonstration and ISV treatment at the Parsons
site. It should be  noted that treatment of the nine cells (approximately 3,000 cubic yards) at Parsons was
actually  accomplished  in eight melts. This economic analysis assumes  that,  in  each case, the process
completes nine melts in  nine settings. Case 3 was selected  to provide information representative of the
current  maximum treatment depth for ISV.

The costs for each case of this economic analysis are presented per cubic yard of contaminated (not total}
soil treated. When using ISV, the total volume of soil treated exceeds the contaminated volume of soil
treated.  Three factors must, therefore, be taken into account to determine the total volume of soil treated
corresponding to the  contaminated volume of soil treated.  These factors are: 1) the layer of clean  fill
(one-half to two feet);  2) the actual treatment depth (one foot beyond the contaminated soil depth); and
3) an overmelt correction of 15% (by volume) to  account for overmelting beyond the perimeter of the
treatment zone and remelting to facilitate overlapping treatment. The amount of soil treated in excess of
the amount of contaminated soil is dependent on the  actual  treatment configuration.

The focus of this cost estimate is  on Case 2 which represents the Demonstration at the Parsons  site.
During  the  Demonstration,  it was  estimated by Geosafe that approximately 330 cubic yards  of
contaminated soil were treated in one treatment cell. In this cost analysis, a cell treatment volume of
approximately 350 cubic yards of contaminated soil is used  in the calculations for Case 2. When taking
into consideration the three factors mentioned  above, the volume  of total soil treated is approximately 500
cubic yards per  cell.  Thus, Case 2 is based on treatment of approximately  3,200  cubic yards of
                                                40

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contaminated  soil and approximately 4,500 cubic yards of total soil. Because  the total amount of soil

treated exceeds the  amount of contaminated soil treated, costs per cubic yard of total soil treated would

necessarily be lower


Overall costs to the site owner would probably be less when staged cells are not used since excavation

and cell construction costs may be eliminated, however, undocumented underground features (e.g.,  buried
tanks,  drums, telephone  or electrical cables, etc.) may potentially  increase treatment costs for in situ

treatment


Important assumptions regarding operating conditions and task responsibilities that could significantly

impact the cost estimate results are presented  below:
        0      The cost estimates presented in this analysis are representative of charges typically
               assessed to the client by the vendor and do not include profit. Costs such as preliminary
               site preparation,  permits and  regulatory  requirements,  initiation  of monitoring programs,
               and site cleanup and restoration are considered to be the responsible party's (or site
               owner's) obligation and are not included in the estimate presented. These costs tend to
               be very site-specific,  and calculations are left to  the reader.  Whenever possible,
               applicable information is provided on these topics so  that the reader may independently
               perform calculations to  acquire economic data desired.

        •      It is assumed that the, contaminated  soil will be staged into treatment cells by an
               independent contractor prior  to Geosafe's arrival on-site.

        •      The density of the untreated soil (on a wet basis) is  assumed to be 1.8 tons per cubic
               yard.

        •      Treatment is assumed take place 24 hours per day, 7 days per week, 52 weeks per year.
               An  on-line efficiency factor of  80% has been  incorporated to account for down-time due
               to  scheduled  and unscheduled maintenance  and other unforeseen  delays. Down-time  to
               move the hood is accounted for separately.

        •      Capital costs for equipment are limited to the cost of the ISV system (off-gas hood,
               electrical transformers,  power  cables, and  electrode feeders)  the basic gas treatment
               system (quench tank, scrubber, demister, particulate filter system, activated carbon
               system, and glycol cooling system), and the backup  gas treatment system.  Percentages
               of the total equipment cost are  used to estimate other costs.

        •      During treatment, three shifts  of workers are  assumed to work eight hours per day, seven
               days per week for three weeks. At the end of three weeks, one shift of workers is rotated
               out, and a new  set replaces the former. The rotation  of  workers  is set up  so that each
               worker works for three weeks straight,  and then rests for one week.

                                                41

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        •      Operations for a typical shift require two workers: one shift engineer and one operator.
               Additionally,  one  site manager and one  project control  specialist  are present on-site
               during the day shift. Off-site office support corresponding to  50% of one  person's full-
               time responsibilities is also required.
        •      The costs presented (in dollars  per  cubic  yard) are calculated based on the number of
               cubic yards of contaminated  soil  treated.  Because  clean fill  and surrounding
               uncontaminated soil are treated as part of each melt, the total  amount of material treated
               may be approximately 35 to 55  percent higher. Costs per cubic yard based on total soil
               treated would, therefore, be lower than those presented in this estimate.
Many actual or potential costs that exist, including treatability studies, were not included as part of this
estimate. They were omitted either because  the costs were assumed to be the obligation of the responsible
party or because  site-specific  engineering designs that are  beyond the scope of the SITE project would
be required.  The costs  of treatability  studies  could range from $40,000 to $80,000 depending on  the
application (2,3,4).  Analytical costs  can be a  major factor in treatability studies, depending on the
number and type of analyses  required

3.3     Basis of the Economic Analysis

This cost analysis was prepared by breaking down the overall cost into 12 categories defined by  EPA.
The  categories,  some of which do  not  have costs associated with them  for this particular technology, are:

        •      Site and Facility  Preparation Costs
        •      Permitting  and Regulatory  Requirements  Costs
        •      Equipment  Costs
        •      Start-up and Fixed Costs
        •      Labor  Costs
        •      Consumables  and  Supplies  Costs
        •      Utilities  Costs
        •      Effluent Treatment and Disposal Costs
        •      Residuals and Waste Shipping  and Handling  Costs
        •      Analytical  Services  Costs
                                                42

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I
        •       Facility  Maintenance  and Modifications  Costs
        •       Site Demobilization  Costs

The 12 cost factors examined as  they apply to the Geosafe ISV system, along with the  assumptions
employed,  are  described in detail  below.

3.3.1   Site and Facility Preparation Costs

For these cost  calculations, "site" refers to the location of the contaminated waste. Site design and layout,
survey and site investigations, legal searches, and access rights and roads are assumed to be the
responsibility of the  site owner.  Support facilities and auxiliary buildings are not required for this
technology  because the system is  self-contained with mobile trailers used for  auxiliary  buildings. Utility
connections may or may not be required; the specific characteristics of the site may cause this cost to
fluctuate greatly,  and  therefore, costs are not included in this  estimate.  It should be noted that utility
connections, while normally available from standard United States electrical grids, may be  of particular
importance for this technology because of the high power demands of the system. Because ISV is an in
situ technology, the location of the contaminated waste is assumed to be the same as the location of the
treatment facility; thus, there are no costs for transportation of the contaminated waste.

For the purposes  of this cost estimate, it is assumed that the contaminated soil will be excavated and
staged into treatment  cells by an independent contractor prior to Geosafe's arrival on-site. Although the
costs of this activity are  not included in this  estimate because they are site-specific, typical excavation and
placement costs may be  assumed here. If staging is  not required, a reduction in site preparation costs may
be experienced; however, if the contaminated soil is not  excavated and consolidated, unidentified buried
items may  be  encountered and must be handled appropriately

Transportation charges are only assessed for travel to a treatment site since it is anticipated that, once a
job is completed, the equipment will be transported directly to the next site without returning  to Geosafe's
home office. Trucking charges include drivers and  are based on an  80,000-pound  legal load. The ISV
process equipment is  contained on or in three mobile trailers:  a process trailer, a support trailer, and an
electrical trailer. The  three process trailers are typically  moved by two tractors (two of the trailers are
towed together). An overweight permit is necessary for transport of the  electrical trailer.  This is the  only

                                                 43

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trailer that requires a permit. Three additional trailers are required for transportation of the hood,
electrode feeders, backup gas treatment system, and other associated piping and equipment.  Thus,
transportation of the ISV system requires a total of five tractors and six trailers. It is assumed that
overweight permits can be obtained for under $50 per state and that permits will be required  for an
average of four states per trip. Using a 1,000-mile  basis as a typical transportation distance and an
estimated  cost per mile of $3.00, the total transportation  cost is approximately $15,000, Depending on
the number of states that are traversed and the amount of state fees that  are assessed for permits and road
usage, this cost may vary. The transportation cost from Geosafe Corporation in Richland, Washington
to the Parsons site  in Grand Ledge, Michigan was  higher than this estimate (approximately $34,000 total)
due in part to the great distance travelled and to the peculiar weight limitations of Michigan roads. The
$15,000 figure has been used for this cost estimate to present what may be anticipated as typical
transportation  costs.

Assembly of the Geosafe ISV system requires a full crew of eight Geosafe employees plus three local
workers working eight  hours per day for ten days. Office support from the home office is also required
for four hours per  day (one person). Two cranes are required: a 25-ton crane for one week (seven days)
and a 100-ton crane for half of one day (four hours). Assembly costs  are limited to labor charges
(including rental cars and per diem) and crane  rental  fees. Information on labor rates may be found under
"Labor Costs. "

3.3.2  Permitting and Regulatory Requirements  Costs

The  cost of permitting  and regulatory requirements  is 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. Modifications to the system
may also  be required to maintain compliance with the regulations. Permitting  and regulatory  costs can
vary greatly because they are very 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.  The costs of environmental monitoring  (including
the development of monitoring  protocols)  are  determined by the requirements imposed by  the local
governing agency.  Because they are site- and waste-specific, these costs are not included here.
                                               44

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Stand-down costs (costs incurred while the  system  is not in use) for this  technology, which are included
in the cost estimate, are in the vicinity of $5,000 per day. It is therefore advisable that, to the maximum
extent possible, permitting and regulatory requirements  are carefully researched and appropriate permits
obtained prior to the initiation of treatment. Even so, it is  likely that some stand-down time will occur
while samples are being analyzed to determine compliance. It is assumed that one day of stand-down time
will be incurred for each sampling  episode and that one  sampling episode  will be required for every three
cells treated.

3.3.3 Equipment  Costs

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

The major pieces of equipment are the off-gas  hood, the electrode feeders, electrical cables, the off-gas
treatment system (including quencher, scrubber, mist eliminator, particulate filter system, and activated
charcoal system), the back-up off-gas treatment  system, the glycol cooling system,  and the electrical
system.  The electrodes themselves are considered consumables. No support equipment is purchased or
sub-contracted for operation of this  system. Rental equipment includes a 25-ton  crane, a 100-ton crane,
a forklift, a front-end loader, a dump truck,  a storage tank, one mobile office trailers, one mobile
decontamination trailer, and two portable toilets.  In some cases,  rental of modular  additions to the gas
treatment system may also be necessary. At the Parsons site, a rented thermal oxidizer was required to
fully treat the off-gases. To remain consistent throughout the analysis, it is assumed that a thermal
oxidizer is required in each  case.

The capital cost of the complete  system is assumed to be $4,000,000.  Although the client does not
purchase the  system, the cost of remediation must account for the annualized cost  of the equipment. The
capital equipment costs are presented as annualized equipment  costs,  prorated for the amount of time the
equipment is used for the project. The annualized equipment cost is calculated using a ten-year equipment
life and 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.
The following equation is used:

                                               45

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                        Capital recovery  =  (V -V)    —	—
                                                          (1  + /)"

where V      = the cost of the original equipment ($4,000,000),
       V,      = the salvage value of the equipment ($400,000),
       n       = the equipment life (10 years), and
       i       = the annual interest rate (10%) (4,5).

The capital cost of equipment is the same for each case. The annualized cost of the equipment is prorated
over the assembly time, startup time, total treatment time, and disassembly time. In each case,  assembly
and disassembly time remain constant at ten days each; startup time remains constant at seven days. Total
treatment time for nine settings,  including  soil melt time and hood move time, is estimated to be 73 days
when the depth of the cell is 5 feet, 130 days when the depth of the cell is 15 feet (as during the
Demonstration), and 150 days when the depth of the cell is 20 feet.

A 25-ton crane is rented at a rate of $95 per hour to provide assistance with hood movement and
electrode addition.  The 25-ton crane is required for an estimated two hours per cell when the cell depth
is 5 feet, for four hours per cell when the cell depth is 15 feet,  and for an estimated six hours per cell
when the cell depth is 20 feet. A 100-ton crane  is rented at a rate of $200 per hour for eight hours (one
day) each  time the hood is moved.  Crane rental  charges for assembly and disassembly are included under
"Site  and Facilities  Preparation Costs" and "Site Demobilization Costs," not "Equipment Costs." A
forklift is rented at a rate of $1,300 per month for assembly time, startup time, total treatment time, and
disassembly time. A front-end loader ($440 per day) and a dump truck ($150  per day) are each rented
for one day to backfill the melt  subsidence each  time the hood is moved, nine  days total. A 20,000-gallon
Baker * storage tank is rented at a rate of $38 per day for the total treatment time; the costs for delivery
and pickup of the tank are each $350. One mobile office trailer and one mobile decontamination trailer
are rented at a rate of $150 per month for assembly time, startup  time, total treatment time, and
disassembly time; the costs for  delivery and pickup are each $180. Two portable toilets are rented at a
rate of $60 per month for assembly time, startup time, total treatment time,  and disassembly  time; the
costs for pickup and delivery are  $40 each. A thermal oxidizer is rented at a rate of $5,000 per month
for  assembly time,  startup  time, total treatment time, and disassembly time; the costs for pickup and
delivery are each $300.
                                               46

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3.3.4   Start-up and Fixed Costs

Start-up and fixed costs are  considered to include such things as startup operations, security, working
capital,  insurance and taxes, and contingency.  For the most part, these costs are independent of the length
of treatment time. Working capital varies slightly with treatment depth  and the time required to treat each
cell. Insurance and taxes and contingency costs are prorated over the assembly time, startup time, total
treatment time, and disassembly time

Startup costs are limited to  labor charges (including rental cars and per diem) for a full crew (eight
persons) working eight hours  per day for one  week (seven days). Operations will not take place 24  hours
per day during startup since  melting is not initiated until after the startup and shakedown processes are
complete.  Information on labor rates may be found under "Labor Costs."

To protect both the site and the public, site security is required whenever Geosafe personnel are not on-
site. Since 24-hour operations are assumed to take place only during  treatment (actual melting), security
is  required  overnight during all  other phases of the project (i.e., assembly, startup, hood moves, and
disassembly). At these times, one security guard is required for eight hours per day. The labor rate for
a security guard is assumed to be $10 per hour.

Working capital is the amount of money currently invested  in consumables and supplies. The working
capital cost  of consumables and  supplies  is based on  maintaining a one-month  inventory of these items.
(See "Consumables and Supplies Costs" for the  specific amounts required for the operation of the system.
Note that the cost of consumables and  supplies  varies slightly with treatment depth and the time required
to treat each cell.) The total cost  of consumables and supplies divided by the total number of treatment
months  yields the monthly cost of consumables  and supplies. This dorresponds  to the amount of money
required to  maintain a one-month inventory of consumables  and  supplies.

Insurance is usually 1% and taxes  are usually 2 to 4%  of the total purchased equipment capital costs
(approximately) on an annual basis. The cost of insurance for a hazardous waste process can be several
times more. Together, annual insurance and  taxes are assumed to be 10% of the purchased equipment
capital costs (7) for the purposes of this estimate. The cost is prorated over the assembly time, startup
time, treatment time and disassembly time.

                                                47

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The cost of the initiation of monitoring programs is very site- and waste-specific. Requirements for the
initiation of monitoring programs are generally determined by the  state agency governing hazardous waste
operations. Applicable costs would be assessed prior to treatment and  would not likely extend into the
treatment phase of remediation. The  cost of environmental monitoring is discussed under "Permitting and
Regulatory Requirements  Costs"  above.

An annualized contingency cost of 10% of the total purchased equipment capital costs is allowed for any
unforeseen or unpredictable cost conditions, such as strikes, storms, floods, and price variations  (5,6).
This cost is prorated over the assembly time, startup time,  treatment time and disassembly time.

3.3.5 Labor Costs

Labor costs include overhead and administrative costs  and are limited to hourly labor rates, per diem,
daily  transportation, and travel. Labor charges  are assessed only during the total treatment time  since
labor  costs for  other activities  (such  as assembly, startup and disassembly)  are included elsewhere.  Labor
charges during treatment are broken down into  two categories: soil melts  and hood moves.

During  a melt, operations take place in three shifts. The day shift (8 A.M.  to 4 P.M.)  requires a site
manager, an engineer, a project control specialist, and an operator. The  swing shift (4  P.M.  to 12 A.M. )
and the graveyard shift (12A.M.  to 8 A.M.) each require an engineer and an operator. During hood
moves,  the full crew (a site manager, three  engineers,  a project control specialist, and three operators)
is present. Operations are  eight hours a day during hood moves. To coordinate on-site operations with
the home office, it assumed that office support requirements total 50% of one  person's full-time
responsibilities.

Hourly labor rates are as follows: site manager, $60; engineer, $40; project control specialist,  $30;
operator,  $30;  local worker, $20; office support, $40.  .Per  diem (daily meals and accommodations)  is
estimated at $75  per day per person. Daily transportation includes a rental car and fuel at $50 per day.
One rental car is provided for the site manager; a second rental car is provided for  the process control
specialist. One additional rental car  is provided for each shift of workers for a total  of five rental  cars.
Round trip travel costs are assumed to be $1,000 per person,  and it is assumed that, based on a rotating
schedule of three  weeks on and one week off, each person will travel home  and back to the site once each

                                                48

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month during treatment. Regular trips home are not scheduled during assembly, startup, and disassembly
The  site  manager,  project  control  specialist,  engineers,  and  operators require  per  diem,  daily
transportation to the site, and round trip travel to the site.  Local workers are only  employed during
assembly and disassembly and do not require per diem, daily transportation to the site, or round trip
travel to the site. Office support personnel provide assistance from the home office and are not required
to be present on-site; hourly labor is the only applicable charge for office support.

3.3.6   Consumables and Supplies Costs

The  Geosafe ISV process utilizes a square array of four electrodes to melt soil. The electrodes used are
solid graphite and supplied in 12-inch outside diameter (OD) six-foot threaded sections. The cost of the
graphite electrodes is approximately $1 per pound, and each six-foot section weighs approximately 500
pounds, resulting in an electrode cost of $500 per section. The total cost for electrodes  is based on whole
(six-foot) sections used during each melt. That is, even if the melt is only sixteen feet deep, electrode
usage is assumed to be eighteen feet (three six-foot electrode sections). Geosafe shears the electrodes near
the surface at the conclusion of a melt for reuse, but the location of the cut with  respect to the threads
determines the usefulness of the sheared electrodes.

A conductive mixture of graphite and glass frit is laid in a pattern on the untreated soil surface between
the electrodes  to provide a starter path for the electrical current  Approximately 75 pounds of frit
available for about $1 per pound, are required for every melt

A synthetic material is used to insulate the untreated soil surface and to protect the hood from undesirable
contact with molten soil during the early stages of treatment. This insulating "blanket"  is available by the
roll  at a cost of $1.70 per square foot.  Approximately  900 square feet  are required to cover the soil
surface beneath the hood for each cell

Refractory concrete is a material that can be used to prevent convective melt erosion of the soil wall and
limit melt width. This material has recently been employed to restrict melt  growth to  the desired areas
Prefabricated sheets can be used  to  form the walls of  the cells constructed for  staged treatment

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Refractory concrete may be considered a staging cost rather than a consumable, but for this cost estimate,
it is categorized as a consumable item. Refractory concrete is available at a cost of $0.25 per pound. The
use of refractory concrete is not required when the cell depth is 5 feet because melt width is not a
problem at such shallow depths. When the cell depth is 15 feet (based on experience at Parsons),
approximately 11,000 pounds of refractory concrete are required per cell, and an estimated  15,000
pounds when the cell depth is 20 feet. The need for and the use of refractory concrete may vary  from
site to site and even from cell to cell. Using  a conservative approach, the quantities  in  this estimate
assume that refractory concrete is used in every cell treated over the entire cell depth. Geosafe proposes
that refractory  concrete may only be required  at the "beltline" (widest point) of the melt and not over the
full depth.

Sodium  hydroxide  (NaOH)  is utilized as a caustic in the scrubbers. For this process, a 50% NaOH
solution is used. It is available for $150 per 55-gallon drum. The amount of NaOH required depends on
the volume and characteristics of soil treated.  It  is also influenced by the performance of  the scrubber and
the ambient weather conditions. It is estimated that one drum per cell is required when  the cell depth is
5 feet, three drums per cell when the cell depth is 15 feet, and four  drums per cell when the cell depth
is  20  feet.

High  efficiency particulate air (HEPA) filters are used in the off-gas treatment system to collect fine
particulate matter. These filters are consumed at a rate dependent on the soil characteristics, the treatment
time,  and the performance of the off-gas treatment system. In some cases, it may not be  necessary to use
HEPA filters to meet state  particulate limits.  Demonstration results  indicate that approximately  25 HEPA
filters were used during  treatment of each 15-foot cell.  It is assumed that an estimated  10  HEPA  filters
are required for each 5-foot cell, and 35 filters are required for each 20-foot  cell. Each HEPA filter  costs
approximately $160. The high cost and high  rate of consumption of HEPA  filters motivated Geosafe to
develop techniques whereby the filters could  be reused and recycled, reducing the overall cost of HEPA
filters.

Bag filters used by the scrubber portion of the  off-gas treatment system are available at $2.50 per filter.
The number of filters used  during treatment of each  cell  is dependent on the amount volume of scrubber
water generated. This volume is highly variable.  Approximately 80 filters were  required per cell during
                                                50

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treatment at the Parsons site (15foot  cells). It is estimated that 25 filters  are required for treatment of
5-foot cells and 100 filters are required for treatment of 20-foot cells.

Carbon filters, employed to process the off-gas  before  release to the atmosphere, are used for normal
operations in  the absence of a thermal oxidizer. In some instances, such as at the Parsons site, carbon
filters may be used in addition to a thermal oxidizer. Carbon filters were consumed at a rate of four per
15-foot  cell at Parsons.  The number of carbon  filters  is variable and dependent on the volume  and nature
of off-gas generated as well as the performance of the off-gas system. It is assumed that an estimated two
filters are required per  5-foot  cell and five filters are required per 20-foot cell

General office supplies  are required to maintain efficient operation  at the site from the time of assembly
and startup through  treatment and disassembly.  The monthly cost  for office supplies is approximately
$150.

Health and safety supplies are required for all phases of the project including assembly, startup,
treatment, and disassembly. The monthly cost of health  and  safety  supplies varies slightly with the phase
of treatment but averages approximately $700.

337 Utilities  Costs

Electricity is  a primary cost for this technology. Rates substantially lower than typical residential rates
are often  available for industrial purposes, particularly when  usage is as high as it is for this technology.
The industrial or commercial  cost of  high voltage line  power varies greatly with location ranging from
as low as $0.025 per kilowatt-hour  on the west coast to as much as $0.08 per kilowatt-hour in the
Midwest and east coast (3). At the time of the  Demonstration in  Grand Ledge, Michigan, the commercial
cost of electricity  was  slightly higher-$0.089 per kilowatt-hour. There was  an additional monthly service
fee of $6.50. These charges reflect the local cost  for electricity. At other sites, this cost may differ. Based
on information gathered during  the Demonstration, the Geosafe ISV process requires approximately 0.37
kWh of electricity for each pound of  soil melted (approximately 0.72 MWh per ton). This value is used
in the cost estimate presented although it is slightly lower than the typical  value reported by Geosafe of
0.50 kWh per pound (1 MWh  per ton). The total electrical usage for the system when treating nine five-
foot deep cells at a  rate of 370 MWh per pound of soil is approximately  2,200  MWh. When the cell

                                                51

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depth is increased to  15 feet,  approximately 5,900 MWh are required for nine cells, and when the cell
depth is 20 feet, approximately 7,700 MWh are  required for  nine cells. The power consumption per
pound of soil reported here is  based on Demonstration results-soil with a density of approximately  3,600
pounds per cubic yard (1.8 tons per cubic yard)  and 16 percent moisture. The density and moisture
content of the  actual soil treated may cause this value  to vary. Additional electricity is  required for power
in the office and process trailers.  However, this is  negligible compared to the amount of power required
to melt the soil and has therefore been ignored in  these calculations. A diesel generator may be utilized
when power lines are  inaccessible.  Cost for use of  diesel generators is equivalent to approximately $0.083
to $0.13 per kilowatt-hour (3)

Natural  gas is utilized by the thermal oxidizer. Approximately  one million cubic feet of natural gas are
required to treat the  off-gas generated from each B-foot cell when using a thermal oxidizer with a
capacity of 10,000 standard cubic feet per minute.  This amount will vary slightly with the time required
to treat a cell, but the overall effect on the total cost is negligible, and  thus the  same natural gas
requirements have been assumed for each of the  three cases.  The local cost for natural gas  in Grand
Ledge, Michigan at the time of the Demonstration was $10 per month plus  approximately $0.00040 per
cubic foot.

Locally, water rates were $21  per quarter (three months) plus a sewage fee  of $0.0029 per gallon  at the
time of the Demonstration. Water usage fluctuated throughout  treatment based on system performance,
soil moisture content, and current weather conditions. On the  average, approximately  3,500 gallons of
water were required for each  cell treated during the Demonstration (cell depth 15 feet). When the cell
depth is 5  feet, water consumption per cell is estimated to be 2,000 gallons per cell,  and when the cell
depth is 20 feet,  water consumption is estimated to be 4,500 gallons per cell.

       Effluent  Treatment and Disposal Costs

The stack gas  and the  scrubber liquor are the only  effluent streams anticipated to  be generated as a  result
of typical  treatment using the Geosafe ISV process.  Depending  on the  on-site contamination and the
ARARS, these streams may be permitted for discharge. In most  instances, when a thermal oxidizer is part
of the off-gas treatment train, emissions may be released directly to the atmosphere without further
treatment.  A likely scenario for the scrubber liquor is  collection  and disposal as a residual waste although

                                                52

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Geosafe claims that scrubber liquor may be recycled to subsequent melts.  During the Demonstration,
scrubber liquor was collected as disposed of as a residual waste, therefore these costs are covered under
"Residuals and Waste Shipping and Handling Costs," At the Parsons site, an additional effluent stream
was encountered when the logistics of treatment required a groundwater diversion system to be installed,
This diverted water was permitted for discharge after carbon filtration. The costs for  treatment of this
additional effluent stream were unique to the Parsons site and have been excluded from this cost estimate.

3.3.9  Residuals and Waste Shipping and Handling  Costs

The primary process residua! generated by the Geosafe ISV technology is the vitrified mass. This material
is generally left intact and in place at the conclusion of treatment. The molten mass may take one to two
years to cool completely. There are no costs associated with the disposal  of the vitrified mass. In some
instances, the treated material may be left uncovered  in order to cool more  rapidly and  thus induce
crystallization and fracturing  of the mass. This may be  a desirable practice if the vitrified mass is to be
removed from the treatment site.  Costs for the removal of the vitrified mass are dependent on the ease
of handling the material (which is in turn dependent on the  degree of fracturing achieved) and  have not
been included in this cost estimate.

A  number of secondary process residuals and  waste streams are generated  by  the Geosafe  technology.
The disposal of these streams requires approximately one week (seven days) of preparation (eight hours
per day).  Personnel requirements are  limited to three  local workers and the off-site assistance of one
person from the Geosafe home office. (See "Labor Costs" for specific labor rates.)

The liquid waste streams include  scrubber liquor and decontamination liquid. The scrubber liquor  was
discussed briefly above as an effluent stream, but  since the scrubber  liquor was not discharged at the
Parsons site, the cost of its disposal is included  in this category. The amount of scrubber liquor generated
is  dependent  on the nature of the treatment media. High levels of contamination and/or soil moisture
content may result in large quantities of scrubber liquor. For treatment of 5-foot cells, it is estimated that
approximately 3,000 gallons of scrubber water (including the initial charge of water to  the scrubber) are
generated per cell. The amount of scrubber liquor generated at the Parson site was highly variable from
cell to cell, but an average of approximately 8,000 gallons of scrubber water (including the initial charge)
were  generated  for treatment of  15-foot cells. It  is estimated that approximately 10,000 gallons of

                                              53

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Geosafe  claims  that scrubber liquor may be recycled to subsequent melts. During the Demonstration,
scrubber  liquor was collected as disposed of as a residual waste, therefore these costs  are covered under
"Residuals and Waste  Shipping and Handling Costs." At the Parsons site, an additional effluent stream
was  encountered when the logistics of treatment required a  groundwater diversion system to be installed.
This diverted water was permitted for discharge after carbon filtration. The costs for treatment of this
additional effluent stream were unique to the Parsons site  and have been excluded from this cost estimate.

3.3.9  Residuals  and Waste  Shipping and  Handling Costs

The  primary process residual generated by the Geosafe ISV  technology is the vitrified mass. This material
is generally left  intact and in place at the conclusion of treatment. The molten mass may take one to two
years to  cool completely. There are no costs  associated with the disposal of the vitrified mass. In some
instances, the treated material may be left uncovered in  order to cool more rapidly and thus induce
crystallization and fracturing of the mass. This may be a desirable practice if the vitrified mass is to be
removed from the treatment site. Costs  for the removal  of the vitrified mass are dependent on  the ease
of handling the  material (which is in turn dependent on  the degree of fracturing achieved) and have not
been included in this cost  estimate.

A number of secondary process residuals and waste streams are generated by the Geosafe technology.
The  disposal  of these streams requires approximately one week (seven  days) of preparation (eight hours
per day). Personnel requirements  are limited to three local workers and the off-site assistance of one
person from  the Geosafe home office.  (See "Labor Costs" for specific labor rates.)

The  liquid waste streams include  scrubber  liquor and decontamination liquid.  The scrubber liquor was
discussed briefly above  as  an  effluent stream, but since the scrubber  liquor was not discharged at the
Parsons site,  the cost of its  disposal is included in this category. The amount of scrubber liquor generated
is  dependent on the nature of the treatment  media High levels of contamination and/or soil  moisture
content may result in large  quantities  of scrubber liquor. For treatment of 5-foot cells,  it is estimated that
approximately 3,000 gallons of scrubber water (including the initial  charge of water to the scrubber) are
generated per cell. The amount of scrubber liquor generated at the Parson site was highly variable from
cell to cell, but an average of approximately 8,000 gallons of scrubber water (including the initial charge)
were generated for treatment of 15-foot cells. It is estimated that approximately  10,000 gallons of

                                                53

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scrubber water (including the initial charge) are generated for treatment of 20-foot cells. The scrubber
liquor may require special handling depending upon the types and levels of contaminants being treated.
Decontamination liquid will only be generated at the conclusion of treatment when the process equipment
is decontaminated prior to transport to the next treatment site. It is estimated that approximately 5,000
gallons  of decontamination water will be accumulated for disposal. Two profile  samples are assumed to
be collected  from each 20,000 gallons of liquid waste accumulated. A full range of analyses  will be
performed on these samples  to characterize the waste stream for disposal. The  analytical cost per sample
is estimated  at $1,500. An  additional one-time $150 profile cost is also assumed for the liquid waste
stream.  Disposal costs for the liquid waste stream are assumed to be $0.75 per gallon, typical for liquid
waste disposal.

Solid secondary wastes include carbon filters, scrub  solution bag  filters,  HEPA filters, used hood panels,
and  personal protective equipment (PPE). Carbon filters and HEPA filters may be recycled to maximize
their use. Other process residuals (such as used scrub solution bag filters, used  HEPA filters, and PPE)
can be disposed in future melt settings to reduce the  volume of these materials requiring ultimate  disposal.

The  number of used hood panels requiring disposal is dependent on the type and extent  of contamination
at the site, the corrosiveness of the off-gases generated during treatment (as well as the corrosion-
resistance of the hood panels), and the. duration of treatment. The vendor claims that under some
treatment conditions, the life expectancy of hood panels may increase, and disposal of the panels may not
be required. The solid wastes may be combined  into a single waste stream for disposal.  Approximately
two  20-cubic yard  roll-off bins of solid waste are generated for treatment of nine  5-foot cells; four roll-off
bins for treatment of nine 15-foot cells; and five roll-off bins for treatment of nine 20-foot cells. Disposal
costs are  assumed  to be $800 per 20-cubic yard roll-off bin. Profile samples are collected to characterize
the waste for disposal  (two per roll-off bin),  and  a full range of analyses performed ($1,500 per sample)
An additional one-time $150  profile cost is  also assessed  to the  solid waste stream.

3.3.10 Analytical Services Costs

Sampling and analysis of the system is performed on a routine basis to ensure proper performance and
compliance with  regulatory limitations. It is assumed that samples are collected from every third cell
treated.  Three samples of each of the  following matrices are collected during each sampling episode for

                                                54

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test soil, off-gas, scrubber liquor, and treated  soil. A full range of analyses ($1,500) is performed on each
sample.  If sampling is  performed by an outside contractor, additional costs will be incurred, particularly
for gas  sampling.  Daily monitoring for fugitive  emissions  is also performed using a photoionization
detector or organic vapor analyzer.  This monitoring equipment is available for approximately $250 per
week and is required only during treatment.

3.3.11 Maintenance and Modifications 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 costs are assumed to be 10% of the
purchased equipment capital costs. Of this, 33% is estimated to be maintenance labor and 67% is
estimated to be maintenance materials. Costs  for design adjustments, facility modifications, and equipment
replacements are not included in this cost estimate. Maintenance labor is assumed to be accounted for
under "Labor Costs, " and therefore  scheduled maintenance costs are limited to maintenance, materials

In addition to typical maintenance materials, the Geosafe  hood panels may require replacement during
and  at the conclusion of treatment. Although  the panels were  stainless steel,  the  harsh environment
beneath the treatment hood at the Parsons site demanded frequent  replacement of the panels. There are
approximately  120  panels (approximately $100 each) on the  hood. It is estimated that 33 % of these panels
will  need replacement during treatment of nine 5-foot cells,  50% during treatment of nine  15-foot cells,
and  58% during treatment of nine 20-foot  cells. Due to  difficulties in decontaminating the hood panels
at the conclusion of treatment, it is Conservatively  estimated that 67% of the hood panels will need
replacement for after treating  nine 5-foot cells, and all 120 hood panels will need replacement after
treating nine  15- or 20-foot cells. The frequency of hood panel replacement depends on operating
conditions during treatment; Geosafe claims  that the typical life expectancy of the panels is greater than
that exhibited during the Demonstration. See Appendix A of this report ("Vendor's Claims") for
additional details
                                               55

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3.3.12  Site  Demobilization Costs

Site demobilization is limited to the removal of all equipment from the site.  Disassembly  of the Geosafe
ISV system holds the same cost requirements as assembly. The disassembly process is identical to
assembly, merely performed in the reverse order. Any other requirements  of the site will  vary depending
on the  future use of the site and are assumed to be the obligation of the responsible party. Therefore, site
cleanup and restoration costs are limited to disassembly labor charges for this cost estimate.
                                                56

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                                          SECTION 4
                               TREATMENT EFFECTIVENESS

4.1     Site History and Contamination

From 1945  to  1979,  Parsons Chemical  Works, Inc.  was  engaged in the mixing, manufacturing,  and
packaging of agricultural chemicals at a 6.5-acre  site located in Grand Ledge,  Michigan.  Sanitary sewage
and wash water were discharged from the packaging plant to a septic tank and tile field system. Wash
water from the  operations was also released to the septic tank system, which was hydraulically connected
to a storm drain emptying into an unnamed creek near the site. Chemicals in the wash water contaminated
the soil in three areas on the site.  The site, now a Superfund site, is currently owned and occupied by
ETM  Enterprises, Inc., a manufacturer of  fiberglass parts. ETM purchased the site from Parsons in 1979.
A total of about  3,000  cubic yards of soil were found to be  contaminated with  chlordane, 4,4'-DDT,
dieldrin, and mercury. Dioxins were also found on the site at very low levels. The  areas of contamination
on the site were relatively shallow, reaching a maximum depth of only five feet.

4.2     Treatment Approach

After a feasibility study was conducted at the Parsons site,  ISV was selected as  the treatment remedy
Treatability tests  on the site soil were completed by Geosafe  Corporation in January 1990. The results
confirmed  the suitability of the site soil and contamination  for remediation by ISV, and thus ISV was
selected as the Removal Action for the  Parsons Superfund site.

Because the contaminated soil at the Parsons site was shallow and located in several small  areas on the
site, the soil was excavated and staged into two adjacent trenches. The trenches  were constructed near
two  of the contaminated soil areas, and also close to the original Parsons building. One trench was 168
feet  long,  and  the adjacent trench was 84 feet long. Each trench was approximately 27 feet wide. A total
of nine ISV treatment cells were planned for the trenches, each a total of 27 feet by 27 feet by  15 feet
deep (See  Figure 4-1)
                                               57

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 1' CONCRETE WALL    INITIALLY PLANNED LOCATION Of
    2'COBBLE FILL     12" DIA. ELECTRODE (TYPICAL)
                      CELLS
                   DEMONSTRATION
                     TEST AREA
  CLEAN FILL SURROUNDS COBBLE
Figure 4-1. Plan View of Treatment Cells

The cells were built using concrete, cobble, and wood as shown in Figure 4-2. They were constructed
by trenching an area of the site, installing wooden concrete forms, and pouring concrete into the forms
to create the nine cell settings. The concrete walls were one-foot thick and 16 feet high; the top  of the
walls were at ground level. A one-foot layer of cobble (which sloped up to approximately three feet in
the comers) was placed in the bottom of each cell, and  approximately two  feet of cobble was used to
surround the  exterior of the cell forms. The  cobble was used to provide a drainage pathway for water that
was known to be present on-site; the resultant flow of water was directed to two sumps and was pumped
from there to a drainage trench.  After construction, the cells were lined with plastic sheeting, and then
filled with contaminated soil from the site. A layer of clean soil approximately two feet deep was placed
on top of the contaminated soil to act as a barrier between the contaminated soil and the surrounding area.

It was planned that the treatment would progress through the nine cells in a designated order. Each cell
was anticipated to require  approximately seven  to ten days to treat, with an additional three days  required
to move the hood and off-gas treatment system between  settings  and start the next cell.
                                                58

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4.3     Treatment Objectives

The treatment objectives for the ISV remediation at Parsons were set by EPA Region V. Final cleanup
levels for the soil were set at 1,000 fig/kg for chlordane;  4,000 Mg/kg for 4,4'-DDT; 80 /xg/kg for
dieldrin; and 12,000 /ig/kg for mercury. A major claim of the ISV developer is that the process can
significantly reduce the leaching potential of heavy metals and other inorganics from the solidified mass.
Leachability was  therefore tested by conducting the  toxicity characteristic leaching procedure (TCLP)  on
pre- and post-treatment samples of the soil. The Federal TCLP limits (40 CFR 9261.24) were used for
comparison with  test results.

4.4     Detailed  Process Description

The ISV process  is designed to treat soil and other earthen materials (e.g., sludge, sediments, and mine
tailings) contaminated with a wide variety of contaminants.  The technology uses joule heating  to melt the
waste matrix, destroying  organic compounds in the process, and encapsulating the inorganic  constituents
in a monolithic and  leach-resistant form. In joule heating, electric current flows through the material and
transfers heat energy to the material (3)

ISV involves the heating and melting of the lithological matrix in  which contamination is present. The
Geosafe process uses a square array of four 12-inch OD graphite electrodes spaced up to 18 feet part.
This allows formation of a maximum melt width of about 35 to 40 feet and a maximum melt depth  of
approximately 20 feet. The electrode spacing is somewhat  dependent on the soil characteristics, and the
electrodes are lowered gradually as the melt progresses.  Figure 4-3 shows a typical ISV equipment layout.

A conductive mixture of flaked graphite and glass frit is placed just below the soil surface between the
electrodes to act  as  a starter path since dry soil is usually not electrically conductive.  The soil surface
beneath the hood is then covered by a layer of insulation. The starter path facilitates the flow of current
between the electrodes until the ground matrix reaches a  temperature and viscosity to conduct the current
and produce melting. At this stage, the soil warms to  approximately 2,900 to 3,600°F (1,600 to
2,000°C), well above the initial melting temperature  of typical  soils (2,000 to 2500°F or 1,100  to
1,400°C). Temperatures at an individual electrode can reach as high as 3,300°F(1,800°C). The graphite
and glass  starter path is eventually consumed by oxidation. Upon  melting, most soils become electrically

                                                59

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                                                                          Electrode
Ctean Fill (Soil)
Figure 4-2. Cut-Away View of Treatment Cells

                               OFF-GAS HOOO	

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                                  •NATURAL
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Figure 4-3,  Geosafe In Situ Vitrification Process
                                                60

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                                                                             Electrode
Clean Fill (Soil)
Figure 4-2.  Cut-Away View of Treatment Cells



                                OFF-GAS HOOD






POWER TO ELECTRODES
/
ELECTRODE
inCATIOM
                           OBWATER
                            HEAT
                                   NATURAL

                                     GAS
                                                                 X
                                                                   OFF-GAS TREATMENT SYSTEM
TO ATMOSPHERE
Figure 4-3. Geosafe In Situ Vitrification Process
                                                 60

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conductive; thus, the molten mass becomes the primary  conductor and heat transfer medium. As a result
of the joule heating, the inherent viscosity is lowered to  approximately 100 poise. At this point,  the melt
begins to grow within the soil matrix, extending radially and downward. Power is maintained  at levels
sufficient to overcome heat losses from the surface and to the  surrounding soil. Heating of the melt is
aided by convection currents within the melt. Heat is transferred to the adjacent soil by conduction from
the melt.

Electric power is supplied to the array of electrodes  through flexible conductors. The ISV hood is
equipped with an  electrode feed system that gravity feeds the electrodes downward as the melt progresses.
Initially, the electrodes are inserted approximately one  to two  feet below grade. As the melt  becomes
established and is no longer subject to any failure in  its conduction of the applied current,  the four
electrodes are released and allowed to descend into the lithological matrix according to their respective
individual weights. Ideally,  this will  proceed  until the  targeted contaminants are completely enveloped
in the melt and the desired treatment  depth is  attained. Graphite extensions are added to the top of each
electrode according to the intended depth  penetration  of the melt. If processing difficulties  are
encountered, the  electrode feed system  may  "grasp" the electrodes  and thus  prevent their downward
movement  until the difficulty is addressed.

The process can remediate contaminated soil at a rate of four to six tons per hour until a maximum mass
of 800 to 1,200 tons has been treated. The downward growth rate of the melt is  in the range of one to
two inches per hour. Because soil typically has  low thermal conductivity, a very steep thermal gradient
of 300  to 480°F  (150 to 250°C) per inch precedes the advancing melt front. This produces  a 212°F
(100'C) isotherm  less than  one foot  away from the molten mass. The soil  volume between the 212°F
isotherm and the  melt is termed the "dry zone." This zone has maximum vapor permeability because  it
exists without the  presence of liquid  water.

As the melt grows, the electrical resistance of the melt  decreases. The ratio between the voltage and the
current must, therefore, be adjusted  periodically to maintain  operation at  an  acceptable  power level.
Generally, the melt grows outward to  a width approximately 50 percent wider than the electrodes  spacing.
The molten zone  is roughly a  cube  with slightly rounded comers  on the bottom  and sides; this shape
reflects the higher power density around the electrodes. Figure 4-4 presents  typical process conditions.
                                                61

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 During processing, ISV removes the void volume present in particulate materials resulting in a volume

 reduction. Further volume reduction also occurs, since some of the material present in the soil such as

 humus and organic contaminants are removed as gases and vapors  during processing. The overall volume

 reduction (typically 20 to 50 percent), creates a subsidence volume above the melt (see Figure 4-4).



 At appropriate temperature regimes within the soil  surrounding the melt, or within the melt itself, the

 solids and contaminants  undergo changes of physical state  .and decomposition reactions. The  possible

 dispositions of contaminants  resulting from ISV  processing  include:
     Off-Gas Collection Hood
      (-0,5 to 1,0 in Water)
     Controlled Air
      input
                                           Off-Gases to
                                            Treatment
                       Electrode (typ)
                      ' - 3-4 MW power level
                       - 0,3 to 0.4 kwh/Ib treated
  Angle of Repose
  Unaffected Soil
  (minimum
  permeability)
   Conductive Heating
   {matt advance rate
   of 1 to 2 in/hr)
                                                                                        212 F Isotherm
                                         Melt Surface
                                                                                   Dry Zone
                                                                                   • thermal gradient of
                                                                                    30Gto4SS F/tn
                                                                                   - maximum permeability
Molten Soil Region
- joule heating between electrodes
-2,900-3,6ofi F
- melt rate 4-6 tons/hr
- molten oxides and contaminants
- chemically reducing environment
• convection currents
Figure 4-4. Typical ISV Process Conditions  for the Geosafe Technology
                                                 62

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       •      chemical  and thermal destruction;
       •      removal from the treatment volume to the off-gas treatment system;
       •      chemical  and physical incorporation within the residual product;
       •      lateral migration ahead of the advancing melt; and
       •      escape  to the environment.

As the thermal gradient advances on solid or liquid organic materials, these materials are either drawn
into the melt or laterally migrate into the dry  zone where the are vaporized and ultimately pyrolyzed.
Only a small fraction of vapor passes through the melt itself. The predominant pathway for vapor
movement from the treatment zone is through the dry zone  adjacent to the melt. Because of gas-phase
permeability differences, the dry zone is the path of least resistance and the adjacent wet soil acts as a
barrier to  outward movement of vapors.  Organic pyrolysis products are typically gaseous; because of the
high viscosity of the molten material,  these gases move slowly through the melt, usually on a path
adjacent to the electrodes, toward the upper melt  surface. While some of these gases  may dissolve into
the molten mass, the remainder move to the surface where those that are combustible react in the
presence of air. Pyrolysis  and combustion products are  collected  in an off-gas collection hood and are
subsequently treated in the off-gas treatment system. Because of the  high temperature of the melt, no
residual organic contaminants are expected to remain in their  original compound form within the  vitrified
product

The behavior of inorganic materials  upon exposure to the advancing thermal gradient is  similar to that
of the organics.  Inorganic compounds may thermally decompose or otherwise enter into  reactions with
the melt. Typically,  the  metals originally  present are  incorporated into the vitrified residual.
Immobilization  may occur when the contaminants  are incorporated  into the glass  network or encapsulated
(surrounded) by the glass. If large amounts of non-volatile metals are present, they may sink to the
bottom of the melt  and concentrate there.

During treatment, a "cold cap" forms  over the surface of the melt. This cold cap, a surface layer of
viscous molten material at the air/melt interface, helps to contain  radiative heat loss.  The cold cap also
performs  the  important function of holding volatilized wastes for possible re-incorporation  into the melt.
The cold  cap is penetrated by the electrodes  which, themselves, are usually hot enough to maintain fluid
                                               63

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behavior in directly adjacent areas.  These highly fluid surface areas  are common vent locations for release
of vapors and gases from the melt.

Once a melt is established, the process may be restarted after a power shutdown or loss, as long as a
molten path remains between the  electrodes. If this is not the case, it will be necessary to lay a new
starter path  of graphite and glass  frit between the  electrodes. The amount of time allowed for restart
depends on the size of the melt. A large melt (e.g., 500 tons) could allow restart even after several days.
Shutdowns during the  first 48 hours of treatment are more difficult to restart and more sensitive to the
length of the outage.

The processing area is  covered by  an octagonal off-gas collection hood with a maximum width between
the flat edges of 60 feet. Footers,  which support the hood, extend  five feet past the maximum width of
the hood.  The large distance between the edge of the hood and the edge of the  melt is designed to enable
off-gas  containment, even under  worst-case subsidence conditions. Flow of air through the  hood  is
controlled to maintain  a vacuum of 0.5 to 1 inches of water on the system. The vacuum prevents the
escape of fugitive emissions from the hood and ground surface interface.  Air provides oxygen for
combustion  of pyrolysis products  and  organic vapors. The off-gases, pyrolysis products,  and air are
drawn from  the hood by an induced  draft blower into the off-gas treatment system. The off-gas is treated
by quenching, pH-controlled  scrubbing, mist  elimination, particulate  filtration, and  activated carbon
adsorption. A thermal  oxidizer was added to the gas treatment train midway through the remediation at
the Parsons  site to complete combustion of organic compounds from the melt and help reduce odors.  A
backup gas treatment system is also present and is designed to be activated automatically in  case of power
interruption.  The backup system employs  a diesel-powered generator, blower,  mist cooler, filter,  and
activated carbon column.

Once power to the electrodes is shut off, the melt begins to cool.  In most cases, no attempts are made
to force cooling of the melt;  slow cooling  is expected to produce a  vitreous (amorphous) and micro-
crystalline structure. Removal  of the hood is normally accomplished within 24 hours after power to the
electrodes is discontinued.  The used graphite electrodes are severed near the melt  surface  and are left
within the treated monolith. After the off-gas hood is removed and the electrodes are severed, the
subsidence volume is filled to  the  desired depth with clean backfill. When melt locations are contiguous,
a single large monolith will ultimately be produced. In  instances where removal of the vitrified mass is

                                               64

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anticipated, the treated area may be left uncovered to speed the cooling process and induce shrink-
cracking of the surface.  This aids the fracturing of the mass prior its removal.

4.5     Testing Methodology

The  EPA Risk Reduction Engineering Laboratory (EPA-RREL) chose the  former operational  site of
Parsons Chemical Works, Inc. (the Parsons  site) in Grand Ledge,  Michigan for the evaluation  of the
Geosafe ISV process as part of the SITE  Program. The site was known to be contaminated with low
levels of pesticides and metals  and  was the first full-scale implementation of the ISV technology to treat
hazardous wastes. Region V of the EPA had also selected the Geosafe technology as part of a removal
action for the Parsons site. The SITE Program, under the direction of EPA-RREL, used this opportunity
to gain  additional valuable information regarding the ISV technology. The SITE Demonstration and the
Region  V cleanup operations were implemented in conjunction with one another during  treatment. The
sampling analysis and process  monitoring  performed as part of the SITE Demonstration  were designed
to supplement those already planned and performed by Region V. For informational purposes,  some data
from EPA Region V is presented in this  report; these data were not used to evaluate the SITE
Demonstration  objectives

Under the SITE Program, the goal  of this  Demonstration was to determine the effectiveness of treatment
and to evaluate the technology from an economic and performance standpoint. The developer of this
technology (Geosafe)  claimed  that the ISV  system could obtain a destruction and removal efficiency
(DRE) of 99.99% for organic compounds  within the soil and  can incorporate inorganic compounds and
metals within the residual vitrified product. Pre-treatment chemical concentrations were too low  to
evaluate this claim appropriately.  Instead, the objectives  presented in the  following  paragraphs  were
established.

The  primary objective of the Demonstration was to determine whether EPA Region V cleanup criteria
could be met. The Demonstration of the ISV technology was designed to allow evaluation of the ability
of the technology to meet regulatory criteria for the major pesticides present and mercury. In addition,
the leaching characteristics of the untreated and the treated waste were evaluated.
                                               65

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Critical objectives are those objectives which are important to developer's  claims and those which can

be evaluated at this site. Secondary (or non-critical) objectives are those which are  of interest to future

applications  of ISV technology but do not relate directly to the  developer's claims. Other objectives, such

as DRE, are not considered here but are expected to be included at future sites where levels of

contamination are higher. The Demonstration objectives  as specified in the QAPP were:


Critical Objective:
        •      To determine if final soil cleanup levels set by the EPA Region V were achieved. These
               specified cleanup levels were 1,000 peg/kg for chlordane, 4,000 ^g/kg for 4,4'-DDT, 80
               jig/kg for dieldrin,  and 12,000 /ig/kg for mercury.


Secondary  Objectives:
        •      To evaluate the teachability characteristics of chlordane, 4,4'-DDT,  dieldrin, and mercury
               in the test soil using the TCLP and determine whether the teachability characteristics  of
               these compounds in the vitrified residue met the regulatory  limits  specified in 40 CFR
               $261.24. (Note: Only  mercury and  chlordane are listed in 40 CFR $261.24.)

        •      To determine the approximate levels of dioxins/furans,  pesticides (specifically chlordane,
               4,4'-DDT,  and dieldrin), mercury, and moisture in the test  soil.

        •      To characterize the liquid residues (scrubber water) of the process with respect  to
               pesticide and  mercury  concentrations.

        •      To evaluate emissions from the process

        •      To identify the operational parameters of the technology

        •      To develop operating costs and assess the reliability of the equipment

        •      To examine potential  impediments  to  the  use of this technology including technical,
               institutional, operational,  and safety  impediments.


A Demonstration  Plan  and Quality Assurance Project Plan  (QAPP) were prepared to specify technical

project objectives to be  used in evaluating the Geosafe ISV technology at the  Parsons site under the SITE

Program.  The QAPP specified the procedures for sampling  and analysis to  evaluate project objectives.

The sampling plan required test  soil  sampling before and  after treatment,  scrubber water sampling before

and after  treatment,  and gas sampling of the emissions to the atmosphere during treatment.
                                                66

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To  evaluate the critical objective for this project,  the treated soil samples analyses for pesticides and
mercury were designated as critical analyses. Other non-critical measurements were performed to
characterize the process. The following sections present  a discussion of the data collected in support of
this evaluation.

Soil placed into the treatment  cells  was sampled by EPA Region V while the cells were being filled.
These samples were composites collected from random locations throughout the cells. Based upon Region
V data, Cell 8  contained the highest levels of organic and  inorganic contaminants, therefore this cell was
selected for evaluation by the SITE Program. In May 1993, five  additional grab samples were collected
by EPA Region V, three of which were analyzed by the SITE Program for pesticides and mercury.  The
TCLP was also performed on these samples, and the leachate was analyzed for pesticides and mercury.
These samples were  intended  to provide  information for use in development of SITE Demonstration
objectives. The results are presented in Table 4-1.  The data suggest that the staged soil is not very
homogeneous before  treatment, exhibiting  wide variations in contamination  levels.

Based upon these results, it was noted that the contaminant levels  were not high enough to warrant a full
statistical-based  sampling strategy to determine the average soil concentration of target  contaminants for
use in DRE, mass balance,  or percent removal  calculations.  Therefore, the SITE Program elected to
collect a limited number of soil samples (three plus one field duplicate) from the test cell to evaluate pre-
treatment soil  conditions. Pre-treatment soil conditions were not as significant as post-treatment  soil
conditions  since determination of DRE was not  an objective, so the heterogeneity  of the pre-treatment
soil was not a concern.

Composite samples of the soil in Cell 8, the cell treated during  the Demonstration,  were collected and
analyzed before treatment was initiated on this cell at a time when sampling did not interfere  with Region
V activities in  adjacent cells. A drill rig equipped with a 2-inch  diameter split spoon sampler was used
to collect sample  cores from three separate boreholes at three locations within the cell. An additional
borehole  was drilled to obtain the field duplicate samples. This boring was located as close as possible
to the primary boring. All samples were collected from depths between 4 and  15 feet  below land  surface.
The soil recovered from all split spoons of a particular  boring were composited together and aliquoted
for  the selected analyses.  Samples from the cell were analyzed for pesticides (chlordane, 4,4'-DDT,  and
dieldrin),  dioxins/furans, mercury, glass formers (alumina and silica), and conductive cations (lithium,

                                                67

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Table 4-1. Results  of Analysis of Pre-Treatment Screening Samples Collected from Cell 8
Analytical Parameter
Sample
Composite*
1'
3f
5'
TCLP 1*
TCLP 2f
TCLP 3f
Units
Mg/kg
Mg/kg
Mg/kg
Mg/kg
Mg/L
/tg/L
Mg/L
4,4' -DDT
72,000 J
1,100
4,800
830
0.11
1.2
< 0.087
Dieldrin
12,000 J
2,600
2,800
180
4.4
6.3
1.5
Chlordane
2,000 J
<8.0
<8.0
<8.0
<0.26
<0.26
<0.26
Mercury
12,000
3,900
15,000
1,400
< 0.00048
O.00048
< 0.00048
        Random composite collected during filling of the cell. Sample collected in February 1991 by
        Ecology and  Environment.
        Samples collected in May 1993 for SAIC by EPA Region V representatives. Five samples were
        collected, but only three were analyzed.
        Value reported is  less than  the reporting  detection limit but greater than the method detection
        limit. Value is an estimate.
        Compound not detected at or above presented value (detection limit).
potassium, sodium). Samples were also subject to the  TCLP for the target pesticides and mercury. During
sampling, the geological characteristics of the borings were recorded. The physical parameters of grain
size and permeability  were determined.  To  evaluate the volume reduction  from treatment, moisture
content and test soil density (on a dry basis) were  measured using a drive cylinder method. In this
procedure, the sample is obtained in situ by driving a cylinder of known volume into the sample matrix.
The cylinder is weighed to determine density and then analyzed for moisture content. Using this
information, dry density can be calculated.
                                               68

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During treatment of Cell 8, the process was visually observed and monitoring of the system was
conducted. Data were recorded at regular intervals.  Stack sampling was conducted as specified in the
QAPP.

Gaseous emissions from the stack downstream of the gas treatment equipment were evaluated using both
sample collection  and continuous emission monitoring techniques. Stack gas  samples were  collected using
Summa canisters for volatile organic compounds, and  sampling trains for semivolatile organics,
pesticides, dioxins/furans, metals, hydrogen chloride, and particulate matter. Continuous emission
monitoring for oxygen, carbon monoxide, and total hydrocarbons was conducted using the on-line
equipment utilized by Geosafe  to comply with operating permits. The  original intent of the stack gas
sampling was to provide an indication of the composition  of the gases emitted to the atmosphere. All of
the stack gas measurements were designated as non-critical. During the first few treatment settings at the
Parsons site, an offensive odor was emitted from the process. To remedy this, Geosafe modified the off-
gas treatment  train to  include  a thermal  oxidizer, thereby oxidizing the  odorous compounds. Local
regulatory agencies also closely  monitored  process emissions and specified emission criteria. As a result
of these developments, the stack gas  sampling objectives for the SITE Demonstration were modified to
evaluate if the process could  operate within regulatory  guidelines. The  emissions of  pesticides  and
mercury, along with arsenic, chromium, lead, carbon monoxide, and total hydrocarbons, were designated
critical measurements. Samples of the  gases emitted to atmosphere were collected after exiting  the thermal
oxidizer

After treatment  of Cell 8 was complete, the off-gas  treatment  system was allowed to run for
approximately  24 hours to remove any fugitive emissions from the melt. After this 24-hour period, the
containment hood was  moved and the ambient air was monitored with an organic vapor  analyzer and a
mercury analyzer. When airborne contaminant levels were determined to be safe,  samples of the treated
material were collected  from just below the surface of  the  melt. These samples were intended to provide
immediate information regarding the  effectiveness of the  ISV  treatment.

The surface material sampled  was part of the "cold cap" and was already solidified by the time the
treatment hood was moved. Samples  were collected by a member of the developer's staff who, wearing
heat-insulating  boots and other appropriate personal protective equipment,  stood upon the  subsided surface
of the melt. The sampler was supported by a lifeline held by  personnel outside the melt area Samples

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of the surface material were then obtained using a decontaminated hammer to chip pieces from the cold
cap. After collection, the samples  were placed in a cotton cloth and further crushed using the
decontaminated hammer. The sample pieces were thoroughly homogenized  and aliquoted into sample
containers for analysis. These post-treatment surface samples were  analyzed for pesticides (chlordane,
4,4'-DDT, and dieldrin), dioxins/furans, and metals. They were also subject  to the TCLP for the target
pesticides and metals. In  addition, density measurements were performed on the treated material.
Admittedly, these surface samples are not representative of the entire melt, but they do provide immediate
information  about the treated surface material.

Additional samples of the  post-treatment soil will be collected  from the core of the vitrified mass after
it has completely  cooled and solidified.  The number of samples collected will exceed then number of
samples required to ensure statistical  credibility. These samples may be collected up  to two years  after
the completion of treatment. It is anticipated that these samples will be collected from the center of the
treatment area using a rotary drill  rig equipped with a diamond-tipped drill bit or another  appropriate
method. The samples will again  be analyzed for pesticides (chlordane, 4,4'-DDT,  and dieldrin),
dioxins/furans,  and metals  and subjected  to the TCLP for target pesticides and metals. The density of
these samples will also be measured. The data will be reviewed by a statistician as required. If the
samples display significant  variability or the  levels are higher than the cleanup objectives,  then additional
samples will be analyzed. Future samples are anticipated to confirm  the results obtained from  the surface
samples. The results from these  sample analyses will be published as an Addendum to this report.

To  account for contaminants removed  by the scrubber, grab samples of the  scrubber water were  collected
before, during, and after treatment of Cell 8. Two samples (primary  and field duplicate) of water charged
to the scrubber were collected before treatment of Cell 8 (but after treatment of the preceding cells) to
provide baseline data regarding the type  and quantity of contaminants present. The scrubber liquor was
also sampled to evaluate the amount  and types of material  accumulating during treatment. Two sets of
samples were  collected  after treatment commenced-one (primary and field  duplicate) during a discharge
sequence, and one at the end of the test. Since the scrubber liquor waste stream may require secondary
disposal, samples were collected to characterize this liquid and to gain information on the type of material
being treated by the off-gas treatment system. All scrubber samples were analyzed for volatile organics,
semivolatile organics,  target pesticides,  dioxins/furans,  and total metals including mercury and arsenic.
These sample analyses were not considered critical objectives for the Demonstration.

                                               70

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4.6    Performance Data

Table 4-2 presents the post-treatment  soil sample results  for target pesticides, mercury, and target TCLP
analytes  in comparison to regulatory limits. The table  also presents  summary stack emission data in
comparison with the ARARs in place  at the time of the Demonstration. Standard deviations are not
presented in this table since only a limited number of samples were collected. The summary clearly
indicates  that Region V cleanup  objectives for the target  contaminants were achieved.  It should be noted
that  some ARARs were achieved prior to treatment, without implementation of the technology. Both
chlordane and mercury were below the specified cleanup objectives  before treatment even began. As
shown in the table, the TCLP results were well within the regulatory  limits. Stack emissions were also
below the ARARs.  The technology was not rigorously challenged by the low levels  of contaminants at
this  site,  and therefore, the ability of the technology to  remediate highly contaminated soil has not yet
been demonstrated. Detailed discussions regarding the analytical data  in this table are presented in the
following sections.

4.6.1 Test  Soil

The  test  soil was subjected to the chemical and physical  analyses  specified in the QAPP both before and
after treatment. A discussion of the results of these analyses is presented below.

4.6.1.1         Pre-Treatment Test Soil Chemical Characteristics

The  results of chemical analyses of the  soil  are presented in Tables 4-3 through 4-6. Standard deviations
are not presented because only a limited number  of samples were collected.  The pesticide target  analytes
were detected in the pre-treatment samples at the average levels shown in Table 4-3.  Chlordane was
below the EPA  Region V cleanup  criteria of 1,000  /ig/kg and was not detected in any of the samples.
4,4'-DDT averaged  13,000  tig/kg, with a range of 2,400 to 23,000 iig/kg. Dieldrm ranged from 1,200
to 8,300  ^g/kg and averaged 4,600 /xg/kg. Levels of mercury in the test soil were below the Region V
cleanup  criteria  of 12,000 /xg/kg, ranging from 2,200 to 4,700 fig/kg  and averaging 3,800 tig/kg.

The  pre-treatment soil was also evaluated for the presence  of dioxins and furans since these compounds
had  been detected in low levels  by EPA Region V at various locations of the Parsons site. The results

                                                71

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Table 4-2. Performance Data During Demonstration Versus ARARs
Analyte
Treated Soil
Chlordane
4,4-DDT
Dieldrin
Mercury
Treated Soil TCLP
Chlordane
Mercury
Arsenic
Barium
Cadmium
Chromium
Lead
Selenium
Silver
Stack Emissions
A r*\pn if*
/** tSv'iliV*
r*"* H r A rn t n rn
v*4.u v/nni4iii
Lead
Mercury
Carbon Monoxide
Total Hydrocarbons
Units

Mg/kg
Mg/kg
fig/kg
Mg/kg

Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L

Ih/hr
I \J 1 i 1 1
Ih/hr
i,U/ lii
Ib/hr
Ib/hr
ppmv
ppmv
Test Result (Average)

< 80
< 16
< 16
110

< 0.50
0.18
13
440
< 5,0
< 10
1,100
< 300
< 10

< I OF-Ofi
^"> i r •"' *~rf \J\J
? 1 p.o^
i_. » 1 1^ \,/^
2.8E-05
1.1E-04
< 10
< 10
Regulatory Limit

1,000 *
4,000 *
80 *
12,000

30 **
200 **
5,000 **
100,000 **
1,000 **
5,000 **
5,000 **
1,000 **
5,000 **

.:.

	 f
5.9E-04 ?
150 i
100
       Cleanup level specified by EPA Region V,
       40CFR §261.24,
       No regulatory limits specified.
       Emission level specified by Michigan Department of Natural Resources.
                                            72

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Table 4-3. Geosafe Test Soil Pesticides and Metals Data Summary*
Analyte
Pesticides +
Chlordane
4,4'-DDT
Dieldrin
Metals ++
Aluminum
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel,
Potassium
Sodium
Vanadium
Zinc
Physical Parameters -H-
Density (wet basis)
Density (dry basis)
Pre-Treatment
(us/kg)
< 80
13,000
4,600
(M8/kg)
3.1E+07
9.0E+03
3.1E+05
2.6E+07
4.1E+04
l.OE+04
7.1E+03
2.4E+07
5.0E+04
8.7E+06
6.7E+05
3.8E+03
3.4E+04
1.3E+07
6.2E+06
5.6E+04
5.6E+04
(ton/yd5)
1.8
1.5
Post-Treatment
(jag/kg)
< 80
< 16
< 16
(Hg/kg)
3.1E+05
3.1E+03
3.6E+03
l.OE+06
1.3E+04
1.9E+03
7.1E+03
2.6E+06
8.6E+03
3.2E+05
1.1E+04
3.3E+01
1.1E+04
1.1E+05
1.2E+05
1.9E+03
4.5E+04
(ton/yd3)
NA
2,0
Post-Treatment
(Hg/kg)
NA
NA
NA
(^g)
3.0E+07
6.4E+03
2.8E+05
4.8E+07
5.0E+04
5.5E+03
1.4E+04
1.6E+07
2.5E+04
1.5E+07
3.4E+05
1.1E+02
1.6E+04
1.1E+07
6.7E+06
4.3E+04
9.2E+04
(toii/yd3)
NA
NA
* - Complete data are presented in the Technology Evaluation Report,
1 - Digestion of metals by SW-846 Method 3050 and mercury- by SW-846 Method 7471,
b - Digestion by HF acid total dissolution.
+ - Data reported are average values from three primary and one duplicate sample collected.
++ - Pro-treatment data reported are average values from three primary samples collected.
     Post-treatment data reported are average values from three primary and one duplicate sample collected,
< - Analyte not detected at or above presented value (detection  limit),
NA - Sample not analyzed for this parameter.
                                                   73

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Table 4-4. Geosafe Test Soil Dioxins/Furans Data Summary*
Anal yte
2,3,7,8-TCDF
Total TCDF
2,3,7,8-TCDD
Total TCDD
l,2,3,7s8-PeCDF
2,3,4758-PeCDF
Total PeCDF
1,23,78-PeCDD
Total PeCDD
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8 HxCDF
2,3,4,6,7,8-HxCDF
l,2,3,7,8,9_HxCDF
Total HxCDF
1,2,3,4,7,8-HxCDD
l,2,3,6,7,8_HxCDD
1,2,3,7,8,9-HxCDD
Total HxCDD
l,2,3,4,6,7,8_HpCDF
l,2,3,4,7,8,9_HpCDF
Total HpCDF
1,2,3,4,6,7,8 HpCDD
Total HpCDD
OCDF
OCDD
2,3,7,8-TCDD Equivalence
Pre-Treatment * *
(ng/kg)
< 0.88
17
6.4
9.2
< 1.7
4.5
52
1.4
7.4
< 6.2
< 5.4
3.6
0.78
53
1.5
6.3
3.2
56
32
< 2.5
130
240
430
200
2,900
17
Post-Treatment **
(ng/kg)
< 0.49
< 0.49
< 0.47
0.011
< 0.51
< 0.31
< 0.51
< 0.34
< 0.34
< 0.51
< 0.43
0.40
< 0.49
0.20
< 0.49
< 0.63
< 1.0
0.0067
< 0.60
< 0.55
0.08
0.78
0.80
< 0.77
4.3
0.034
* - Complete data are presented in the Technology Evaluation Report.
** - Data reported are average results from one primary and one duplicate sample collected.
< - Analyte not detected  at or above presented value (detection limit).
                                               74

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Table 4-5,  Geosafe Soil TCLP Pesticides and Metals Data Summary*
Pre-Treatment
Analyte
Pesticides
Chlordane
4,4'-DDT
Dieldrin
Metals
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Sample 1
(Hg/L)

< 0,50
0,17
8,2

NA
NA
NA
NA
NA
0.050
NA
NA
Sample 2
Oig/L)

< 0.50
< 0.10
8.9

NA
NA
NA
NA
NA
0,035
NA
NA
Sample 3
(Mg/L)

< 0.50
< 0.10
6.5

NA
NA
NA
NA
NA
0.010
NA
NA
Sample i
(ug/L)

< 0.50
< 0.10
< 0.10

< 4,0
330
< 5,0
11
< 50
0.20
< 300
< 10
Post-Treatment
Sample 2
(Hg/L)

< 0.50
< 0.10
< 0.10

13
540
2.9
< 10
4,300
0.23
< 300
< 10
Sample 3
(ng/L)

< 0.50
< 0.10
< 0.10

31
550
4.1
5.8
15
0.090
< 300
< 10
* - Complete data are presented in the Technology Evaluation Report.
NA - Sample not analyzed for this compound.
< -  Analyte concentration is less than or equal to presented value (detection limit).
in Table 4-4  indicate that  dioxin/furan contamination was  extremely low  with a  2,3,7,8-TCDD
equivalency, averaging 17 ng/kg with a range between. 14 and 19 ng/kg.
The pre-treatment soil samples were subjected to the toxicity characteristic leaching procedure to evaluate
the teachability of the  critical target anaiytes before treatment (see Table 4-5),  Only chlordane and
mercury are listed, in 40 CFR §261,24 where TCLP limitations are specified. Chlordane was not detected
in any of the TCLP samples, and mercury was well below regulatory limits. However, low levels of 4,4'-
DDT were detected between less than 0.10 and 0.17 jig/L, and dieldrin was detected between 6,5 and.
8.9

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Table 4-6. Geosafe  Pre-Treatment Test Soil Conductive Cations and Ultimate Analysis Data*
 Analysis	Result	units	

 Conductive Cations* *
 Aluminum                                            33,000                 mg/kg
 Lithium                                                   18                 mgfkg
 Potassium                                             12,000                 mgn
-------
Table 4-6. Geosafe  Pre-Treatment Test Soil Conductive Cations and Ultimate Analysis Data*

 Analysis	Result	units	

 Conductive  Cations**
 Aluminum                                             33,000                 mg/kg
 Lithium                                                   18                 mg/kg
 Potassium                                             12,000                 mg/kg
 Silicon                                               280,000                 mg/kg
 Sodium                                                6,600                 mg/kg

 Ultimate Analysis* * *
 Carbon                                                     1.3                 %
 Nitrogen                                                    0.23                %
 Oxygen                                                     7.0                 %
 Sulfur                                                      0.010               %

 • - Complete data are presented in the Technology Evaluation Report.
 • * - Data reported arc average values from one primary and one duplicate sample collected.
 • ** - Data reported are average values From three primary samples collected.

An important consideration when using the in situ vitrification technology  is the  confirmation  of sufficient
amounts of conductive cations and glass-forming metal  oxides in the test soil to allow soil melting and
subsequent formation  of a stable monolith. For the SITE Demonstration,  inductively coupled plasma
(TCP) analyses using standard SW-846 procedures were conducted on the pre-treatment test soil to
evaluate these  parameters. The results  are  summarized  in  Table 4-6.  Geosafe typically uses  an X-ray
diffraction technique rather than ICP analyses to evaluate these parameters before treatment. Before the
onset of remediation at Parsons site, Geosafe independently determined that the concentrations of these
materials were  high enough to allow the Parsons soil to  be  vitrified without  supplemental oxide addition.

During the processing of the test cells prior to the cell  selected for the  Demonstration,  odor  problems
were observed.  Because of the odor, Region V and Geosafe  investigated potential sources of the problem.
Geosafe  suspected sulfur as the culprit since site records  indicated that  sulfur was previously used  at the
Parsons site, and low concentrations of sulfur-based  compounds in the  exhaust gas  are often very
odorous. The SITE Program analyzed some of the pre-treatment samples  using an ultimate  elemental
analysis  technique to evaluate the sulfur content of the soil. These analyses  were not originally planned
                                                76

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as part of the Demonstration. As noted in Table 4-6, some sulfur was present in the pre-treatment soil,
but at very low levels. To solve the odor problem, Geosafe added a thermal oxidizer to the end of the
off-gas treatment train to polish and completely  combust partially  oxidized melt gases. The thermal
oxidizer  was effective in removing melt odors. The  ultimate source of the  odor was never positively
identified.

Additional  studies were  conducted on the pre-treatment test  soil after learning  that arsenic, lead, and
chromium were being detected  in stack gas  samples  collected by EPA  Region V and in HEPA filter
samples.  The SITE Program elected to  make these metals critical  analytes in the stack gas samples since
their emission to the atmosphere may be a human health risk. Because of this decision, samples  of the
pre-treatment test soil were analyzed to evaluate metal content  within the  soil. The soil was analyzed for
standard  ICP metals and arsenic (using a graphite furnace method). The results of these analyses are
presented in Table 4-3.

4.6.1.2        Post-Treatment Test Soil  Chemical  Characteristics

In the laboratory, all vitrified soil samples were ground  into a fine powder before digestion and/or
teachability  testing was  performed.  The  samples were ground  in  a comminution device specifically
designed to prepare  laboratory  samples by minimizing heat  effects (friction of grinding) and sample
contamination. The laboratory was instructed to grind  portions of the treated soil that were most
representative of the center of the treated  area, not the  cold cap.  The cold cap was easily distinguished
by the  amount  of entrained bubbles in  the vitrified sample.  Solid  (bubble-free) portions of the melt were
selected  for analyses since they probably best represent the final  product.

Samples  of the  ground vitrified  material were  extracted and  analyzed for pesticides using SW-846 Method
8080. The results of  these analyses are  summarized in Table 4-3. The results indicate that the technology
met the removal criteria for the  organic contaminants of interest. As noted  by the data, all pesticides were
below their  detection limits in  each of the samples. Table  4-3 shows that 4,4'-DDT  was reduced from
an average concentration of 13,000 /ig/kg to less than 16 /ig/kg. Dieldrin was reduced from 4,600 uglkg
to less  than  16  /tg/kg. Since chlordane  was not detected in  any of the pre-treatment samples, the  ability
of the technology to  treat this compound cannot be evaluated  as part of this Demonstration.
                                               77

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Metal analyses were performed using two different digestion procedures—SW-&46 Method 3050 (7471
for mercury) and a microwave procedure using a mixture of hydrofluoric, nitric, and hydrochloric acids
to obtain total dissolution of the sample. The data for both of these analyses are summarized in Table 4-3.
As noted in the table, the metal,concentrations detected by the microwave digestion procedure are much
greater than those found in the standard procedure since the microwave digestion with hydrofluoric acid
is more agpessive and provides a better dissolution of the vitrified soil. Comparison between the two
samples is assumed to be valid because aliquots from the  same sample were used for both analyses. The
only metal which does not appear  to  have been recovered at higher concentrations in the microwave
procedure was lead.  Lead recoveries  may have been impacted by sample detection limits. The data
suggest that most of the metals are retained within the vitrified solid after treatment. However, due to
the limited data set,  it is difficult to accurately draw this conclusion pertaining to any specific mete!
because of sample and analytical variability. Metals were not the primary focus of this Demonstration.

Mercury concentrations that were determined using the microwave-digested samples may not be accurate.
During the QA review of these data, it was noted that some signal enhancement or depression may  have-
occurred.  A National Institute of Standards and Technology (NIST) fly ash sample was analyzed with
routine samples. This sample exhibited high recovery and matrix spike samples were biased low using
the microwave procedure. Therefore, mercury concentrations obtained using standard SW-846 digestion
and analytical procedures may provide a better indication of mercury concentrations since all associated
quality control data was acceptable. The data  from either procedure, however, clearly indicate that the
regulatory limits for mercury levels  in soil were easily achieved. Other metal concentrations closely match
the pre-treatment  soil samples (hydrofluoric acid digestion method) with the exception of mercury and
perhaps arsenic (see Table 4-3). This is not surprising given the  relative volatility of these metals at high
temperatures. It was not possible to thoroughly evaluate the ability of the process  to retain other metals
due to the limited number of samples  collected. • •

Some of the  ground vitrified samples were subjected to the TCLP to evaluate the teachability of the
critical analytes after treatment. TCLP results  are presented in Table 4-5 (target pesticides and regulated
metals only). As noted by the results, all samples were below the regulatory criteria for the      metals
and chlordane, however, no firm conclusion can be stated regarding chlordane since this compound was
below its detection limit before treatment. Leachable levels of the pesticides dieldrin and 4,4*-DDT were
reduced to non-detectable levels in the leachate. One of the three samples contained leachable levels of

                                              ft

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lead at 4,300 ^g/L which is close to the regulatory limit of 5,000 /ig/L. The reason for this single data
outlier is not clear, especially since lead was not present at high levels in the test soil and was 50  jig/L
or less in the other two samples. The TCLP was not performed for regulated metals other than mercury
during the pre-treatment sampling event. Therefore, no  conclusive statements can be made regarding the
technology's impact on teachability characteristics of these  metals  (pre- and post-treatment comparison).

Dioxin/furan  samples of the treated material collected suggest that  these  compounds were reduced to
levels much lower than those found in the samples of the soil before treatment. This evaluation can be
made by comparing the 2,3,7,8-TCDD  equivalence calculations on pre-  and  post-treatment soil (see Table
4-4). The data table indicates that 2,3,7,8-TCDD equivalences were reduced from an average of 17 ng/kg
to 0.034 ng/kg. The decrease of the equivalences appears to be real since the concentrations of the
individual isomers seem to have been reduced.

4.6.1.3        Pre-Treatment Test Soil Physical Characteristics

Physical properties of the test soil were investigated as part of the Demonstration. The soil was  a sandy
clay-like material containing approximately 45 % of material with a grain size greater than 0.1 mm.  The
remainder of the test soil consisted of some finer grain sands.  The detailed results of the grain size
measurements and the  geological  information gathered  during sampling are  found in an  appendix of the
accompanying Technology Evaluation Report. Table 4-3 presents the results of the soil density
measurements on both a  wet and a dry basis.  It should be noted that the pre-treatment samples were
collected in July 1993 and the Demonstration did not commence until late March 1994. It is unlikely that
the percent moisture values (used to determine soil density on a dry basis) obtained from the  pre-
demonstration samples are identical to the actual moisture  content of the soil at the time of treatment.
However, sampling logistics required pre-treatment samples  to be collected well in advance of treatment,
while the test cell was not covered by the hood and before directly adjacent cells were  treated.

4.6.1.4        Post-Treatment Test Soil Physical Characteristics

Samples of the post-treatment soil were also collected to  evaluate the density of the treated material.
These data, along with pre-treatment dry  density information were used to  evaluate the volume reduction
upon treatment  (Table 4-3). Dry density was  used in these calculations in order to compare pre- and

                                               79

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treatment data. It was assumed that sample moisture was contained in the porosity of the soil and, upon
driving the moisture off during treatment, no appreciable volume reduction would occur. The result of
this evaluation indicated that,  on a dry basis, a volume reduction of approximately 30% occurred as a
result of treatment. Vendor claims  for volume reduction  as a result of treatment are calculated somewhat
differently; the vendor should be contacted if additional information regarding this claim is desired.

4.6.2 Scrubber  Liquor

At the time  of the SITE Demonstration,  Geosafe had completed five melt settings.  Before the start of the
SITE Demonstration (treatment of Cell 8), the off-gas treatment system was prepared with fresh  HEPA
filters and  activated carbon.  The  scrubber system was  also drained, cleaned, and charged with fresh
water. The results of analysis  of the scrubber water samples for organics, metals, and dioxins/furans are
presented in Tables 4-7, 4-8,  and  4-9, respectively.

4.6.2.1         Pre-Treatment Scrubber Liquor

The pre-treatment scrubber samples, obtained from the scrubber tap, were slightly  brown and cloudy
from  suspended and  dissolved solids which remained after cleaning. The  results of the pesticide analyses
(Table 4-7) indicated that there were no traces of chlordane or 4,4'-DDT in the  scrubber solution. The
primary and duplicate samples both showed approximately 3.0 pg/L of dieldrin before treatment. These
results indicate that some  of the dieldrin was escaping the vitrification process during treatment of cells
previously  remediated. This loss  can probably be attributed to volatilization of the pesticide within the
dry zone of the approaching melt

Volatile and semivolatile scrubber water data that  were obtained before the start of the Demonstration are
summarized in Table  4-7. The  volatile pre-treatment scrubber samples  contained ketones (specifically
acetone and methyl  ethyl  ketone) and some  benzene. Benzene was detected in the  scrub  solution at a
concentration of approximately 15 jxg/L. Samples analyzed for semivolatile organics before testing
indicated that there were low levels (approximately 2.0 to 50 pg/L) of polynuclear aromatic hydrocarbon
(PAH) compounds along with some moderate  levels (approximately 100 to 400 Mg/L) of phenolic
compounds  in the scrubber before the test.
                                                80

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Table 4-7. Gcosafe Scrubber Water Organics Analysis  Summary  Data*
Pre-Treatment**
AMJyte (Mg/L)
Pesticides
ChJordane
4,4' -DDT
Dieldrin
Volatiks
Ace tone
Benzene
Methyl ethyl ketone
Semivolatiks
Acenaphthylene
Anthracene
Bcnz(a)anthracene
Bcnz(a)pyrene
Bcnzo(b)fluoranthene
Benzo(g,h,i)perylene
Benzo(k)fluoranthene
Benzoic acid
chrysene
Di-n-butylphthalatc
Dibcnzofuran
2,4-Dimethylphcnol
bis(2-cthylhexyl)phthalate
Fluoranthene
Fluorcnce
Indenol 1,, 2,3cd)pyrcne
2-Methylnaphthalene
4-Methylphenol/3-Metfaylphenol
2-Methylphenol
Naphthalene
4-Nitrophenol
Phenanthitne
Phenol
Pyrene

< 5.0
C 1.0
3.0

450
15
90

2.1
9.3
21
3.2
17
1.5
17
< 50
39
1.2
13
34
6.6
33
6.5
1.2
7.3
150
90
33
3.6
41
380
24
During Treatment**
(H8/L)

< 50
< 10
< 10

1,500
21
200

< 100
< 100
11
< 100
< 100
< 100
< 100
22.000
20
< 100
8.0
< 100
< 100
29
6.1
< 100
< 100
690
345
31
6,100
43
5.100
2Q
Post-Treatment***
(Mg/L)

< 50
< 10
10

2.ooo
24
310

< 100
< 100
18
< 100
< 100
< 100
< 100
11.000
33
< 100
15
< 100
c 100
53
10
< 100
< 100
3,100
660
31
2,6QO
78
11,000
36
    • - Complete dara are presented in the Technology Evaluation Report.
    • * - Data reported are average values from one primamy an one duplicate sample collected.
    ***- Data reported are from one primary sample collected.
    < - Analyte not detected at or above presented value (detection limit).

                                                  81

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Table 4-8.  Geosafe Scrubber Water Metals Analysis Summary Data*
Analyte            Pre-Treatment**          During Treatment**            Post-Treatment*
                        (Hg/L)                      
-------
Table 4-9.  Ckosafe Scrubber Water Diojcins/Furans Analysis Data"
Pit-Treatment**
AnaJyte (Hg/L)
2,3,7.8-TCDF
Total TCDF
2,3,7,8-TCDD
Total TCDD
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
Total PeCDF
1,2,3,7,8-PeCDD
Total PeCDD
1 ,2,3,4,7, 8-HxCDF
1,2,3,6,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,7,8.9-HxCDF
Total HxCDF
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7.8,9-HxCDD
Total HxCDD
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
Total HpCDF
1, 2,3,4,6,7, 8-HpCDD
Total HpCDD
OCDF
OCDD
2,3,7,8-TCDD Equivalence
2.1E-04
4.6E-Q3
3.2E-04
1.6E-02
< 5.7E-04
2.5E-04
1.9E-03
8.3E-04
1.6E-02
2.1E-04
2.1E-04
1.4E-04
< l.OE-04
1.4E-03
4.2E-04
5.6E-04
3.9E-04
1.3E-02
4.1E04
< l.OE-04
4.3E-04
2.7E-03
6.61-03
1.5E-W
3.7E-G3
l.OE-03
During Treatment*
C^ig/L)
1.4E-04
3.0E-03
1.4E-04
4.7E-03
< 2.6E-G4
I.3E-04
1.3E-03
2.8E-04
4.7E-03
< l.OE-04
5.3E-GS
4.3E435
< l.OE-04
2.6E-04
1.2E-04
1.8E-04
1.7E-04
3.6E-03
9.0E-05
< l.OE-04
9.0E-05
9.3E4M
2.2E-03
3.0E-OS
1.6E-03
4.2E^M
Post-Treatment***
(Hg/L)
3.5E-04
7.8E-03
3.0E-04
1.4E-02
2.3E-04
3.3E-04
4.3E-03
6.2E-04
9.5E-G3
< l.TE-04
< 1.5E-04
1.2E-04
< i .OE-04
6.6E-04
2.8E-04
4.1E-04
1.8E-04
6.9E-03
2.6E-4M
< l.OE-04
2.6E-04
2.3E-03
5.3E-03
8.3E-05
4.0E-03
9.5E4M
* - Complete data are preseattsd in the Technology Evaluaticnj Repwt,
** - Data reported ait average values from one primary and one duplicate sample collected.
*** - Data reported are from one primary sample collected.
< - Analyte not detected at or above presented value (detection limit).
                                               83

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The pre-treatment scrubber water was also analyzed for the presence of dioxins and furans. There were
no  appreciable levels of these  compounds detected (2,3,7,8-TCDD equivalence was  1.0 x  10"3iig/L).

The metals data for the scrubber water is  summarized in Table 4-8. Some residual metals were present
in the scrubber solution in the form of either dissolved or precipitated salts. As noted by the data,
moderate levels of arsenic, chromium, lead, and mercury were present at the beginning  of the
Demonstration. Sodium hydroxide was used in the scrubber to neutralize acid vapor from the melt and
to assist in the precipitation of  dissolved metals; therefore, the average sodium concentration in the pre-
treatment  scrubber water was 110,000 itg/L.

4.6.2.2         Scrubber Liquor During and After Treatment

No target pesticides were detected in samples collected from the scrubber sump  discharge during
treatment.  These results  are summarized  in Table 4-7. The samples required a dilution, and the detection
limits achieved for the pre-treatment samples could not be achieved due to chromatographic interferences.
The sample collected at the end of the Demonstration contained dieldrin at a concentration of 10 tig/L.
This value was the same as the reporting detection limit of this sample.  The positive identification of
dieldrin suggests that some of this compound is  not thermally  decomposed by the vitrification  process and
must be treated by the off-gas treatment system.

Post-treatment scrub  solution samples analyzed for  volatile and semivolatile compounds required  dilution
to reduce  chromatographic interferences (see Table 4-7). The concentration of benzene in the scrubber
liquor did not appear to change significantly during treatment while increases in concentrations of other
volatile analytes (especially acetone  and  methyl  ethyl ketone)  were observed. The post-treatment samples
showed  increases in  the concentrations of the phenolic  compounds and nitrophenols.  These  compounds
were present in the post-treatment scrubber liquor in concentrations ranging from approximately 650 to
11,000 jug/L. Benzoic acid was also detected at 11,000  /xg/L.

The post-treatment scrubber water was also  analyzed for the  presence of dioxins and furans. No
appreciable levels of these  compounds were detected in the samples (see Table 4-9), and in most cases,
the concentrations detected  would not be a regulatory concern. The scrubber concentrations were on the
                                                84

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order of 1.0 x 10~Vg/kg2,3,7,8-TCDD  equivalence for pre-treatment, blowdown,  and post-treatment
samples

The metal analyses of the scrubber water during and after treatment indicated that some mercury (a target
analyte) was present in the  scrub solution (Table 4-8).  However, in comparison to pre-treatment samples,
there was no net increase beyond what may be attributed to analytical error. Reductions and/or no
significant change were observed for many of the metals. This was most likely due to the addition of
sodium hydroxide to  the scrubber solution which was  used to neutralize acid gases and assist in the
precipitation of dissolved metals. Treatment of metal vapors by the scrubber probably resulted in
precipitable salts which were removed in the  scrubber filtration  system. Significant increases were noted
in aluminum,  antimony, potassium,  selenium, thallium, and zinc. These metals do not  readily form
precipitable salts at the pH  conditions under which the scrubber was  operating.

463 Stack Gas

Stack gas samples for the parameters specified in the  QAPP were collected during treatment of Cell 8.
The  stack gas was also monitored continuously for oxygen, carbon monoxide,  and  total hydrocarbons.

Because pesticides were known to be present in the soil,  pesticide  emissions were evaluated  by the
analysis of samples collected by three primary and one duplicate sample train. The soil concentrations
were too low to  allow evaluation of a destruction and removal efficiency  (DRE)  claim. Even so, any
detectable quantity of pesticides in the stack  gas would indicate a low DRE  for these compounds. The
results of the pesticide stack samples are presented in Table 4-10. As shown in the table, none  of the
target pesticides were detected in the stack gas.

Samples collected for  volatile and  semivolatile analyses did not  contain any significant target compound
hits.  The volatile  samples were obtained  using a time-integrated Summa@  canister  sampling technique.
The  results of these analyses are summarized  in Table 4-10.  Since both volatile  and semivolatile samples
were analyzed using gas chromatography/mass spectrometry, a search of the 10 largest non-target
compounds were conducted. None of the  unknown responses were positively identified; these compounds
were, therefore, classified as unknown hydrocarbons. The unknown compounds were  present at negligible
levels. The emission data corresponds well with the total hydrocarbon measurements.

                                               85

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The stack emissions  of dioxins/furans  was very low during testing. Most of the target isomers were not
detectable in the stack samples. For the two samples (primary and duplicate), the  2,3,7,8-TCDD
equivalences were 1 .O x 10'6 and 2.8 x 10"8 /ig/m3. Complete data are presented in the Technology
Evaluation  Report.

To characterize  metal emissions, samples were collected using three primary and one field duplicate
multiple  metals  sample train.  The results of these samples are presented in Table 4-11.  Total metals
emissions were  calculated by summing the vapor phase and solid phase contributions.  In cases where the
vapor phase or solid  phase emissions were not detected at or above the detection limit, the detection limit
was used in the calculations. All metals emissions were in compliance with the established regulatory
guidelines.  The majority of the mercury emitted from the  process was  in the vapor phase;  levels near
Table 4-10. Geosafe  Organic  Stack Emissions Summary Data*
                                                                              Result
Analyte                                                          (ng/m3)                  (Ib/hr)
Pesticides**
Chlordane
4,4'-DDT
Dieldrin
Semivolatiles***
Benzole acid
Di-n-butylphthalate
Diethylphthalate
bis(2-ethylhexyl)phthalate

< 1.4
< 0,28
< 0.28

23
1.0
0.73
2.5

< l.OE-05
< 2.0E-06
< 2.0E-06

1.6E-04
7.2E-06
5.0E-06
I.7E-05
* - Complete data are presented in the Technology Evaluation Report.
** - Data reported are results from three primary and one duplicate sample collected
*** - Data reported are results from one primary and one duplicate sample collected.
< - Analyte not detected at or above presented value (detection limit).
                                                86

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Table 4-11.  Geosafe Metal Stack Emissions Summary Data*

Analyte
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Strontium
Thallium
Vanadium
zinc
Vapor
(H8/m3)
< 4.7
< 2.3
< 0.057
0.069
< 0.047
0.14
13
0.52
0.49
0.62
3.0
1.2
3.5
140
16
< 1.2
0.43
110
2.7
0.69
32
0.042
< 2.3
< 0.47
1.7
Phase**
(Ib/hr)
< 3.4E-05
< 1.7E-05
3.8E-07
4.9E-07
c 3.4E-07
1 .OE-06
9.3E-05
3.7E-06
3.5E-06
4.4E-06
2.2E-05
8.9E-06
1.9E-05
1 .OE-03
1.2E-04
< 8.5E-06
3. OE-06
8.1E-04
1.9E-05
4.9E-06
2.3E-04
3.0E-07
< 1.7E-05
< 3.4E-06
1.2E-05
Solid
(Hg/m3)
41
< 2.9
< 0.22
1.8
< 0.058
0.13
410
2.4
< 0.28
0.84
43
1.5
5.6
1.4
0.0046
5.5
1.1
18
4.7
< 0.29
73
0.74
< 2.9
< 0.57
5.7
Phase**
(Ib/hr)
2.9E-04
< 2.1E-05
< 1.6E-06
1.3E-05
< 4.2E-07
9.4E-07
2.9E-03
1.7E-05
< 2.0E-06
6.0E-06
3.1E-04
1 .OE-03
4.0E-05
9.9E-06
3.3E-08
3.9E-05
7.6E-06
1.3E-04
3JE-05
< 2.1E-06
5.2E-04
5.3E-06
< 2.1E-05
< 3.9E-06
4.0E-05
Total
(Hg/m3)
44
< 2.8
< 0.27
1.9
< 0.058
0.20
420
2.9
0.5 1
1.5
46
2.1
8.2
140
16
5.5
1.3
130
3.2
< 2.3
76
1.7
< 2.9
< 0.57
7.4
Metals**
(Ib/hr)
3. IE-04
< 2.0E-05
< 1.9E-06
1.3E-05
< 4.2E-07
1.5E-06
3 .OE-03
2.1E-05
3.6E-06
1 .OE-05
3.2E-04
1.5E-05
5.9E-05
1 .OE-03
1.2E-04
3.9E-05
9.5E-06
9.3E-04
2.2E-05
< 1.6E-05
5.4E-04
1.3E-05
< 2.1E-05
< 3.9E-06
5.3E-05
* - Complete data are presented in the Technology Evaluation Report.
** - Data reported  are average values from three primary and one duplicate sample collected.
< - Analyte not detected at or above presented value (detection limit).
                                                87

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non-detect were found on particulate filters. Arsenic was  below reporting detection limits in  all samples.
Chromium emissions were mostly in the particulate form,  as were most of the remaining  metal emissions.
It was not determined whether the chromium emissions were  in the hexavalent or trivalent form. The
emission of lead was close to the detection limit in of the samples collected. Stack gas modeling
performed by the local regulatory agencies indicated that metal  emissions were at levels that did not pose
a significant human health risk.

The hydrogen chloride emissions during the Demonstration were about  5.0  X 10" Ib/hr, well  below the
4 Ib/hr performance standard of 40 CFR $264.343. This standard is established for an incinerator burning
hazardous waste. Although  it may not be directly  applicable,  this standard does provide a background  for
evaluating these emissions.

Particulate emissions averaged approximately 3.0  mg/m3.  This value was not corrected for oxygen content
in the stack since  supplemental  oxygen was  supplied to the thermal oxidizer. Even if the particulate
emissions were corrected, they would still be below the referenced performance  standard for incineration
(see 40 CFR $264.343).

During the  entire Demonstration, oxygen, carbon monoxide, and  total hydrocarbons (as propane) were
monitored by Geosafe. The  emissions of both  total hydrocarbons and carbon monoxide were well within
the operational limits of the process and were each consistently below 10 ppmv throughout  the
Demonstration

4.6.4   Limitations of the Data Results

The conclusions presented  in this  report have  been  based upon the information gathered during  the
Demonstration. Great care was taken to ensure that the measurements collected were accurate and
representative. However, in some instances,  engineering and  analytical limitations restrict the use  and
interpretation of some of these data. This section discusses some of these limitations.

After treatment, samples  of the vitrified soil were collected from the surface of the  treatment area.  There
are some limitations associated  with these samples. Although  the vendor  claims that the molten  mass
becomes well-mixed by  thermal gradients within the  melt, a "cold cap" typically forms on  the  upper

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surface of the melt. Upon cooling, the upper surface of the melt may have been incorporated into the cold
cap and therefore is probably not representative of the center of the  treatment area. It is highly likely that
all organic material within the test soil was destroyed by the intense heat  generated during treatment.
Mercury and other metals may be found in higher concentrations at the center of the treatment area due
to a higher amount of vapor entrainment than that present at the melt surface. Additionally, the test soil
was covered with two feet of clean fill. It is possible that some of the post-treatment samples collected
may have been treated fill  material. It should be noted that great care was  taken to select samples that
represented the center of the treatment area. Large rock-like samples were collected from the melt
surface; the bottom portions  of these  samples were placed in containers  for analysis. Given the volume
reduction upon treatment, it is highly probable that these samples were  obtained from a depth that
contained contaminated soil. Future sampling is planned to obtain material closer to the center of the
treatment area after the soil has cooled. These samples  will be used  to verify the results presented in this
report. When obtained, the final results and conclusions of the Demonstration will be published  in an
Addendum  to  this report.

Although the currently available data indicate that the technology was successful in achieving  the Region
V cleanup criteria, it should be noted that some of the contaminants were already below the  established
limits before treatment. This was especially true  for chlordane which was not detected in any of the pre-
treatment soil  samples collected during the  SITE Demonstration. However,  data collected by Region V
indicate that chlordane was present in the soil at the time the cells were filled (see Table 4-1). Mercury
levels were  also below the target criteria  before treatment. The  data collected during this Demonstration
do  indicate  that substantial  reductions occurred  in  contaminant  concentrations  after  treatment.

The TCLP measurements were performed using standard SW-846 procedures. The method specifies that
the samples must be ground  before leaching. This analytical procedure exposes a much greater teachable
surface area than would be present after actual  remediation since practical  applications of ISV create a
single  large monolith. Therefore, the results of the TCLP analyses presented in this report  most  likely
represent a worst-case scenario. Actual teachability of a treated area is conservatively estimated to be as
good as or better than the results present in this report. The TCLP data presented for chlordane is
inconclusive because chlordane was not detected  at or above  its  detection  limit in  the pre-treatment TCLP
samples
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Although dioxins and furans were known to be present in the test soil, they were not the primary focus
of this study because their concentrations in the soil were very low.  The dioxin/furan results are limited
since only a few samples were collected from each matrix. The data collected suggest that the process
does not generate significant quantities of dioxins/furans  during treatment.

Stack sampling  activities concentrated on  pesticide and metals emissions. Other stack samples were
performed at a limited frequency. It was  not possible to collect stack samples throughout the entire ten-
day Demonstration. This would have been technically difficult and cost prohibitive. Therefore, the
samples collected represent emissions over a shorter time period than the average emissions throughout
the Demonstration.  The investigators believe that these samples are representative of typical emissions
since sampling occurred  while contaminated soil was being treated.

Volume reductions  were calculated based upon density information gained from the surface samples.  It
is possible that samples  collected from the center of the treatment  area may be more  dense due to the
weight of the melt  upon itself. During cooling, the material  may form a more crystalline structure and
entrained gases (bubbles) may redissolve in the material  during cooling. The volume reductions will be
confirmed during the future sampling event.

4.6.5   Process  Operability and Performance at the Parsons Site

This section summarizes the operability of the process and the overall performance of the Geosafe ISV
system at the  Parsons  site. It includes discussions about  developments and problems encountered, along
with the manner  in which these items were resolved.

The in situ vitrification of the staged cells at Parsons improved with the progression of treatment.
Although the  initial cells presented some treatment difficulties,  during the Demonstration (treatment  of
Cell 8), the system ran continuously for  approximately ten days with only minor operational problems.
System operation was only  interrupted for routine maintenance such as electrode segment addition and
adjustment. Throughout the  remediation  project, problems encountered were minor  and  limited to those
associated with  the replacement of scrubber system heater cores (due to solids buildup), periodic
replacement of the  hood panels, and final disassembly of the hood panels
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Originally, remediation of the  nine  cells at the Parsons site  was scheduled to be completed in three
months. Treatment began in June 1993. Treatment time for the  early cells exceeded the average treatment
time, as well as the expected treatment time. The amount of water that was present in the soil and close
proximity  of shallow perched water contributed to longer treatment times in the early cells.  Additionally,
unexpected lateral growth of the early melts increased treatment times when the  original cell walls did
not effectively contain the treatment area. By early March  1994, Geosafe had completed five melts and
treated six cells. These five melts had unusually large overlap  areas; the fourth and fifth melts extended
slightly into  the Demonstration cell  (Cell 8). Because of this  overlap (and additional overlap in future
melts), the Parsons site was  completely  remediated in eight melts rather than nine (see Figure 4-5).  In
late March and early April of 1994, the Demonstration  was conducted  on the sixth melt (Cell  8). All eight
melts were completed by June 1994, nine months after the original  anticipated finish date. Data in the
economic  analysis presented in  this report is  based  on  the planned treatment of nine  melts in nine  cells.

Geosafe did not meet the schedule for treatment at the Parsons site. This may be attributed to a number
of factors-some due to problems with the process, others due to constraints imposed by regulatory
agencies. EPA Region V and the Michigan Department of  Natural Resources (MDNR) required Geosafe
to modify treatment procedures  so  that the emissions and odors from the stack were controlled.  Because
the Parsons  site  is in a residential  area, the offensive  odor drew public attention. Further treatment was
halted until new permit conditions  were established  and  process  modifications were  completed. The
technical requirements of an  Air Quality Permit were specified by MDNR in a document entitled
"General  and Special  Conditions." Because  Geosafe was required to comply with these conditions, this
document became a (Superfund site) ARAR for the State  of Michigan. Verification of emissions rates
(including volatiles,  semivolatiles,  pesticides, dioxins/furans,  metals, particulate matter, hydrogen
chloride, sulfur dioxide,  carbon monoxide, nitrogen oxides, carbon  monoxide, and total hydrocarbons)
was stipulated.  All changes and modifications  to the  Geosafe equipment were required to be approved
by  the EPA Region V.  Because the system could not operate during this period, the permitting and
approval process added significantly to the time required to complete treatment.

Sulfur compounds in the scrubber liquor were suspected  by  Geosafe  as the source of the odors. To
alleviate this problem, the scrubber water was changed at a higher  frequency  to reduce the amount  of
sulfur compounds  accumulating in  the  scrub solution.  Additionally, Geosafe added a thermal oxidizer to
the end of the off-gas treatment system as a final treatment step prior to release of the gas stream to the

                                                91

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IT 0 v, 0 v , E3 1
O : 0 ; C
•K' " "" * X- * - - A' v ^
r a -
0
Ik
y 	 ' 	 ~ 	 ^

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shapes, limit emissions of vapor or steam, and restrict the melt energy inside the cell boundaries. Based
upon the experience Geosafe gained at Parsons, the design and construction of staged treatment cells will
be modified for future projects. It should be noted that the use of cobble in treatment cell construction
was unique to the Parsons site where the configuration and flow of the on-site groundwater dictated its
application.

During the treatment of Cell 2, a fire occurred as a result of a melt disruption. The fire was caused by
a rapid  volatilization of 12-foot by 1-foot poly vinyl chloride (PVC) casing which had been left in the
treatment area to accommodate the previous electrode design. The PVC casing was empty and open at
the surface similar to an  open-cased well. Four of these casings were located within each test cell.
Geosafe determined that the molten soil had contacted the PVC  casing and  melted a hole in it. This
allowed molten material to flow into the casing. The molten material immediately volatilized the PVC
casing and caused the  expulsion of a small amount of molten material onto the surface soil within the
hood. This resulted in an  excessive temperature rise on the hood surface and  the subsequent burning  of
combustible  hood components.  Although  very smokey because of  burning rubber materials,  the  fire was
small and did not cause the release of any hazardous materials or loss of off-gas containment. The fire
caused a disruption of Cell 2 treatment for over 100 hours while Geosafe repaired and replaced damaged
equipment. After the damaged equipment was replaced, the treatment  of Cell  2 was continued. Geosafe
was successful in restarting and continuing the melt without the addition of a new starter path.

During the treatment of Cell 3  another small fire  was encountered.  This fire was caused by a molten area
that was exposed  due to a collapsed portion of the cold cap. The radiant energy released was close to the
hood surface and caused excessive heating. The  instrument lines leading to the electrode feeders began
to smolder and bum. This  fire was quickly extinguished by  Geosafe personnel and had little effect upon
treatment of Cell 3.

As a result of the fires, Geosafe removed all  PVC casings from future melts and removed all combustible
materials from the hood. These corrective actions solved the fire-related problems, and no further
incidents of this nature were recorded during the treatment  of the Parsons site.

Vitrification of some of the early  cells  at Parsons required considerably more time and power  than
anticipated,  and large  amounts  of  scrubber water were generated. This was due in part to the  high

                                               93

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moisture content of the soil and the close proximity of shallow perched water. The perched water flowed
intermittently through a sand lens located eight to ten feet below the surface. Because of the large
amounts of water encountered during treatment of the early cells, Geosafe constructed an intercept system
to collect the perched water at the upgradient end of the treatment zone in a cobble wall. The collected
water ran under and beside the treatment zone in cobble and was then directed to two sump locations
from which it was  pumped to a surface drainage ditch. The amount of water entering subsequent cells
was substantially reduced as a result of this action. A permit was obtained for discharge of water and
some liquid wastes  generated  during treatment after minor  on-site  treatment; however,  all  scrubber  water
was collected and sent off-site for treatment and ultimate disposal, and therefore the on-site treatment
permit was not used.

Cells treated later in the remediation of the Parsons site required less energy than those treated in the
early stages of the project. Cell 8 was the sixth of eight melts performed at the Parsons site.  Figure 4-6
graphically depicts  the power input applied to Cell  8  during treatment. From this figure, it is apparent
that power levels were low during startup. Once the starter path melts enough of the surrounding soil,
power can gradually be increased. After the melt was established, power levels were maintained at
approximately 3 MW.

Some of the first few cells treated at the Parsons site did not achieve the desired treatment depth of
approximately 16  feet, possibly because of the accumulation of water at  the bottom of the treatment areas.
This was observed  during the first three melts, with melt three only reaching a depth of approximately
14 to  15 feet below land surface  (BLS).  During these  initial melts,  the rate of electrode penetration
slowed noticeably as the  depth increased. Treatment of these cells was discontinued because further depth
progression could not be  achieved in an economical  manner. Large  quantities of scrubber water were also
generated during these melts. During cell  construction, thermocouples were strategically placed in the
treatment area to provide an indication of melt progress.  Geosafe monitored temperatures indicated by
the thermocouples during treatment, and their data suggest that sufficient temperatures were achieved  at
the bottom and  comers  of each setting such that,  theoretically, mercury would volatilize and organic
contaminants  would thermally decompose by pyrolysis. Since the contaminated soil was located  at a depth
of 15 feet BLS,  it  is highly probable that all of the soil in these cells was vitrified or experienced
temperatures  high enough to treat the soil. Depth objectives were met for all subsequent melt settings
after improvements were made to the groundwater intercept system.

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                            Power  versus Time
I

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                       Electrode Depth Versus Time
       18
       16
       14
 *    12
 ~    10
	Electrode A1
 *	Electrode A2
	Electrode Bl
	• Electrode B2
       0
      03.22.94 0X24.94 03.2594 03.26% 03.27.94 03.28.94 03.30.94 03.3194 04.01.94
        16:57    15:00    20:18    19:38    18:23    22:49    9:08     6:50     6:57
                                        Tim*
Figure 4-7.  Treatment Time Versus Electrode Depth During the Demonstration (Cell  8)

indefinitely.  As each melt was completed, the surface was covered with several feet of clean fill  soil. This
soil cover minimized emissions from  the  still-hot molten mass, and  allowed equipment  to travel over the
previously treated areas. After all of the melts were completed, the entire site was graded for future use
to be determined by the site owner. This is generally the disposal method  that will  be used for ISV,
especially when  contaminated soils are treated without  excavation and staging. If the material is not
removed from the ground, it cannot be  subject to any RCRA  land disposal restrictions.  Additionally,
since there is  a significant volume reduction from the original material, the layer of clean fill placed on
top can be deep  enough to support grass or other ground cover without increasing the overall  height of
the area.

At some sites, it may be  desirable to remove the vitrified material. In this  case, the  monolith can be
excavated and removed by breaking  it into pieces.  Because of its immense size and weight, it is only
practical to  remove the vitrified  mass in pieces. Fracturing the mass may be aided by rapid cooling of
the molten material as  described previously. The vitrified material  can then disposed of elsewhere.
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The characteristics  of the treated soil were found to meet the developer's expectations  based on  the
sampling of the treated soil surface. Visual inspection and physical analyses showed that the material was
hard, dense, and glassy. Leachability was insignificant for any target compounds (see Table 4-2 and 4-5).
Based  on these characteristics, the material is believed to have a lifespan similar to natural obsidian, a
material known to last for'thousands to millions of years.  Over the long term, it should be safe to place
this material in landfills or leave it in  place at the site. Because this technology is still new and unproven
over the  long term, this projection cam-tot be supported with any data at this time.

The ISV process generates a waste water stream during treatment. Some of the water removed from the
soil undergoing treatment may be reintroduced to the exhaust  stream  in the form of condensed humidity.
This occurs when lower operating temperatures are used in the off-gas treatment system or when  the
amount of water removed from the soil exceeds the amount of water than  can be passed through the  off-
gas treatment system as humidity. When the soil undergoing treatment has a high moisture content,  the
amount of water removed can be significant. During the Demonstration, the scrubber water generated
contained small quantities of the compounds previously identified; it was transported off-site for treatment
and ultimate disposal  at a permitted  facility.  Decontamination liquid is produced at the conclusion of
treatment. Depending on contaminant levels, it is likely that this waste stream  must be  transported off-site
for disposal at a permitted facility. A third liquid stream generated at the Parsons site was diverted
groundwater. This waste stream was  unique to the Parsons facility and was due to the close proximity
of shallow perched water. A discharge permit was obtained to carbon filter this water and discharge it
to a local drainage  ditch.

The ISV system  uses filters and activated carbon to remove particulates  and vapors from the scrubber  and
the gas stream. These materials  may  be recycled, however,  when they  are spent, they require disposal.
The filters and carbon can be treated in a subsequent ISV melt or  they  can be removed to an off-site
disposal facility. The amount of these materials generated is dependent on the soil characteristics
(moisture content, in particular)  and the performance of the off-gas  system

Miscellaneous wastes are also generated during treatment with ISV. These include used personal
protective gear (such as gloves  and coveralls). These  materials can sometimes be decontaminated  and
disposed of as non-hazardous waste.  Alternatively, they too can be placed in a new melt setting and
                                                97

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treated with the waste. Miscellaneous waste generated from the last melt setting may need to be
containerized and disposed of as hazardous waste in an appropriate facility.

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                                          SECTION 5
                          OTHER TECHNOLOGY REQUIREMENTS

5.1     Environmental  Regulation Requirements

Federal, state, and local regulatory agencies may require permits before mobilization  and operation of
the  ISV technology. Most federal permits will be issued by the authorized state agency. Federal and state
requirements may include obtaining  a hazardous waste treatment permit or modifying  an existing permit.
Air emission permits may be required for any unit that could emit a hazardous substance. The Air Quality
Control Region may also have restrictions  on the types of process units and fuels that would be used.
Local agencies may have permitting requirements for excavation, land treatment, and health and safety.
In addition, if waste water is disposed via  the sanitary sewer, then the local water district would have
effluent limitations and sampling requirements, Finally, state or local  regulatory agencies  may  also
establish  cleanup  standards  for  the  remediation.

At the Parsons site, federal and state permits included a National Pollutant Discharge  Elimination  System
(NPDES) permit to discharge diverted groundwater to a nearby  waterway.  Air permits were acquired
from the state of Michigan. These permits specified  changes  in stack  gas treatment  monitoring that were
carried out before the Demonstration began.  A thermal oxidizer was added to the  treatment train to ensure
that permitting requirements were met. Sampling and monitoring was required for volatile organic
compounds, pesticides,  mercury and other metals,  total  hydrocarbons, carbon monoxide, particulates,
sulfur dioxide, and nitrogen oxides. The requirements also specified the afterburner temperature,
calibration frequencies for continuous emission monitoring and discharge limits for components of the
stack gas

Local permits  included various  construction and  operation permits from  the Department of Building  and
Safety, and permission to operate granted by the local Fire Department.

Transportation of the ISV process units  across state lines requires permits; one of the trailers is
overweight. Current  specifications for placarding, warning  lights, and  load limitations must be followed
during transportation of the system
                                               99

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       Personnel Issues

During treatment, the ISV system operated continuously. Three shifts of workers are required for
operation. Each shift has at least two people: a shift engineer and an operator. One site manager and one
project control specialist are also employed during the day shift to oversee operations. A rotating system
is used such that, each shift of workers is on-site for three continuous weeks. This is followed by one
week off, during which the workers may return home,  if desired.  A replacement shift of workers is sent
out each  week to  relieve the shift completing their three-week cycle.

Personnel operating the ISV technology must be trained in both the process operation and in health and
safety practices associated with hazardous material.  Each worker must have  completed the OSHA-
mandated 40-hour  training  course  for hazardous waste work,  and  have an  up-to-date  refresher
certification.  At least one member of each shift team must be certified in CPR and First  Aid, and
additional high voltage training is required. Personnel must be enrolled in a medical monitoring program
to ensure that they are fit to perform their job duties and  to detect  any symptoms  of exposure to
hazardous materials

       Community Acceptance

A Visitor's Day  meeting was held in March 1994  to distribute information to the  public on the
remediation project and on the SITE Demonstration of  the  ISV technology.  The meeting included
presentations by Geosafe and  the EPA SITE project manager, along with a brief tour of the site and
technology. Participants in the  Visitor's Day included regulatory personnel, remediation contractors, and
members of the local public. The turnout at the Visitor's Day was high, indicating strong interest in the
ISV technology and its application for  remediation at Parsons and similar sites.

The ISV  technology can operate on soils in situ, reducing the need for excavation, and the accompanying
noise, traffic, and dust generation. Treatment of a small area can be completed rapidly if no technical or
regulatory  delays are encountered. After backfilling  the  subsidence with  clean soil, the site can  be
landscaped or converted for another beneficial use. ISV remediation at the Parsons site was conducted
near inhabited areas; a church and residences were located within a few hundred feet of the treatment
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5.2    Personnel Issues

During treatment, the ISV system operated continuously. Three shifts of workers are required for
operation. Each shift has at least two people: a shift engineer and an operator. One site manager and one
project control specialist are  also employed during the day shift to oversee operations. A  rotating system
is used such that, each shift of workers is on-site for three  continuous weeks. This is followed by one
week off, during which the workers may  return home, if desired. A replacement shift of workers is sent
out each  week to relieve the shift  completing their three-week  cycle.

Personnel operating the ISV technology must be trained in both the process  operation and in health and
safety practices associated with  hazardous material. Each worker must have completed the OSHA-
mandated 40-hour training course for  hazardous  waste work,  and have an up-to-date refresher
certification. At least one member of each shift team must be certified in CPR and  First Aid, and
additional high voltage training is  required. Personnel  must be enrolled in a  medical monitoring program
to ensure that they  are fit to perform their job duties and to detect any symptoms  of exposure to
hazardous  materials.

5.3    Community Acceptance

A Visitor's Day meeting was held in March 1994 to distribute information to the public  on the
remediation project and on the SITE Demonstration of the ISV technology. The meeting included
presentations by Geosafe and the EPA SITE project manager,  along with a brief tour  of the site and
technology. Participants in the Visitor's Day included  regulatory personnel, remediation  contractors,  and
members of the local public. The  turnout  at the Visitor's Day was high, indicating  strong interest in the
ISV technology and  its application for remediation at Parsons and similar sites.

The ISV  technology can operate on soils in  situ, reducing the need for excavation, and the accompanying
noise, traffic, and dust generation. Treatment of a small area can be completed rapidly if no technical or
regulatory delays are encountered. After backfilling the subsidence with clean soil,  the site can be
landscaped or converted for another beneficial use. ISV remediation  at the  Parsons site was conducted
near inhabited areas: a church and residences were located  within a few hundred feet of the treatment
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area. Other than during mobilization and demobilization activities, the treatment neighborhood did not
experience any significant increase  in  traffic at the site dut; to the remediation activities,

There are potential  inconveniences associated with treatment operations.  The hood to cover the treatment
melt is large, lighted,  and therefore conspicuous.  Since operation must  occur continuously once a melt
has staled, lights and noise will be present at all  hours, This may not be  acceptable in residential areas.
boring  the first melt,  porous pathways in the cobble walls of the treatment cells caused minor problems
adjacent to the site. Odors from the operation were also a source of public complaint. During the second
melt, a fire  occurred which required the response of the local fire  department and attracted public
attention to the site,  Construction and operational  changes were made  during treatment  so that these
problems were no longer occurring at the time  of the SITE Demonstration, These solutions  will be
implemented  at subsequent treatment operations, thus  reducing the potential for recurrence.  The ISV
process consumes a great deal of electrical dower"  During the treatability phase of ISV application, the
electrical  infrastructure should be examined and augmented as necessary to avoiid any negative impact on
the community

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Prior to the  SITE Demonstration, EPA Region V had already performed sampling events on the Geosafe
system to evaluate the cleanup effort at the Parsons site. Data were also gathered in response to odor
complaints and problems identified during the first five melts prior to  the Demonstration. These data were
provided to  the  SITE investigators, and this information was used  to  refine sampling strategies used
during the Demonstration. This section presents some of the Region V data and discusses some
conclusions  which are suggested from the  interpretation of these data.

On December 1 and 2, 1993, Region V conducted stack sampling both before and after the off-gas
treatment system to evaluate its effectiveness. At that  time, the Geosafe system was fully operational  and
was performing the fourth melt at the Parsons site.  The inlet data represents samples collected from the
piping connecting the off-gas hood to the off-gas treatment system. A special  section of piping  was
constructed  to facilitate stack sampling at this location.  The thermal  oxidizer had not been added to the
off-gas system prior  to this sampling event,  so the  outlet data represents the exhaust to the atmosphere
immediately after the blower. Subsequent modifications to the off-gas  treatment system, including the
installation of the thermal oxidizer, were made to  improve system  performance in cleanup of gaseous
emissions. The  sampling indicated that the VOC levels at the stack  were below state ARAR values.

Table 6-1 presents volatile organic  compound emissions for the two  sampling days at both the inlet and
outlet of the off-gas treatment system. Approximately five samples  were taken per day from these
locations;  the values presented are the averages of those results.  The data indicate that there is some
variation in  the emissions generated during treatment. In some cases (Day Two), the data indicate  that
some of the volatiles were removed from  the air stream by the  off-gas treatment system. However, the
Day One  data suggest that the treatment train did not  reduce these compounds. This is not surprising
since the treatment system was not specifically designed to treat volatile organic emissions. Although
activated carbon was part of the treatment train, the data suggest that it was ineffective in eliminating
volatile  organic  emissions

Presented in Table 6-2 is the semivolatile  organic compounds emission  summary  data. The data suggest
that the off-gas  treatment system is effective in treating semivolatile organic compounds as all
concentrations detected at the inlet were reduced at the outlet sampling location. Most concentrations were
reduced by  two to three orders of magnitude
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Table 6-1. Region V Geosafe Stack Volatile  Organic Compound  Emissions Summary Data
VOST Emissions
Acetone
Benzene
Bromomethane (Methyl Bromide)
2-Butanone (MEK)
Carbon Disulfide
Chloromethane (Methyl Chloride)
Ethylbenzene
Methylene Chloride
4-Methyl-2-Pentanone (MIBK)
Styrene
Toluene
Vinyl Chlonde
Xylenes (Total)

Inlet
(ppmv)
2.6
0.92
0.076
0.29
0.069
0.55
0.014
1.3
0.0012
0.014
0.12
0.0031
0.00050
Dayl
outlet
(ppmv)
1.9
1.3
0.0060
0.35
0.12
0.51
0.26
1.4
0.11
0.11
0.34
0.0040
0.45
Day 2
Inlet
(ppmv)
3.4
14
0.045
2.0
0.27
0.60
0.94
8.0
0.64
0.44
6.3
1.6
1.5

outlet
(pprmA
3.4
7.5
0.034
1.0
0.18
0.57
0.20
2.9
0.29
0.33
4.0
0.55
0.30
<- Compound not detected at or above presented value (detection  limit).

Metals stack emission summary data is presented in Table 6-3. As with semivolatile compounds, all metal
concentrations were significantly reduced after being treated by the off-gas treatment system. Specifically,
mercury concentrations were reduced by  slightly more than three orders of magnitude to indicate the
effectiveness of the off-gas treatment system on metals

At the time these samples were collected,  Region V monitored the stack gases using continuous emission
monitors (CEMs) to evaluate  the concentrations of carbon monoxide, carbon dioxide, nitrogen oxides,
sulfur oxides, and total hydrocarbons. Typical results are presented in Table 6-4. As noted, the gas
treatment system was effective  in removing  the nitrogen and sulfur oxide emissions.  The carbon monoxide
emissions ranged between 33  and 53 Ib/hr which was significantly below the state ARAR level of 638
Ib/hr. The total hydrocarbon data verified the organic stack emission data, confirming that organics were
not being completely removed by the off-gas treatment system.
                                                104

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Table 6-2. Region V Geosafe Stack Semivolatile Organic Compound Emissions Summary Data


Semivolatile Organic Emissions
Acenaphthene
Acenaphthylene
Anthracene
Chrysene
Dibenzofuran
Di-n-butylphthalate
2,4-Dimethylphenol
Fluoranthene
Fluorene
2-Methylnaphthalene
2-Methylphenol
4-Methylphenol
Naphthalene
2-Nitrophenol
Phenanthrene
Phenol
Pyrene
Day 1
Inlet Outlet
(romv) tromv)
0.010 < 4.2E-04
0.0080 < 4.3E-04
0.010 < 3.6E-04
0.0030 < 2.8E-04
0.059 < 3.8E-04
0.0070 4.0E-04
0.075 < 5.3E-04
0.015 1.6E-05
0.038 < 3.9E-04
0.17 2.7E-05
0.35 < 6.0E-04
0.55 < 6.0E-04
0.49 1.1E-03
0.010 < 4.7E-04
0.087 7.3E-05
2.0 2.9E-03
0.010 < 3.2E-04

Inlet
(ppmv)
0.014
0.0080
0.013
0.0030
0.071
0.0050
0.07 1
0.022
0.048
0.18
0.28
0.59
0.51
0.019
0.12
2.1
0.013
Day 2
Outlet
(ppmv)
. < 4.2E-04
< 4.3E-04
< 3.7E-04
< 2.9E-04
< 3.9E-04
< 2.3E-04
< 5.3E-04
< 3.2E-04
< 3.9E-04
< 4.6E-04
1.8E-04
2.4E-04
<5.1E-04
< 4.7E-04
< 3.7E-04
4.2E-03
< 3.2E-04
< - Compound not detected at or above presented value (detection limit).
Table 6-3. Region V Geosafe Stack


Metals Emissions
Arsenic
Chromium
Lead
Mercury
Metals Emissions Summary Data
Day 1
Inlet Outlet
(Ib/dscf) (Ib/dscf)
5.2E-05 < 3.6E-08
1.6E-06 2.8E-07
7.2E-05 2.2E-06
4.1E-06 1.3E-09


Day 2
Inlet
(Ib/dscf)
1.1E-04
5.5E-06
7.3E-05
5.5E-06
Outlet
(Ib/dscf)
< 3.6E-08
5.4E-07
5.2E-07
3.4E-09
 : - Metal not detected at or above presented value (detection limit).
                                               105

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Table 6-4. Region V Geosafe Typical CEM Emissions
Analyte                                                                      Emission Rate (Ib/hr)
Carbon Monoxide                                                                      43
Nitrogen Oxides                                                                        0.21
Total Hydrocarbons                                                                     3.0
Sulfur Oxides                                                                          0.050
 Part of the investigation into the process emissions included sampling a portion of one of the used high
 efficiency particulate air (HEPA) filters. The HEPA filter was analyzed for semivolatile organics,
 pesticides,  dioxins/furans,  metals, and sulfur. The results are summarized in Table 6-5. As noted in the   A,
 table,  high levels of arsenic (1,700 mg/kg),  lead (1,600 mg/kg) and mercury (1,200 mg/kg) were  ^
 detected. Chromium was also present at 57 mg/kg.  All other detectable target organic compounds were
 present at moderately low levels. The metals arsenic, lead, and mercury can be classified as somewhat
 volatile, and therefore their detection in the particulate form on the  HEPA filters is not surprising.
 Chromium may have come from the melt  and from deterioration  of the hood panels and other parts of
 the stainless steel off-gas treatment system since this metal is relatively non-volatile. The results presented
 in Table 6-5 indicate that the filters performed very well.

 Region V also performed various analyses pertaining to  the off-gas hood itself. These tests included an
 interior wipe of the hood after treatment of  a cell, and analysis of deposits  of the off-gas hood wall itself.
 By wiping the interior of the off-gas hood and analyzing the residue, Region  V hoped to gain insight
 about equipment contamination and contamination buildup during operation. An analysis of the Region
 V samples for semivolatile organic  compounds and pesticides yielded concentration values below the
 detection limits for the wipe residue. Mercury was detected in the wipe sample.

 When  moving the hood at the completion of a melt, flaky deposits from the interior of the hood fell  off
 and were deposited on top of the clean soil surrounding the treated area. Analysis of these deposits

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Table 6-5. Region V Geosafe HEPA  Filter Analysis
Analysis
 Units
                                                                                    Result
Total  Solids
% Solids
                                                                                     92
Metals
Arsenic
Chromium
Lead
Mercury

Semivolatile Organics
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(g,h,i)perylene
Bis(2ethylhexyl)phthalate
Butyl benzyl phthalate
Chrysene
Fluoranthene
Phenanthrene
Pyrene

Organochlorine  Pesticides  and PCBs
4,4'-DDE

Polychlorinated  Dioxins
HxCDDs (total)
HpCDDs (total)
l,2,3,4,6,7,8_HpCDD
OCDD
 m&g
 mg/kg
 mg/kg
 Hg/kg
 ^g/kg
 Hg/kg
 Hg/kg
 Hg/kg
                                                                                  1,700
                                                                                     57
                                                                                  1,600   J
                                                                                  1,200
                                                                                    220
                                                                                    380
                                                                                    160
                                                                                    500
                                                                                    150
                                                                                    300
                                                                                    230
                                                                                    270
                                                                                    370
                                                                                     22
                                                                                      0.41
                                                                                      0.78
                                                                                      0.33
                                                                                      0.83
J - Value reported is less than the reporting detection limit but greater than the method detection limit.
   Value is an estimate.
                                               107

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showed metals  concentrations  at the levels presented  in Table 6-6. Region V expressed concern over the
chips since they flaked easily from the interior surface of the hood during movement. The problem was
easily remedied by using a vacuum to remove  the deposits from the ground surface and the hood interior
panel surfaces. The  flakes and associated dust were placed into  subsequent  melt settings for treatment.
After treatment was  completed at Parsons, the hood panels were disposed of as secondary waste since the
cost of decontamination activities would have exceeded the value of the panels.  Because the hood  panel
corrosion at the Parsons site was  much more rapid than anticipated, Geosafe investigated the situation and
found that high levels of sulfur  at the site  resulted in unexpected and increased rates of corrosion. In
addition, Geosafe determined that the long periods of inactivity experienced between the first  few melts
resulted in exposure to moisture  conditions that enhanced corrosion.  When the corrosion  rate was  noted
to be  of concern, Geosafe initiated "coupon" testing directed  at identifying  alternative materials for
improved hood panel performance. The coupon testing at the Parsons site has identified hood materials
that are currently being testing as  part of full-scale treatment at  another site.

Region V also performed  a limited number of analyses on treated  soil obtained from melts  completed
prior to the  SITE Demonstration.  Some of these samples  were analyzed using neutron activation analysis.
This  is a non-intrusive procedure that can eliminate interferences and recovery bias associated with
standard sample digestion procedures for metals. In this procedure, neutrons produced  during nuclear
fission are used to activate a  sample to form radioactive  isotopes. As these isotopes decay, the energy is
quantized and related to a particular element. By counting the disintegrations per unit of time, a
statistically valid concentration of elemental abundances can be determined. There were no published EPA
methods pertaining  to this procedure  at the time of testing, and therefore this  procedure was not used
during the Dimonstration.  Results of the  Region  V treated soil metal  data are presented  in Table  6-7.

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Table 6-7. Region V Geosafe Neutron Activation Analysis on Treated Soil
Metal	Concentration  (mg/kg)
Arsenic                                                                             2.3
chromium                                                                         48
Mercury                                                                        <  5.0
Region V conducted an excavation of the first melt to determine the extent of treatment and to evaluate
if migration of site contaminants into adjacent clean soil had occurred as a result of treatment. The
samples collected during this excavation were analyzed for volatile organics,  semivolatile organics,
dioxins/furans,  pesticides, and metals. The results of these data are presented  in Table  6-8. There were
no semivolatile or dioxin/furans  detected in these samples.  All Region V target analytes were  well below
the cleanup criteria. Traces  of the pesticides  were detected. Because pre-treatment sampling was  not
conducted outside the treatment area, the source of these pesticides is unknown.  It may stem from existing
contamination from previous  chemical  activities at the Parsons site or migration from other contaminated
area of the site via rainwater runoff. It is inappropriate to  assume that these low levels of pesticides were
a result of ISV treatment. In most instances, the concentrations detected are considered insignificant.

Current information regarding the  status of  Geosafe's commercial activities have been  provided by the
vendor and is presented below.  After  completion of vitrification operations at  the Parsons site, Geosafe
mobilized its equipment to a  General Electric Company site  in  Spokane,  Washington for performance of
a TSCA demonstration project in support of an application for a National TSCA Operating Permit. The
GE/TSCA demonstration involved treatment of 3,500 tons of soil  contaminated with  polychlorinated
biphenyls  (PCBs)  to a maximum level of 17,000 mg/kg.  The soil was staged in five treatment cells to
a depth of 15 feet. In addition to the contaminated soil, the treatment volume contained approximately
80 unsealed steel drums and significant quantities of asphalt and concrete debris.

The  TSCA demonstration project was performed under a permit  issued by EPA's TSCA  authorities. EPA
personnel witnessed critical melting operations and participated in the acquisition, analysis, and evaluation
of performance data. The five melts were performed without difficulty, and Geosafe was able to complete
the project on schedule. Preliminary off-gas  treatment data indicated that the level of PCBs in the stack

                                                109

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outlet was less than  the  detectable limit.  The ISV equipment operated without difficulty during the
complete project.  Geosafe was able to make further improvements in operations efficiency and reduced
hood movement time to less than two days.  Geosafe expects to receive a National TSCA Operating Permit
for treatment of PCBs at the conclusion of EPA's evaluation process.

Geosafe completed the GE/TSCA  project in early  October 1994. The ISV equipment was then mobilized
to the Wasatch Chemical Superfund Site in Salt Lake City, Utah where it is being  used to treat
approximately 7,000  tons of soil  and debris  contaminated with  dioxins,  pentachlorophenol,  several
pesticides, and other organics.  Vitrification operations began at the Wasatch  site late  in 1994.

6.2     Scaling Capabilities

Geosafe has stated that ISV can be  used to treat contaminated soil in situ in  several configurations. They
have proposed to treat soils that are deeper than the 20-foot maximum depth of a single ISV melt in
stages.  There are two approaches. The shallower intervals can be treated initially, and the vitrified
product can be removed,  allowing the deeper intervals to then be treated. Alternately, the top layers of
soil can be removed and stored separately until the deeper soils are vitrified. The  soils can then be
replaced and vitrified on top of the first set of melts. Due to the volume reduction, additional  soil from
other areas can be added in the same space. These methods  have not been fully demonstrated, however
future activities are planned.

Geosafe's  existing full-scale equipment is the largest ISV equipment that has been developed. A single
system is  in  existence. Battelle Memorial Institute has studied larger units for the U.S.  Department of
Energy and has determined that significantly larger ISV systems can be designed and fabricated. To date,
this has not been performed.

In the future, more than one full-scale ISV system may be used to expedite treatment of large sites in an
economic  fashion. Cost savings may also be incurred by the use of an ISV system two to three times
larger than the current 4 MW system. A larger system would not only have a higher throughput rate and
lower operating cost,  but  would also be able to produce  larger melts  and process to greater depths.

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Table 6-8. Region V Geosafe Melt  1 Excavation Soil Analysis
Metals


Analyte
Arsenic
Lead
Mercury
Organochlorine Pesticides


Analyte
B-BHC
G-BHC
4,4 '-ODD
4,4 '-DDE
4,4 '-DDT
Dieldrin
Endrin
Heptachlor
Heptachlor epoxide
Volatile Organics


Analyte
Benzene
2-Butanone (MEK)
Methylene chloride
Toluene
Xylenes
Sample 1
Concentration
(me/kg)
4.1
7.4
< 0.050

Sample 1
Concentration
(Hg/kg)
3.4
2.7
< 3.3
9.2
< 3.3
2.7
3.6
1.8
3.2

Sample 1
Concentration
(Hg/kg)
4.0
< 10
49
3.0
1.0
Sample 2
Concentration
(me/ke)
3.4
5.0
0.12

Sample 2
Concentration
(Hg/kg)
2.7
1.7
7.9
13
9.6
3.6
< 3.3
< 1.7
< 1.7

Sample 2
Concentration
(Hg/kg)
< 4.0
16
11
1.0
< 1.0

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                                       REFERENCES
1       U.S.  Environmental Protection Agency. 1993. Innovative Treatment Technologies: Annual Status
              Report; Fifth Edition. EPA 542-R-93-003. U.S.  Environmental Protection Agency. Office
              of Solid Waste and Emergency Recovery. Washington, D.C.

2      Hansen, J.E. 1993. "In Situ Vitrification (ISV)  for Remediation of Contaminated Soil Sites.
              Geosafe Corporation. Richland,  Washington.

3      Timmons, D.M., V. Fitzpatrick, and S. Liikala.  1990.  "Vitrification Tested on Hazardous
              Wastes." Pollution Engineering, June 1990. pp. 76-81.

4      U.S. Environmental Protection Agency. 1992. Handbook on Vitrification Technologies for
              Treatment of Hazardous  and Radioactive  Waste.   EPA/6225/R-92/002. U.S.
              Environmental Protection Agency. Office of Research and Development. Washington
              D.C.

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.      Liikala, S.C. 1991. "Applications of In Situ Vitrification to PCB-Contaminated Soil." Presented
              at the 3rd International Conference for the Remediation of PCB  Contamination, Houston,
              Texas, March  25-26, 1991.

9      U.S.  Environmental Protection Agency. 1986.  Test Methodsfor Evaluating Solid Waste. SW-846.
              U.S. Environmental Protection Agency.  Office of Solid Waste. Washington D.C.

10.     Geosafe Corporation.  1992. "Whole Rock Analysis." In Situ  Vitrification Technology Update
              Geosafe Corporation. Richland,  Washington.

11     Timmons, D.M.  and V. Fitzpatrick.  1990. "In Situ Vitrification: Heat  and Immobilization are
              Combined for  Soil  Remediation." Hazmut World, December 1989.

12     Dragun, J. 1991.  "Geochemistry and Soil Chemistry Reactions Occurring During In Situ
              Vitrification."  J. Hazardous Materials,  1991. pp.343-363.

13     Science  Applications International Corporation. 1993.   "Geosafe In Situ Vitrification
              Demonstration Plan."  Science Applications  International Corporation. Process
              Technology Division. San Diego, California

14     Office of Federal  Register. 1993.  Code of  Federal Regulations  Title 40, Protection of
              Environment.  U.S. Government Printing Office, Washington, D.C.  July 1993.


                                             112

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                                        APPENDIX  A
                                    VENDOR'S CLAIMS

This appendix presents the claims made  by the  vendor, Geosafe Corporation, regarding In Situ Vitrifi-
cation (ISV),  the technology  under consideration. This appendix was written solely by Geosafe, and the
statements presented herein represent  the vendor's  point of view based  on over  190  tests,
demonstrations, and commercial melts  performed since 1980. Publication  here does not indicate EPA's
approval or endorsement of the statements made  in this section; EPA's point of view is discussed  in the
body of this  report

A.I    Summary

Geosafe considers that the  SITE demonstration performed at the Parsons Chemical site was very
successful.  Geosafe believes that the SITE demonstration, together with the other seven melt settings
of the  Parsons project, over 190 other tests and demonstrations of the technology, and  large-scale
remediation work that has been performed since the demonstration, have clearly shown the efficacy of
the ISV technology for treatment of contaminated soil sites. The technology has been shown effective
for the treatment of soil and other earthen materials contaminated with a broad range of organic,
inorganic, and radioactive materials. This Vendor Claims  section summarizes the capabilities of the  ISV
process that have  been  developed to date; it also comments on the results  of the Parsons Project and the
SITE demonstration  performed  there.

The  ISV technology is  a unique on-site and in situ  thermal treatment technology with specific advantages
relative to  alternative technologies, including:

       o       ability  to simultaneously process mixtures of all contaminant types
       •      ability  to attain high destruction, removal, and/or immobilization treatment effectiveness
       •      production of a  vitrified residual product with unequalled chemical, physical,  and
               weathering  properties
       •      maximum  permanence of treatment,  including geologic life  expectancy of the vitrified
               product
                                              113

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        •      maximum volume reduction
        •      good public acceptance related to on-site and in situ safety benefits and quality of
               treatment and residual vitrified product
        •      cost effectiveness that increases with increasing site difficulty and stringency of cleanup
               standards.

Numerous application configurations are available to allow application of ISV to a wide range of site
conditions. The equipment system has been demonstrated to be highly reliable,  and to be adaptable to
specific site  needs. There are few site conditions that cannot be handled by adaptation of the site and/or
the process  and equipment. The process is  now available  for contaminated soil site remediation on a
large-scale commercial basis. The process continues to  be developed for buried wastes and other
advanced  applications.

The Parsons Site  Project was Geosafe's first large-scale  remediation project performed on a commercial
basis. The site presented several challenges that  had  not been previously experienced during large-scale
ISV operations. It  was necessary for  Geosafe to make several adaptations to  the technology,  which
allowed successful demonstration both of the technology's and Geosafe's ability to adapt to  site-specific
challenges

The SITE demonstration was performed on the sixth of eight melts performed during the Parsons
Project. Demonstration results confirmed the capabilities  of the  ISV technology where relevant site
conditions existed.  The demonstration confirmed that all performance criteria for the site  were met.

A.2    Introduction

The ISV process  involves electric melting of soil and other earthen materials for purposes of removing,
destroying,  and/or  permanently immobilizing hazardous  and  radioactive contaminants. The patented
process was originally  developed by Battelle Memorial institute  for the  U.S. Department of Energy
(DOE), with the intent of possibly treating transuranic-contaminated soils in situ at  DOE sites.
Developmental testing of the  process proved it to be highly effective for a  broad  range of hazardous and
radioactive  contaminant types, earthen media types,  and application  configurations.
                                               114

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The ISV process, which has been described in more detail elsewhere in this report, involves the melting
of a solid media. It is the molten media that conducts  the electricity, and converts it to heat (joule
heating). The high melt temperature results in removal and/or destruction of organic and other
vaporizable  contaminants.  Immobilization of heavy  metals, whether radioactive or non-radioactive,
occurs as the heavy metals are incorporated into the residual vitrified product that forms upon cooling
of the melt. Because of these simultaneous removal, destruction, and immobilization treatment
mechanisms, EPA has variously classified  ISV as a thermal treatment, a solidification/stabilization treat-
ment ,  and  a physical/chemical treatment  process.

A. 3     Applicability to Contaminated Soil and Other Earth-Like Materials

ISV may be applied to any media that is  capable of forming and supporting a joule-heated melt.  Such
materials include most natural soils, sediments, mill tailings, and other earthen materials. These
materials consist predominantly of metal  oxides (e.g., Si02, A1203, F^C^)  that have adequate electrical
conductivity in the molten state and will produce a vitrified product  upon cooling. In relatively
infrequent cases, some natural earthen materials do not contain adequate alkali materials to provide the
desired molten  state electrical  conductivity. In such cases, fluxant materials may be  added to obtain the
desired melt properties.. In similar manner, some natural earthen materials, e.g., limestone, may not
produce the desired vitrified product properties upon cooling. In such cases, typical silicate type  soils
may be added to produce a good quality vitrified product.

Because of these features, ISV is most often applied to contaminated earthen materials. It may also be
applied to various non-soil waste materials (e.g., process sludges, incinerator ash) by combining  them
with earthen media for treatment. For example, non-soil sludges  may be processed by intermixing with
soil for treatment, or by forming a melt in soil placed above the sludge and allowing it to melt down
through the sludge. Waste  lagoons and evaporation ponds may be treated in this manner

In some cases,  the waste material itself may be analogous to earthen  materials and be processed without
modification. Municipal  incinerator and coal power plant ashes are  examples of such materials; their
origin  lies  in other earthen materials  (e.g.,  coal,  metal ores), and they  possess essentially  the  same
chemical composition as earthen materials.
                                               115

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       Application Configurations

ISV is applied to contaminated media in place where it presently exists (termed in situ melting), as
opposed to bringing the media to, and feeding it into, the melting equipment (termed ex situ melting).
The materials subject to ISV may be undisturbed soil deposits that have inadvertently become
contaminated, or they may be earthen materials that have become contaminated through some
engineered waste treatment and/or disposal process  (e.g., buried/landfilled  waste, sludge lagoons and
evaporation ponds). In many cases,  ISV may be applied to these materials where they presently exist;
alternatively,  the configuration of the materials may  be changed if desired to  allow more efficient or
cost-effective  ISV treatment. For example, soils from a shallow evaporation pond may be reconfigured
(staged) to a greater depth to allow for more economic ISV treatment. Figure A-l illustrates some of
the reconfiguration options that allow ISV application to most situations involving contaminated earthen
materials.

A.5    Contaminant Treatment Effectiveness and Permanence

Organics are completely removed from the media volume melted due to their inability to exist within
the typical soil melt temperature range of 2,900 to 3,600°F (1,600 to 2,000°C). During ISV, organic
contaminants are vaporized by heat from the thermal gradient present in front of the melt. Upon
vaporization,  the  organics move toward  the  ground surface, either through the melt or very closely
adjacent to it. The specific soil gas-phase  permeability has a direct bearing on the pathway of gases and
vapors to the surface.

Several options exist for the final treatment of the organic vapors,  including: 1) destruction by pyrolytic
thermal decomposition below grade, 2) oxidation upon contacting air at the ground surface, and/or 3)
entry into  the  off-gas volume followed by removal and/or thermal destruction  during off-gas treatment.
Typically, substantially all of the organics are destroyed during ISV processing, with the possibility of
very small  amounts  becoming part of the  off-gases which are subsequently removed or  destroyed by the
off-gas treatment  system

Heavy metals are predominantly immobilized by ISV processing to the extent of their solubility in the
molten media. The immobilization mechanisms are chemical and physical incorporation into the  vitrified

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IN SfTU VITRIFICATION
 Configuration  Alternatives
       In Situ
   Contaminated Soil
             In Situ
                     Staged In Situ
           Stationary/
               Batch
             Intermittent
            Molten Material
              Removal
                    Intermittent
                      Materiel
                      Feeding
        Stacked

                Upper Melt Done
Lower Melt Done     After Replacement
After Excavation    & tuctnt^ Material
     (1)
(2)
                                        Layered
                                Upper Material
                                  Treated
                                 Upper Material
                                 Removed After
                                   Treatment
                                                Lower Material
                                                  Treated
Figure A-l. Various Configuration Options for ISV Processing

                              117

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product. The retention efficiency (i.e., percentage entering the melt  as opposed to volatilizing to  the  off-
gases) is a function of many variables which can be analyzed in advance of treatment to determine
expected performance.  Most priority pollutant metals, including semivolatiles like lead and arsenic, are
retained at very high levels, with the remainder being subject to removal during off-gas treatment. At
the other extreme, ISV is a removal process for mercury due to its high vapor pressure and low
solubility in typical silicate melts. The quality of heavy metal immobilization within the vitrified
product,  as  measured by TCLP testing, is unequalled compared to other immobilization/stabiliza-
tion/solidification  technologies.

Radioactive materials of interest are typically heavy metals (e.g., plutonium, uranium, cesium,
strontium) and are immobilized like heavy metals during  ISV as described above. ISV may  also be
employed to prevent radon  release to the environment (air pathway).  Radon, a gas that is formed by
decay of radium within a vitrified material, is contained by the material until such time that it decays
further, back to a solid. Several orders of magnitude reduction in the radon emanation rate can be
achieved.

A. 6    Residual Vitrified Product

ISV treatment of natural earthen materials results  in a single, large, monolithic, rock-like mass that is
predominantly vitreous (glassy) in nature.  Some  amount  of microcrystallinity may exist within  the
vitrified mass depending on  the mixture of metal oxides that were  melted together and the cooling time
experienced. Vitrified product from natural soil melts possesses the following characteristics:  1) it is
typically about  10X the strength of unreinforced concrete in both tension and  compression,  2) it is
unaffected by wet/dry and/or freeze/thaw cycling, 3) it has acceptable biotoxicity (i.e., not toxic  to near-
surface life forms), 4) it is unequalled compared to other treatment products in its ability to withstand
weathering for a geologic time period.

Conversion of treated media into a vitrified product results in a large volume reduction (e.g., 25  to 50%
for  most natural soils). The volume reduction results from removal of void  volume present  between
solid particles, the removal  of vaporizable  materials  present, and the  thermal  decomposition of some
mineral materials (e.g., limestone will calcine to lime while giving off  COJ. Volume reductions on the
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order of 70 to  80% or more are achievable for certain sludges and buried wastes. The  resulting density
of vitrified product from soil melts is typically in the range of 2.5 to 2.8 g/cc.

Because the vitrified material contains zero organics, and it securely immobilizes the heavy metals
present, the vitrified material is no longer hazardous  and should be suitable for "delisted" regulatory
status. Given such status, the vitrified monolith should be suitable for leaving on-site, and the land
should be available for other uses without restriction.

A. 7     Air Emissions and Other ARARs

The  existing ISV off-gas treatment system design has been demonstrated capable of meeting air emission
standards for the states of Washington, Michigan, and Tennessee (see results for Parsons Project in later
section). It is important to note that the system can be modified if necessary to meet specific state stan-
dards. Geosafe is not aware of any state or federal air emissions standards that would preclude its  use
within the U.S.

In similar manner, Geosafe is not aware of any other state or federal ARARs that would prohibit the
use  of  ISV  compared  to other alternative technologies.  The technology is quite flexible regarding
application configurations, and the  remedial design can be adapted as necessary to  comply with typical
ARARs.

A. 8     Application Limitations

ISV is subject to eight (8) basic types of limitations as defined below

A.8.1 Media  Melting  Characteristics

The  contaminated media must be suitable for melting within the operating  capabilities of the equipment
system. This  suitability  for melting relates primarily to the geochemical composition of the media,
which determines  melting properties  (e.g.,  melt temperature, viscosity)  and  molten  state electrical
conductivity. Most natural soils can be efficiently melted by ISV  without  any modification. In relatively
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rare cases (e.g., highly leached soils), the  addition of alkali materials may be desirable to increase melt
electrical conductivity and to  lower melting temperature or melt viscosity.

        Vitrified Product Quality

The media composition and melt cooling rates are the primary  determinants  of vitrified product quality.
Most natural soils and other  earthen materials  possess sufficient glass forming minerals (e.g.,  silica,
alumina) to produce an excellent residual product. Note that it is a common misconception that sandy
soil is required to obtain a vitreous product. In fact, most soil types (e.g., gravel,  sand, clay, silt)
possess glass forming  materials  in abundance. Limestone and dolomite  soils are  possible exceptions to
this.  Whereas these soil types  typically contain some amount of silica, they  may  require some addition
of good glass forming soil to produce the desired quality of vitrified product.

The ISV process typically produces a higher quality vitrified product than  do other vitrification
technologies because ISV can be operated at a higher temperature  than melter- or furnace-based
technologies. Because glass at high temperatures can corrode the refractory linings of ex situ melters,
furnaces, kilns, and similar devices, fluxants are added in such applications  to lower the melting
temperature, which also results  in some diminishing of vitrified product quality. Such "fluxing down"
is not required in ISV since there is no refractory lining to be concerned about. Therefore, the higher
melting temperature of ISV produces the highest possible vitrified product quality.

A high quality vitrified  product is necessary if heavy metals immobilization is  a  desired objective.  If
ISV  is  employed only to destroy/remove  organic contaminants, then the vitrified product quality is not
important because no organics continue to  exist within the vitrified mass

A.8.3 Water  Recharge

ISV  may  be applied to fully saturated, even  supersaturated, media. This is possible  because the thermal
gradient in front of the advancing melt  simply dries the wet media out  before melting it.  Water can be
a limitation to ISV processing  if site conditions  allow recharge to the treatment zone at  a rate faster than
the drying and melting rate. In such cases, ISV cannot be applied without  some engineered provision
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for limiting recharge (e.g., slurry wall,  intercept trench, temporarily lowering the water table by
pumping).

Since water removal by ISV consumes energy (about the same amount as melting soil), it is desirable
to maintain the material to be treated at as low a water content as possible. During cooling, completed
ISV melts  will dry out the surrounding soil to a distance of 8 to  10 feet from the melt.

A.8.4 Processing  Depth

The maximum practical depth of processing for a given  site  is dependent upon  many factors including
media melting properties,  water content and recharge conditions, and processing  equipment capabilities.
The greatest single melt depth attained by Geosafe to date is  slightly over 22 feet. If deeper vitrification
depths are desired, application concepts are available  that involve  multiple melts to achieve increased
depth (reference the "stacked"  and  "layering" concepts of Figure A-l).  Increased single melt depth
capability is  under development.

A.8.5 Total  Organic Content

Treatment  of organic materials results in heat  generation due  to the pyrolytic decomposition of  organics
followed by oxidation of the pyrolysis products. This heat enters the off-gases and must be removed by
the quenching stage of the off-gas treatment system. The heat removal capability of the existing large-
scale equipment is capable of removing the heat produced from a treatment zone containing about 10
wt % organic content. This is a much higher organic  loading than exists at most contaminated sites.

If it is desired to employ ISV for higher organic loadings, it would be necessary to employ equipment
with additional  heat removal  capacity, or to "average  down" the organic loading. This  can be  done by
intermixing high and low contamination level media,  or by  adding more lowly  contaminated  or clean
soil to the contaminated media.
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A.8.6 Debris Content

The ISV process  is unique in its  ability to accommodate large amounts of various types of debris  in the
treatment volume. Organic debris (e.g., plants, roots, tires, PPE, trash) will be  disposed in a manner
similar to that of organic contaminants discussed above. Inorganic debris (e.g.,  concrete,  rocks, scrap
metal) will behave similarly to earthen materials and heavy metals (i.e., dissolve into the melt).

Such  debris within the treatment zone  normally does not limit ISV if it is not present in such a way as
to physically interfere with the melting  process, or is not present at such high quantities as to adversely
affect the melt properties. Such extreme conditions are rare  at most sites, with the exception of landfills,
and particularly  construction debris  landfills.  With proper  remedial design, including the possibility of
removing or reconfiguring some debris content, the ISV  process is capable of processing significant
quantities of organic and inorganic  debris

Large quantities  of metallic debris  can also be accommodated. Metals in the reduced state (e.g., iron
scrap) normally remain in the reduced state and sink to the bottom of the ISV melt. The presence  of
molten metal at  the bottom of a melt actually enhances downward  melt  growth.  By maintaining the
electrodes  a short  distance  above  the molten metal, ISV processing  can continue without electrical
shorting  difficulties being caused by the presence of the metal.

A.8.7 Sealed Containers

Whereas ISV has been  demonstrated capable of processing sealed containers possessing a variety  of
waste materials,  the conditions under which  such processing can be safely and reliably accomplished
have  not yet been fully  defined.  Therefore, at this time Geosafe does not treat sites containing  sealed
containers of vaporizable materials  (e.g., organic liquids) on a  commercial basis. Geosafe  will consider
such  applications on a research,  development, and demonstration basis with the objective of eventual
commercial   application.
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A. 8.8  Media Gas-Phase Permeability

During ISV processing, gases  and vapors are generated in  advance of the melt and move to the  surface
through the dry zone adjacent the melt and/or through the melt itself. It is necessary that each
application be analyzed and, if necessary, designed to ensure that the gases and vapors may move to
the  surface without causing excessive levels of melt disturbance.

A.9    cost

The cost of ISV is defined as  Geosafe's price for ISV-related services, including treatability testing,
technical support of remedial design, and remedial  action. Geosafe's price includes  its direct costs for
materials, supplies,  electricity,  and labor;  indirect costs  including subcontracted services  and labor
burdens; corporate overhead; and profit margin. Geosafe's  price covers all  activities it  performs  for the
client.  It does not cover other activities the client may perform or have performed  at a site (e.g.,  site
characterization,  site  preparation, remedial design,  etc.).

The cost of treatability testing  usually falls in the range  of $40,000 to  $80,000 of which $25,000 to
$30,000 is for performance and evaluation of the test, and  the remainder  ($15,000  to $50,000) is for
analytical chemistry services. The cost of treatability testing is highly dependent upon the number of
contaminants and number and types of chemical analyses that must be performed. Treatability  testing
is usually performed  at engineering-scale  and produces  a  150-  to 200-pound vitrified mass.  Actual
contaminated media from the site is employed in such  testing at Geosafe's facilities in Richland,
Washington.  In most cases, Geosafe is able to utilize engineering-scale treatability test data for large-
scale remedial design  and  cost estimation purposes.  Geosafe also  has the capability to  perform one-ton
melts for larger treatability tests. Such testing can  be performed  in situ on the client's site if desired.

The combined cost of mobilization  and demobilization of Geosafe's large-scale  ISV equipment  system
usually falls in the  range of $300,000 to $400,000.  Transportation distance from the prior  site location
is a large variable determining the level of cost in this range. The mob/demob  cost covers  all activities
associated with transporting, setting up, readiness testing, decontamination, disassembly, and transport
away from the site.
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The  equipment system is permanently mounted  on three over-the-road trailers  so  that it is truly mobile
as opposed to transportable. The off-gas hood is transported on an additional trailer and must be erected
at the site. Additional trailers (typically two to  four) are employed to transport materials and supplies
to the site (e.g., electrodes, cables,  tools). Mobilization and demobilization costs are fixed costs that
should be allocated to all the tonnage involved  in a remediation project.

The  cost of vitrification  operations currently falls in the range of $350 to $450/ton (wet  density basis)
for typical non-radioactive U.S.  projects.  The three primary factors impacting vitrification costs are:
1) the local price of electrical power, 2) rate and depth of processing, and 3) the amount of water
requiring removal during processing. Electrical  power is usually  obtained at large consumer industrial
rates. Costs are less for deeper and drier sites than for shallow, wet sites.  These cost estimates are based
on Geosafe's current use of a single large-scale  ISV system. It is  anticipated that costs will come down
as additional machines are added, which will  provide a larger  revenue base over which to allocate
indirect  corporate costs.  Costs  involved with treatment of  radioactive sites will be higher due to radio-
logical  safety requirements.

A. 10   Regulatory and Public  Acceptance

The  ISV process has received good support from regulatory authorities that recognize its potential for
satisfying  regulatory cleanup objectives and the  regulatory preference for  implementation  of innovative,
on-site,  in situ treatment  technologies. It is noted that this  support is sometimes countered  by potentially
responsible party  resistance against  use  of innovative technologies. Geosafe acknowledges the fine
support given to ISV by EPA's Technology Innovation Office, the SITE Program, and Regions IV,  V,
VI, VTII, and X; and by the States of North Carolina, Michigan, Illinois, Texas, Utah, Idaho, and
Washington. Geosafe  recognizes  that no  innovative technology  may  be successfully commercialized
without solid regulatory support.

ISV  has also received excellent public acceptance to date. We believe that  this high acceptance is due
primarily  to the on-site  and in situ public and  environmental safety benefits of the  technology, and
recognition of the  superior safety  and permanence of the residual  vitrified product. The robustness (i.e.,
broad capabilities)  of the technology, and the large volume reduction it produces  are also  well received
by the  public. Public acceptance  for ISV is  also attributable to the technical credibility of the

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organizations who developed and continue to support the technology:  Battelle Memorial Institute and
DOE.

A.ll   Development Status and Commercial Implementability

ISV is  commercially  available for contaminated  soil/sludge/sediment/tailings type  applications. It
continues to be  developed for buried waste,  underground tank, barrier wall, and construction-related
applications.

The Parsons Chemical/ETM  Enterprises Superfund Site was  the first large-scale commercial application
of ISV. After completion of vitrification operations there,  the equipment was mobilized to  Spokane,
Washington for performance of a 3,500-ton  TSCA  demonstration  project involving PCB  contamination
to 17,000 mg/kg  in soil that was staged to a depth of 16 feet in five treatment cells. The demonstration
was completed  very successfully and on schedule. Preliminary results at the time of this writing
(November  1994) indicated very effective  treatment  of PCBs and full compliance  with air emission
standards. PCB levels  in the off-gas stack emissions were below  detection  limits. This demonstration
was performed in support of Geosafe's application for a National  TSCA Operating Permit from EPA.
Based on the preliminary results, Geosafe is quite confident  that the desired  permit will be forthcoming
after EPA has completed their evaluation of the project.

After completion of the TSCA demonstration  project, Geosafe mobilized its  equipment to the Wasatch
Chemical Superfund Site in Salt Lake City, Utah. Here the process will be employed for treatment of
approximately 6,000 tons of soil and debris  contaminated  with dioxin, pentachlorophenol, numerous
pesticides, and other organics.  In addition,  Geosafe has obtained contracts for significant test work
involving hazardous, radioactive, and mixed waste applications for sites in Australia and Japan.

The ISV  technology was originally  developed for the U.S. Department of Energy (DOE),  Office of
Technology Development,  at the Pacific Northwest Laboratory (operated by Battelle Memorial  Institute).
DOE continues to fund an ISV development  program directed to  exploring  many  possible applications
for ISV within the DOE Weapons Complex. Tests and demonstrations are being  performed at engineer-
ing-, pilot-, and large-scale.  The technology  is  scheduled  for demonstration at large-scale on buried
cesium- and strontium-bearing waste at the Oak Ridge National Laboratory during the 1995 fiscal year.

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A. 12    Review of Parsons  Chemical  Site Experience

Geosafe considers the  Parsons  Chemical project to have  been highly  successful, while recognizing that
there were difficulties  associated with it that had to be overcome.  The site posed many challenges that
had not been previously experienced by Geosafe or the ISV technology.  These challenges had the effect
of slowing the project down during the first few melts; however, they were  all overcome and the ISV
technology was further advanced from the experience.

A. 12.1  Unusual Challenges

The site soil conditions posed  the biggest challenges. Treatability testing at engineering-scale  had been
successfully performed on soil from the site prior to initiation of large-scale activities. Although the
testing was useful for indicating expected treatment  effectiveness, it  did not provide indication of the
challenges that would be posed  by the very high moisture  content, high clay  content soil at the site.  This
soil proved to be very difficult to work with in either the wet (fully saturated, highly fluid) or dry
(concrete-like) conditions.  These characteristics required special provisions  for the placement  of starter
paths  and the  operation of wheeled  equipment on the site.  These provisions included  establishing  a dry
area over the wet soil to allow proper starter path  placement, stabilizing high traffic personnel and
vehicle pathways  with rock, and using wood "floats" to support crane outriggers.

The saturated soil and high  ambient humidity conditions resulted in  unusually high  moisture removal
loadings on the off-gas  treatment  equipment.  Whereas moisture  removed  from the treatment  zone
usually can be passed through the treatment  system as humidity (water vapor), without accumulation
as liquid,  the quantity  of  water encountered at times  during the project resulted in  water accumulation.
It was necessary to send this water off-site for treatment and disposal.

Water from the soil also contained dissolved solids at high enough levels to cause solids buildup
problems between the  quencher and scrubber  stages of the  off-gas treatment  system. This problem was
solved by modifying the  quencher in a manner that  prevented  the occurrence of deposits.

When  wet, the  soil  exhibited a noticeable sulfurous  odor.  In addition,  a nonhazardous but noticeable
odor developed during  ISV processing that was due to sulfur and organic materials in the soil. The odor

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was initially minimized during operations by  minimizing the level  of sulfurous buildup in the scrub
solution.  The odor was eliminated midway through the project by the addition of a thermal oxidizer as
a final polishing stage of the off-gas treatment system.

The last  challenge was due to  site soil conditions which resulted in a greater melt width to depth ratio
than had previously been experienced with the  ISV technology. This resulted in melting more clean  soil
than desired adjacent to the treatment trench; it also resulted in difficulties attaining the desired depth
in the early melts. The cobble  rock walls that had been placed around  the designated melting region to
minimize overmelting into  clean adjacent soil were found to be  only  partially  effective for this purpose;
they slowed the  lateral melt growth but did not stop it. This challenge was overcome by using refractory
barriers  that effectively controlled melt width and helped attain  the desired depth. A significant benefit
from the wider than expected melts was that the number of melts was reduced from nine to eight.

A. 12.2 Performance Results

The project statement of work  stipulated the following performance criteria for the vitrification treatment
portion of  the project:

        •       organic ORE  of 99.999%
        •      production  of a high integrity  vitrified monolith that:  1) is highly resistant to erosion,
               2) is substantially chemically inert,  and 3) permanently immobilizes toxic metals and
                radionuclides present in  the  soil;
        •      volume reduction of at least 10% ; and
        •       compliance with Michigan State air  emission standards

Large amounts of performance  data were acquired during the project. The SITE demonstration
performance results  reported in this  document are typical for the project overall. The results indicate
attainment of all the technical performance criteria, as discussed  further below.

Relative  to organic DRE, chemical analyses and TCLP testing confirmed  the  absence of organics in the
vitrified  product. It is reasonable to assume zero levels of organics in the vitrified material, regardless
of analytical method detection limit capabilities  due to the  fact that organics cannot exist at the

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temperatures experienced in molten  soil. Therefore, relative to the treatment  zone itself, essentially
100% destruction and/or removal of organics was  attained.

Relative to removal of organics from the off-gases, typical stack  emission values  for the target pesticides
were  at less than detectable levels as indicated in Table A-l. Assuming the presence of contaminants
at the detection limit values, and  considering the low concentrations of contaminants  in the starting soil,
it was not possible to compute organic DREs with a  mathematical significance beyond three nines.
Geosafe recognizes this result as  an  analytical  limitation rather than an actual performance measure  for
the ISV process.  Geosafe's off-gas treatment system is  qualified to produce a minimum of three nines
itself, and numerous prior tests have  indicated that another two to three nines of destruction efficiency
may be expected within the treatment zone before  entering the off-gases.

Relative to the vitrified monolith, a typical high integrity, chemically inert vitrified product was
produced. TCLP  testing indicated full  compliance for  organics and all priority pollutant metals. The
required 10% minimum volume reduction  was far exceeded by an actual volume  reduction of about
35%.

The process was  found to be in full  compliance with air  emission standards. Stack gas  sampling was
performed many  times during the project. Typical  results  are presented in Table A-l.

A. 12.3  Notable  Achievements

Geosafe recognizes that the project had value for the ISV technology far beyond the meeting of site
cleanup and performance objectives. Since this was Geosafe's first commercial  large-scale remediation
project, this project was very important for demonstrating  the capabilities of Geosafe  and the ISV
technology in many related areas, including:

        •      demonstrated applicability to high  moisture  (fully saturated), high clay content soils;
        •      demonstrated ability to process soil contaminated with organics and heavy metals;
        •      demonstrated ability  to process debris  (drum lids, tires, roots and vegetation, PPE);
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Table A-l.  Off-Gas Emission Performance
               Comuonent            ARAR Level flb/hr)          ISV Level


               Mercury                 5.9 x 10"                       1.2  x 1CT* I


               Chlordane               2.5  x 10+1                   <1.1  x 10'7*


               Dieldrm                 2.8 x 10"                    <2.2  x 10'5*


               DDT                    1.0  x ID'2                    <2.2  x 10'5*
               *  Detection limit value
               demonstrated ability to comply with typical state ARARs, especially air emission
               standards;

               ability to control/eliminate  odors;

               demonstrated  high  equipment  reliability;

               demonstrated  flexibility/adaptability of the off-gas treatment system to accommodate
               varying site conditions;

               demonstrated  process  equipment  controllability;

               verification of staff capabilities and remote site staffing policies;

               developed methods  of melt width control;

               developed method of startup in fully saturated soils;

               verification  of thermal efficiencies;

               acquisition of soil vapor pressure  data adjacent to the melt, and confirmation  that such
               pressures do not pose problems to application of the process in tight (high clay) soils;

               ability to operate during severe winter weather;
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        o      a good level of public acceptance for the project; and
        o      acquisition of cost related performance information.

Geosafe notes that overall operations efficiencies improved throughout the project.  Whereas the first
four melts required about six months to complete (due somewhat to technical and regulatory delays),
the final four melts were performed in less than three months. This is indicative of the advancement of
ISV processing capability that was developed during the project.

A. 13   Review  of SITE Demonstration Results

Geosafe has  reviewed the SITE  demonstration results  presented in this document and does not take
significant issue with the information reported. Geosafe operations staff noted that the demonstration
melt was performed  without any notable difficulties,  and that the  equipment performed flawlessly
throughout the  demonstration.

Geosafe does note that the economic analysis portion of the document makes a number of assumptions
that are based on the  Parsons experience but  which  do not represent Geosafe's current capabilities with
the ISV technology. We  understand the standardized approach used for this analysis, and the necessity
to use  the demonstration  results as the primary basis for projections. However, we  note that the Parsons
project was the  first large-scale commercial  remediation project performed with the ISV technology.
Geosafe made significant improvements to the equipment and process efficiencies throughout the project.
Further advances have been made since completion of the Parsons project, most notably in the areas
of reduced hood movement time and ability  to control  melt width and the amount of overmelting into
clean soil. Geosafe did not perform well in these two areas during the first half of the Parsons project.
That resulted in excessive time and costs which are not a good basis for estimating  Geosafe's current
capabilities

Geosafe also notes that the  ISV technology is quite adaptable to unusual site conditions, and that there
are many engineering means by  which apparent limitations  can be accommodated.  Geosafe  does  not
fault the SITE Program for the analysis presented. However, given these considerations, Geosafe
encourages potential users to request  an applicability analysis and cost estimate for specific  applications
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rather than assuming that the  application limitations and cost estimates presented by the SITE Program
are correct for all applications

A. 14  Acknowledgement

Geosafe acknowledges the support provided by EPA, and the fine work by Science Applications
International  Corporation  (SAIC), and EPA's other contractors throughout the Parsons Project and the
SITE demonstration. Geosafe believes  that such support is critical to the  development,  demonstration,
and commercial implementation  of  innovative  technologies.
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•& U.S. GOVERNMENT PRINTING OFFICE: 1995 651-342

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