EPA/540/R-94/528
                                               April 1995
INNOVATIVE TECHNOLOGY EVALUATION REPORT

   Radio Frequency Heating, KAI Technologies, Inc.
  RISK REDUCTION ENGINEERING LABORATORY
   OFFICE OF RESEARCH AND DEVELOPMENT
  U.S. ENVIRONMENTAL PROTECTION AGENCY
           CINCINNATI, OHIO 45268
                                      Printed on     Paper

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                                          NOTICE
       The information in this document has been funded by the U.S. Environmental Protection Agency
(EPA) under the auspices of the Superfund Innovative Technology Evaluation Program under Contract No.
68-CO-0048 to Science Applications International Corporation. 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 or 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 in the 1986
Superfund Amendments.  The SITE Program is a joint effort between the U.S. Environmental Protection
Agency (EPA) Office of Research and Development (ORD) and Office of Solid Waste and Emergency
Response.  The purpose of the program is to enhance the development of hazardous waste treatment
technologies necessary for implementing new cleanup standards that require greater  reliance on permanent
remedies.  This is accomplished by performing technology demonstrations designed  to provide engineering
and economic data on selected technologies.

       This project consisted of an evaluation of an in situ radio frequency heating (RFH) technology
developed by KAI Technologies, Inc. (KAI).  As a part of this evaluation, a Demonstration Test was
conducted by the 'SITE Program in coordination with research efforts sponsored  by the U.S. Air Force
(USAF).  During the demonstration, the KAI in  situ RFH system was used to heat soil containing organic
contaminants.  The goals of the SITE Program study, summarized in this Innovative Technology Evaluation
Report were:  1) to assess the ability of in situ RFH to remove organic contaminants from a contaminated
site at Kelly Air Force Base and 2) to develop capital and operating costs for the technology.

       Additional copies of this  report may be obtained  at no charge from  EPA's Center for
Environmental Research Information  (CERI), 26 West Martin Luther  King  Drive,  Cincinnati, Ohio, 45268,
(513) 569-7562, using the EPA document number found on  the report's front cover.  Once this supply is
exhausted, copies can be purchased from the National Technical Information Service, Ravensworth
Building, Springfield, Virginia, 22161, (800)  553-6847.  Reference copies will  be available in the
Hazardous Waste Collection at EPA libraries. Information regarding the availability of other  reports can
be obtained by calling ORD Publications at (513) 569-7562 or the  SITE Clearinghouse Hotline at (800)
424-9346.  To obtain further information regarding the SITE Program and other  projects within the SITE
Program, telephone (513) 569-7696.
                                                  E. Timothy Oppelt, Director
                                                  Risk Reduction Engineering Laboratory
                                              111

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                                         ABSTRACT
       The KAI Technologies radiofrequency heating system was demonstrated at Site S-l at Kelly Air
Force Base in San Antonio, Texas.  Site S-l was formerly used for intermediate storage of wastes destined
for      reclamation and was contaminated with mixed solvents,  carbon cleaning compounds, petroleum
oils and lubricants at depths up to 30 feet.  The radiofrequency heating system was to be used to heat the
soil to facilitate the removal of these contaminants via soil vapor extraction. A separate soil vapor
extraction system was used for this demonstration, but was not evaluated as part of this demonstration.

       Results of this demonstration indicate that contaminant removal (measured as TRPH) varied
between 29 % and 42 % .  Reasons behind the results observed are discussed in this report.  A cost analysis
of the use of the technology is also presented.
                                              IV

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                                  TABLE OF CONTENTS
Section                                                                                 Page

Notice	      ii
Foreword	     ill
Abstract	     iv
List of Tables  	    viii
List of Figures  	    viii
Abbreviations  	     ix
Acknowledgments  	      x
Executive Summary 	     xi

1.  Introduction         	     1

    1.1     Background  	    1
    1.2    Brief Description of the SITE Program and Reports	     2
    1.3     Purpose of the ITER	     4
    1.4    Technology Description  	• •   4
    1.5     Key Contacts   	   9
2.  Technology Applications Analysis  	    11

    2.1     Objectives:  Performance  Versus ARARs	   11

           2.1.1     CERCLA	   11
           2.1.2     RCRA	   14
           2.1.3     CAA	   15
           2.1.4     SDWA	    15
           2.1.5     CWA  	   16
           2.1.6     TSCA  	   16
           2.1.7     OSHA Requirements  	  17

    2.2    Operability of the Technology  	    18
    2.3    Applicable Wastes  	    19
    2.4    Key Features of theKAI RFH Technology  	    20
    2.5    Availability and Transportability of the System  	    20
    2.6    Materials Handling Requirements  	    21
    2.7    Site Support Requirements	    21
    2.8    Limitations of the Technology	  22
    2.9    References  	   23

3.  Economic  Analysis	    24

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                             TABLE OF CONTENTS (CONTINUED)
Section
    3.1     Introduction  .................................................  24
    3.2     Basis of Economic Analysis ......................................   24
    3.3     Issues and Assumptions .........................................   25

           3.3.1     Site Preparation .......................................   27
           3.3.2     Permitting and  Regulatory  ................................   27
           3.3.3     Equipment   ...........................................  27
           3.3.4     Startup and Fixed .......................................  29
           3.3.5     Operating Costs for Treatment  .............................   30
           3.3.6     Supplies  .............................................  31
           3.3.7     Consumables ..........................................  31
           3.3.8     Effluent Treatment and Disposal  ....................... ,  - - - -   32
           3.3.9     Residuals and Waste Shipping, Handling, and Transport ............  32
           3.3.10   Analytical Services  .....................................   32
           3.3.11    Facility Modification,  Repair, and Replacement  ..................   33
           3.3.12   Site Demobilization   ....................................   33

    3.4     Results of Economic Analysis  .....................................   33
    3.5     References   ..................................................  34

4. Treatment Effectiveness   .............................................   36

    4.1     Background  .................................................  36
    4.2     Methodology  .................................................  41

           4.2.1     Soil ................................................  41
           4.2.2     SVE Vapor Stream .....................................   46
           4.2.3     Soil Vapor  ..........................................   46
           4.2.4     Groundwater .........................................   46

    4.3     Performance Data  ............................................   47

           4.3.1      Soil Samples .........................................   47
           4.3.2     SVE Vapor Stream ......................................   51
           4.3.3      Soil Vapor Gas .......................................    52
           4.3.4     Groundwater Samples ...................................    53
           4.3.5      Moisture   ............................................   53

    4.4    Contaminant  Migration  ...........................   53
    4.5    Residuals   [[[   56

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                          TABLE OF CONTENTS (CONTINUED)


Section                                                                           Page

5.  Other  Technology Requirements	  57

   5.1    Environmental  Regulation Requirements	    57
   5.2    Personnel  Issues   	   57
   5.3    Community Acceptance	   58
   5.4    References 	   59

6.  Technology  Status	• •	    60

APPENDIX A: Performance Data  	    61
APPENDIX B: Case  Studies	   126
APPENDIX C: Vendor Claims                                                         129
                                          vn

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                                   LIST OF TABLES


Number                                                                            Page

 1   Summary of SVOC Decreases Inside Treatment Zones	   xiii

 2   Evaluation Criteria for the KAI RFH Technology	   xiv

 3   Federal and State ARARs for the KAI RFH Technology	    12

 4   Treatment Costs for the KAI RFH System Treating 10,940 Tons of Soil with a
      95 Percent On-Line Time   	    34

 5   Target VOCs  	  39

 6   Target SVOCs (Acid Extractables)	   40

 7   Target SVOCs (Base/Neutral Extractables)  	    40

 8   Summary of Number of Samples Analyzed for the KAI RFH Test	  45

 9   Summary of SVOC Decreases Inside Treatment Zones	   49

 10   Average Particle Size Distribution (Wet-Sieving Only) 	      51

 11   Radio Frequency RadiationTLVs  	   59
                                   LIST OF FIGURES


Number                                                                             Page

1    Diagram of KAI RFH System 	     6

2    Regional Maps Showing Demonstration Location  	    37

3    Plan View of Demonstration  Site  	     38

4    Sampling Depths and Locations  	  42

5    Locations of Groundwater  Sample Collection 	    53
                                         VIM

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                                           ABBREVIATIONS
AC      Alternating Current
ACGIH   American Conference of Governmental
         Industrial Hygienists
AFB     Air Force Base
ANGB    Air National Guard Base
ARAR    Applicable or Relevant and Appropriate
         Requirement
ASTM    American Society for Testing and Materials
ATTIC   Alternative Treatment Technology
         Information Center
bgs      below ground surface
B&RE    Brown & Root Environmental
CAA     Clean Air Act
CERCLA Comprehensive  Environmental Response,
         Compensation, and Liability Act
CERI    Center for Environmental Research Information
CFR     Code of Federal Regulations
CPR     cardiopulmonary resuscitation
CWA    Clean Water Act
DOT     Department of Transportation
EPA     Environmental Protection Agency
FCC     Federal Communication Commission
FID     flame ionization detector
ITER    Innovative Technology Evaluation Report
KAI KAI Technologies, Inc.
LDR     Land Disposal Restrictions
MCL    Maximum Contaminant Level
MDL    Method Detection Limit
MS/MSD Matrix spike/Matrix spike duplicate
NAAQS  National Ambient Air Quality Standards
NPDES  National Pollutant Discharge
         Elimination System
ORD        Office of Research and Development
OSC       on-scene coordinator
OSHA      Occupational Safety and Health
           Administration
OSWER    Office of Solid Waste and
           Emergency Response
PCB       polychlorinated biphenyl
PPE       personal protective equipment
ppm     parts per million
PQL       Practical quantitation limit
QA/QC     quality assurance/quality control
RCRA      Resource Conservation and Recovery Act
RF         radio frequency
RFH       radio frequency heating
RI/FS      remedial investigation/feasibility study
RPM      remedial project manager
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
SVE       Soil vapor extraction
S V O C    Semivolatile organic compound
TLV       Threshold Limit Value
TRPH      Total recoverable petroleum hydrocarbons
TSD       Treatment, Storage, and Disposal
TSCA      Toxic Substances Control Act
USAF      U.S. Air Force
VISITT     Vendor Information System for Innovative
           Treatment Technologies
v o c      Volatile organic compound

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                                  ACKNOWLEDGMENTS
       This report was prepared under the direction and coordination of Ms. Laurel Staley, Environmental
Protection Agency (EPA) Superfund Innovative Technology Evaluation (SITE) Work Assignment Manager
in the Risk Reduction Engineering Laboratory (RREL), Cincinnati, Ohio. EPA-RREL contributors and
reviewers for this report were Teri Richardson, Michelle Simon and Robert Stenburg.  Other contributors
and reviewers were Raymond Kasevich and Dave Faust of KAI Technologies, Inc. and Victoria Wark,
Paul Carpenter and Lt. Donald Aide of the United States Air Force.

       This report was prepared for EPA's SITE Program by the Technology Evaluation Division of
Science Applications International Corporation (SAIC) in Cincinnati, Ohio under Contract No. 68-CO-
0048. This report was written by Sharon Krietemeyer and Eric Saylor. The Work Assignment Manager
for the project was Margaret Groeber.

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                                  EXECUTIVE SUMMARY

       This document is an evaluation of the performance of an in situ radio frequency heating (RFH)
system developed by KAI Technologies, Inc. (KAI). This report examines data from the demonstration
concerning the technical and economic aspects of KAI's RFH technology, particularly its ability to
remediate soil contaminated withorganics.

       A demonstration of KAI's in situ RFH system was conducted from January 1994 to July 1994 at
Kelly Air Force Base in San Antonio, Texas.  This demonstration was conducted as a joint effort of the
U. S . Environmental Protection Agency (EPA) Superfund Innovative  Technology Evaluation (SITE)
Program  and the U.S. Air Force (USAF).

       EPA  conducted pre- and post-treatment soil sampling and analysis. USAF provided the site for
the test; necessary logistical and administrative support; and made arrangements with the technology
developer, KAI, to operate its  RFH process during the test.

       Both  EPA and USAF intend to prepare separate reports on this project. Each report will examine
the data and results of the test in light of its own perspective.  This report, prepared by EPA, discusses the
results of the  KAI demonstration with respect  to the technology's potential Superfund applications.

       The technology was never intended to remediate the site during the demonstration. Nevertheless,
within certain limitations, changes in contamination levels within the area treated  during the demonstration
can be used to provide  a very preliminary indication of how the technology in its present state of
development might perform if used to remediate a site.   These limitations include the fact that the
technology is still being developed and may perform differently when used at a future date and at a
different site.  In addition, during the demonstration,  implementation of the soil vapor extraction (SVE)
system and other factors may have affected the data obtained from the demonstration, making it difficult
to isolate the effect of the RFH on contaminant removal from the soil.  These limitations  are  discussed in
more detail in the report.
                                              XI

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       KAI Technologies disagrees with the use of data from the demonstration to predict performance
in an actual remediation.  For a more detailed discussion of KAFs perspective on the results of the

demonstration, please see Vendor's Claims in Appendix C


       The RFH technology uses electromagnetic energy in the radio frequency (RF) band to heat
contaminated soil in situ, thereby potentially enhancing the performance of standard SVE technologies.

The RF energy volatilizes contaminants and moisture in the soil, and the resulting steam and  contaminant

vapors are collected by a standard SVE system.


       The demonstration  began with initial sampling conducted from January 11, 1994 through January

19, 1994, during the installation of the  subsurface system components.  RF energy was applied to the soil
from April 24, 1994 through June 7, 1994. The soil was allowed to cool for 1 month, and final sampling

was conducted from July 7, 1994 to  July 13, 1994. Based on the sampling data collected before and after

treatment, an evaluation was made concerning the technology's ability to  remove total recoverable

petroleum hydrocarbons (TRPH)  contamination from soil. This was considered the primary objective of
the demonstration. Because RFH  was actually applied only to the upper half of the original treatment zone,

this upper region is designated the "revised treatment zone."  A comparison of TRPH concentrations in

the pre- and post-treatment soil samples within these two zones yielded the following results:

            Within the original treatment zone there was a statistically significant change in TRPH
            concentrations at the 90 percent confidence level.  The estimated geometric mean decrease
            was 29 percent.  Concentrations in the pretreatment samples varied from less than 169 to
            105,000  parts per million(ppm); post-treatment samples varied from less than 33 to 53,200
            ppm.

            Within the revised treatment zone there was a statistically significant change in TRPH
            concentrations at the 95 percent confidence level.  The estimated geometric mean decrease
            was 49 percent.  Concentrations in the pretreatment samples varied from less than 169 to
            6,910 ppm;  post-treatment samples varied from less than 33 to 4,510 ppm.

            Outside the original treatment zone there was a statistically significant  change in TRPH
            concentrations at the 97.5  percent confidence level. The estimated geometric mean  increase
            was 90 percent.  Concentrations in the pretreatment samples varied from less than 171.5 to
            43,500 ppm; post-treatment samples varied from 762 to 92,600 ppm.

            Outside the revised treatment zone there was a statistically significant change in TRPH
            concentrations at the 80 percent confidence level. The estimated geometric mean increase
            was 39 percent.  Concentrations in the pretreatment samples varied from less than 171.5 to
            105,000  ppm; post-treatment samples varied from 184 to 92,600 ppm.
                                             xn

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       Contaminant removals did not meet projections. Before the RFH system was turned on, USAF
and KAI made the decision to apply heat to the revised treatment zone.  They targeted only volatile
organics,  specifically gasoline-range hydrocarbons, as the contaminants of concern, which allowed KAI
to lower the treatment temperature from 150°C to a range of 100 to 130°C.  These changes were based on
timing and funding limitations placed on the project by USAF just prior to startup. (No changes in the
Demonstration Plan were made because the SITE  Program was not informed about this decision until after
post-treatment  sampling was completed.)

       A number of problems with the design and operation of the SVE  system were identified after the
demonstration was complete. These problems included vapor extraction wells screened below the revised
treatment zone, which may have drawn contaminants into the cooler soil,  and SVE  system configurations
which may have resulted in slow vapor flows within the revised treatment zone and in high vapor flows
from areas outside the revised treatment zone. These problems may have resulted in contaminant migration
into the original treatment zone from the revised treatment zone and from surrounding soils.  In  addition,
only a portion of the revised treatment zone appears to have reached the revised target temperature range
of 100 to 130°C, which was at least partly due to a power supply problem unrelated to the operation of the
KAI RFH system.

       Because of changes  in the RFH system prior to startup and the design of the SVE system, it cannot
be concluded that the changes in TRPH concentration inside  and outside the treatment zones were a result
of RFH treatment.   The soil data indicate changes in TRPH concentration, but it is not possible to
determine what impact RFH had on contaminant removal rates, with the alternative being using the SVE
system alone.

       An economic evaluation was performed based on the original design of the RFH system for the
demonstration. Because of the problems encountered during the demonstration, several assumptions had
to be made about the technology.  Even though no conclusions about the success of RFH at this site can
be made, the economic evaluation assumes the technology  will meet target cleanup levels within a given
time frame.  The results of  this evaluation are as follows:
            The cost to treat approximately 10,000 tons of  contaminated soil using a proposed  full-scale
            in situ RFH  system (including costs  associated with SVE) was estimated by scaling up costs
            for the original treatment zone.  Cleanup costs are estimated to be $336 per ton if the system
            is  utilized 95 percent of the time.  This estimate does not include costs for several site- and
            project-specific factors.
                                              xiii

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       In addition to evaluating changes in TRPH concentrations, evaluations were made concerning the
technology's ability to remove semivolatile organic compounds (SVOCs) and volatile organic compounds
(VOCs) from soil. These were considered secondary objectives of the demonstration.

       A comparison of SVOC concentrations in the pre- and post-treatment soil samples within the
original  treatment  zone  indicated that  only benzo(b)fluoranthene,  benzo(a)pyrene, and bis(2-
ethylhexyl)phthalate exhibited statistically significant decreases at a confidence level of 80 percent or
greater. In the revised treatment zone, benzo(b)fluoranthene,  benzo(a)pyrene, chrysene, pyrene, and
fluoranthene only exhibited statistically significant decreases at a confidence level of 80 percent or greater.
Estimated mean decreases for SVOCs in the original and revised treatment zones are presented in Table 1.

                 Table 1. Summary of SVOC Decreases Inside Treatment Zones

 contaminant                 Geometric Mean Percent Decrease in   Geometric Mean Percent Decrease in
	Original Treatment Zone	Revised Treatment Zone	
 Benzo(b)fluoranthene                        44                                 40
 Benzo(a)pyrene                             44                                 43
 Bis(2-ethylhexyl)phthalate                     55                                  **
 Chrysene                                                                     40
 Pyrene                                                                       60
                                           ;k ;k
 Fluoranthene	53	
** No statistically significant change at the 80 percent confidence level.

       As with the TRPH data, it cannot be concluded that the changes in SVOC concentrations inside
and outside the treatment zones were a result of RFH treatment or were due solely to the application of
SVE. Pre- and post-treatment concentrations of individual VOCs were also measured, but an evaluation
of these data did not indicate any statistically significant decreases. No conclusions about changes in VOC
concentrations  can be made.

       The KAI RFH technology was evaluated based on the nine criteria used for decision-making in the
Superfund feasibility study process. Table 2 presents the evaluation.
                                              XIV

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                    Table 2. Evaluation Criteria for the KAI RFH Technology
Evaluation Criteria
Performance
Overall Protection of Human
Health and the Environment
Compliance with Federal
ARARs1
Long-term Effectiveness and
Performance
Reduction of Toxicity, Mobility,
or Volume through Treatment
Short-term Effectiveness
Implementability
Cost2


State  Acceptance

Community Acceptance
    The contaminant removals achieved may not provide adequate
    protection.
    Requires measures to protect workers during installation and
    treatment.
    During the limited time period of the SITE demonstration, soil
    samples exhibited estimated average TRPH decreases of 29% in the
    original treatment zone and 49% in the revised treatment zone.

    Vapor collection and treatment are needed to ensure compliance with
    air quality standards.
    Construction and operation of onsite vapor treatment unit may require
    compliance with location-specific ARARs.
    RF generator must be operated in accordance with Occupational
    Safety and Health Administration (OSHA) and Federal
    Communication Commission (FCC) requirements.

    The contaminant reductions observed during the demonstration period
    show that the RFH technology may not adequately remove the
    contamination  source.
    Involves some residuals treatment (vapor stream).

    Potentially reduces waste volume by volatilizing contaminants, which
    are then collected (in a more concentrated form) by an SVE system.
    Potentially reduces long-term contaminant mobility by volatilizing
    contaminants, which are then removed from the soil and collected by
    an SVE system.

    Presents minimal short-term risks to workers and community from air
    release during treatment.
    No excavation is required, although drilling will disturb the soil to
    some extent.

    RF generator must be operated in accordance with OSHA and FCC
    requirements.
    Other pilot-scale tests have been completed; no full-scale applications
    to date.

    $336 per ton based upon scaling up the pilot-scale, manually- operated
    system to full-scale, with 95% on-line efficiency.

    No excavation is required, which should improve State acceptance.

    No excavation is required, which should improve community
    acceptance.
    May  require  some community education to assure residents that the
    operation of the RFH system is compliant with OSHA safety
    requirements.	
          = Applicable or Relevant and Appropriate Requirements
   Actual cost of a remediation technology is highly site-specific and dependent on the original target cleanup level, contaminant
   concentrations, soil characteristics, and  volume of soil.  Costs associated  with permitting, site preparation, analytical
   programs, and residuals management were not included.  Cost data presented in this table are based on the treatment of
   approximately 10,000 tons of soil (95% on-line efficiency), and include costs associated with SVE. It assumes target cleanup
   levels will be met within a given time frame, even though this was not observed during the demonstration.
                                                  XV

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                                       SECTION 1
                                    INTRODUCTION
       This section provides background information regarding the Superfund Innovative Technology
Evaluation (SITE) Program, discusses the purpose of this Innovative Technology Evaluation Report
(ITER), and describes the in  situ radio frequency heating (RFH) technology developed by KAI
Technologies, Inc. (KAI). For additional information about the SITE Program, this technology, and the
demonstration site, contact the individuals listed at the end of this section.

1.1    BACKGROUND
       A Demonstration Test of KAFs RFH technology was conducted by the SITE Program in
coordination with research efforts sponsored by the U.S. Air Force (USAF).  Although the  technology
was developed by KAI, Brown & Root Environmental (B&RE) was EPA's primary contact during the
demonstration. B&RE was hired by USAF to provide an evaluation of KAFs RFH technology. (The
USAF contract  was awarded to Halliburton NUS, which has since reorganized.  The work was performed
by B&RE which is owned by Halliburton NUS.) B&RE provided project and site management, designed
and operated the vapor collection and treatment systems, provided  logistical support, and assisted KAI
in the onsite assembly and operation of the RFH system.  KAI was subcontracted by B&RE to operate
its Mobile RFH system with an applicator design adapted for the Kelly Air Force Base  (AFB) test
environment.

       The KAI RFH process was demonstrated under the SITE Program from January  1994 through
July 1994 at Kelly AFB near San Antonio, Texas. The SITE demonstration was conducted at Site S-l,
located near the northern boundary of Kelly AFB.  This site was historically used as an intermediate
storage area for wastes destined for offsite reclamation. The soil is contaminated with mixed solvents,
carbon cleaning compounds, and petroleum oils and lubricants. The results of the Demonstration Test
constitute the basis for this report.

       The RFH technology uses electromagnetic energy in the  radio frequency (RF) band to heat
contaminated soil in situ. Standard alternating current (AC) electricity is converted to RF energy by an

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RF generator. The RF energy is conveyed into the  soil by one or several  antennae. The design
temperature will vary from site to site, depending on the contaminants of concern. KA1 claims that the
RFH technology can be applied to soil contaminated with volatile and semivolatile organic compounds
(VOCs and SVOCs), which are volatilized when the soil is heated. Soil moisture is also volatilized
during treatment and may provide a steam sweep within the treatment zone. A vacuum is applied to the
treatment zone, and the steam and organic vapors are collected and channeled to an above-ground vapor
treatment system.   A vapor barrier assists in the collection of the hot gases and prevents fugitive
emissions.

1.2    BRIEF DESCRIPTIONS OF THE SITE PROGRAM AND REPORTS
       In 1986, the U.S. Environmental Protection Agency (EPA) Office of Solid Waste and Emergency
Response (OSWER) and Office of Research and Development (ORD) established the SITE Program to
promote the development and use of innovative technologies to clean up Superfund sites across the
country.  Now in its ninth year, the SITE Program is helping to provide the treatment technologies neces-
sary to implement new Federal and State cleanup standards aimed at permanent remedies rather than
quick fixes. The SITE Program is composed of four major elements: the Demonstration Program, the
Emerging Technologies Program, the Measurement and Monitoring Technologies Program, and the
Technology Transfer Program.

       The major focus has been  on the Demonstration  Program, which is designed to provide engineer-
ing and cost data for selected technologies.  To date, the Demonstration Program projects have not in-
volved funding for technology developers. EPA and developers participating in the program share the
cost of the demonstration. Developers are responsible for demonstrating their innovative systems at
chosen sites, usually Superfund sites. EPA is responsible for sampling, analyzing,  and evaluating all test
results. The final product of each demonstration is an assessment of the technology's performance,
reliability, and costs. This information is used in conjunction with other data to select the most appro-
priate technologies for the cleanup of Superfund sites

       Developers  of innovative technologies typically apply to the Demonstration  Program by respond-
ing to EPA's annual solicitation. EPA also accepts proposals any time a developer has a Superfund waste
treatment project scheduled.  To qualify for the program, a new technology must be available  as apilot-
or full-scale system and offer some advantage over existing technologies. Mobile technologies are of
particular interest to EPA.

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       Once EPA has accepted a proposal, EPA and the developer work with the EPA Regional Offices
and State agencies to identify a site containing waste suitable for testing the capabilities of the technology.
EPA prepares a detailed sampling and analysis plan designed to evaluate the technology thoroughly and
to ensure that the resulting data are reliable.  The duration of a demonstration varies from a few days to
several years, depending on the length of time and quantity of waste needed to assess the technology.

       KAI entered the SITE Program through  a cooperative  agreement between USAF and EPA
USAF invited EPA to participate in the demonstration to provide sampling and analytical services. EPP
would then publish reports based upon the outcome of the demonstration.

       The results of the KAI RFH Technology Demonstration  are published in two documents:  the
ITER and the SITE Technology Capsule.  The ITER includes information on demonstration costs and
performance, implementation problems/limitations, site conditions for which  the technology is applicable,
waste handling requirements, and an evaluation of the technology with consideration of the nine criteria
used by remedial project managers (RPMs) during the remedial  investigation/feasibility study (RI/FS)
process.   The  ITER  also describes the demonstration, the developer's experience prior to  the
demonstration, and the adaptability of the technology.  The SITE Technology Capsule is a concise
summary of the ITER  Both the SITE Technology Capsule and the ITER are intended for use by RPMs
making a detailed evaluation of the technology for a specific site and waste.

       The second element of the SITE Program is the Emerging Technologies Program, which fosters
the further investigation and development of treatment technologies that are still at the laboratory scale.
Successful validation of these technologies can lead to the development of a system ready for field
demonstration and participation in the Demonstration Program.

       The third component of the SITE Program, the Measurement and Monitoring Technologies
Program, provides assistance in  the development and demonstration of innovative technologies to
characterize Superfund sites.

       The fourth component of the SITE Program is the Technology Transfer Program, which reports
and distributes the results of both  Demonstration and Emerging Technologies Program studies through
ITERs and abbreviated bulletins

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1.3    PURPOSE OF THE ITER
       This ITER provides information on the KAIRFH technology and includes a comprehensive
description of the demonstration and its results. The ITER is intended for use by EPA RPMs, on-scene
coordinators (OSCs), contractors, and others involved in the remediation decision-making process and
in the implementation of specific remedial actions.   The ITER is designed to aid decision makers in
determining whether specific technologies warrant further consideration as applicable options in particular
cleanup operations.   To encourage  the general use of demonstrated  technologies, EPA provides
information regarding the applicability of each technology to specific sites and wastes. The ITER
includes information on cost- and site-specific  characteristics. It also discusses advantages, disadvantages,
and limitations of the technology.

       This report presents information useful in determining the applicability and estimated cost of
using a full-scale RPH system at a Superfund site. The proposed commercial-scale system, which utilizes
a 200-kilowatt (kW) RF generator, is  described in this document. The applicability of the proposed
system and treatment costs for a full-scale remediation using the 200-kW system are presented.   Costs
are presented on a per ton basis to facilitate comparison to other available technologies.

       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 waste treated at the
demonstration site.   Therefore, successful field demonstration of a technology at one  site does not
necessarily ensure that it will be applicable to 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.

1.4    TECHNOLOGY DESCRIPTION
       RPH technologies  use RF energy to heat soil in situ,  thereby potentially enhancing the
performance of  standard SVE technologies.  The RF energy heats the soil by a dielectric heating process
that does not rely on soil permeability or conductive heat transfer  mechanisms.   The developer claims
that, for low thermal conductivity solids,  RFH is a faster and more efficient heating mechanism than
convective or radiative heating processes.   Some conductive heating  also occurs in the soil.  It is
potentially applicable to unsaturated (vadose zone) soils contaminated withVOCs and SVOCs. Moisture
present in the soil is also volatilized and may  provide a steam sweep within the treatment zone.  Steam

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and contaminant vapors are collected by a standard soil vapor extraction (SVE) system and channeled to

a vapor treatment system. The vapor treatment system is site- and contaminant-specific, and therefore

was not included in this evaluation.  A basic schematic of the RFH system used during the SITE

demonstration is shown in Figure 1.


       The components of the KAI RFH system have three major purposes: transmission,  monitoring,

and control of RF energy; collection of vapors; and treatment of vapors.  The primary components of
the system include the following:

       •   RF  Generator — The RF generator is designed to convert 3-phase AC power to RF energy.
           A typical system is designed to operate on one or more Industrial, Scientific, and Medical
           (ISM) bands designated by the Federal Communications Commission (FCC). The RF
           generator used during the SITE  demonstration was operated at 27.12 megahertz (MHz) with
           a maximum power level of 25 kW.

       •   Matching Network — The RFH system also  includes a matching network, which allows the
           RFH system to maximize the fraction of the power from the RF generator that is absorbed
           by the soil. This is important  for two reasons.  First, the higher the fraction of power
           absorbed by the soil, the more energy-efficient the system. Second,  power that is not
           absorbed by the soil is reflected back to the RF generator and other electrical components.
           Excessive reflected power will cause the electrical components to overheat.  The developer
           claims that full automation of the matching network is possible. During the demonstration,
           however, there was always at least one person onsite when the RF power was on.

       •   Diagnostic and Control System — The diagnostic and control system is used to monitor the
           operation of the complete RFH system.   The developer claims that the control computer
           allows for complete, unattended operation with remote control and alarm functions. During
           the  demonstration, however, there was always at least one person onsite when the RF power
           was on.

       •   Applicators — Energy from the RF generator flows through the matching network to the
           applicators, which convey the energy into the soil.  The two applicators used during the
           demonstration were connected with rigid copper transmission lines that were pressurized with
           nitrogen to increase their high voltage handling capability. The applicators were alternately
           selected with a remote-controlled coaxial switch. Each applicator was 3.5  inches in diameter
           and was constructed with aluminum, stainless steel, Teflonn, ceramic, brass, and copper
           components.

       •   Temperature Measuring Devices —  Soil temperature in and around the treatment zone is
           monitored during treatment.    During the SITE demonstration, soil temperatures were
           measured using thermocouples,  fiberoptic sensors, and infrared sensors.  Temperature
           measurement locations are shown in Figure 1. All sensors within the revised treatment zone
           measured temperature indirectly through fiberglass walls or sand barriers. Temperature
           measurements obtained from active extraction wells may have been reduced by air flowing
           through the SVE system. The developer claims that there were no sensors within the revised
           treatment zone that measured the instantaneous, microscopic heating of the contaminants, and

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                                 TD1& TD2Q
                                                                                  /\ = antenna
                                                                                  Q = pressure transducer
                                                                                     . extraction well
3-Phase, 6OHz AC Power
TD3Q






El
1
25'kW,27.12»MHz
Power Source with ~
Instrumentation & Controls


.
r-





-




F1
a




•
F4


E2 £3
A A
W XTC1 T
.-

I Switch |
E4 F3 E5 JA2
• --Hi--^---A---

•
F5
----^ -A- =.=.=.****=** * -A


TC2
*--

.-




i 	
Vapor
Collection
System

TC3
O x
TD6

field profiling wells
• = thermowell
X= thermocouple string




0
TD5





	 1
i
i

Vapor
Treatment System
O
TD4

                       E6
                                          E7
                        EB
                                           0  TD7 & TD8
                                           Figure 1. Diagram of KAI RFH system.
                                                    6

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           that all sensors were likely to provide readings lower than the actual temperatures of the
           materials in the heated zone. No data were provided to support these claims.

           Electromagnetic Field Measuring Devices—  The electromagnetic field generated by the RF
           energy is measured in and around the treatment zone to determine whether the system is
           complying with all regulations concerning electromagnetic fields.   During the SITE
           demonstration, a magnetic field sensor was inserted into five  wells to monitor the
           electromagnetic field within the treatment zone.  Two antenna-based devices were used to
           measure the electromagnetic fields above the surface:   an electric field radiation hazard
           sensor was used near the system, and a biconical dipole antenna was used at distances of 1
           meter, 10 meters, 30 meters, and 300 meters.

           Pressure Transducer Wells  — Pressure transducer wells can be installed to determine the
           effects of the  SVE system.  Prior to and during the SITE demonstration, the vacuum caused
           by the SVE system was measured at the pressure transducer wells. Vacuum measurements
           were also taken at the extraction wells.

           Vacuum Manifold — The extraction  wells feed into a vacuum manifold, which gathers the
           vapors together and channels them into the vapor treatment system.

           Vacuum Source —  A vacuum is induced throughout the treatment zone by pulling air
           through the vacuum manifold and extraction wells. During the SITE demonstration, an air
           compressor and a Venturi tube were used to induce a vacuum.  In a full-scale system, a
           blower would typically be used.

           Vapor Barrier — The system includes a vapor barrier to prevent the release of volatilized
           contaminants and to help to maintain a vacuum in the treatment zone.  During the SITE
           demonstration, a sheet of heavy plastic served as a vapor barrier.

           Vapor Treatment System — Contaminant vapors removed from the treatment zone must
           typically be collected or treated. During the  SITE demonstration,  vapors that condensed in
           the vapor collection system piping were collected as liquids. The uncondensed portion of
           the vapor stream was incinerated in a propane-fueled flare.  Other sites may require more
           complex vapor treatment systems. Because the design of the vapor treatment system is site-
           and contaminant-specific, the vapor  treatment system used during the SITE demonstration
           is not included in this evaluation.
       The RFH system is transported to the site in a trailer with a removable steel shelter that houses
the RF generator, matching network, and diagnostic and control equipment. The onsite assembly of the

RFH system begins with the installation of the subsurface components.  Extraction wells, temperature
measurement wells, electromagnetic field measurement wells, and fiberglass borehole  liners for the
applicators are installed by drilling a hole to the required depth, inserting the  appropriate component, and
backfilling around the component.  Support structures positioned above the applicator boreholes are used

to insert the applicators into the fiberglass borehole liners.  A portion of each subsurface component must
extend above the surface to allow connection to the appropriate above-ground portion of the system.

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       After all subsurface components are installed, the vapor barrier is placed over the treatment zone.
Holes are cut in the vapor barrier to allow connections between the subsurface components and the above-
ground portions of the system.  The vapor barrier is then sealed around each connection. Extraction
wells are connected to the vapor treatment system through the vacuum manifold. Thermocouples are
connected to monitoring instruments.   The applicators are connected to the coaxial switch with RF
transmission  lines.

       After all subsurface components are installed, the vapor barrier is placed over the treatment zone.
Holes are cut in the vapor barrier to allow connections between the subsurface components and the above-
ground portions of the system.  The vapor barrier is then sealed around each connection. Extraction
wells are connected to the vapor treatment system through the vacuum manifold.  Thermocouples are
connected to monitoring instruments.    The antennae are connected to the RF generator and
instrumentation by 1-5/8" rigid copper transmission lines.

       After installation and assembly, the system is tested and any necessary adjustments are made.
If desired, the SVE system may be  operated before heat is applied to  the soil.  The SVE system continues
to operate as the RF system is activated and heat is applied to the soil. The RF energy is applied to the
soil until the termination criteria are  met.  Termination criteria should be established prior to the
remediation effort based  on treatability  study results, site characterization data, and target cleanup levels.
For application of RFH at Super-fund sites, factors such as average soil temperature in the treatment zone
over a specified amount of time and contaminant concentrations in the vapor stream should be considered
when determining termination criteria.   The termination criteria may require adjustment based on
information collected during treatment.

       Because of time and funding constraints imposed on the developer by USAF, RFH was applied
for a predetermined number of days before the RF power was turned off.  These termination criteria may
have limited the RFH system's ability to reach the target removal level.

       After treatment is complete, the treatment zone must be allowed to cool.  If the treatment zone
did not encompass all of the contaminated soil at the site, the above-ground components of the RFH
system can be disassembled, moved to another portion of the site, and reassembled while the soil in the
treatment zone  cools.    If the commercial-scale system includes two sets of subsurface components,
treatment of a second zone can begin while the first zone is cooling.  During the SITE demonstration,
                                              8

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the soil was allowed to cool for 1 month prior to post-treatment sampling. The SVE system was operated
for the first 14 days of the cool-down period.


       After the treatment zone cools, post-treatment soil samples are collectedto determine the extent

of treatment.  Depending upon local regulations, it may be necessary to remove all subsurface

components, and then redrill and seal all boreholes. During the SITE demonstration, it was necessary
to redrill all boreholes and seal them with bentonite at the end of the test.


1.5     KEY CONTACTS

       For more information on the demonstration of the KAI in situ RFH technology, please contact:
       EPA Project Manager for the SITE
       Demonstration  Test:

       Ms. Laurel Staley
       U.S. Environmental Protection Agency
       Risk Reduction Engineering Laboratory
       26 West Martin Luther King Drive
       Cincinnati, Ohio 45268
       (513) 569-7348

       Process Vendor:

       Mr. Raymond Kasevich
       KAI Technologies, Inc.
        170 West Road, Suite?
       Portsmouth, NH 03801
       (603) 431-2266

       Kelly AFB Project Engineer:

       Ms. Victoria Wark
       SA/ALC/EMRO
       305 Tinker Drive, Suite 2, Building 305
       Kelly AFB, TX 78241-5915
       (210) 925-1812
USAF Technical Program Manager, Site
Remediation  Division:

Mr. Paul F. Carpenter
AL/EQW-OL
139 Barnes Drive, Suite 2
Tyndall AFB, FL 32403
(904) 283-6187

B&RE Project Manager:

Mr. Clifton Blanchard
B&RE
800 Oak Ridge Turnpike, Suite A600
Oak Ridge, TN37830
(615) 483-9900

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       Information on the SITE Program is also available through the following on-line information
clearing houses:

       •   The Alternative Treatment Technology Information Center (ATTIC) is a comprehensive,
           automated information retrieval system that integrates data on hazardous waste treatment
           technologies into a centralized, searchable source.  This data base provides summarized
           information on innovative treatment technologies.  The system operator can be reached at
           (703) 908-2137, and system access is available at (703) 908-2138.

       •   The Vendor Information System for Innovative Treatment Technologies (VISITT) data base
           contains information on 154 technologies offered by 97 developers,  (800) 245-4505.

       •   The OSWER CLU-IN electronic bulletin board contains information on the status of SITE
           technology demonstrations. The system operator can be reached at (301) 589-8268.
       Technical reports can be obtained by contacting the EPA Center for Environmental Research
Information (CERI), 26 West Martin Luther Ring Drive, Cincinnati, Ohio 45268 at (513) 569-7562.
                                             10

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                                       SECTION 2
                       TECHNOLOGY APPLICATIONS ANALYSIS

       This section addresses the applicability of the KAI in situ RFH technology to the remediation of
soils contaminated with VOCs and SVOCs. Conclusions are based on results obtained from the SITE
demonstration as well  as additional data provided by KAI and B&RE.  The results of the SITE
demonstration are presented in Section 4 and supplementary data from the demonstration are presented
in Appendix A.  The results of previous RFH treatability studies are summarized in Appendix B.

2.1     OBJECTIVES:  PERFORMANCE VERSUS ARARS
       This subsection discusses specific environmental regulations pertinent to the operation  of the KAI
RFH system, including the transport, treatment, storage, and disposal of wastes and treatment residuals.
The impact of these regulations will be evaluated in light of the demonstration results.  State and local
regulatory requirements, which may be more stringent, will also  have to be addressed by RPMs.
Applicable or relevant and appropriate requirements (ARARs) may include regulations associated with
the following:   the  Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA); the Resource Conservation and Recovery Act (RCRA); the Clean Air Act (CAA); the Safe
Drinking Water Act (SDWA); the Clean Water Act (CWA); the Toxic Substances Control Act (TSCA);
and Occupational Safety and Health Administration (OSHA) regulations. These seven general ARARs
are discussed in the following subsections; specific ARARs must be identified by RPMs for each site.
Some specific Federal  and State ARARs that may be applicable to the  KAI RFH technology are identified
and discussed in Table 3.

2.1.1  CERCLA
       CERCLA of 1980, as amended by the  Superfund Amendments and Reauthorization Act  (SARA)
of 1986, provides for Federal funding to respond to releases of hazardous substances to air, water, and
land. Section  121 of SARA, Cleanup Standards, states a strong  statutory preference  for remedies that
are highly reliable and provide long-term protection.  It strongly  recommends that remedial actions use
onsite treatment that "	permanently and significantly reduces the volume, toxicity, or mobility of
                                            11

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       Table 3. Potential Federal and State ARARs for the Treatment of Contaminated Soil by the KAI RFH System
                                                         at a Superfund Site
Process Activity
Waste
characterization
(untreated waste)
Storage prior to
processing
Waste processing
Storage after
processing
ARAR
RCRA' 40 CFR2 Part 261 or
State equivalent
TSCA3 40 CFR Part 761 or
Stale equivalent
< 90 days: RCRA 40 CFR
Part 262 or State equivalent
> 90 days: RCRA 40 CFR
Part 264 or State equivalent
RCRA 40 CFR Part 264 or
State equivalent
CAA4 40 CFR or Stale
equivalent
RCRA 40 CFR Part 264 or
Stale equivalent
TSCA 40 CFR Part 761.65
Description
Identification and charactetization of
the soil to be treated.
Standards that apply to the treatment
and disposal of wastes containing
polychlotinated biphenyls (PCBs).
Standards applicable to the storage of
hazardous waste in containers or tanks.
Standards applicable to the treatment of
hazardous waste at permitted facilities.
Standards applicable to emissions from
treatment equipment.
Standards that apply to the storage of
hazardous waste in containers or tanks.
Standards that apply to storage of
wastes containing F'CBs.
Basis
A requirement of RCRA prior to managing the
waste.
During waste characterization, PCBs may be
identified in the waste and, if present above
regulatory thresholds (50 ppm for TSCA), the
waste is subject to TSCA regulations.
Contaminated groundwater extmcted by
dewateting wells and soil cuttings from
boreholes meeting the definition of hazardous
waste must meet substantive requirements of
RCRA storage regulations.
Treatment of hazardous waste must be conducted
in a manner that meets the substantive
requirements of a RCRA Part B permit.
Air emissions may have to be controlled to meet
the substantive requirements of CAA permit.
Contaminated groundwater extmcted by
dewateting wells, condensate, spent carbon (if
used), and soil cuttings from boreholes meeting
the definition of hazardous waste must meet
substantive requirements of RCRA storage
regulations.
Groundwater, condensate, spent carbon (if used),
and soil cuttings may contain PCBs above
regulatory thresholds.
Response
Chemical and physical analyses must
be performed.
Analysis for PCBs must be
performed if potentially present.
Ensure storage containers and tanks
are in good condition, provide
secondary containment, when
applicable, and conduct regular
inspections.
Equipment must be operated,
maintained, and monitored properly.
Emission control devices may need
to be installed to treat air emissions
from the SVE unit.
The contaminated groundwater,
condensate, and soil cuttings must be
stored in containers or tanks that are
well maintained.
Ensure disposal of TSCA-regulated
wasle within 1 year of placement
into stomge.
1   RCRA is the Resource Conservation and Recovery Act.    5
2   CFR is the Code of Federal Regulations.               6
3   TSCA is the Toxic Substances Conlrol Act.             7
4   CAA is the Clean Air Act.
CWA is the Clean Waler Act.
SDWA is the  Safe Drinking Water Act.
DOT is the Department of Transportalion.
                                                                12

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                                                                       Table 3. (continued)
 Process Activity
                      ARAR
                                  Description
                                          Basis
                                                  Response
  Waste
  characlerizalion
  (treated waste and
  residuals)
RCRA 40 CFR Part 261 or
Stale equivalent
Identification and characterization of in
situ soil, soil cuttings,  spent carbon (if
used),  groundwaler,  and condensate.
A requirement of RCRA prior lo managing the
waste necessary to determine regulatory status of
in situ soil.
Chemical and physical testa must be
performed on the in situ soil,
groundwater, soil cutting:, and
condensale.
                      TSCA 40 CFR Part 761 or
                      Stale  equivalent
                                  Standards that apply to the treatment
                                  and disposal of wastes conlaining
                                  PCBs.
                                          Soil cuttings, spent carbon (if used), and
                                          condensale may contain PCBs above regulatory
                                          thresholds.
                                                  Analysis for PCBa must be
                                                  performed if PCBs were present ia
                                                  untreated soil.
 Transporlalion
 for offsite
 disposal
RCRA 40 CFR Part 262 or
State  equivatenl
Manifesting, packaging, and labeling
requirements  prior to transporting.
The  contaminated groundwater, condensate,  and
soil cuttings may need to be manifested and
managed as a hazardous waste.
An identification (ID) number must
be obtained from EPA.
                      RCRA 40 CFR Part 263 or
                      Slale  equivalent
                                 Packaging, labeling, and transportation
                                 standards.
                                          Transporters of hazardous waste must be
                                          licensed by EPA and meet specific requirements.
                                                  A licensed hazardous waste
                                                  transporter must be used to transport
                                                  the hazardous waste.
                      DOT  49  CF'R
                                                                           Hazardous  malerials must meet specific
                                                                           packaging and labeling requirements.
                                                                                            Shipments of material must be
                                                                                            properly containerized  and labeled.
  Groundwaler and
  condensale
  discharge
CWA5 40 CFR Parts 301,
304.306,307,308,  402, and
403
Standards that apply to  discharge of
contaminated water into sewage
treatment plants  or surface water
bodies.
The groundwater and condensate may not meet
local pretreatment standards without further
treatment or may require a NPDES permit for
discharge  10 surface  waler  bodies.
Determine if the groundwater and
condensate could be discharged to a
sewage treatment plant or surface
waler body without further
treatment. If not, Ihe  water may
need to be further treated lo meet
discharge requirements.
                      SDWA6 40 CFR Parts 144 and
                      145
                                  Standards that  apply lo the disposal of
                                  contaminaled waler in underground
                                  injection wells  (including infiltration
                                  galleries).
                                          Injection of the groundwaler  and condensate may
                                          be the preferred oplion for management of water
                                          from treatment at remole sites.
                                                  If underground injection is selected
                                                  as a disposal means for treated
                                                  waler,  testing musl be performed
                                                  and permission must be obtained
                                                  from EPA to use existing  permitted
                                                  underground  injection wella or 10
                                                  construct and operate  new wells.
I   RCRA is the Resource  Conservation and Recovery Act.
2   CFR is the  Code of Federal Regulations.
3   TSCA is the Toxic  Subslances  Control Act.
4   CAA is the  Clean Air Act.
                                       5   CWA is the Clean Water Act.
                                       6   SDWA is  the Safe Drinking Water Act.
                                       7   DOT is the Department of Transportation.
                                                                                  13

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hazardous  substances. " In addition, the nine criteria used by RPMs during the RI/FS process must be
addressed by CERCLA remedial actions. The criteria include:
        •    Overall protection of human health and the environment
        •    Compliance with ARARs
        •    Long-term effectiveness and permanence
        •    Reduction of toxicity, mobility, or volume
        •    Short-term effectiveness
        •    Implementability
        •    cost
        •    State  acceptance
        •    Community  acceptance

        The performance of KAFs RFH technology in each of these nine categories was evaluated, and
the results are presented in Table 1 in the Executive Summary.

2.1.2  RCRA
        RCRA is the primary Federal legislation governing hazardous  waste activities. Although a RCRA
permit is not required for hazardous waste treatment for onsite remedial actions at Superfund sites, the
KAI RFH system must meet all of its substantive requirements if treating a hazardous waste.  RCRA
administrative requirements such as reporting and recordkeeping, however, are not applicable for onsite
actions. Subtitle C of  RCRA contains requirements for generation, transport, treatment, storage, and
disposal of hazardous  waste.  Compliance with these requirements is mandatory for CERCLA sites
producing hazardous waste onsite.

        The substantive requirements of a Part B Treatment, Storage,  and Disposal (TSD) permit may
be required when the soil undergoing treatment is considered to be hazardous. Invariably, a Uniform
Hazardous Waste  Manifest must accompany offsite shipment of RCRA hazardous wastes, and transport
must comply with Federal DOT hazardous waste packaging, labeling,  and transportation regulations. The
receiving  TSD facility must be permitted and in compliance with RCRA standards. The RCRA land
disposal restrictions (LDR) in 40 CFR 268 preclude the land disposal  of hazardous waste that fails to
meet stipulated treatment standards. The technology or treatment standards applicable to the residuals
produced by the KAI RFH  system will be determined by the characteristics of the material treated and
                                             14

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the residuals generated. Wastes that do not meet these standards must receive additional treatment to
bring the wastes into compliance with the standards prior to land disposal, unless a variance is granted.

2.1.3  CAA
        The CAA establishes primary and secondary ambient air quality standards for the protection of
public health and emissions limitations for certain hazardous  air pollutants. Requirements under the CAA
are administered by each state as part of the State Implementation Plans developed to bring each state into
compliance with the National Ambient Air Quality Standards  (NAAQS). The ambient air quality
standards listed for specific pollutants will generally be applicable to the operation of the RFH system,
since it volatilizes contaminants and removes them from the soil as vapors.  A vapor barrier and vapor
collection system (described in Subsection  1.4) prevent the release  of these contaminants to the air.   The
system that will be used to treat the collected vapors varies  depending on the location of the site and the
contaminants present. The vapor treatment system must be designed in compliance with the  CM.  The
operating permits required and allowable emission limits must be evaluated on a case-by-case basis.

        The vapor treatment system employed during the SITE  demonstration consisted of condensate
collection and a propane-fueled flare.  According to B&RE, the flare was operated under  Standard
Exemption Number 68 as defined in Section 382.057 of the Texas Clean Air Act.  The vapor stream
prior to the flare was periodically sampled prior to, during,  and after RFH treatment. Vapor stream data
are presented in Appendix A.

2.1.4 SDWA
        SDWA establishes primary and secondary national  drinking water standards.  CERCLA refers
to these standards and Section 121(d)(2) explicitly mentions two of these standards for surface water or
groundwater: Maximum Contaminant Levels (MCLs) and Federal Water Quality Criteria. Alternate
Concentration Limits (ACLs) may be used  when conditions of Section 121 (d)(2)(B) are met and cleanup
to MCLs or other protective levels is not practicable. Included in these sections is guidance on how these
requirements may be applied to Superfund remedial actions. The guidance,  which is based on Federal
requirements and policies, may be superseded by more stringent promulgated State requirements, resulting
in the application of even stricter standards than those specified in Federal regulations.
                                              15

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        Approximately 2,000 gallons of condensate were collected from the vapor treatment system and
transferred to the Kelly AFB industrial wastewater treatment facility for treatment. In other applications
of the RFH technology, the amount of condensate generated and the contaminants present in the
condensate will depend on the temperature to which the soil is heated, the moisture content of the soil,
the contaminants present in the soil, and the design of the vapor treatment system. Aqueous residuals
were also generated during equipment and personnel decontamination and treated as the condensate above.
If commercial applications of the RFH  technology require dewatering to lower the water table,
groundwater residuals will also be generated.

2.1.5  CWA
        CWA regulates direct discharges to surface water through the National Pollutant Discharge
Elimination System (NPDES) regulations.   These regulations require point-source discharges of
wastewater to meet established water quality standards.  The discharge of wastewater to a sanitary sewer
requires a discharge permit or, at least, concurrence from State and local regulatory authorities that the
wastewater is in compliance with regulatory limits.  As discussed in Subsection 2.1.4, the aqueous
residuals generated during the SITE demonstration were  condensate from the vapor treatment system and
washwater from  equipment and personnel  decontamination.

2.1.6  TSCA
        The treatment and disposal of asbestos and materials containing PCBs at concentrations of 50
parts per million (ppm) or greater are regulated by TSCA.  Asbestos is not generally present at the type
of site that would be remediated using the RFH technology. It is possible that the RFH technology could
be used to treat soil that contains PCBs  The regulation of treatment of PCB-contaminated materials is
based  on PCB concentration.  Materials containing PCBs in concentrations between 50 and 500 ppm may
be disposed of in TSCA-permitted landfills or incinerated in TSCA-approved incinerators; materials
containing PCBs  in concentrations greater than 500 ppm must be incinerated.  It is permissible, however,
to use other technologies to reduce the volume of material containing PCBs in concentrations less than
500 ppm.  If RFH was used to treat material containing PCBs, the PCB vapors would require collection
and condensation followed by disposal in accordance with TSCA.

        Sites where PCB spills have occurred after May 4, 1987, must be addressed under the PCB Spill
Cleanup Policy in 40 CFR Part 761, Subpart G.  The policy applies to spills of materials containing PCBs
                                              16

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in concentrations of 50 ppm or greater and establishes cleanup protocols for addressing such releases
based on the volume and concentration of the spilled material.

2.1.7 OSHA  Requirements
        CERCLA remedial actions and RCRA corrective actions must be performed in accordance with
OSHA requirements detailed in 20 CFR Parts 1900 through 1926, especially Part 1910.120, which
provides for the health and safety of workers at hazardous waste sites. Onsite construction activities at
Superfund or RCRA corrective action sites must be performed in accordance with Part B of OSHA,
which provides safety and health regulations for construction sites. State OSHA requirements, which may
be more stringent than Federal standards, must also be met.

        All personnel involved in the operation of the KAI RFH system must have completed a 40-hour
OSHA training course covering personal protective equipment (PPE), safety and health, emergency
response procedures, and quality assurance/quality control (QA/QC).  Additional  training addressing the
site activities, procedures, monitoring, and equipment associated with the technology is also necessary.
Training provided prior to the operation of the system should include information regarding emergency
evacuation procedures; safety equipment locations; the boundaries of the exclusion zone, contaminant
reduction zone, and support zone;  and PPE requirements.  Onsite personnel must also participate in a
medical monitoring program. Health and  safety monitoring and incident reports should be routinely filed,
and records of occupational illnesses and injuries (OSHA Forms 102 and 200)  should be maintained.
Audits ensuring compliance with the health and safety plan should be carried out.

        Proper PPE should be available  and properly utilized by all onsite personnel.  At each site, the
level of PPE required will be determined based on the potential hazards associated with the site and the
work activities being conducted.

        OSHA has also provided guidance, published in 20 CFR Part 1910.97,  for exposure to
electromagnetic radiation in the RF region.  This guidance  states that "for normal environmental
conditions and for incident electromagnetic energy of frequencies from 10 MHz to 100 gigahertz (GHz),
the radiation protection guide is 10 mW/cm2 (milliwatt  per square centimeter) as averaged over any
possible 0.1-hour period. " This means that a power density of 10 mW/cm2 for  periods of 0.1 hour or
more or an energy density of 1 mW-hr/cm2 during any 0.1-hour period should not be exceeded without
careful consideration of the reasons for doing so.

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2.2     OPERABILITY OF THE TECHNOLOGY
        KAFs RFH system is described in Subsection 1.4.  The components of an RFH system have three
major purposes: heating the soil by applying RF energy to it, collecting vapors released by the heated
soil, and treating those vapors.   During the SITE demonstration, KAI was subcontracted by B&RE to
design and operate the RFH system, but not the vapor collection and vapor treatment systems.  B&RE
provided project and site management, designed and operated the vapor collection and treatment systems,
and assisted KAI in the construction and operation of the RFH system.

        Several problems were encountered in the implementation of KAFs RFH system. Start-up was
delayed because the chosen frequency required the approval of both the FCC and the Air Force
Frequency Manager.  This delay may not be expected to occur at all remedial sites. There was also
significant downtime after start-up because of problems with the  3-phase AC power transmission system.
The instability of the AC power available to the RFH system caused occasional shutdown.  The AC
power problem also contributed to the need to adjust the RF generator. In addition, it was periodically
necessary to discontinue the application of RF energy to allow the borehole liner to cool, although
borehole cooling tubes were later installed to minimize this problem.

        Operating  parameters  that affect the  performance of the RFH system include treatment
temperature and duration of treatment.   The treatment temperature determines the rate at which
contaminants are volatilized as well as the range of contaminants  that will  be volatilized. Both the
treatment temperature and the  duration of treatment influence the final contaminant concentrations.
Operating temperature and treatment time are typically selected based on the  contaminants of concern and
the required cleanup levels.  Based on input from USAF; its contractor, B&RE; and the developer, KAI,
the SITE Demonstration Plan specified total recoverable petroleum hydrocarbons (TRPH) as the primary
contaminant of concern, 1 SOT as the operating temperature, and approximately 6 weeks as the treatment
tune.  Because of the expected low initial concentrations, decreases of VOCs  and SVOCs were listed as
secondary  objectives.

       Just prior to system installation, KAI and B&RE  changed the planned operation of the system.
They targeted only volatile organics, specifically gasoline-range hydrocarbons, as the contaminants of
concern, which allowed KAI to lower the treatment temperature range to 100 to 130°C.  (these changes
were not reflected in the SITE Demonstration Plan because the SITE  Program was not notified until after
the demonstration was completed.)

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        The design and operation of the vapor collection and vapor treatment systems will also affect
performance.   Factors that can be varied include the number, location, spacing, and design of the
extraction wells; the amount of vacuum applied to the vapor collection system; the air flow rate through
the vapor collection system; the  amount of time for which the vapor  collection system is operated (it can
be operated after the application  of heat to the treatment zone has been discontinued); and the components
of the vapor treatment system.

2.3     APPLICABLE WASTES
        The RFH technology is potentially capable of remediating  soils contaminated with VOCs and
SVOCs, including petroleum hydrocarbons. According to KAI, the  maximum temperatures that can be
sustained are in the 300 to 400°C range.  SVOCs with boiling temperatures below  this range are suitable
candidates for RFH. Inorganics, metals, and  other nonvolatile contaminants will not normally be
removed

        KAFs RFH technology is best applied to contaminated soil in the vadose zone.  If saturated soil
is to be remediated by RFH, the treatment zone should be dewatered prior to treatment.  If the water
table is close to the contaminated soil and the groundwater is also contaminated, it may be difficult to heat
the soil without volatilizing contaminants in the groundwater, which can be more effectively treated by
another method.

        Although the economics of treatment by this technology are not favorable for saturated soils (i.e.,
the cost of treating saturated soils by this technology exceeds the treatment costs incurred by  using other
technologies, such as  pump and treat), it is applicable to unsaturated  soils regardless of moisture content.
Theoretically, RF energy preferentially heats polar molecules, and water molecules  are strongly polar.
As a result, moist soils can provide improved absorption of the RF energy.   However, this also means
that moist soils will  require additional energy,  particularly if the target soil temperature is above the
boiling point of water. At soil temperatures  above 100°C, chemically-bound water molecules continue
to absorb RF energy.  The dielectric constant of the soil determines the soil's ability to absorb RF energy
directly.  Other than the impact of the soil dielectric constant, RFH should be applicable to any soil type.

        Soil type will, however, impact the operation of the SVE system. For example,  soils containing
a large fraction of clay may have low air permeability.   Theoretically, RFH may enhance the air
permeability of soil by removing moisture from  it.  Since RFH is  a technology designed to  enhance SVE

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performance, site conditions that limit the effectiveness of SVE will affect the level of enhancement
achievable by RFH.

2.4    KEY FEATURES OF THE KAI RFH TECHNOLOGY
       KAFs RFH technology is similar to both in situ steam extraction and in situ SVE. In SVE,
vacuum blowers induce air flow through the soil, stripping VOCs and SVOCs from it [1]. In steam
extraction, steam is injected into the ground to raise the soil temperature and strip VOCs and SVOCs
from it [2]. The primary difference between these technologies and RFH is that RFH uses  RF energy
to heat the soil in the treatment zone.  Because the RFH technology uses higher temperatures, it is more
aggressive than either steam extraction or SVE. Theoretically, RFH can therefore be applied to less
volatile contaminants.

2.5    AVAILABILITY AND TRANSPORTABILITY OF SYSTEM
       KAI owns and operates one 25-kW RFH system, which was used for the SITE demonstration.
The assembly of this system is a multistep process.  The applicators  and the installation towers were all
shipped as part of the same truck/trailer system that contained the RFH system. The extraction wells,
pressure transducer wells (if used), electric field measurement wells (if used), thermowells, and antennae
are installed in boreholes. After the subsurface components are  installed, above-ground wiring and piping
is completed and the vapor collection and treatment  systems are connected to the subsurface components.

       The assembly of the proposed 200-kW RFH  system will be similar to  the assembly of the existing
25-kW system. It is projected that the 200-kW  system will be transported on four trailers. The system
will use more antennae and extraction wells than the pilot-scale system, but the multistep installation
process will be the same.

       For both pilot-scale and commercial-scale projects, the vapor treatment system will vary from
site to site.   During the SITE demonstration, the vapor treatment system consisted primarily of a
condensate collection system and a propane-fueled flare. The flare was mounted on a trailer, and the
condensate collection system was assembled onsite   An air compressor and instrumentation for the vapor
treatment system were installed in a small building  that was constructed for the demonstration.

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2.6    MATERIALS HANDLING REQUIREMENTS
       Materials handling requirements prior to treatment are minimal because this is an in situ system.
Although not evaluated during this demonstration, KAI claims that soil removed from boreholes during
the installation of the electrodes and thermowells may be placed on top of the treatment zone and treated
with the undisturbed soil.  If the soil cuttings are not treated with the undisturbed soil, they must be
treated or disposed of in some other fashion.

       Depending on its design, the vapor treatment system may generate residuals.  The 'materials
handling requirements for these residuals will vary depending on the design of the vapor treatment system
and the contaminants present in the  soil.   During the SITE demonstration,  uncondensed vapors were
channeled directly to a propane-fueled  flare. Vapors that condensed in the vapor treatment system were
collected in a 55-gallon drum, and then transferred to the Kelly  AFB industrial wastewater treatment
facility for treatment and disposal.    The residuals generated by the vapor treatment system of a
commercial-scale RFH system will depend on the vapor treatment system used and the nature of the site
being remediated.

       Another aqueous residual generated during the RFH SITE demonstration  was the washwater from
personnel and equipment decontamination. Commercial applications of the RFH technology will also
generate groundwater residuals if dewatering is employed.

2.7    SITE SUPPORT REQUIREMENTS
       Remediation using the RFH process will require  that certain utilities be available at the site.
Water must be available for steam-cleaning the drill rig and auger and for other equipment and personnel
decontamination activities. Electrical power must also be available. It is projected that 480-volt, 3-phase
power will be needed at an onsite distribution point and that a 3-phase 480- to 240-volt transformer will
be needed to establish the required single-phase service. The primary component connected to the 480-
volt, 3-phase power will be the RF generator; the majority of the minor system  components will use 240-
volt, single-phase power.

       A mobile drill rig and drill crew will be required onsite  for the installation of the subsurface
components.  Depending upon local regulations, it may  also be  necessary to remove all subsurface
components after treatment, and then redrill and backfill all boreholes. During the  SITE demonstration,
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it was necessary to redrill all boreholes and backfill them with bentonite at the end of the test. The drill
rig will also be used to install dewatering wells, if dewatering is necessary.  A fork lift truck and operator
will be required during disassembly. Onsite storage requirements include temporary storage for residuals
collected from the vapor treatment system (if any), groundwater collected during dewatering (if
dewatering is required), and water used in decontamination activities.

2.8    LIMITATIONS OF THE TECHNOLOGY
       In general, KAI's RFH technology is not recommended for the remediation of saturated soils.
If saturated soil is to be remediated by RFH, the treatment zone should be dewatered prior to treatment.
This will add to the total treatment cost and may not be effective, depending on the local hydrogeologic
conditions. If the water table is close to the contaminated soil and the groundwater is also contaminated,
it may be difficult to heat the soil without volatilizing contaminants in the groundwater which can more
effectively treated by another method.

       KAI's RFH system can only be used to remove contaminants that can be volatilized at soil
temperatures  that the system can practically achieve throughout the treatment zone.  This limits the
technology to soil contaminated  with  VOCs and SVOCs, since nonvolatile  organics,  metals, and
inorganics will not normally be removed at temperatures the system can achieve.

       Contaminants in silty or clayey soils are usually strongly sorbed and difficult to remove.  Clayey
soils may also have insufficient air permeability for adequate extraction of vaporized contaminants.
Vacuum  extraction of vapors from heterogeneous soils may also be difficult. Extraction of vapors from
such soils frequently bypasses lower-permeability zones, leaving contaminants behind.

       The SITE  demonstration provides an example of the application of KAI's RFH system to
heterogeneous soil.  The demonstration treatment zone included highly permeable  zones, containing
primarily  gravel and sand, as well as less permeable zones, containing a significant percentage of silt and
clay. As will be discussed in Section 4, significant residual contamination was measured in the treatment
zone after the SITE demonstration.  It is not clear, however, whether this indicates a limitation of the
system or a problem with the implementation of the  system.  Because only a portion of the revised
treatment zone reached the target temperature range of 100 to 130*0, it is possible  that the system was
not allowed to operate long enough to achieve an  adequate treatment temperature. This was at least partly
due to the amount of time available for treatment and problems with the  electrical power source. The

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design and operation of the SVE system may have also adversely affected contaminant decreases.

       As discussed in Subsection 2.2, problems with the 3-phase AC power transmission system led
to significant downtime at the beginning of the SITE demonstration. If adequate power is not available
at a site, it must be produced by a generator.

2.9     REFERENCES
1.     Engineering Bulletin: In Situ Soil Vapor Extraction Treatment. EPA/540/2-91/006, May 1991.
2.     Engineering Bulletin: In Situ Steam Extraction Treatment. EPA/540/2-91/005,  May 1991.

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                                               SECTION 3
                                       ECONOMIC  ANALYSIS


3.1     INTRODUCTION

        The primary purpose of this economic analysis is to estimate the costs (not including profit) for
a commercial-scale system using KAFs in situ RFH technology to remediate 10,940 tons of soil
contaminated with volatile and semivolatile organics.   This analysis  is based upon on the results of a SITE
demonstration that utilized KAFs pilot-scale RFH system, information from previous tests conducted by
KAI, and information obtained from engineering textbooks.
3.2
BASIS OF  ECONOMIC  ANALYSIS
        The cost analysis is typically prepared by breaking down the overall cost into 12 categories.  The
cost categories, and the areas that each of them generally comprise, are listed below.  As presented, not
all categories are included in the economic analysis associated with this document.
    Site preparation
    —  site design and layout
    —  surveys and site logistics
    ™  legal searches
        aceea right* afKt roads
        .land clearing
    —  preparations for support and decontamination facilities
        utility  connections
    —  auxiliary buildings

    Permitting and regulatory
    ™  ICIIM!  peraiit coils
    —  system monitoring requirements

    'Equipment
    ™-  equipreent used during treatiiiei&l
    —  freight
        sties tax

    Startup snd  Sxeci
        transportation of personnel So the site
        wageu  tod living expenses
        assembly of the unit
    —  shakedown, testing, and training
    —'•  working capital
    —  insurance
        contingencies
        property taxes
        process monitoring equipment
        engineering and supervision
                                                 Operating costs for treatment
                                                 —  tabor
                                                 —  fabrication
                                                     drilling

                                                 Supplies
                                                 —  spare part*
                                                 —  bentonite
                                                 Consumables
                                                 —  electricity
                                                     water
                                                     diesei fuel

                                                 Effluent, treatment and disposal
                                                 —  further treatment/disposal of effluent(s)
                                                 —  onsite storage of effluent(s)

                                                 Residuals and waste shipping, handling, and transport.
                                                     storage of residuals/wastes
                                                     transportation of residuals/wastes
                                                 —  treatment/disposal of residuals/wastes
                                                 Analytical services
                                                 —  sampling and analytical program
                                                 Facility modification, repair, and replacement
                                                     maintenance material costs
                                                 —  design adjustments
                                                     equipment replacements

                                                 Site demobilization
                                                     disassembly costs
                                                 —  site cleanup and restoration
                                                 —  wages and living expenses
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3.3    ISSUES AND ASSUMPTIONS
       This subsection summarizes the issues and assumptions of the economic analysis for this study.
The objective of this SITE demonstration was to treat a single cell having dimensions of 15 feet by 10
feet by 20 feet (111 cubic yards or 171 tons) using a25-kW system. This economic evaluation was based
on the original design of the RFH system for the demonstration.  Because of the problems encountered
during the demonstration, several assumptions had to be made about the technology. Even though no
conclusions about the success of RFH at Kelly AFB can be made, the economic evaluation assumes the
technology will meet target cleanup levels within a given timeframe.

       For this analysis, the goal was to  estimate remediation costs of a full-scale system based upon a
site of approximately 10,000 tons at a depth of 20 feet.  The size of the full-scale system is estimated to
be 200-kW (modular system of eight 25kW generators).  Therefore, a factor of eight was used to scale-up
the system used in the SITE demonstration to the full-scale level. Desiring to keep the length of the cell
at 1.5 times its width, the cell dimensions at the full-scale level would be approximately 42 feet by 28
feet by 20 feet (900 cubic yards or approximately 1,400 tons). Based upon these dimensions, it was
determined that the mass of eight cells (10,940 tons) would be the mass used for this analysis since it
most nearly met the 10,000 ton goal.  The full-scale site is  assumed to be 2 cells in length by 4 cells in
width. It is assumed the full-scale cleanup will proceed along the width of the site, allowing savings to
occur due to the overlapping of extraction well rows.  The exact configuration of the full-scale system
in each cell is site-specific and is not included in this analysis.

       It is assumed that the frequency of operation of the 200-kW unit will be 13.56 MHz.  It is also
assumed that the RFH system will operate 24 hours per day, 7 days per week with a 95  percent on-line
time. Therefore, the total estimated time  the equipment will be onsite is 76 weeks.

       A utilization factor of 90 percent  was assumed.   The utilization factor is used to adjust the unit
treatment cost to compensate for the fact  that the system is not leased to a client at all times because of
limited market demand for this type of technology.  Through the use of the utilization factor, costs
incurred while the system is not leased out are incorporated into the unit  cost and distributed evenly to
all occasions when the system is applied  to a project.  Costs that accrue  when the system is not in use
include insurance, taxes, and capital equipment costs.
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       The cost of the SVE system is generally a significant part of the RFH treatment costs.  Therefore,
to estimate the SVE system as a percentage of the treatment costs, it was assumed that the SVE system
would incur 50 percent of the following costs:
       •    Insurance                •   Labor during treatment
       •    Electrical                •   Labor during fabrication
       •    Freight                  •   Electricity
       •    Tax                     •   Site demobilization and transportation
       •    Labor during startup      •   Labor during site demobilization
       •    Assembly

       The primary pieces of equipment of the SVE system used in this cost analysis  are PVC pipes
for extraction wells and above-grade conduit, and a well junction box.

       The following subsections (Subsections 3.3.1 through 3.3.12) describe assumptions that were
made in determining project costs for 7 of the  12 cost categories. This analysis  does not include cost
values for: site preparation; permitting and regulatory;  effluent treatment and disposal; residuals and
waste shipping, handling, and  transport; and sampling and analytical services.  Costs  for these categories
are highly dependent upon site-specific factors, and therefore, no estimates are  presented in this economic
analysis. Consequently, the actual cleanup costs incurred by the site owner or responsible party may be
significantly higher than the costs shown in this analysis. The actual cost is expected to fall between 70
percent and 150 percent of this estimate.  This level of accuracy  is accepted by  the SITE Program as
appropriate for generating estimates without the benefit of detailed engineering  data  [1].  However, since
this cost estimate is based on a preliminary design, the range may  actually be wider.

       According to Plant  Design and Economics for Chemical Engineers [2], insurance, property taxes,
spare parts, contingency costs, and maintenance materials can be estimated as a percentage of the fixed
capital investment required for a project. The components  of the fixed capital investment that apply to
this project are:
       •   Total equipment cost applied to the project (including freight and sales tax)
       •   Supply of spare parts (5 percent of fixed capital investment)
       •   Transportation (other than freight)
       •   Assembly
       •   Shakedown, testing, and training
       •   Contingencies  (10 percent of fixed capital investment)
       •   Engineering and supervision for system installation
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       Since some of these components are estimated independently of the fixed capital investment (e.g.,
assembly), and others  are percentages of the fixed capital investment applied to the project (e.g.,
contingencies), a formula for calculating the fixed capital investment was developed.

       The vendor claims that the treatment cost estimate presented in this analysis may  be significantly
higher than the actual cost since some components of the RFH system used in the SITE demonstration
may not be required in the full-scale system.  Vendor claims are presented in Appendix C.

3.3.1 Site Preparation
       The amount of preliminary  site preparation  required is  highly  dependent  on the site.
Consequently, site preparation costs are not included in this cost estimate and are assumed to be the
responsibility of the site owner or responsible party.  It is essential to consider that site preparation
measures may significantly increase the costs associated with the use of this technology.

3.3.2 Permitting  and  Regulatory
       Permitting and regulatory costs can vary greatly because they are site- and waste-specific.
Consequently, no permitting or regulatory costs are included in this analysis. This category may be a
significant factor in determining project costs since permitting activities can be both expensive and time
consuming.

3.3.3  Equipment
       The primary pieces of equipment of the KAI RFH system include:
           •          RF generator and tuner
           •          Antennae
           •          Extraction  wells
           •          Fiberoptic wells and electric field measurement wells
           •          Vapor barrier
           •          Vapor collection system
           •          Vapor treatment system
           •          Instrumentation
           •          Electrical

       Equipment cost estimates are based on vendor quotes, estimates by B&RE  or information
provided by Plant Design and Economics for Chemical Engineers [1]. When necessary, the Chemical
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Engineering Cost Index [3] is used to estimate current costs from earlier cost data. The annualized cost
(rather than depreciation) is used to calculate the annual equipment costs incurred by a site. The
annualized cost is calculated using the following formula:
where:
       A   =   annualized cost,  $
       P   =   present value principal sum, $
       i   =   interest rate, %
       n   =   years

The value "n " is the useful life of the RFH unit and equipment(n = 10).  It is assumed that a 1-year loan
at 8.5 percent interest has been secured to cover the cost of the equipment.  The annualized equipment
cost prorated to the actual time the unit is at the remedial site (including assembly, shakedown and
testing, treatment, and disassembly) is $332,268 over a period of 76 weeks (1.46 years). The unit is
assumed to have no salvage value.

       The list prices of the RF generator and tuners are estimated to be $836,000.  The prices for the
antennae and extraction wells were determined from a standard engineering reference [2] and are
estimated to be $168,449 and $7,618,  respectively.   The developer states that full-scale commercial
systems would utilize less-expensive  temperature measuring instruments, such as thermocouples.
Consequently, the use of thermocouples has been assumed for this estimate. Thermocouple well prices
were based upon information from instrument and plastics catalogs  [4] [5] and are estimated to be
$11,081.

       The price of the vapor barrier system, as provided by a silicon rubber sheet manufacturer, is
estimated to be $392. This process requires two vapor collection  systems, the prices of which are
estimated to be $4,704 each, based upon prices obtained from a parts catalog [6]. The process also
requires a vapor treatment system;  however, the system is  considered to be a site-specific cost since it
is dependent on the contaminants present and local regulations. Therefore, the cost for the vapor
treatment system is not  included in this cost estimate. Instrumentation for the system is assumed to be
13 percent of the purchased equipment cost and estimated to be $174,394 for the project [2] Electrical
costs are assumed to be  10 percent of the purchased equipment cost and estimated to be $134,149 for the
project

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       Freight costs are assumed to be 6 percent of the total equipment purchase cost and estimated to
be $80,489 for the project [2].  Sales taxes are assumed to be 5.5 percent of the total equipment purchase
cost and estimated to be $73,782 for the project. When these costs are added to the total equipment
purchase cost, the overall equipment cost is estimated to be $1,341,490.

334 Startup and  Fixed
       Transportation activities include moving the KAIRFH system to the site. Travel costs for
equipment are covered under the freight charge applied to the total equipment purchase cost discussed
in Subsection 3.3.3.

       Assembly consists of unloading the system from the trailer and assembling it at the site.   It is
assumed that one fork lift truck at $325 per hour and one operator at $25  per hour will be required.The
cost to transport the fork lift truck to and from the site is $55 per hour, and it is assumed that it will take
4 hours to drop off and pick up the forklift.  The total assembly cost is estimated to be $1,545.

       It is estimated that 3 weeks will be required to set up equipment onsite, install antennae,
extraction wells, and thermocouples, and 1 week to assemble the above-ground components of the system.
Assembly and shakedown and testing are assumed to require five workers (two junior electricians, one
senior electrician, one technician, and one project manager).  The assembly will consist of two 2-person
crews for 12 hours per day each; two-man crews were chosen since it is common practice at Superfund
sites to enact the "buddy system."  The first shift will consist of a junior electrician and the technician,
and the second shift will consist of a junior electrician and the senior electrician.   It is estimated the
project manager will spend  50 percent of his or her time on the project during assembly.  Workers are
assumed to be local or will maintain residence near the site  and will not be paid for travel or living
expenses. However, to compensate for the lack of living expenses, each worker's salary was increased
by a factor of 1.33.  A multiplier of 1.8 was used for each of the worker's salaries to cover benefits and
other overhead costs. The estimated labor cost for assembly is $91,413. Listed below are the fully-
burdened costs (including wages, benefits, overhead, and profit) for all onsite personnel involved with
assembly and all other phases of the project.
           •  Junior Electrician  — $99,000/year
           •  Senior Electrician  — $135,000/year
           .  Technician         -   $108,000/year
           •  Project  Manager    —   $162,000/year

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       Working capital consists of the costs of borrowing capital for supplies, utilities, spare parts, and
labor necessary to keep the RFH system operating without interruption due to financial constraints [2].
The working capital for this system is based on maintaining 2 months of payroll for labor, 2 months of
payroll for the drilling subcontractor, and 1  month of inventory of the other items.  For the calculation
of working capital, 1 month is defined as one-twelfth of 1 year. The estimated required working capital
is $103,043. The working capital cost at 8.5 percent interest for the time the equipment is onsite is
$13,590. Therefore, the total working capital cost is $116,633.

       Insurance is assumed to be 2 percent of the fixed capital investment and estimated to be $33,752
per year and $54,660 for the project.  Property taxes are assumed to be 3 percent of the total fixed capital
investment [5]  and are estimated to be $50,628 per year and $81,990 for the project.

       The  cost for the initiation of process  monitoring programs has not been included in this estimate.
Depending on  the site, local authorities may impose specific guidelines for monitoring programs.  The
stringency and frequency of monitoring requirements may have a significant impact on the project costs.
Air monitoring is likely to be required due to the potential release of air emissions during treatment.

       A contingency cost is included to cover additional costs caused by unforeseen or unpredictable
events, such as strikes, storms, floods, and price variations [2]. The project contingency cost is estimated
to be 10 percent of the fixed capital investment. The annual contingency cost is $168,851 for a cost of
$184,579 to the project.

3.3.5   Operating Costs for Treatment
         Treatment operations for the RFH  system will be conducted 24 hours per day, 7 days per week
for 51 weeks. It is assumed that energy will  be applied to each cell for a total of 6 weeks (same duration
that energy was applied during the SITE demonstration).  It is estimated that it  will  take 3 weeks for each
cell to cool  down. However, the time required to cool down will only add 3 weeks to the total time
onsite for the last cell, since all of the duplicated components can be removed during cool-down.  It is
also assumed that it will take one week to move from one cell to the next.  Labor  costs consist of fully-
burdened personnel  costs for five workers.  Fully-burdened personnel costs are provided in Subsection
3.3.4. The treatment labor force will be structured as described in  Section 3.3.4. The total labor cost
for treatment is estimated to be $732,302.
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        It will be necessary to subcontract a drilling company for the installation and removal of the
electrodes and thermowells. A two-person crew will operate the drill rig. Boreholes for extraction wells,
antennae, electric field wells, and thermowells are assumed to be drilled to a depth of 20 feet. The  cost
for drilling a 10-inch-diameter hole with a hollow stem auger is assumed to be $18 per foot. The
estimated costs for installing and removing the extraction wells and antennae are $6.50 and $2.50 per
foot, respectively.  The total drilling costs for the project are estimated to be $1,161,020.

3.3.6   Supplies
        For this project, supplies consist of spare parts and bentonite for backfilling the boreholes after
the extraction wells and antennae are installed. Annual spare parts costs are estimated to be 5 percent
of the fixed capital investment [2], which is approximately $84,379 per year and $122,986 for the entire
project,

        Bentonite used to backfill the boreholes after the extraction wells and antennae are installed is
assumed to cost $12 per bag with each bag containing 50 pounds of bentonite chips.  It is estimated that
13,744  bags of bentonite will be required for the project at atotal cost of $164,394.

3.3.7 Consumables
        Electricity is required not only  during the heating  of the cell but also during its cool-down period.
The average hourly power usage rates during the heating and  cool-down periods are estimated to be 484.5
kW and 84.5 kW, respectively. Based on a 6-week duration for heating a cell and 3-week duration for
a cooling period for each cell, the total electricity cost for the project is approximately $327,074 (at a rate
of $0.077 kWh).

        In order to implement the KAI RFH technology, the site must have a supply of uncontaminated
water available.  Water will be used for decontamination  of the drill rig augers and be added to the
bentonite used in backfilling the boreholes and is estimated to be 600 gallons per day.  A sewerage charge
is also assumed for all water used even if it is not discharged to the sewer.  Based upon rates provided
by the Cincinnati Water Works, the total water and sewerage bill for the project is estimated to be $985.
                                              31

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3.3.8   Effluent Treatment and Disposal
       Steam and vaporized contaminants will be given off during treatment using the RFH system.
Entrained liquid may also be present in the effluent stream.  This vapor stream should be the only effluent
from the system. A vapor treatment system may be operated in series with the RFH system. The design
of this vapor treatment system will vary depending on the contaminants present in the soil.  Therefore,
for the purposes of this report, this site-specific cost is assumed to be the obligation of the site owner or
responsible party and is not included in this analysis.

3.3.9   Residuals  and Waste Shipping, Handling, and Transport
       If the treatment area extends below the natural water table, it will be necessary  to install
dewatering wells to lower the water table. The groundwater pumped out of these dewatering wells is
likely be contaminated. However, because dewatering will only be required at some sites and because
the quantity of groundwater removed and the contaminants present in the groundwater will vary from site
to site, this site-specific  cost is assumed to be the obligation of the site owner or responsible  party and
thus is not included in this estimate.

       Several boreholes will be drilled for installation of the extraction wells and antennae.   The soil
cuttings removed from these boreholes will be contaminated and will require treatment. During the
demonstration, these cuttings were drummed for later disposal For this cost estimate, it is assumed that
the cuttings will be placed on top of the soil surface and treated along with the undisturbed  soil.  If the
cuttings are not treated along with the undisturbed soil, they will be a contaminated residual.   The
residual treatment cost is also assumed to  be the obligation of the site owner or responsible  party and is
not included in this estimate.

3.3.10 Analytical  Services
       No analytical costs are included in this cost estimate. The responsible party may elect or may
be required by  local authorities to initiate a sampling and analytical program at its own expense. If
specific sampling and monitoring criteria  are imposed by local authorities, these analytical requirements
may contribute significantly to the cost of the project.
                                              32

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3.3.11  Facility Modification, Repair, and Replacement
       Maintenance costs vary with the nature of the waste and the performance of the equipment and
include costs for design adjustments, facility modifications, and equipment replacements. For estimating
purposes, annualized maintenance costs (excluding labor) are assumed to be 3 percent of the fixed capital
investment [2]  and are estimated to be $50,655 per year and $55,374 for the project.

3.3.12  Site Demobilization
       It is assumed  that the transportation costs in the demobilization phase will be equal to the
transportation costs of the assembly phase of the project.  Therefore, the cost for site demobilization is
estimated to be $10,820.  It is assumed that 1 week will be required for disassembly of the above-ground
components and 1 week will be required for preparation time needed to remove the equipment from the
site.  Labor will be structured as described in  Subsection 3.3.4 and will cost approximately $159,775.

3.4    RESULTS OF ECONOMIC ANALYSIS
       This subsection summarizes the results of the economic analysis of the KAIRFH  system treating
10,940 tons of soil based upon the developer's claim that the RFH system is capable of operating with
an on-line factor of 95  percent on a full-scale level. The on-line factor is used to  adjust the  unit treatment
cost to compensate for the fact that the system is not on-line constantly because of maintenance
requirements, breakdowns, and unforeseeable delays, and considers costs incurred while the system is
not operating.

       Table 4 summarizes the estimated treatment costs per ton using the KAI RFH system in the
treatment of 10,940 tons of soil with an on-line percentage of 95 percent.  Table 4 also presents the
treatment costs of the 12 cost categories as a percentage of the total cost. It is  important to remember
that the five cost categories not included in this analysis may significantly add to the unit cost.  These
costs are considered order-of-magnitude estimates as defined by the American Association of Cost
Engineers. The actual cost based upon EPA's  evaluation is expected to fall between 70 and 150 percent
of the estimated cost.  The vendor claims the  cost may be as low as 50 percent of the cost indicated in
Table 4.
                                             33

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    Table 4. Treatment Costs for the KAI RFH System Treating 10,940 Tons of Soil with a
                                   95 Percent On-line Time
Item
Site preparation
Permitting and regulatory
Equipment
Startup and fixed
Operating costs for treatment
Supplies
Consumables
Effluent treatment and disposal
Residuals and waste shipping, handling,
and transport
Analytical
Facility modification, repair, and
replacement
Site demobilization
Total operating costs
Cost (S/ton)
NE
NE
30.37
54.13
173.06
26.32
30.02
NE
N-E
NE
6.74
15.59
336.24"
Cost (as a 96 of total cost)
NE
NE
9.0
16.1
51.5
7.8
8.9
NE
NE
NE
2.0
4.6
100b
a   Approximately $50 per ton of the total cost is attributed to the SVE system.
b   The SVE system is approximately 15% of the total cost.
NE = Not estimated in the analysis. The cost for this item is highly dependent on site-specific factors.
       Table 4 indicates that the RFH system will cost approximately $336 per ton to remediate the

 10,940-ton  site.   Table 4 also illustrates that startup and fixed and operating costs for treatment

contributed the most to the unit cost, and labor is approximately 27 percent of the total cost.  SAIC

estimates that the SVE system is responsible for approximately $50 per ton of the treatment costs (15%

of the total cost)[7].


3.5     REFERENCES

 1.      Evans, G.M.  Estimating Innovative Technology Costs for the SITE Program. Journal of the Air
       and Waste Management Association, Vol. 40, No. 7, July 1990. pp. 1047-1051.

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

3.      Chemical Engineering. McGraw-Hill, Inc. Volume 101, Number 11, November 1994.

4.      Cole-Parmer 1995-1996 Catalog. Niles, Illinois.
                                             34

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5.      Consolidated Plastics Catalog. Twinsburg, Ohio, 1994.

6.      Grainger Industrial  and Commercial  Equipment and  Supplies  1994  General Catalog.
       Lincolnshire, Illinois, 1994.

7.      U.S. Environmental Protection Agency In Situ Soil Vapor Extraction Treatment Engineering
       Bulletin. EPA/540/2- 91/006, February 1991.

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                                        SECTION 4
                             TREATMENT EFFECTIVENESS

4.1     BACKGROUND
       The SITE demonstration of KAFs RFH system took place at Site S-l at Kelly APB near San
Antonio, Texas (see Figure 2). From 1960 to 1973, Site S-l was used as an intermediate storage area
for wastes awaiting offsite reclamation.  Waste liquids including mixed solvents, carbon cleaning
compounds, petroleum oils, and lubricants were temporarily stored in tanks located within this area.
Spills during waste transfer operations and flooding of storage tanks are reported to have caused the
current soil contamination.  Much of the spilled waste accumulated in a long sausage-shaped "sump,"
which was the lowest portion of a depression on the eastern side of the site.   After waste transfer
operations at the site were halted, the tanks were removed,  the sump and depression were backfilled, and
the area was graded.   Soil contamination persists down to the saturation zone, which begins
approximately 25 to 30 feet below the surface.

       Figure 3 shows the locations of the depression and the sausage-shaped sump. The SITE
demonstration  was  conducted in the southern end of the sump, where preliminary sampling indicated that
contaminant concentrations were highest. The original treatment zone, as specified in the Demonstration
Plan, was 10  feet wide, 15 feet long, and 20 feet deep.  The original plan specified that the lo-foot
applicators  would be moved up and down in their liners, applying heat from 0 to 20 feet below ground
surface (bgs). However, before the RF'H system was turned on, B&RE and KAI made the decision to
apply heat to only half of the original treatment zone. The "revised treatment zone" is 10 feet wide and
15 feet long but only extends from 4 to 14 feet bgs.  The depth was reduced because the applicators
remained stationary in their liners.  All of these modifications were made based on timing and funding
limitations placed on the project just prior to startup. The SITE Program was not informed  of any of
these changes until after sampling was completed; therefore, no changes to the Demonstration Plan were
made.
                                            36

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       . Growden Dr.
                                                   W. Thompson
Figure 2. Regional maps showing demonstration location.
                           37

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         N
                               Approximate limit of
                               former sump area
                     Approximate limit of
                     former depression area
                   feel
Site
Boundary
                                        •x—N—x- Fence
                50
                     100
                           150
                          Figure 3. Plan view of demonstration site.

       During the demonstration, power was supplied alternately to the two antennae, Al and A2.
Power was applied to A2 for 28.9 days, then switched to Al.  After the Al heating commenced, a high
voltage discharge occurred within the transmission line near it.  The center conductor heated beyond the
system's thermal expansion capability and shorted Al, so power was only  applied to Al for 8.2 days.

       Heating was switched back to A2 for the final 12.9 days. This malfunction caused the soil
surrounding the Al liner to be heated to a significantly  lesser degree than  the soil surrounding the A2
liner.

       The primary objective of the SITE Program demonstration was to evaluate the ability of theRFH
system and associated SVE system to remove TRPH from the soil.  In addition to the SITE Program's
primary objective, the following secondary objectives were developed:
       1.  Evaluate the removal of VOCs feasible under the conditions of the test. Target VOCs are
           listed in Table 5.
                                             38

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       2.  Evaluate the removal of SVOCs feasible under the conditions of the test. Target SVOCs are
           listed in Tables 6 and 7.

       3.  Determine the outward migration, if any, of contaminants into a zone outside the treatment
           area.

       4.  Characterize the soil being treated by determining particle size  distribution.
After a review of data from another RFH demonstration conducted at the same site, the following

additional secondary objectives were added as part of the demonstration:

        1.  Characterize the vapors extracted by the SVE system by collecting vapor samples at six key
           times before, during, and after the operation of the RFH system.

        2.  Characterize the soil vapor at the site by collecting soil gas samples before treating the soil.

        3.  Characterize the groundwater at the site and identify if the groundwater could be a potential
           source of contaminant migration into the treatment zones by collecting groundwater samples
           from existing wells.
                                     Table 5. Target VOCs
 Acetone

 Bromoform

 Carbon disulfide

 Chlorodibromomethane

 chloroform

 1,2-Dichloroethane

 1,2-Dichloropropane

 Ethylbenzene

 4-Methyl-2-pentanone (MIBK)

 Tetrachloroethene

 1,1,2-Trichloroethane

 Vinyl chloride
Benzene

Bromomethane

Carbon tetrachloride

Chloroethane

Chloromethane

 1,1-Dichloroethene

cis-l,3-Dichloropropane

2-Hexanone

Styrene

Toluene

Trichloroethene

Xylenes, total
Bromodichlorobenzene

2-Butanone

Chlorobenzene

2-Chloroethyl vinyl ether

1,1-Dichloroethane

trans-l,2-Dichloroethene

trans-l,3-Dichloropropene

Methylene chloride

1,1,2,2-Tetrachloroethane

1,1,1-Trichloroethane

Vinyl acetate
                                                39

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                            Table 6. Target SVOCs (Acid Extractables)
 Benzoic acid
 2,4-Dichlorophenol
 2,4 -Dinitropheno 1
 2-Nitrophenol
 Phenol
4-Chloro-3 -methylphenol
2,4-Dimethylphenol
2-Methylphenol
4-Nitrophenol
2,4,5 -Trichlorophenol
2-Chlorophenol
4,6-Dinitro-2-methylphenol
4-Methylphenol
Pentachlorophenol
2,4,6-Trichlorophenol
                          Table  7. Target  SVOCs  (Base/Neutral  Extractables)
 Acenaphthene
 Benzo(a)anthracene
 Benzo(ghi)perylene
 bis(2-Chloroethoxy)methane
 bis(2-Ethylhexyl)phthalate
 4-Chloroaniline
 Chrysene
 Di-n-butylphthalate
  1,4-Dichlorobenzene
 Dimethylphthalate
 Di-n-octyl  phthalate
 Hexachlorobenzene
 Hexachloroethane
 2-Methylnaphthalene
 3-Nitroaniline
 n-Nitrosodiphenylamine
 Pyrene
Acenaphthylene
B enzo (b) fluoranthene
Benzo(a)pyrene
bis(2-Chloroethyl)ether
4-Bromophenyl phenyl ether
2Chloro naphthalene
Dibenz(a,h)anthracene
1,2-Dichlorobenzene
3,3' -Dichlorobenzidine
2,4-Dinitrotoluene
Fluoranthene
Hexachlorobutadiene
Indeno( l,2,3-cd)pyrene
Naphthalene
4-Nitroaniline
n-Nitrosodipropylamine
1,2,4-Trichlorobenzene
Anthracene
B enzo (k) fluoranthene
Benzyl alcohol
bis(2-Chloroisopropyl)ether
Butyl benzyl  phthalate
4-Chlorophenyl  phenyl ether
Dibenzofuran
1,3 -Dichlorobenzene
Diethylphthalate
2,6-Dinitrotoluene
Fluorene
Hexachlorocyclopentadiene
Isophorone
2-Nitroaniline
Nitrobenzene
Phenanthrene
        The first step of the data evaluation process was to determine which contaminants were present
in a sufficient number of pretreatment samples at sufficient concentrations to warrant a statistical
evaluation. Many analytical method-specific VOCs and SVOCs were not detected in any pretreatment
samples.  The process used to select contaminants for the statistical evaluation is described in Appendix
A.
                                                  40

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       Changes in concentrations were determined for each compound by comparing analytical data
generated from soil samples taken before and after the RFH treatment. Initial and final soil samples were
taken from "matched" boreholes (i.e., final boreholes were placed as close as possible to the original
boreholes and samples were collected from the same depth). Initial and final contaminant concentrations
were compared to determine a concentration change for each matched pair.  Concentration changes for
all matched pairs within a specified zone were used to calculate the  geometric mean concentration change
for that zone (the geometric mean was used because it was determined that TRPH concentrations were
log-normally distributed).   The matched pairs of initial and final contaminant concentrations were
analyzed using a paired t test, which determined whether the geometric mean concentration change within
a specific zone was statistically significant. A description and application of the paired t test is presented
in Appendix A.

       B&RE also evaluated KAFs RFH system in terms of operational features such as performance
of the vapor barrier, performance of the vapor collection system,  amount of heat lost to the soil
surrounding the treatment zone, and measurement of RF fields radiated from the test array.   Because
these  operational features are not central to the SITE demonstration, data collected by B&RE are not
presented in Appendix A.

4.2    METHODOLOGY
4.2.1  Soil
       Pretreatment soil sampling was conducted concurrent with the installation of the subsurface
components. A mobile, hollow-stem auger drill rig was used to  drill the boreholes required for the
installation of the subsurface components.  Figure 1 shows the locations of all subsurface components.
The drill rig was also used to drive a split spoon into the boreholes wherever a soil sample was needed.
Sampling procedures are described in greater detail in following paragraphs.

       The Demonstration Plan specified the collection of samples for TRPH, VOC, and SVOC analyses
at the depths and locations shown in Figure 4. Pretreatment soil samples were generally collected at the
designated depths, but in a few cases, insufficient soil was recovered in the split spoon at the specified
depth. When insufficient recovery was obtained, the next deeper interval was sampled instead. Samples
were labeled with ID numbers that identified their locations (borehole and sampling interval).
                                             41

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4*
to
                                                                                                        >:
                                                                                                         x
                  El    A1   Ei
F1    E4   F4   E2
F3   E?   F2   E5   F5   E3   A2    E8   TD3  TO8   TO6
                                     has
                                    for TRPH

                                     has
                                    for TRPH, VOC,
                         SVOC
                        fx| =          THPH
                         ., ^          TRPH
                          '                           for
                                 and
                                                  4

                                                          42

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        RFH began on April 24, 1994 and ended on June 7, 1994.  Electrical power supply problems
experienced at the beginning of the heating period reduced the amount of RF energy applied to the soil.
The vapor collection system was operated from April 13,  1994 until June 24, 1994 to enhance the
removal of contaminant vapors. The soil was then allowed to cool undisturbed until July 7, 1994, when
final sampling began.  The above-ground components of the system were disassembled and removed prior
to final sampling. Subsurface components were removed following final sampling.

       Post-treatment boreholes were placed within 2 feet of the corresponding pretreatment boreholes.
An attempt was made to obtain all post-treatment  samples from the same depth as the corresponding
pretreatment sample, but insufficient material was collected from one sampling point, and it was
necessary to collect that sample 2 feet deeper than planned.   All other post-treatment samples were
collected at approximately the same depths as the corresponding pretreatment samples.

       Soil samples  were collected using 3-inch-diameter split spoons. The split spoon was pushed or
hammered into the soil (at the appropriate location and depth) using the drill rig.  The split spoon was
then removed from the borehole  and placed on a  flat surface covered with clean aluminum foil.  The main
portion of each split spoon was 2.0 or 2.5 feet long and contained four or five 6-inch-long stainless steel
liners, which were numbered from bottom to top.  The bottom portion of the split spoon, which was
approximately 3 inches long and was called the "shoe," did not contain any liners.

       The soil characteristics at each sampling point affected the number of liners that were filled with
soil.  The split spoon filled from the bottom:  first the shoe filled, then the first liner, then the second
liner, and so on.  For example, if the split spoon was pushed into the soil 12 inches, and then hit a large
rock that stopped its  progress,  only the shoe and the first liner would have been filled with soil. The
second liner would have been partially  filled with soil. For each given sampling point, one to four liners
were filled with soil.

       Soil samples were collected for both chemical and particle size analyses. When a soil sample was
selected for chemical analyses, the field sampling crew did not remove it from the stainless steel  liner in
which it was collected.  The ends of the liner were securely covered with Teflon sheets and polyethylene
caps. The liner was labeled, sealed in a plastic bag, and placed in a cooler with ice for preservation.
When a soil sample was selected for particle size analysis, the field sampling crew removed the sample
from its liner and placed it in a plastic jar or a plastic bag. When rocks were present in the sample, extra
                                             43

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material (from the shoe or from other liners) was frequently added to the particle size sample, since larger
quantities of material are required for particle size analyses of soils containing large particles.  Samples
selected for particle size analyses did not require preservation.

       When the split-spoon was filled or nearly filled (i.e., three or four liners were full of soil) the
second liner was selected for chemical analysis. The third liner was generally selected for particle size
analysis. When a chemical analysis field duplicate was collected, the third liner was then used as the
chemical analysis field duplicate and the first liner was the particle size sample.  When a particle size
analysis field duplicate was collected, the  first and third liners were the particle size duplicate and sample.
When field  duplicates for both chemical and particle size analyses were collected from the same split
spoon, the second liner was the sample for chemical analysis, the third liner was then used as the field
duplicate for chemical  analysis, and the first and fourth liners were the particle size sample and duplicate.

       When only two liners were full  of soil, the second liner was selected for chemical analyses.
When a chemical analyses field duplicate was collected, the first liner was selected as the chemical
analyses field duplicate, and material from the shoe and any material from the third liner was selected
for particle size analysis.  When the sampling location was not designated for the collection of a field
duplicate for chemical analyses, the first liner was selected as the particle size sample.

       When only the first liner was full of soil, it was selected for chemical analyses.  Material from
the shoe and any material in the second liner was  selected for particle size analysis. No  field duplicates
were collected if only the first liner was  full.

       Samples, blanks, and QA/QC samples were collected and prepared for chemical analyses.  The
samples  and  blanks  described  in this  paragraph were prepared  during  each phase  of sampling
(pretreatment and post-treatment). For each phase of sampling, 64  samples were analyzed for TRPH and
moisture; 32 of those samples were also  analyzed for VOCs and SVOCs. Within the original treatment
zone,  40 samples were analyzed for TRPH  and moisture; 20 of these samples were also  analyzed for
VOCs and SVOCs. Within the  revised treatment zone, 20 samples were analyzed for TRPH and
moisture; 7 of these samples were also analyzed for VOCs and SVOCs.
                                                 44

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       Also during each phase of sampling, six field duplicates were collected for TRPH and moisture;
three of those field duplicates were also analyzed for VOCs and SVOCs. Five  laboratory duplicates were
prepared for moisture during the pretreatment sample analysis and four during the post-treatment
analyses. Four laboratory duplicates were prepared for TRPH during each phase of testing. Samples
were analyzed for VOCs, SVOCs, and TRPH as matrix spike/matrix spike duplicate (MS/MSD) samples
at the frequencies specified in Table 8. Three field blanks were analyzed for VOCs, SVOCs, and TRPH.
Each cooler used to ship samples for VOC analyses contained a trip blank, which was analyzed for
VOCs.

       Additional samples were collected for particle size analysis. During pretreatment sampling, 58
samples and 5 field duplicates were submitted for particle size analysis. During post-treatment sampling,
52 samples and 6 field duplicates were submitted for particle size analysis.  One particle size analysis
laboratory duplicate was prepared for each phase of sampling. The numbers and types of samples
analyzed for theKAI RFH SITE demonstration are summarized in Table 8.

          Table 8. Summary of Number of Samples Analyzed for the KAI RFH Test
Measurement
Pretreatment
TRPH
Moisture
Particle Size
Distribution
VOCs
SVOCs
Post-treatment
TRPH
Moisture
Particle Size
Distribution
VOCs
SVOCs
Number
of
Samples

64
64
58

32
32

64
64
52

32
32
Field
Duplicates

6
6
5

3
3

6
6
6

3
3
Laboratory
Duplicates

4
5
1

NA
NA

4
4
1

NA
NA
Matrix
Spikes

7
NA
NA

5
4

5
NA
NA

5
3
Matrix
Spike
Duplicates

7
NA
NA

5
4

5
NA
NA

5
3
Field
Blanks

3
3
NA

3
3

3
3
NA

3
3
Trip
Blanks

NA
NA
NA

10
NA

NA
NA
NA

6
NA
Total

91
78
64

58
46

87
77
57

54
44
NA = not applicable
                                            45

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422 SVE Vapor Stream
       The SVE system was designed with eight extraction wells.  Six of the eight wells (El, E3, E4,
E5, E6, E8) were screened 10 to 20 feet bgs, which is almost entirely below the revised treatment zone
of 4 to 14 feet bgs. The other two (E2 and E7) were screened from 0 to 10 feet bgs, which covered all
but the last 4 feet in the revised treatment zone.  Throughout the demonstration, the SVE system operated
using various combinations of extraction wells. At least one extraction well was operating at any given
time, and as many as four were used simultaneously. Wells that were not being  used at a particular time
were capped, with the exception of several days when some wells were open  to the atmosphere (i.e.,
operated in the passive mode).  Operating data on the SVE system is presented in Appendix A.

       The vapor stream from the SVE system  was sampled and analyzed six times during the
demonstration.  Vapor stream samples were collected from a combined header  exhaust port downstream
of where the individual extraction wells  were tied in. The VOC samples were collected in SUMMA
polished stainless steel canisters and analyzed using a gas chromatograph (GC) with dual columns and
multiple detectors (GC/MD). The SVOC samples were collected using a modified version of EPA
Method 0010 and analyzed using Method  8270. These samples were collected to characterize the
compounds being removed from the subsurface during system operation.

423 Soil  Vapor
       Six soil vapor samples were collected and analyzed from the existing pressure transducer wells
positioned near the treatment area (TD1, TD2, TD3, TD6, TD7, TD8). TD1 and TD2 are deep wells
screened from approximately 20 to 24 feet. The others are shallow wells screened from about 10 to 14
feet. The samples were collected in SUMMA polished stainless steel canisters  and analyzed for VOCs
using GC/MD  These samples  were collected prior to the start of RFH and were used to determine what
VOCs may have been present in the soil vapor prior to heating.  This data is presented in Appendix A.

4.2.4 Groundwater
       Groundwater samples were collected from three wells near the treatment zone (MW-10, MW-09,
andDW-02) during drilling activities. Three well volumes were purged from each well before the sample
was collected. Groundwater samples were analyzed for the same compounds as the soil samples (TRPH,
the target VOCs in Table 5, and the target SVOCs in Tables 6 and 7).   Data from these samples were
used to characterize the groundwater and to identify whether the groundwater was a potential source for
                                            46

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                      into 'the        soil

4.3
       It is           to note that
not under the control of the developer. These factors                 with the delivery of         AC
power to the RFH system, the          and                of extraction wells, and the       of time
                  to the soil. Commercial            of the RFH technology with      factors
control of the developer may yield significantly         results.

4,3.1  Soil
       Soil         were             and     the soil                 KAFs RFH technology.  As
discussed in  Subsection 4.2,1, the post-treatment soil         were      as close as  possible to  the
             sampling locations. The analytical     were          as               of pre- and post-
          samples.  If concentrations had only                           the percent decrease would
                   for      pair.  Howe¥er, in                                       were higher
                 concentrations. As a result, for     contaminant, the log-transformed ratio of the post-
          concentration to the pretreatment concentration was calculated for each sample pair. The ratios
were evaluated statistically      a t test to                  the            concentration had exhibited
a statistically significant change (starting at the 80                   level)         the pre- and post-
          sampling events.  The                ratio of post-treatment concentration, to pretreatment
concentration was also calculated. This geometric       ratio was converted to a geometric mean percent
         or a geometric                       as

4.3,1.1
       The soil         were          by  EPA         907!A  [2] prior to TRPH analysis by EPA
Method 4(8.1 [3], Samples were also                   for moisture by ASTM        D2216,  The
TRPH sesults were then adjusted, to a dry-weight basis.  TRPH.  concentrations exhibited statistically
significant changes at  the  95     90 percent confidence  levels within the revised treatment zone and,
original treatment zone, respectively.  The          geometric       decreases were 49 percent within
'the                 zone and 29 percent within the                  zone.  Data from pre- and post-
          TRPH         are            In Appendix A.
                                               47

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       TRPH removals were not as projected.  A number of problems with the design and operation of
the SVE system were identified after the demonstration was complete. These problems included
extraction wells screened below the revised treatment zone, which may have drawn contaminants from
the revised treatment zone into the cooler soil, where they condensed. The SVE system configuration also
may have resulted in low vapor flows within the treatment zone and in high vapor flows from areas
outside the treatment zone.   These problems may have resulted in contaminant migration into the
treatment zone from surrounding soils. In addition, temperature sensors indicated that only a portion of
the revised treatment zone reached the revised target temperature range of 100 to 130°C. The developer
claims that the actual soil temperatures were higher than the recorded values since measurements were
taken within boreholes. This is due to there being no sensors  that measured the instantaneous,
microscopic heating of the  contaminants, and all sensors were likely to provide readings that were lower
than the actual temperatures of materials.

       Because of changes in the RFH system prior to startup and the design of the SVE system, it
cannot be concluded whether the changes in TRPH concentration inside and outside the treatment zones
were a result of RFH treatment or were due solely to application of SVE.

       As discussed in Subsection 4.1, significantly more power was applied to A2 than Al during the
demonstration.    Because  Al and A2 were heated differently,  Al and  A2  zones were evaluated
individually in addition to the evaluations of the original and revised zones. Like the revised zone, the
Al and A2 zones both extend from 4 to 14 feet bgs.  Because the RFH system heats soil radially, the Al
and A2 zones were elliptically shaped and centered around each antenna. The Al zone, comprising 15
samples, contains the following boreholes:  El, E6, Fl, Al, F4, E4, E2, F3, E7, and E5. The A2 zone,
comprising 15 samples, contains the following boreholes: E2, F3, E7, ES,  F2, A2, F5, E3, E8, and E4.
(See Figure  1 for borehole locations.) The Al zone did not exhibit a  change in contaminant  concentration
that was statistically significant (at the  80 percent confidence level).  The A2  zone exhibited a statistically
significant change at the 80 percent confidence level. The estimated geometric mean decrease was 44
percent.   Because only a portion of the revised treatment zone reached the target temperature range of
100  to 130°C, it seems most likely that the  system did not achieve an adequate temperature. The low
temperatures were at least partially due to problems with the electrical power available at the site.
                                             48

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4.3.1.2 SVOCs and VOCs
       SVOCs and VOCs were designated as noncritical measurements for this demonstration because
samples collected prior to the demonstration indicated that the soil at the site generally contained low
concentrations of SVOCs and VOCs   SVOCs and VOCs were designated as noncritical measurements
in the Demonstration Plan and therefore their concentrations were measured in only half of the soil
samples.  SVOC samples  were extracted by EPA Method 3540 [2] prior to  analysis by EPA Method 8270
[2]. VOC concentrations were determined using EPA Method 8240 [2]. SVOC and VOC results are
presented on a dry-weight basis.

       Concentrations of individual SVOCs and VOCs in the soil samples  were evaluated using the same
procedures described for TRPH.  Concentrations of several SVOCs exhibited  statistically significant
changes (at an 80 percent confidence level) within the original and revised treatment zones.  Statistically
significant changes in SVOC concentrations within the original and revised treatment zones are presented
in Table 9.  As with the  TRPH data, it cannot be concluded that the changes in SVOC concentrations
inside and outside the treatment zones were affected byRFH treatment.

                Table 9. Summary of SVOC Decreases Inside Treatment Zones

                                     Geometric Mean Percent Decrease      Geometric  Mean Percent  Decrease
         contaminant                     in Original Treatment Zone            in Revised Treatment Zone
        Benzo(b)fluoranthene                        44*                                40b
        Benzo(a)pyrene                             44C                                43b
        Bis(2-ethylhexyl)phthalate                     55d                                ***
Chrysene
***
Pyrene
Fluoranthene
40"
60*
53b
*** No statistically significant change at the 80 percent confidence level.
a  Change accepted at a 97.5% confidence level.
b  Change accepted at a 80% confidence level.
c  Change accepted at a 95% confidence level.
d  Change accepted at a 90% confidence level.

       Pre- and post-treatment concentrations of individual VOCs were also measured.  None of the
individual VOCs exhibited statistically significant changes (at an 80 percent confidence level) within the
original or revised treatment zones.  High concentrations of some VOCs (toluene, chlorobenzene,

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methylene chloride) were detected in some soil samples, but the changes in concentrations were not
statistically significant.  However most target VOCs in the pre- and post-treatment soil samples had low
concentrations, and a statistical evaluation could not be made.  No conclusions about changes in VOC
concentrations can be made.

       Due to fewer data points (as compared to amount of TRPH points), and since the analysis of
SVOCs and VOCs was not a critical parameter, contaminant changes were not examined in the Al and
A2 zones

4.3.1.3 Particle Size Distribution
        Laboratory tests were conducted to determine sample grain size distribution. The full procedure
as described  in ASTM D422 [2] was used for at least 10 percent of the samples.   Samples that were
processed in accordance with the ASTM procedure as prescribed are referred to as wet-sieved samples.
The remaining samples  were analyzed by dry-sieving.   Regardless of which procedure was used to
perform the grain size distribution, the soils were first prepared according to ASTM Method D421. In
this method, the soils are dried and processed to break down all soil particles into their component sizes.
Samples processed by dry-sieving were simply taken from this sample preparation procedure and screened
using twelve sieve  sixes, ranging from 3 inches (7.62 cm) to 75 /xm (#200 sieve). For the samples
processed by wet-sieving, the dried soil sample is initially segregated into two fractions using a #10 sieve.
Soils that pass through the #10 sieve are then dispersed in an aqueous solution and passed over the
remaining sieves "wet. "  Particles that pass the #200  sieve are further classified using a hydrometer,
which results in a minimum size classification of approximately 0.001 mm. To provide information
required for the reduction of the hydrometer data, the specific  gravity of the soils subjected to wet-sieving
was  determined using the procedure outlined in ASTM D854-83 [1].

       This  combined use of dry- and wet-sieving was specified in the Demonstration Plan because
discussions with laboratory personnel indicated that the two procedures should yield similar results for
particle sixes  not passing the #200 sieve.  This was not the case for the soil samples associated with this
site.  The dry-sieve method produced results  that overestimated the sand fraction  of the soil. The soil
preparation method was  apparently insufficient to break down  clumps of cohesive clay particles. It was
known that wet-sieving and subsequent hydrometer testing  would be required to characterize particles that
passed the #200 sieve further and, therefore, a decision was made to subject a subset of the entire sample
set to the wet-sieving procedure. Since dry-sieving is less costly, and the further characterization of these

                                              50

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small particles was a minor point, it seemed reasonable to use dry-sieving primarily.

        As a result, particle size distribution data obtained by wet-sieving is being used to characterize
the site, and the data obtained by dry-sieving are not being used. The particle size distribution summary
from wet-sieving tests is listed in Table 10.  For evaluation purposes, the data were simplified into three
standard geologic categories: gravel, sand, and fines. Particles that are less than 3 inches in diameter
but will not pass through a #4 sieve (4.75 mm) are classified as gravel, particles that will pass through
a #4 sieve but will not pass through a #200 sieve are classified as sand, and particles that will pass
through a #200 sieve are classified as fines.  Additional particle size distribution data are presented in
Appendix A.

                Table 10. Average  Particle  Size  Distribution  (Wet-Sieving Only)

Pretreatment
Post-treatment
Average Percent Gravel
29.4
42.9
Average Percent Sand
30.7
29.1
Average Percent Fines
39.9
28.1
        The data show a predominance of sand and gravel at this site, which indicates the soil should be
amenable to RFH and SVE.

4.3.2 SVE Vapor Stream
        Appendix A lists the results of the vapor stream samples.  Approximately 70 VOCs and 12
SVOCs were detected in these vapor samples, indicating that these contaminants were removed from the
soil. Typically, vapor stream concentrations from SVE systems are higher when the system is first
started, then decreases as the system continues to operate. Because RFH volatilizes the contaminants as
it operates,  this type of pattern should not be observed.  In  fact, vapor stream concentrations may increase
as the soil temperature increases.  In particular, if an area of high contaminant concentration is heated,
corresponding increases in the vapor stream concentrations are expected.

        During the demonstration, numerous changes were made to the operation of the SVE system.
Over the course of the demonstration, the SVE system was operated using 55 different combinations of
operating parameters.  Operating parameters that were varied included the number of wells being operated
                                              51

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as extraction wells, the number of wells being operated as passive vent wells (if any), and the operating
pressure.

       The first sample was collected when the SVE system was operational, but prior to the start of
the RFH system. Although the SVE system was not yet operating continuously, it was operating for this
sampling event. This sample established baseline conditions (i.e., removal with SVE only). Sample 2
was collected just after the RFH system was turned on. Sample 3 was collected when soil temperatures
were approximately 100°C near the operating antenna.  (At 100°C, moisture in the soil should begin to
be driven off.) Sample 4 was collected when soil temperatures reached their maximum. Sample 5 was
collected several days after the RFH system was turned off, but while the SVE system continued to
operate. The sample  represented the start of the cool-down phase.  Sample 6 was collected just prior to
the shut-off of the SVE system.

       In general, contaminant concentrations in the first and second vapor samples were almost equal
to one another.  The third and fourth samples had lower contaminant concentrations than the first two
samples.  The fifth sample had the lowest concentrations of the six samples, while the last sample had
the highest concentrations.    These relative concentrations do not match the patterns that would be
expected for an SVE system or an SVE system used with an RFH system.  However, because the
operation of the SVE system varied considerably throughout the demonstration (e.g., wells E4 and E5
were used for vapor extraction for  the third and fourth sample, but not the fifth), it is not possible to
explain the observed vapor  stream contaminant concentrations. The data indicate the SVE system is
removing contaminants; however, it is not possible to determine how RFH enhanced SVE performance.

4.3.3  Soil Vapor  Gas
       These samples were collected on the same day that the baseline sample for the SVE vapor stream
was collected (Sample 1). Appendix A lists the results of the soil vapor samples. The soil vapor data
appear similar to the vapor stream data from the SVE system (i.e., compounds detected in the soil vapor
were also detected in the SVE vapor  stream).  Because the SVE system  operated under varying
conditions, no attempt was made to correlate these data sets.

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4.3.4  Groundwater  Samples
       Groundwater was sampled from three different wells just outside the treatment zone before it
received RFH. The results of this sampling are listed in Appendix A. The groundwater data, which are
considered noncritical, show concentrations of TRPH and several target VOCs and SVOCs. All of these
compounds were also detected in either the soil, soil vapor and/or the SVE vapor stream.  No attempt
was made to correlate these data sets to each other.  The approximate location of the wells is displayed
in Figure 5.
                                                                               MW09
                  > N                                                             •
                                                    MW10
           DW02
                                                            Original Treatment Zone
 •  Groundwater  sample collection  point

                   Figure 5. Locations of Groundwater Sample Collection

4.3.5 Moisture
       Moisture analysis was conducted so that soil sample concentration results could be converted to
dry weight. Appendix A presents the results of moisture analyses.

4.4    CONTAMINANT MIGRATION
       An RFH system generates a flow of contaminant vapors in the soil that must be collected with
an SVE system.  A properly designed SVE system will collect the contaminant vapors and prevent the
inward flow of contamination into the treatment zone from the surrounding area. It will also prevent the

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outward migration of contaminants.  In order to determine if migration is occurring, samples must be
collected and analyzed in the treatment zone and the surrounding area before and after RFH. Changes
in concentrations between samples inside the treatment zone would be compared to changes in
concentrations  between samples outside the treatment  zone.

        In evaluating the soil data to determine if contaminant migration had occurred, a number of
problems with the SVE system were identified. A vapor barrier was installed to prevent air infiltration
and consequent short-circuiting at the surface and to prevent the escape of fugitive emissions. The vapor
barrier extended 10 feet laterally beyond the treatment zone boundaries on each of the four sides. With
the particular operational configurations of vacuum wells selected, the presence of the vapor barrier
resulted in low gas flows within much of the treatment area and in high flow rates from areas outside the
treatment zone.   This may have resulted in contaminant migration into the treatment zone from
surrounding  soils.

        The original  SVE system design called for three of the six surrounding wells (E6, E7, and E8)
to be passive vent wells; air would be extracted from one or more of the other wells. This design would
help to isolate the treatment zone, which would have minimized contaminant migration into it.  However,
during the demonstration, the SVE system was generally operated with no passive vent wells and a
variety  of different configurations of extraction wells.  Wells not being used  in  any particular
configuration were capped. Normally, two or more extraction wells were operated at the same time.
With no passive vent wells, the soil gas flow rates would have been very low in the area bounded by the
vacuum wells because the gas pressure gradients  in this region would have been quite small.  This would
have been true even when the vacuum on the extraction wells was high.   Since two or more extraction
wells were generally  in operation at one time, and there were no passive vent wells, and also since the
area was covered by an impermeable cap, there would have been very little gas flow in most of the region
lying within the polygon having the vacuum wells at its comers.

        The extraction wells were generally screened well below the revised treatment zone,  so that
organics volatilized in the revised treatment zone may have condensed when drawn into the cooler
underlying soil.

        TRPH concentrations increased outside the revised treatment zone at the 80 percent confidence
 level.   The estimated geometric mean increase was 39 percent. The increase is probably  due to inward

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vertical and lateral migration from the surrounding area. TRPH increased outside the original treatment
zone at the 97.5 percent confidence level. The estimated geometric mean increase was 96 percent. This
increase was probably due to the design and operation of the SVE system, which resulted in inward
vertical and lateral migration from the surrounding area.

        Because of the low concentrations of most target SVOCs in the pre- and post-treatment soil
samples, only benzo(a)anthracene was present in sufficient quantity to make a statistical evaluation. It
decreased 43 percent outside the revised treatment zone at the 90 percent confidence level; however, its
decrease inside the original zone was not statistically significant. It is not known why this compound
decreased outside the revised treatment zone.

        High concentrations of several VOCs (toluene, chlorobenzene,  methylene chloride) were detected
in some soil samples, but the changes in concentrations were not statistically significant.  However most
target VOCs  in the pre-  and post-treatment soil samples had low concentrations, and a statistical
evaluation could not be made.

        Several groundwater samples were collected to characterize  the site and to determine whether
contaminants from the  groundwater were migrating into the treatment zone. Chlorobenzene was one of
the predominant contaminants  in the groundwater, but very little chlorobenzene was detected in the
revised and original treatment  zones.  The highest chlorobenzene concentrations  were  in the deeper  soil,
closer to the groundwater.

        Pretreatment chlorobenzene concentrations  in the soil within the revised treatment zone ranged
from less than 22.7 ppb to less than 50 ppb, with none of the eight samples having concentrations above
the PQL level.  Because  of the  low pretreatment concentrations within the revised treatment zone, no
statistically significant decrease could  be observed.  Chlorobenzene concentrations in the soil within the
remainder of the original treatment  zone were higher, but no statistically significant decrease  was
exhibited within the original treatment zone.

        Chlorobenzene concentrations in the soil below the original  treatment zone were significantly
higher than those inside the revised and original treatment zones. Analyses of soil samples below 20 feet
indicated chlorobenzene concentrations as high as 239,000 ppb in pretreatment and 291,000 ppb in post-
treatment samples.  Even with these high starting concentrations, no statistically significant decrease of

                                              55

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chlorobenzene was observed in the area outside the original treatment zone. However, this zone was not
heated or screened during the demonstration and was not expected to show contaminant decrease.

        In spite of the fact that no statistically significant chlorobenzene decrease was observed in the
soil, SVE vapor stream data indicate significant amounts of chlorobenzene being extracted before, during,
and after the heating stage of the demonstration.  It is possible that the amount of chlorobenzene extracted
from the soil was not enough to cause a statistically significant decrease. Alternatively, the chlorobenzene
present in the SVE vapor stream may indicate some source of chlorobenzene other than the soil.

        Significant concentrations of chlorobenzene were found in groundwater samples collected from
surrounding wells before the demonstration.  These wells are located outside of the treatment area
sampled for this demonstration.  Chlorobenzene concentrations are 12,000 ppb in MW-09, 25,500 ppb
in MW-10, and 15,500 ppb in DW-02. This indicates that the groundwater, which is probably causing
high levels of chlorobenzene outside the demonstration area, may be a source of the chlorobenzene in the
SVE vapor stream.

4.5     RESIDUALS
        The residuals resulting from the  demonstration  of the KAI RFH technology include soil;
contaminant vapors removed from the soil; condensate collected within the vapor treatment system;
washwater from equipment and personnel decontamination; and miscellaneous solid wastes, such as used
PPE. All residuals remained the responsibility of Kelly AFB. The treated soil was left in place, and soil
cuttings from drilling activities were drummed and removed from the site for disposal.  Contaminant
vapors that condensed within the vapor treatment system were collected and transferred to a Kelly AFB
industrial wastewater  treatment facility. Vapors that did not condense  were  channeled to a propane-fueled
flare for destruction.

4.6     REFERENCES
1.      American Society for Testing and Materials, Annual Book of ASTM Standards.
2.      U.S. Environmental Protection Agency, Test Methods for Evaluating Solid Waste (SW-846):
        Third Edition, November, 1986,  and Final Update, September, 1990.
3.      U.S. Environmental Protection Agency, EPA Methods for Chemical Analysis of Water and
        Wastes, 1983.
                                              56

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                                        SECTION 5
                         OTHER TECHNOLOGY REQUIREMENTS

5.1     ENVIRONMENTAL  REGULATION  REQUIREMENTS
       State regulatory agencies may require permits for the onsite installation and operation of KAI's
RFH system. An air emissions permit may be required for the vapor treatment system. If offsite
disposal of contaminated residuals is required, the residuals must be removedfrom the site by a licensed
transporter.  These residuals must be treated or disposed of by a permitted incinerator or other treatment
or disposal facility. Additional environmental regulations may apply, depending on the characteristics
of the specific site and the contaminants present.

5.2    PERSONNEL ISSUES
       Proper PPE should be available and properly utilized by all onsite personnel.  PPE requirements
will be site-specific and should be determined based on the contaminants present at the site and on the
work activities being conducted,  During the demonstration, PPE levels were designated according to the
potential hazards associated with each work activity. At a minimum, Level D PPE was required for all
personnel working at Site S-l.  During most demonstration activities, site personnel were not in contact
with the contaminated soil because it was covered with a layer of gravel. The potential for exposure to
soil contaminants was increased  during drilling activities, including pretreatment sampling, installation
of subsurface system components, and post-treatment sampling.

       Site  monitoring should be conducted to identify the extent of hazards and to document exposures
at the site. Monitoring results should be maintained and posted. During the demonstration, a flame
ionization detector (FID) was used to monitor the air near the soil and in the breathing zone during
drilling, groundwater sampling,  and related activities.  Because the degree of soil and groundwater
contamination varied considerably, the drill crew and other personnel alternated use of Level C PPE and
Level D PPE.  They upgraded to Level C PPE when the FID indicated breathing zone air contaminant
concentrations greater than 5 ppm over background for 5 minutes; they were permitted to downgrade to
Level D when the FID indicated breathing zone air contaminant concentrations less than 5 ppm over
background. Respirators were required periodically during both pre- and post-treatment sampling.
                                             57

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        OSHA 40-hour training covering PPE application,       and health, and  emergency
procedures should be         tor all           working with, the RFH technology.  Additional training
provided prior to the operation of die        at a given site should include Information, regarding
emergency evacuation            safety            locations;  the            of the exclusion zone,
                      zone, and         zone; PPE              and site-  and  technology-specific
hazards. Potential                  with the RFH                  drilling          and personnel
exposure to RF fields.  Safe operating procedures should always be observed, particularly during drilling
operations.  Periodic monitoring for RF electromagnetic fields will also reduce the technology-specific
hazards.

        Onslte                             In a                    program.   Health and  safety
monitoring and  Incident reports should be routinely filed, and         of occupational illnesses and
injuries (OSHA Forms 102     200) should be maintained.  Audits, ensuring compliance with, the health
and safety     should be carried out. In the event of an accident, illness, hazardous situation at the site,
or           act of harm,           should be            sought from the local  emergency response
       and.     aid or                 should be          if             To       a
In       of an  emergency,                  review  the             plan, fircfigiiting procedures,
cardiopulmonary             (CPR)  techniques, and                            procedures before
         the system. An evacuation vehicle  should be available at all times.

5.3
        Community           of a technology is         by both       and perceived hazards. The
fact     the RFH technology allows In situ            of contaminated     should improve the potential
for community acceptance,                of                               volatile
Although some contaminants are likely to be  released during electrode     thermowell Installation, the
potential for           during drilling is             lower            excavation.

        Disadvantages           with  in situ 'RFH and,      in situ             are the difficulty of
determining         the treatment      has      uniformly           and the potential for contaminant
migration if pockets of contamination remain in the soil. Actual or perceived hazards associated with the
WF energy      also become an Issue, as potential              of electromagnetic  fields have recently
received significant publicity.       community education may be          to        residents'that the
operation of the RFH        Is in compliance with, safety              and guidelines. The American

                                               58

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Conference of Governmental Industrial Hygienists (ACGIH) has established Threshold Limit Values
(TLVs) for radio frequency radiation.  The TLVs are dependent on the frequencies of the radio waves.
TLVs and formulas for calculating TLVs are presented in Table 11.  The RFH system used during the
SITE demonstration was designed to operate at a frequency of 27.12 MHz.  TLVs for this specific
frequency are also presented in Table 11.

                       Table 11. Radio  Frequency Radiation  TLVs [1]
Frequency
27.12MHz
30 kHz to 3 MHz
3 MHz to 30 MHz
30 MHz to 100 MHz
100 MHz to 1,000 MHz
1 GHz to 300 GHz
Power Density
(mW/cm2)
1.22
100
900/f2
1
f/100
10
Electric Field
strength squared
(Wm2)
4,613
377,000
3,770(900/f2)
3,770
3,770 (f/100)
37,700
Magnetic Field
strength squared
(A^m2)
0.033
2.65
900/(37.7 x f2)
0.027
f/(37.7 x 100)
0.265
f = frequency in MHz
       REFERENCE
       American Conference of Governmental Industrial Hygienists. Threshold Limit Value. 1992.
                                           59

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                                        SECTION 6
                                 TECHNOLOGY STATUS

       KAFs RFH system was used to treat approximately 56 cubic yards of soil at Kelly AFB during
the SITE demonstration. The soil in the treatment zone was contaminated with mixed solvents, carbon
cleaning compounds, and petroleum oils and lubricants. The results of this demonstration are summarized
briefly in Section 4 of this report and are summarized in greater detail in Appendix A.

       Prior to the SITE  demonstration conducted at Kelly AEB, KAI's RFH system was tested at
several other sites. The results of two of these tests are available to the public.  One test was conducted
at the Savannah River Superfund site to investigate the effectiveness of the KAI RFH system as an
enhancement to vacuum extraction. During the Savannah River test, KAFs RFH system was used in the
removal of residual solvents (primarily trichloroethylene and perchloroethylene) from vadose zone clay
deposits approximately 40 feet bgs.  A second test was conducted to evaluate the ability of the KAI RFH
system to enhance the removal of #2 Fuel Oil from silty soil.  Both tests are described in greater detail
in Appendix B.
                                            60

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                                      APPENDIX A
                                     Performance Data

A.1    CHEMICAL ANALYSES
A.I.I  Procedure for Selecting Contaminants for Statistical Evaluation
       All soil samples were analyzed for TRPH, and half of the soil samples were analyzed forVOCs
and SVOCs. TRPH in the soil samples was extracted by Method 9071A prior to analysis by Method
418.1.  VOCs in the soil samples were analyzed by Method 8240. Target VOCs are listed in Section 4,
Table 5.  SVOCs in the soil samples were extracted by Method 3540 prior to analysis by Method 8270.
Target SVOCs are listed in Section 4, Tables 6 and 7.

       The first step of the data evaluation process was to count the number of pretreatment samples in
which each target compound was detected above its method detection limit (MDL).  Many target VOCs
and SVOCs were not detected in any pretreatment samples. Table A-l lists those compounds that were
detected and the number of samples in which each compound was detected above its MDL.

       Only  13 contaminants were detected above their MDLs in over 15 samples (numbers shown in
bold in the second column of Table A-l).  The number  of complete matched data pairs inside the original
treatment zone was determined for each of these 13 contaminants. A complete matched pair consists of
a pretreatment sample and a post-treatment sample collected as close as possible to the pretreatment
sample.  In order to be included in the  evaluation process  for a given compound, a matched pair must
also meet the following criteria:
       1)  The pre- and post-treatment concentrations  of the selected compound must not both be below
           their MDLs.
       2)  If either  the pretreatment or post-treatment concentration of the selected compound is below
           its MDL, its MDL must not be greater than the measured concentration of the other sample.

       As  shown in Table A-l, six of the contaminants evaluated had 10 or more complete matched
pairs within the original treatment zone  (numbers shown in bold in the third column of Table A-l).
Practical quantitation limits (PQLs) of five times the MDLs were calculated for all data points for each
                                            61

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                             Table A-l. Summary of Data Evaluation Process
  Contaminant
# of pretreatment samples in
  wnich contaminant was
  detected above its MDL
# of complete matched pairs
within the  orignal treatment
   zone,  based on MDLs
# of complete  matched pairs
within the revised  treatment
   zone, based on  PQLs
TRPH
Acetone
Benzene
Chloxvbenzene
Ethylbenzene
Methyl ethyl ketone
Methylene chloride
Tetrachloroethene
Toluene
Trichloroethene
Xylenes
Acenaphthene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Bis(2-cthylhexyl)phthalate
2-Chlorophenol
Chrysene
Dibenz(ah)anthracene
Dibenzofuran
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,4- Dichlorobenzene
2,4-Dimethylphenol
Di-n-butylphthalate
Fluoranthene
Fluorene
Hexachlorobenzene
Indeno (123cd)pyrene
2-mcthylnaphthalene
Naphthalene
Phenanthrene
1,2.4-Trichlorobenzene
Pvrene
TOTALS
64 40
14
2
29 9
5
221
20 0
1
20 3
1
11
7
9
16 13
15 13
17 14
27 16
1
16 12
4
5
14
14
15
5
10
27 19
13
2
11
20 9
15
23 13
6
22 18
519 188
20


2


0

1




5
4
5
5

5













0

5
57
a  Similar concentrations were observed in laboratory blanks; therefore, this compound was not considered during tbe statistical analyses.
                                                        62

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of these six contaminants; these PQLs were then used during the statistical analyses.  The use of PQLs
eliminates estimated values and results in more conservative evaluations. The number of complete
matched data pairs inside the original treatment zone was then redetermined for these six contaminants,
based on PQLs rather than MDLs.

        Because the PQLs were five times the MDLs, the conversion to PQLs eliminated many complete
matched pairs.  In addition, the SITE Program was informed at this point that KAI and B&RE changed
the test plan during installation and decided to heat only the upper half (approximately) of the original
treatment zone.  Throughout this document, the upper half or the original treatment zone is referred to
as the "revised treatment zone", which ranges in depth from 4  feet to 14 feet. When the evaluation was
changed to the revised treatment zone, this further reduced the number of complete matched pairs.  As
shown in the last column of Table A-l, TRPH had 20 complete matched pairs, within the heated zone
(using PQLs).   All other contaminants evaluated had between zero and seven complete matched pairs
within the revised treatment zone.

        As a result, paired t-tests for the revised treatment zone were performed on all VOCs which met
the first requirement.  Paired t-tests were performed on all  SVOCs which met the first two requirements
and also contained three or greater matched pairs in the revised  zone. Results are reported only for those
compounds that exhibited statistically significant changes at confidence levels of 80 percent or greater.
The methodology for conducting a paired t test for a given compound is described in the following
subsection

A. 1.2 Methodology  for Statistical Evaluation
        The number of complete matched pairs for a given contaminant was determined  and was
represented by N.  Because the TRPH data were found to be log-normally distributed, logarithms of all
data were calculated before the data were manipulated.  Xw was used to represent the pretreatment  log
concentration of this compound from the i* sample location, and XS1 was used to represent the post-
treatment log concentration from the i* sample location (where i varied from 1 to N). The difference in
log concentrations (Xu - Xffl) was calculated for each data pair and was denoted by <^.  The mean of the
differences in log concentrations was calculated according to the following formula:
                                            63

-------
                                             "ft
       R was used to represent the geometric mean of the ratios of post-treatment concentration to
pretreatment concentration, which was calculated from the geometric mean of the differences in log
concentrations according to the following formula:

                                           R = 103

R was then converted to either percent decrease or percent increase, as  appropriate.

       The standard deviation of the differences in log concentrations was calculated according to the
following  formula:
                                       \
                                         N-1
 M
£  C4
i=i
        It was assumed that the unknown pre- and post-treatment logmean concentrations throughout the
entire site were % and % respectively, and the logvariances were equal.  The following equation defines
the statistic used in the paired t-test:
The resulting value of t was compared to tabulated values of t for two-tailed tests to determine the
probability that the measured change (percent decrease or percent increase) was representative of the
revised treatment zone.

A. 1.3  Data Summary
       TRPH
       Tables  A-2 through A-7 present pre- and post-treatment TRPH data from analyses of soil
samples.  The sample locations presented in these tables correspond to the subsurface components labeled
on Figure 1 .
                                             64

-------
Table A-2. TRPH Samples Revised Zone (ppm)
Sample Location
E1-U1012
E6-U0810
F1-U0406
F1-U1012
E4-U0709
E4-U0911
F4-U1214
E2-U1012
F3-U0406
F3-U1012
E7-U1214
E5-U0406
E5-U0608
E5-U1012
E5-U1214
F5-U1214
A2-U0406
A2-U1012
A2-U1214
E8-U0608
Pretreatment
Reported Value
(* if PQL)
3,350
1,860
6,910
1,240
1,310
729
1,790
168.5*
4,920
336
1,400
2,710
1,530
668
739
1,220
1,530
1,290
622
655
Post-treatment
Reported Value
(* if PQL)
1,160
930
828
1,580
1,090
593
643
582
702
4,510
825
673
587
330
1,450
1,530
154
33.3 *
106
861
Post-treatment •
Pretreatment Value
-2,190
-930
6,082
340
-220
-136
-1,147
414
-4,218
4,174
-575
-2,037
-943
-338
711
310
-1,376
-1,257
-516
206
                   65

-------
A-3. TMPH
Sample Location
E1-U0002
E1-U1012
E1-U1618
A1-U0002
A1-U1618
A1-U1820
E6-U0810
E6-U1618
F1-U0406
F1-U1012
F1-U1820
E4-UG7G9
E4-U0911
F4-U0002
F4-U1214
F4-U1618
E2-UQOG2
E2-U1012
F3-U0406
F3-U1012
E7-U0204
E7-U1214
F2-U1416 '
E5-U0406
E5-U0608
E5-U1012
E5-U1214
E5-U1820
F5-U1214
Pretreatment
Reported Value
(*if'PQL)
352
3,350
22,000
458
79,700
39,300
1,860
3,160
6,910
1,240
5,440
1,310
729
1,220
1,790
1,090
1,730
168.5*
4,920
336
492
1,400
3,250
2,710
1,530
668
739
105,000
1,220
Post-treatment
Reported, Value
(* if PQL)
4,830
1,160
19,200
184
20,800
28,300
930
253
828
1,580
23,100
1,090
593
448
643
12,500
3,620
582
702
4,510
161
825
555
673
587
330
1,450
35,800
1,530
Post-treatment -
Pretrcatinent Value
•4,478
2,190
2,800
274
58,900
11,000
930
2,907
6,082
-340
-17,660
220
136
772
1,147
-11,410
-1,890
-414
4,213
-4,174
331
575
2,695
2,037
943
338
-711
69,200
-310
                 66

-------
                                      Table A-3. (continued)
Sample Location
 Pretreatment
Reported Value
   (* if PQL)
 Post-treatment
Reported Value
  (* if PQL)
                                                                                Post-treatment -
                                                                                Pretreatment Value
F5-U1618

F5-U1820

E3-U1416

E3-U1618

A2-U0002

A2-U0204

A2-U0406

A2-U1012

A2-U1214

A2-U1618

E8-U0608
     22,100

     35,000

       1,210

       7,410

       2,330

        203

       1,530

       1,290

        622

     23,800

        655
       20,900

       53,200

        1,770

        2,820

        8,850

        2,570

          154
           11
           33.

          106

        6,500

          861
  1,200

-18,200

   -560

  4,590

 -6,520

 -2,367

  1,376

  1,257

   516

 17,300

   -206
                                               67

-------
A-4.
Sample Location
E1-U0002
E1-U1618
E1-U2425
A1-U0002
A1-U1618
A1-U1820
A1-U2728
E6-U1618
E6-U2022
F1-U1820
E4-U2426
F4-U0002
F4-U1618
F4-U28291
E2-U0002
E2-U2628
F2-U1416
F2-U2628
E5-U1820
E5-U2022
F5-U1618
F5-U1820
F5-U2324
E3-U1416
E3-U1618
E3-U2022
E3-U2829
A2-U0002
A2-U1618
Pretreatment
Reported Value
(*ifPQL)
352
22,000
4,690
458
79,700
39,300
2,240
3,160
22,700
5,440
3,660
1,220
1,090
1,670*
1,730
4,440
3,250
4,440
105,000
43,500
22, 100
35,000
10,300
1,210
7,410
1,360
325
2,330
23,800
Post-treatment Post-treatment-
Reported, Value Pretreatment Value
(* ifPQL)
4,830
19,200
6,830
184
20,800
28,300
5,880
253
92,600
23,100
3,170
448
12,500
1,520
3,620
23,100
555
6,270
35, mo
31,200
20,900
53,200
7,590
1,770
2,820
58,800
3,810
8,850
6,500
4,478
-2,800
2,140
-274
-58,900
-11,000
3,640
-2,907
69,900
17,660
-490
-772
11,410
-150
1,890
18,660
-2,695
1,830
-69,200
42,300
-1,200
18,200
-2,710
560
-4,590
57,440
3,485
6,520
-17,300
                          68

-------
                                                Table A-4.  (continued)
Sample Location
A2-U2022
A2-U2628
E8-U2426
E8-U2628
TD3-U0406
TD3-U1416
TD3-U2426
TD5-U0406
TD5-U1416
TD5-U2425
TD6-U0406
TD6-U1416
TD6-U2527
Pretreatment
Reported Value
(* if PQL)
21,200
2,730
10,100
2,060
1,420
171.5*
5,700
445
31,300
2,080
538
2,980
2,940
Post-treatment
Reported Value
(* if PQL)
58,900
4,800
6,060
3,060
4,740
1,940
5,040
762
1,540
14,300
893
6,120
2,020
Post-treatment-
Pretreatment Value
37,700
2,070
4,040
1,000
3,320
1,769
660
317
-29,760
12,220
355
3,140
-920
1   Because the pretreatment PQL for this sample pair is greater than the post-treatment concentration,  this  sample pair was not included in
    the statistical evaluation of the data.
                                                      69

-------
                Table A-5. TRPH Samples Outside Original Treatment Zone (ppm)
Sample Location
E1-U2425
A1-U2728
E6-U2022
E4-U2426
F4-U28291
E2-U2628
F2-U2628
E5-U2022
F5-U2324
E3-U2022
E3-U2829
A2-U2022
A2-U2628
ES-U2426
ES-U2628
TD3-U0406
TD3-U1416
TD3-U2426
TD5-U0406
TD5-U1416
TD5-U2425
TD6-U0406
TD6-U1416
TD6-U2527
Pretreatment
Reported Value
(* if PQL)
4,690
2,240
22,700
3,660
1,670*
4,440
4,440
43,500
10,300
1,360
325
21,200
2,730
10,100
2,060
1,420
171.5*
5,700
445
31,300
2,080
538
2,980
2,940
Post-treatment
Reported Value
(* if PQL)
6,830
5,880
92,600
3,170
1,520
23,100
6,270
31,200
7,590
58,800
3,810
58,900
4,800
6,060
3,060
4,740
1,940
5,040
762
1,540
14,300
893
6,120
2,020
Post-treatment-
Pretreatment Value
2,140
3,640
69,900
-490
-150
18,660
1,830
-12,300
-2,710
57,440
3,485
37,700
2,070
-4,040
1,000
3,320
1,769
-660
317
-29,760
12,220
355
3,140
-920
I    Because the pretreatment PQL for this sample pair is greater than the post treatment concentration, this sample pair was not included in
    the statistical evaluation of the data.
                                                    70

-------
Table A-6. TRPH Samples Al Zone (ppm)
Sample
Location
E1-U1012
E6-U0810
F1-U0406
F1-U1012
E4-U0709
E4-U0911
F4-U1214
E2-U1012
F3-U0406
F3-U1012
E7-U1214
E5-U0406
E5-U0608
E5-U1012
E5-U1214
Pretreatment
Reported Value
(* if PQL)
3,350
1,860
6,910
1,240
1,310
729
1,790
168.5*
4,920
336
1,400
2,710
1,530
668
739
Post-treatment
Reported Value
(*ifPQL)
1,160
930
828
1,580
1,090
593
643
582
702
4,510
825
673
587
330
1,450
Post-treatment •
Pretreatment Value
-2,190
-930
-6,082
340
-220
-136
-1,147
414
4,218
4,174
-575
-2,037
-943
-338
711
                 71

-------
Table A-7. TRPH Samples A2 Zone (ppm)
Sample
Location
E2-U1012
E4-U0709
E4-U0911
F3-U0406
F3-U1012
E7-U1214
E5-U0406
E5-U0608
E5-U1012
E5-U1214
F5-U1214
A2-U0406
A2-U1012
A2-U1214
E8-U0608
Pretreatment
Reported Value
(*ifPQL)
168.5*
1,310
729
4,920
336
1,400
2,710
1,530
668
739
1,220
1,530
1,290
622
655
Post-treatment
Reported Value
(* if PQL)
582
1,090
593
702
4,510
825
673
587
330
1,450
1,530
154
33.3*
106
861
Post-treatment -
Pretreatment Value
414
-220
-136
-4,218
4,174
-575
-2,037
-943
-338
711
310
-1,376
-1,257
-516
206
                72

-------
       Table A-8 summarizes the TRPH pretreatment and post-treatment concentration geometric means
and percent decreases.  Figure A-l summarizes the TRPH contaminant concentrations used in the final
statistical evaluation. To illustrate sampling locations, the results are presented on cross-sections of the
original design treatment zone.   This figure consists of three cross-sections of the original design
treatment zone. The first cross-section shows samples collected from the ground electrode row E-l to
E-3, the second cross-section shows samples collected from the exciter electrode row, and the third cross-
section shows samples collected from ground electrode row E6 through E8. TD3 is actually outside the
original treatment zone entirely, but is included in the first cross-section for convenience. TD5 and TD6
are included in the second cross-section because they are in line with the exciter electrodes.

       Both the original and revised design treatment zones are shown on the cross-sections.  For each
cross-section, samples included in the original treatment zone are inside a box formed by a thin black
line.   Samples included in the revised treatment zone are inside a box formed by a thick black line.

       In Figure A-l, the TRPH concentration is presented on a dry-weight basis. When TRPH was not
detected at or above its PQL, the PQL is presented.  An asterisk to the right of a value indicates that
value is the PQL, rather than a measured concentration.

       SVOCs and VOCs
       Tables A-9 and A-10 summarize the pre- and post-treatment geometric mean concentrations and
percent decreases in  each of the zones for the primary SVOC and VOC contaminants respectively.
Figures A-2 through A-9 summarize the SVOC and VOC contaminant concentrations used in the final
statistical evaluation.  These figures are in the same format as the data presented for TRPH in Figure A-l.
       SVE Vapor Stream
       The vapor stream was sampled and analyzed at six critical points during the demonstration.
Sampling times are summarized in Table A-ll, and vapor extraction system conditions during sampling
are summarized in Table A-12.  Concentrations of VOCs and SVOCs in the vapor stream from the six
sampling points are summarized in Tables A-13 and A-14, respectively.
                                            73

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                           Table A-8. Summary of TRPH Percent Change
Treatment Zone
Revised
original
Outside Revised
Outside Original
Al
A2
Pretreatment
Geometric Mean (ppm)
1,238
2,141
4,259
3,289
1,382
981
Post-treatment
Geometric Mean (ppm)
636.9
1,497
5,862
6,444
1,008
520
Percent Change
49% decrease11
29% decrease"
39 % increase6
96% increase11
a
44% decrease0
a  Not accepted at an 80 percent significance level.
b  Accepted at a 95 percent significance level.
c  Accepted at an 80 percent significance level.
d  Accepted at a 97.5 percent significance level.
e  Accepted at a 90 percent significance level.
                                                   77

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                               101

-------
                                      A-9.               of SVOC
Contaminant
Benzo(b)fluoranthene



Benzo(a)anthracene



Benzo(a)pyrane



Bis(2-«thylhexyl)phthalate



Chrysene



Pyrene



Fluoranthene



Pretreatment Geometric
Mean
Treatment Zone (ppm)
Revised
Original
Outside Revised
Outside Original
Revised
Original
Outside Revised
Outside Original
Revised
Original
Outside Eevise4
Outside Original
Revised.
Original
Outside Revised
Outside Original
Revised
Original
Outside Revised
Outside Original
Revised
Original
Outside Re¥ised
Outside Original
Revised
Original
Outside Revised
Outside Original
.5271
.7653
,5907
.1908
,2249
,2969
,2784
.115?
.2112
.3533
,5917
_>
1.921
5.752
9.372
5,362
.3129
.3768
.4071
_>
.5503
.5865
.3597
.1229
.5084
,8462
1,368
1.309
Post-treatment
Geometric Mean
(ppm)
.3168
,4315
,4669
,3046
.1401
.2181
.1583
.1024
.1204
,1966
.3330
__b
.5141
2.593
7.861
8.239
,1.879
.2863
.2971
_>
.2203
.3269
.2373
.1491
.2399
.6063
.9958
1.188
Percent
Decrease
40C
44d
at
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JM
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43f
a
43°
44°
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55f
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at
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a
a.
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601"
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a
53C
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a
s
a  .Not accepted at ait 80 percent eoafidcnc* level.
b  Value could not be deterroiiiedL
s  Accepted ai a SO percefii confidence level.
d  Accepted at. a 97,.5 percent confidence level
e  Accepted at a 95 perceal confidence level,
f  Accepted at a 90 percent confidence level.
                                                          102

-------
                                 A-10.             of VOC
Contaminant
Toluene



Chlorobenzene



Methylene Chloride



Treatment
Zone
Revised
Original
Outside
Revised
Outside
Original
Revised
Original
Outside
Revised
Outside
Original
Revised
Original
Outside
Revised
Outside
Original
Pretreatment Post-treatment
Geometric Meaa, Geometric Mean
(ppb) (,ppb)
.__» __*
134.2 437.7
15,851 9,078
12,71.5 7,54?
23.59 38.41
2,058 1,201
20,360
37,326 53,265
__» __*
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_* __*
Percent
Decrease
_•
— b
	 b
— -b
_>
— b
_J»
_J»
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__»
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a   Due to the hck of matched pairs, the value could not be determined
b   Not accepted at an 80 percent confidence level.
                                                    103

-------
                              A-ll.          Times for SVE
             Sample Date                                      System Condition
             April 8, 1994             Vapor extraction system, on, RFH yet to begin,

             May 6, 1,994              RFH system on (since April 24, 1994}

            May 31, 1994             Soil temperature at approximately 100°C in areas near operating
                                      antennae

             June 7, 1994              Maximum soil temperature achieved just prior to RFH system being
                                      turned off

            June 14, 1,994             Soil cooling, vapor extraction system on

            June 24, 1994             Just prior to vapor extract) m  \ ftnj mm »«tt
                       Table A-12.  S'VE                     During
Date
04/08/94
04/08/94
05/06/94
05/31/94
06/07/94
06/14/94
06/24/94
•PCH.O)
1,35
0,30
0,1,0
0,45
0,40
0,64
0.25
Pressure
("Kg)
28.25
26.69
26,69
2,7,34
28.25
28,47
28,69
Temperature
fF)
90
105
126
15?
157
100
116
Moisture*
2,0
10,0
1 0.0
32.0
32,0
8.2
5,0
Duct Velocity
(ft/sec)
81,91
40.89
24,04
54,08
50.16
57,37
36.00
AC.FM2
108,1
54.0
31.7
71,4
68,2
75.7
10
DSCFM3
96,4
40,6
23,0
38.1
36,5
62.6
' .
     ust gas moisture content eMHiwtoBoaieaoSauH^niperacyre anaiTioSSreiractioooasea^ssaGjraiioa uif f
"* Actual cubic feet per minute,-,
3 Dry standard cubic feet per minute.
                                                  104

-------
                                                               in the
                                                                               >A.
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8
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Fluorene
2-Melhylnaphthalene
N-Nitroso-di-n-propylamine
'
Phenanthrene
1 ,2,4-TrichIorobenzene
* 4 *..-#
ND
10.2
ND
14.7
ND
4,!
5J.7
10.2
147
ND
22!
24. 0
124

ND ND
59,1 j 83.2
83,7 | ND
166 1 177
ND I ND
ND 1 ND
1 2.
	 	
ND

ND
3.4
ND
3.9
!«„; ,
ND J

ND 1
ND |
ND 1
ND I
                                                    105

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           iiexaual
           1-Octeiu:
           it-Octane
           BroiiHiiwrni
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ociiloromethane
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rimethylhexane
tf
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1,100
3,290
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1,110
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444
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613
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ND
198
ND
175
771

ND
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14,3
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328
211
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183
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ND
ND
93,9
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381
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ND
576
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199
401
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ND
259
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38,6
260
107
423

                                                                        108

-------
109

-------
        Soil Vapor Analysis
        Soil vapor was sampled and analyzed at six locations after the demonstration. Table A-15
summarizes the VOC concentrations in each of the soil vapor samples.

        Groundwater
        Table A-16 summarizes the pretreatment groundwater analytical results of samples taken from
wells MW-10, MW-09, and DW-02.  The groundwater was analyzed for TRPH, SVOCs, and VOCs.

A.2     Particle  Size Distribution Analyses
        Tables A-17 and A-18 present the results of particle size distribution analyses, which were
conducted to characterize the soil. Particle size analyses were conducted using two techniques: dry-
sieving  and wet-sieving. The majority of the samples were just dry-sieved; however, a few samples were
wet-sieved.  Particle size distribution data from dry-sieving is presented in Table A-17 and particle size
distribution data from wet-sieving is  presented in Table A-18. For evaluation purposes, the data were
simplified into three categories: gravel, sand, and fines. Particles that are less than 3 inches (7.62 cm)
in diameter but will not pass through a #4 sieve (4.750 mm) are classified as gravel, particles that will
pass through a #4 sieve but will not pass through a #200  sieve (0.075 mm) are  classified as sand, and
particles that will pass through a #200 sieve are classified as fines.

        Contrary to what was expected, wet-sieving produced significantly different results than did dry-
sieving.   Discussions with laboratory personnel indicated that the two procedures should have yielded
similar  results. Since dry-sieving is less costly, and the use of dry-sieving was part of the approved
Demonstration Plan, the decision to dry-sieve seemed to be sound. It appears, however, the sample
preparation associated with the dry-sieved samples was not rigorous enough to break down many of the
cohesive silt and  clay particles into sixes that would pass the #200 sieve. The results from the dry-sieving
probably do not  reflect actual site conditions, and the percent sand data are likely to be lower and the
percent  fines correspondingly higher.  As a result, only particle size distribution data from wet-sieving
are being used to characterize the site.  The data from dry-sieving are not being used.
                                              110

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ylpentane

loDCinethane
ncthylpeniune
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186,000
124,000
2,0213

1,540
157,000
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21,900
77,100
176,000
40,400
90,400
563,000
78,400
87,400
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4 1 ,900
48,100
89,5
87,700
3,480
1,090
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2,990
25.6
2,780
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589
3,320
4,150
1,320
613
13,400
669
5,820
354
1,040
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38,6
3,120
209
5,520
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10,000
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9,050
ND
19,500
15,500
20,400
11,100
63,2
9 1 ,000
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40,100
3,300
11,600
13,700
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2,590
2,230
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3,490
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3,660
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665
4,280
5,750
1,490
740
93,700
1,880
6,710
354
1,590
2,060
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4,850
39.1
8,340
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13,900
ND
12,400
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14,100
18,700
21,600
11,300
9,6
700
960
33,300
2,570
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10,100
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18,500




















112

-------

                                                                             HV.
"f"«,3.«;- -..
;                   I                  !                  I                 :          P 3^5  '                  i'
Dibruinochloroiuelhane
3-Methylheptane
Hexanal
1,2-Dibromoetliane
2,2,5-Triinethylhexane
I -Octcne
n -Octane
Tetrachtoroelhylenc
Cliiorobciizene
Hlhylbenzene
p-Xylene + in-Xylene
Bruinuturni
Styrene
Hepianal
1 , 1 ,2,2-Tetrachluroethane
<>-Xylene
n-Ni)iiane
lsoprojwlbenz«JiWJ
a-Pinene -f
n - P top
m-Hlhyiloluene
p-Gthyltoluene
ND
14,It30
20,200
8,5
35,800
ND
23.SOO
2,470


22,000
ND
ND
ND
ND
6,070
17,100
ND
4,560
ND
ND
4,070
19.7
424
1,770
48,0
1,280
ND
700
187
11,700
595
1S240
63,0
278
ND
§3,3
708
134
119
219
101
238
___

ND
5,880
20,900
ND
18,400
1,080
6,000
6,5
168,000
3,110
1 ,220
ND
2,920
ND
ND
792
617
l,9!0
7,130
3,520
494
4,560
ND
723
1,970
ND
1 ,940
ND
1,300
201
7,950
612
2,730
ND
362
ND
ND
924
713
181
358
214
604
462
ND
2,400
11,000
ND
9,190
523
2,680
ND
44,900
S95
679
ND
71S
ND
ND
215
123
271
709
363
ND
496
ND
ND
61.2
ND
72,5
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61,3
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ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                                        113

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                                                        114

-------
Table A-16. Summary of Groundwater Sampling Results
Well ID Number
MW-10



















MW-09















Measurement
TRPH (mgL)
Volatiles (ug/L)
Acetone
Benzene
Chlorobenzene
Trans- 1,2-Dichloroethene
Methyl ethyl ketone
4-Methyl-2-Pentanone (MIBK)
Toluene
Vinyl Chloride
Semivolatiles (jjLgfL)
2,4-Chlorophenol
2-Chlorophenol
1, 2-Dichlorobenzene
1,3-Dichlorobenzene
1, 4_Dichlorobenzene
2-Methylnaphthalene
Naphthalene
Phenol
1,2, 4-Trichlorobenzene
TRPH (mg/L)
Volatiles (ug/L)
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Vinyl Chloride
Xylenes
Semivolatiles (/ig/L)
2-Chlorophenol
1, 2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Methylnaphthalene
Naphthalene
Phenol
Result
4.92

61.9
782
25,500
14.0
16.4
11.5
51.2
28.0

36.3
193
11,200
760
2160
16.2
121
22.3
51.4
0.834

596
12,000
91.9
5.65
10.2
12.0

37.4
163
23.5
183
59.2
71.1
3.58
                        115

-------
                                      Table A-16. (continued)
Well ID  Number
Measurement
Result
DW-02
                                   TRPH (mg/L)

                                   Volatile s(ug/L)
                                       Chlorobenzene

                                   Semivolatiles (ug/L)
                                       Acenaphthene
                                       2-Chlorophenol
                                        1 ,2-Dichlorobenzene
                                        1,3-Dichlorobenzene
                                        1,4-Dichlorobenzene
                                       bis(2-ethylhexyl)phthalate
                                       Fluoranthene
                                       Fluorene
                                       2-Methylnaphthalene
                                       Naphthalene
                                       Phenanthrene
                                        1,2,4-Trichlorobenzene
                                         267
                                         15,500
                                         7.79
                                         22.1
                                         1820
                                         152
                                         529
                                         218
                                         29.3
                                         7.51
                                         124
                                         86.8
                                         7.17
                                         15.5
                                                  116

-------
                             A-17.            Size                       (Dry-Sieving)

»,4 i/'t 'Li
\\ "'"-'.I
M ;\ih
A2-U0002**
A2-U0204
A2-U1214
A2-U1618
A2-U2022
A2 "132623
E1-U0002**
E1-U1012
El -U 1618
E2-U2628
E3-U1416
E3-U1618
E3-U2022
E4 - U0709
E4-U0911
E4-U2426
E5-U0406
E5-U0608
85 -U 1012
E5-U1214
E5-U1820
E5-U2022
E6-U0810**
E6-U2022
E7 	 U0204
E7-U1214D
E8-U0608
E8-U2426
E8-U2628
F1-U1012
F! 	 -U1820
F2-U1416
F2-U2628
F3-U0406
F3 -01012
F4-U0002
F4-U1214
F4-U2829
F 5 -111214
F5-U1618
F5-U1820
TD3-U1416"
TD3-U2426
TD5-U0406
TD5-U1416
TD5-U2425
TD6-U0406
TD6-U2426
Average
i'tl ! It "
'' ( 11 tVft
i i"
K ,ti»
27.4%
23,7%
23.4%
18.3%
5,6%
79,1%
32,6%
36.9%
61,0%
67.3%
15.0%
8.2%
6,6'*
11.2%
27.11%
61.5%
23.5%
20.9%
32.2%
13.0%
13,7%
29.7%
33.3%
48.2%
50.9%
25,1%
33.4%
66.7%
51.2%
14.8%
53,7%
7.7%
59,1%
40.1%
20,8%
36.2%
21.4%
73.1%
19,1%
25.5%
27.2%
45,5%
67,7%
31.2%
25.2%
55,9%
36,2%
62.3%
35,4%
Hi
Ml i
!' i
>»' i
68,4%
74.3%
72,6%
793%
37,5%
20,3%
64.0%
57.9%
36.4%
32,2%
81.6%
84.1%
85.9%
84.3%
61.6%
34,4%
72,1%
72.8%
61.9%
77.8%
80.3%
64,4%
61.9%
48.6%
46,0%
63.3%
63,1%
30.8%
45.4%
79,8%
40.1%
84.2%
38.5%
55.6%
72,0%
592%
67.9%
25,4%
73.2%
67,4%
67,1%
49.4%
30.1%
62,1%
69.1%
43.4%
58.3%
36,8%
59.8%
Post —treatment
! fi «,
6 *
* 1 !
4,3%
2.0%
4.0%
2,4%
6.9%
0.6%
3,5%
5.2%
2.6%
0,5%
3,4%
7.7%'
7.5%
4,5%
11.4%
4.1%
4.4%
6.3%
5.9%
9.2%
6,0%
5.9%
4,9%
3.2%
3.1%
11.1%
3.5%
2,5%
3,4%
5.4%
6,2%
8.1%
2.4%
4.3%
7.2%
4/i%
10,7%
1.5%
7.7%
7.1%
5.7%
5.2%
2.2%
6,7%
5,7%
0.7%
5.5%
0.9%
4.8%
Sample ID
Al A -110002**
A1A-U1820
A1A-U2627
A2A-U0002
A2A-U0204
A2A-U0406
A2A-U1012**
A2A-U1214**
A2A-U2022
E1A-U0204
E1A-U1618
E1A-U2425
E2A-U0204
E2A-U1012
E3A-U1416
E3A-U1618
E3A-U2022"
E3A-U2830
E5A-U0406
E5A-U0608
E5A-U1214
E5A-U1820**
E5A-U2022
E6A-U0810
E6A-U1618
E7A-U0204
E7A-U1214**
E8A-U2426
E8A-U2628
F1A-U1820
F2A-U2628
F3A-U0406
F4A-U0002
F4A-U1214
F4A-U1618
F4A-U2830
F5A-U1214
F5A-U1618
F5A-U1820
F5A-U2224
TD3A-U0608
TD3A-U1416
TD3A-U2426
TD5A-U1416
TD6A-U0406
TD6A-U1416
Average




% Grave!
35.4'*
41.5%
63,8%
35.8%
33.4%
34.0%
33.4%
20.2%
29.6%
43,9%
51.4%
60,5%
51.7%
48.5%
42.7%
29.7%
17.9%
59.5%
57.5%
27.8%
63,9%
28.9%
29,6%
35.2%
41.3%
58,1%
33.0%
77.8%
60,7%
37,0%
65,9%
48,4%
45.2%
34,2%
15,9%
69.8%
38.3%
44.8%
40.7%
56,9%
52,7%
25,8%
73,7%
61.5%
43.6%
50.6%
44.6%




% Sand
59,3%
50,2%
34.6%
58.7%
63.3%
58.1%
54.7%
69.8%
66.6%
54,9%
43.8%
38,1%
44,3%
48,6%
51.0%
61.2%
73.0%
38,5%
37,3%
61.6%
33.5%
63.4%
64,0%
62.2%
54.5%
39,4%
61,5%
20.4%
37,4%
56,5*
33.5%
45,0%
51.9%
63,5%
77,8%
29.1%
58.4%
51.5%
53.1%
40,6%
45.0%
71,0%
25,1%
33.8%
53.7%
44.4%
50,8%




% Fines
5.4%
8,3%
1.6%
5.5%
3.3%
7.9%
12.0%
10.1%
3.8%
1.2%
4.8%
1.4%
3,5%
2.9%
6.3%
9.1%
9.2%
2,0%
5.2%
10.6%
2,6%,
7,7%
6,4%
2,6%
4.2%
2.5%
5.6%
1.8%
1.9%
6,5%
0.6%
6,6%
2.9%
2.3%
6,3%
1.1%
2,8%
3.7%
6.2%
2.5%
2.3%
3,2%
1.2%
4,7%
2,7%
5,0%
4,6%




•'Particle size distributions determined by dry-sieving were significantly different than those determined by wet —sieving,
** Average of two duplicate analyses.
                                                      117

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                    Table A-18. Particle Size Distribution Data (Wet-Sieving)

                   Pretreatment                                          Post -treatment
 Sample ID	% Gravel    % Sand     % Fines       Sample ID	% Gravel     % Sand     % Fines
 A2-U0002            34.4%      29.5%      36.1%       A2A-U1618         42.5%      27.0%      30.5%
 A2-U0406          19.2%      48.0%      32.8%       E1A-U0204          43.7%      33.2%      23.1%
 A2-U1012**         22.9%      34.3%      42.8%       E5A-U1012         29.6%      23.9%      46.5%
 E2-U1012           19.8%      30.3%      49.9%       E8A-U0608          43.6%      26.9%      29.5%
 E3-U2830         44.8%      38.3%      16.9%       TDSA-U0406        47.5%      30.5%      22.0%
 E6-U1618           32.7%      19.5%      47.8%       TD6A - U2627	50.2%      32.9%      16.9%
 E7-U1214**          5.2%      21.3%      73.6%       Average             42.9%      29.1%      28.1%
 F5 -U2324	56.5%      24.5%      19.0%
 Average             29.4%      30.7%      39.9%


 •  Pardcle size distributions determined by dry-sieving were significantly different than those determined by wet -sieving.
 . ** Average of two duplicate analyses.
A.3 Moisture  Data

       Moisture  analyses were conducted so that soil sample concentration results could be converted to

dry weight results.  Figure A-10 presents the results of moisture analyses in the same format used to

present the results of the chemical analyses.   Based on the final statistical evaluation, there were

statistically significant decreases in percent moisture inside the original and revised treatment zones.

Moisture results  for all zones are summarized in Table A-19.


                       Table A-19. Summary of Percent Moisture Results


                                           Estimated Change in            Confidence Level
                                           Mean Concentration

 Inside Original  Treatment Zone                  -53 %                         > 99.9%

 Inside Revised Treatment Zone                  -70%                          >99%

 Outside Original Treatment Zone                 + 19%                         >95%
                                                    •k .k                             .k .k
 Outside Revised Treatment Zone

   = Did not exhibit a statistically significant change at 80% confidence level.
                                                118

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A.4    Operational and Process Data
       Operational data for the KAI RFH SITE Demonstration was collected primarily by KAI and by
the USAF contractor, B&RE.  Operational data collected by B&RE and KAI were not independently
verified by the SITE Program or its contractors. Table A-20 summarizes extraction well pressures and
temperatures during the demonstration.  Table A-21  summarizes the compressor and flare flow rates
during  the demonstration.
                     Table A-20. Summary of Operating Conditions Data
Well
El
E2
E3
E4
E5
E6
E7
E8
MinimumPressure
(in. H20)
-17.0
-30.0
-30.0
-49.0
-72.1
-3.3
-3.8
-4.6
Maximum
Pressure
(in. 11,0)
0
0
0.1
-0.4
0
-0.3
0
0
Minimum
Temperature
(°C)
18.9
19.8
19.4
18.1
23.3
19.5
19.5
19.7
Maximum
Temperature
CO
36.6
60.7
45.3
93.5
93.5
31.7
31.3
31.4
                 Table A-21. Summary of Compressor and Flare Flow Rates
Component
Compressor
Flare
Minimum Flow Rate (scfm)
35
50
Maximum Flow Rate (scfm)
70
140
A.4.1 Temperature
       Soil temperatures within and outside the revised treatment zone were indirectly monitored at
various depths throughout the demonstration. The demonstration system was designed to heat the soil
in the revised treatment zone to a temperature range of 100 to 130°C.   Soil temperatures within and
outside the revised treatment zone were monitored at various depths throughout the demonstration using
                                            122

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thermocouples, infrared temperature sensors, and fiberoptic temperature probes. All temperature
measuring devices were mounted in lined boreholes, which made direct readings of the soil temperature
impossible. The developer claims that actual soil temperatures were higher than the measurements
indicate; however, this difference cannot be quantified. The maximum measured temperature on the
perimeter of the revised treatment zone was 61°C  The maximum measured temperature near the center
of the revised treatment zone was 234°C, but this peak was not representative of the majority of the
temperature measurements  at this location. During most of the heating  period, temperatures between 100
and 150°C were measured near the antenna to which energy was being applied.  Although not observed
during the demonstration, the developer claims that temperatures will become more uniform after all
moisture is removed from around the antennae.

A.4.2 Residuals
       Condensate from the vapor treatment system was pumped into a 500-gallon truck-mounted tank
during the KAI RFH SITE  demonstration.   The  condensate was transferred to the  Kelly AFB
Environmental Pollution Control Facility for treatment and discharge.  Approximately 2,000 gallons of
condensate were collected from the vapor treatment system during the KAI demonstration.

       All soil cuttings were drummed and transferred to the Kelly AFB Drum Lot for disposal.  Soil
cuttings  filled 40 drums during pretreatment sampling and 35  drums during post-treatment sampling.  One
drum filled with miscellaneous solid wastes (PPE, plastic sheets, etc.) was also transferred to the Kelly
AFB Drum Lot for disposal.

A.4.3 Utilities
       According to measurements taken by KAI, 15,749 kW of RF energy were delivered to the soil
during the demonstration.  Based on a 90 percent delivery efficiency,  KAI estimates that 17,351 kW of
RF energy were generated by the RF source. KAI further estimates, based on a 65 percent conversion
efficiency, that 26,693 kW of AC electric power were consumed by the RF source.  Total electric
consumption for the site was measured during the demonstration. The B&RE project report states that
36,053 kWh of electricity were consumed during the project.
                                             123

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A.4.4 RF Emissions and Electric  Field Measurements
       RF emissions were measured with a broad band, vertically polarized, 2-meter high, calibrated,
biconical antenna. The antenna signal was processed by a portable calibrated spectrum analyzer. Initial
and closing measurements were witnessed by representatives of the Kelly AFB frequency management
office. Detailed tests were logged on May 3, 18, and 24, 1994 and on June 6, 7, 8, and 10, 1994.

       The first through sixth harmonics of the operating frequency were measured in compliance with
FCC part 18.305(b).  Part 18.305(b) specifies a harmonic emission limit of 169 uV/m or 44.58 dB-uV/m
at a distance of 300 m for the operating frequency of 27.12 MHz.  Harmonics were measurable 10  meters
from the active antenna but were typically unmeasurable or at the threshold of detection 300 meters from
the active antenna.  On June 7, with the RF generator operating at 23.21 kW, the second harmonic was
detected at 2 uV/m or 3.90 dB-uV/m, which is easily within the FCC emission limit.

       In addition to the harmonics, fundamental frequency  emission levels (27.12 MHz) were measured
in compliance with USAF requests.  Surface emissions 10 m from the active antenna were typically about
0.4 V/m when the RF generator was operating at 20 kW The highest surface emission measured 10 m
from the active antenna was 1  V/m during an RF generator output power level of 23.56 kW.  The highest
surface emission measured 300 m from the active antenna was 0.25 V/m during an RF generator output
power level  of 23 kW.

       The electric field at the site was measured with the  calibrated electric and magnetic probes of a
broad-band isotropic field strength meter.  Electric field measurements were taken at defined locations
on 23 heating days. Initial measurements were witnessed by Kelly AFB site safety personnel.

       The site safety plan required maintaining the 6-minute average electric field exposure level for
site personnel below 70 V/m.  The  permissible exposure limit (PEL) of 70 V/m was calculated for the
27.12 MHz  operating frequency using a formula from AFOSH Standard 161-9, February 12, 1987.
Electric field measurements are summarized in Table A-22.

       The only electric field measurements that exceed 70 V/m were taken O.lm from the antenna.
The electric field strength that  close  to the antenna is not believed to represent a risk to incidental  human
exposure.  In addition, two red warning lamps, which were controlled directly by the RF generator's
power enabling circuitry, alerted site personnel when the RF generator was operating.

                                             124

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         Table A-22. Summary of Electric Field Measurements
Distance from Active Antenna
Range of Electric Field Measurements
          O.lm



           1m



           3m



           10m
          25 to 132



          7 to 59.1 V/m



           1 to 14 V/m



           up to 1 V/m
                                   125

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                                       APPENDIX B
                                      CASE STUDIES

B.I    SAVANNAH  RIVER SUPER FUND  SITE
       The objective of the demonstration was to investigate the effectiveness of the KAI RFH system
as an  enhancement to vacuum extraction of residual  solvents (primarily trichloroethylene and
perchloroethylene) held in vadose zone clay deposits approximately 40 feet below the surface at the
Savannah River Super-fund site.   The KAI RFH system is mounted in an 8 ft  x 8ft x 20 ft shelter that
is mobilized by a 28-foot   flatbed trailer and a 1-ton pickup truck. The system was configured for
complete, unattended, remote control operation as well as for onsite support diagnostics.  The AC power
was provided by a diesel generator [1].

       The demonstration integrated RF antenna technology and vacuum extraction from a single,
horizontal well. The horizontal well was continuously screened over a  300-footdiorizontal section. The
antenna, approximately 17 feet long, operated at a maximum power output of 2 kW and a frequency of
13.5 6MHz  The antenna was inserted to a location approximately 100 feet from the start of the screened
zone to heat one section of the well.    The vacuum extraction system consisted of a rotary lobe blower
capable of providing a flow of approximately 150 cubic feet per meter (cfm) at 6 inches Hg vacuum.
Several vertical boreholes were placed both in and adjacent to the expected heat  zone and in a "cold"
control zone to monitor temperatures, pressures, and soil gas concentrations.  Approximately 11,000 kWh
 of RF energy were successfully coupled to the  subsurface sediments and heated a soil volume of nearly
1500 cubic feet to temperatures greater than  60°C.  n The total volume heated to temperatures above
ambient (20°C) was calculated at nearly 30,000 cubic feet [1].

       Several problems were encountered during the demonstration. Well flooding  occurred due to
residual water or near saturated soil conditions in the proximity of the screen.  The well flooding resulted
from heavy rainfall encountered during the first half of the test period. The system also experienced a
low vapor flow which was a result of the low permeability and high water content of the clay A vapor
lock formed down hole at the antenna from steam generated by the  RF energy.  Heat loss and
condensation from the gas stream through the long transition to the surface were also encountered in this
demonstration [1].
                                            126

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       Over 170 kilograms of chlorinated solvents were successfully extracted from the sediments over
the course of the demonstration.  However, since the RFH system did not perform optimally, definite
conclusions as to whether the technology enhanced the contaminant extraction cannot be drawn.  Results
show that any new system design should use extraction wells that are independent from the well used for
RF application.   It was concluded that extraction wells could be horizontal or vertical but should be
located both within and on the perimeter of the zone anticipated to be heated by the RF antenna [1].

B.2    PILOT-SCALE TREATMENT OF SOIL  CONTAMINATED WITH #2 FUEL OIL
       A pilot-scale study was conducted to evaluate the ability of the KAI RFH system to enhance the
removal  of #2 Fuel Oil from silty soil. The water table was located at 22.5 feet bgs and the layer of
contaminated soil extended from approximately 17.5 feet  bgs to 22.5 bgs. An SVE system was in use
at the site prior to the KAI test.   At the initiation of treatment, the SVE system yielded recovery rates
of thousands of gallons of oil per hour. The decrease of recovery rates to hundreds of gallons of oil per
month prompted an evaluation of the ability of RFH to enhance the SVE product recovery rates [2].

       Bench-scale testing indicated that substantial oil recovery  could be expected at a soil temperature
of 130°C. KAI also conducted "low-power" RF  tests to characterize the soil, then designed a site-specific
RF antenna to transfer RF energy into the contaminated soil.  Subsequent "high-power" tests used this
RF antenna and the existing SVE system in conjunction with KAFs 25kW, 13.56-MHz, mobile RFH
system. The RFH system was cycled on and  off to maintain a temperature  of  150°C or less in the
antenna borehole. The test lasted 2 weeks and 8,000 kWh of power were applied to the contaminated
soil during the test [2].

       At the completion of the high-power test, the soil temperature was measured at  four points within
the zone  of contamination.  Two feet from the RF antenna, the temperature was approximately 80°C at
19 feet bgs and approximately 70°C at 21 feet bgs.   Four feet from the antenna, the temperature was
approximately 65°C at 19 feet bgs and approximately 75°C at 21 feet bgs.  In addition, the fluid saturation
of the soil was measured before and after KAI's  RFH test.   The results of the  fluid saturation
measurements, which are presented in Table B-l,  appear inconclusive [2].
                                             127

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                          Table B-l. Fluid Saturation of the Soil [2]
Depth, feet
17
19
21
22
23
24
25
Percent
Before RFH Test
NA
NA
NA
6.5
36.5
9.6
17.9
Pore Oil
After RFH Test
1.0
3.5
6.6*
6.7
21.5*
NA
1.6
Percent
Before RFH Test
NA
NA
NA
31.1
53.1
77.3
66.5
Pore Water
After RFH Test
16.6
4.7
9.0*
3.0
70.0*
NA
92.4
*  Value is the average of two measurements (all other values are from single measurements).
NA = not analyzed
B.3    REFERENCES

1.      Final  Report: In  Situ Radio Frequency Heating  Demonstration.  Westinghouse Savannah  River
       Company. Revision 0. Aiken, SC.

2.      Price, S.L.,  R.S. Kasevich, and M.C. Marley.   Enhancing Site Remediation through Radio
       Frequency Heating.  Preprint to be presented at the Eighth Annual Conference on Contaminated
       Soils - Moving Towards Site Closures.   Presented by CHESS (Council for the Health and
       Environmental Safety of Soils), University of Massachusetts at Amherst, September 23, 1993.
                                             128

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                                          Appendix C

                                     Vendor Claims Section
                                                for
                             Innovative Technology Evaluation  Report

                                            March 1995

                                            Prepared by

                       Raymond S. Kasevich                 David L. Faust
                       KAI Technologies Inc.                 KAI Technologies Inc.
                       Eastern Office                        Western Field Office
                       170 West Road, Suite 7               P.O. Box 859
                       Portsmouth, NH 03801                Provo, UT 84603-0859
                       603-431-2266                         801-225-7448

                    Introduction  to In-situ  RF Heating for SVE Enhancement

        The radio frequency (RF) heating (RFH) process discussed in this  document is based on the
use of an antenna' technology to efficiently and specifically apply electromagnetic energy to a soil
matrix.  The focused electromagnetic energy pattern from the antenna heats the soil by directly
interacting with the soil components at the molecular level. The RF energy desorbs and mobilizes the
hydrocarbon contaminants and water by a very efficient direct heating action that does not require any
soil permeability for energy propagation2.  The mobilization of the hydrocarbons and water can
significantly increase the permeability of the soil matrix and in some cases can  create permeability'.
Soil can be heated in a controlled manner to temperatures above 400 degrees C by RF energy.

        The soil vapor extraction (SVE) process is dependent on the ambient vapor pressure of a
contaminant in the soil  and the permeability of the soil.  The success of the SVE process is  dependent
on the flow of air through the soil matrix which is directly determined by its permeability.  The
addition of heat to the soil strongly volatilizes and mobilizes the contaminants that can be removed
from the soil by the extraction air  flow. The heat also increases soil permeability by the mobilization
   1 Traditional RF heating technology relies on placing the material to be heated between two conductive plates or metal
rod grids that form a capacitor cell. Typically these plates are five to 15 foot square and separated by three to 20 feet,
depending on the operating frequency of the RF energy. The KAI technology uses a dipole antenna structure that resembles
a single pipe, several inches in diameter. The length is dependent on the operating frequency. Typical frequencies used for
RF heating provide for antennas ranging in length from six to 20 feet which allow for the treatment of comparable soil
thicknesses.

   2 RF energy propagates easily through dielectric materials such as dry soil. Wet or hydrocarbon impregnated soils
absorb RF energy until the water and hydrocarbons are volatilized and driven from the soil. As the soil drys and is
decontaminated the RF energy passing through the soil loosing less energy and therefore more strongly heats the soil at a
greater distance from the antenna.

   3 The production of      from water bound in some rocks is typically adequate to cause explosive fracturing which is a
macroscopic permeability enhancing mechanism.

                                                129

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of water and some types of contaminants.  Therefore, RFH enhances two of the governing
mechanisms of the SVE process.  Therefore, active in-situ RFH can be expected to dramatically
shorten the SVE system closure time and improve recovery efficiency in comparison to that of a
passive system.

       Soil heating by steam or hot air injection are considered competitive processes to RFH. Both
injection techniques require a minimum level of soil permeability for successful application. Heat is
transferred into the soil by fluid propagation and thermal conduction mechanisms. Both processes
require the use of high levels of energy generation and transmission to deliver relatively low levels of
predictable heat to the subsurface environment due to significant thermal losses in the propagation
process and the uncertainty of the fluid propagation paths within the soil matrix.  Steam injection is
limited to the delivery of temperatures below 100 degrees C and requires a removal and disposal
strategy for the contaminated condensate.  Hot air injection does not suffer this drawback but does  not
carry as high a level of thermal energy level into the formation as steam does.  Both thermal  injection
approaches have been shown to be of value to remediation efforts.  However, neither technique
provides the precision and controlled delivery of heat that is available through RFH techniques.
                                      Table of Contents

                      Comments on the Kelly Program   	   3
                      1.0     Program Summary  	   3
                      2.0     Details of the Basic RFH System   	   6
                      3.0     Review of Soil Chemical Analysis	    15
                      4.0     Review of Soil Vapor Extraction Data  	   20
                      5.0     Cost Projections for an RFH system	   23
                                             130

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COMMENTS ON THE KELLY PROGRAM

       The five sections presented here have been adapted entirely or in part from a December 1994
draft of a technical appendix4 supplied by KAI Technologies to Brown and Root Environmental.
This technical appendix was written for inclusion in the final program demonstration report to the Air
Force Center for Environmental Excellence.

1.0    PROGRAM SUMMARY

1.1   Overview

       KAI Technologies, Inc. demonstrated its emerging in-situ radio frequency heating (RFH)
process at Kelly Air Force Base, San Antonio, Texas, IRP site S-l during the spring of 1994.  The
technology demonstration was conducted under contract with Halliburton NUS5 under contract with
the Armstrong Laboratory. Environics Directorate, AL/EQW, Tyndall Air Force Base in cooperation
with the U.S. Environmental Protection Agency.

       The primary objective of the RFH test of the KAI technology was to provide useful
information to assist the Air Force in preparing for a commercial scale demonstration of RFH
decontamination.  This effort included the qualitative evaluation of vapor extraction and soil heating,
the evaluation of contaminant movement through soil, and the removal of volatile organic compounds
from the soil  through the vapor stream.  An important aspect of the program was to document RFH
applied with a single borehole, dipole antenna, in contrast to previous RFH testing that used a cage of
electrodes to  form a capacitor heating cell.

       Other important objectives of this test were: 1) validation of electromagnetic and thermal
modeling; 2)  demonstration of dual heating applicator (antenna) interactions during the heating  cycle
as a diagnostic tool; 3) documentation of safe near-field electromagnetic emission levels;  4)
documentation of compliance with harmonic interference levels set by the Federal Communications
Commission  (FCC) for systems operating under part 18 rules.

       The RFH test of the KAI technology was not a remedial action test.  The soil vacuum
extraction (SVE) system test used in the RFH demonstration was an experimental design with a
number of unique operating configurations. The SVE system was operated with numerous
configurations and was not optimally designed or operated for the heating pattern developed by the
KAI heating antennas.  Funding limitations did not allow the SVE portion of the RFH program to be
explored and optimized. Therefore the absolute TRPH,  VOC and SVOC removal  rates measured
versus the applied RF  energy for this program cannot be used as statements on the effectiveness of
RFH.
   j
     "RF System Operating Description- Appendix to the final program report," for the report titled, Technology
Demonstration of Radio Frequency Soil Decontamination, submitted to Brown and Root Environmental for delivery under
USAF Contract No. F33615-90-D-4011, Delivery Order No. 0007, contract Project No. 3688. December 1994 Draft
submission.

   5 Currently identified as Brown and Root Environmental, a Division of the Halliburton Corporation.

                                             131

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       The KAI mobile RF system was prepared and ready to start heating within six working days
of the system's arrival on site. The KAI RFH system successfully delivered 15,549 kilowatt hours of
energy to the heating zone within a total time span of 5 1.3 days The efficiency of the RF energy
transfer to the soil during the heating period exceeded 85% .  These are significant operational
achievements that are prerequisites for commercial system development.

       A dual antenna system was employed for this test. Measurements of mutual coupling between
antennas during the heating periods provided information on the removal trends of moisture and
contaminants.  Significant changes in the mutual coupling measurements occurred during the heating
periods. Refinement of this measurement technique will be an important diagnostic and control
component of a fully automated commercial system.

       The program accomplishments summarized below are from the perspective of the RFH system
operation and interaction with site conditions.

1.2     Accomplishments

       •   The uniformity of soil heating within test volumes - The heating program provided an
           extensive data set of temperature profiles.

           The initial heating rate of the test and several aspects of the SVE configuration produced
           thermal records that suggest that there are significant regions of uniformity with soil
           temperatures elevated well above 100 degrees centigrade (C).

           There were regions, at a 3-foot radius from the antenna that  exceeded 120 degrees C,
           even in the context of SVE flow influences (see section 4.0 of this document).   These
           infrared (IR), indirect temperature profiling measurements suggested that adjacent soils
           should have had localized heating temperatures for the hydrocarbons at or above the 150
           degree temperature goal of the program.  The highest measured temperature for the
           program was a direct, peak measurement of 233.9 degrees C by a fiber optic temperature
           probe located on the outside of the heating well liner wall.  The sustained high
           temperature readings in this region suggested a flow of a hot liquid into the volume
           surrounding the well liner sensor.  This indirect measurement suggested that a significant
           mass of liquid was heated to a temperature in the vicinity of 240 degrees C within the
           heating zone.

       •   Commercial Operation - The later portion of the heating program (21.3 days) provided
           operating statistics that can be used for commercial system cost and operation projections.
           System costs for an automated, low labor requirement, system can be developed from the
           optimum operation periods of the program.

1.3     Modifications to Program Cost and Operation

       This program was executed within the framework of several modifications. The most
significant are:

       •   The on-site heating zone was defined as one-half of the volume originally planned as the
           treatment zone.  This was due to the choice of a 27.12 MHZ frequency to heat two
                                             132

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           thinner, 10-foot thick, adjacent volumes faster than the 13.56 MHZ alternative ISM6
           frequency. The 13.56 MHZ frequency would have required more on-site heating time
           but would have covered the original, 20-foot thick treatment zone.  The lower frequency
           also would have extended the volume of heating influence further beyond the SVE
           extraction and injection wells. Therefore, the collection efficiency of the SVE system, as
           installed, would have been increased.

       •   The RFH applicators were positioned high in the well liner borehole spanning from 4 feet
           down to 14 feet within the heating zone.  Program time was not available to move the
           applicator to  additional heating  positions.

       •   Initial delivery of 3-phase AC utility power to the RFH system limited the RF energy
           generation rate.  For the first 22 days of the  program the system generated RF energy at
           an average rate of 9.42kW/hr as opposed to  the last 21.3 days that  maintained generation
           at an average rate of 19.93 kW/hour.

       •   The initial low power delivery rate did not allow the sequential heating of boreholes Al
           and A2 in a manner that would allow their heating patterns to overlay as an
           approximation of a dual applicator, dual RF  generator system operated as a phased array.

       •   The design of the SVE system prevented meaningful conclusions being drawn about the
           measured changes in TRPH VOC and SVOC concentrations inside and outside the
           treatment zone as a result of RFH treatment.

1.4    Conclusions

       Site set-up time was relatively fast and efficient with a 2-person KAI field team. The KAI
mobile RF system performed as expected and provided significant RF energy coupling to the soil.
The applicator system (antennas) allowed for flexibility in the in-situ application of RF energy at
selected depths.  The coupling efficiency or  energy transfer to soil surrounding the antennas was high
(> 85%).  The application of energy to the heating zone  increased the permeability of the zone bya
factor of more than 207. This result has significant implications for commercial  RFH systems
operating with tight soils. SVE efficiency appeared to increase substantially during the demonstration
period.
   * ISM is an abbreviation for the Industrial Scientific and Medical frequencies authorized for RF heating under the part
18 regulations of the Federal Communications Commission.

   7 This is believed to be a conservative number. Factors of 50 can be derived from the data set but SVE conditions are
not directly comparable for all calculations.

                                              133

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2.0
DETAILS OF THE BASIC RFH SYSTEM
       The KAI RFH system is mobilized as a self-contained field unit with work space and storage
capability to support two heating applicators. Figure 1 is a side view of the mobile system. The
overall length is 52 feet and 2 inches with a trailer bed length of 28 feet.  Figure 2 outlines the
component groups of a basic radio frequency (RF) heating system. The system power is supplied
from the local utility power grid or a diesel generator through the 3-phase power distribution panel.
The panel supplies power to the RF generator and a cooling blower as well as lighting, air
conditioning and instrumentation. The power system also includes an uninteruptable power supply for
critical instrumentation and control functions. The RF  Generator supplies power through the
transmission lines and the matching network to the RFH applicator or "antenna" which typically
radiates 95% of the energy it receives into the surrounding medium (soil, rock, oil).

       The system controller is interfaced to all elements  of the system.   Site environmental monitors
can detect overheated components, energy leakage and component tampering. The controller is
capable of transferring the complete monitoring of the  system to a remote location through a phone
line or a cellular telephone data link.

       Alarms and system status messages  can be set via the telephone link or messages can be sent
as pre-recorded voice segments via the same UHF radio frequency transceiver used for site
communications.   On-site diagnostics instruments periodically measure the system's performance and
verify operation.
 1 Mobile RF heating system with removable instrument shelter, storage trailer and a utility tow
vehicle.
       Figure 3 shows the switched, dual applicator configuration that was used for the Kelly
program. The RF  generator is connected alternately to applicator #1 and applicator #2 under
computer control.
                                             134

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                                      Vi ER

                                  'T«'(.JTiQN

             PHONE LINE
                               !  CONTROLLER   DIAGNOSTICS
                                                             —I
                                                           f     J
ENVIRONMENTAL
  MONITORS;
                                                                          • MATCHING NETWORK
                                                                              /—TRANSMISSION  LINE
                                                                                  '
                                                     HEATING PATTERN
2 Block          of an RF
                                                         135

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         INSTRUMENT SMELTER
                                                  • TRANSMISSION UN£
                                 r
1
ORO'UNO PLANE
{AS REQUIRES)
                                             APPLICATOR |1
                                                                   APPLICATOR |2
3 Him k iiai'i jin )i a >t, t.:f«
-------
4 lljn view of the RF heating        trailer and         applicators as configured for the Kelly
progiam tests.
Instrument  Shelter:
Trailer:
8 ft. x 8 ft. x 20 ft. insulated steel utility shelter with HVAC and AC power
distribution. The unit features an air-shock isolation rack configured to
protect the 25 kW RF generator cabinet and an instrumentation and control
rack. The shelter also has a filtered air system to cool the RF generator.

A 28-ft flat bed trailer a with neck mounted deck and steel shelter is used to
transport the shelter. The trailer includes a heat exchanger tank and cooling
fluid circulation system for a 25 kW dummy load which is used to setup and
test the RF generator. The under deck area also contains four 28-foot
applicator storage  bays.  A typically loaded trailer weighs 20,000 Ibs.
                                              137

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Truck:                A heavy-duty pickup truck modified for operation with the trailer as a 30,000
                     Ib. GCVW combination highway vehicle mobilizes the system. The truck
                     frame also carries a roof rack system suitable for transport of applicator
                     assemblies of up to 30 feet in length and emplacement tower sections. The
                     truck is used for general site  support tasks during a heating program.

2.1.2   Kev System Components Within the Instrument Shelter

       These components are listed by generic names in the block diagrams of Figures 1 and 2.

AC Power panel:    The shelter is equipped to accept 3-phase 208 to 240 VAC power from a utility
                   or Diesel generator source. The shelter has a 3-phase 200 Ampere power panel
                   (WYE and DELTA feed options). The lines are metered  with two levels of
                   transient and surge/over-voltage protection. The system also has a 1-phase 100
                   Ampere, 110/220 VAC panel that is powered from a 3-phase WYE service or a
                   separate 1-phase feed. The  1-phase power distribution system includes a 1 KVA
                   uninteruptable power supply (UPS) to protect critical control and data acquisition
                   functions.  The 1-phase panel also controls power for the  auxiliary cooling
                   blower of the RF generator as well as for the air conditioning and lighting of the
                   shelter.

RF Generator:       RF Power Products model 25,001D generator (built to KAI specifications and
                   with KAI operation and control modifications). Designed for operational
                   compliance under Part 18 of FCC regulations for Industrial, Scientific and
                   Medical (ISM) equipment.

                   Frequency:     27.12 or 13.56 MHZ operation (crystal controlled)
                   Emission:       AO  (CW unmodulated)
                   output:         25,000 Watts, tuned output stage (harmonics suppressed)

                                 The output is continuously adjustable from 100 to 25,000 Watts,
                                 the maximum power is set by the line voltage of the site's 3-
                                 phase power service.

                   Details:        The generator was operated at 27.12 MHZ for this program. The
                                 unit is an optimized industrial design with a 3CX15000A7
                                 ceramic vacuum tube output stage and automatic power controls.
                                 The modifications include interfaces for remote control and
                                 function  monitoring.

Matching Network: KAI custom design with proprietary features.
(Tuner)
                   Frequency:     design centers of 13.56 MHZ and 27.12 MHZ for specified
                                 impedance  transformations.
                   Power:         > 25,000 Watts
                                             138

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Controller:
Details:        "T" network design with input and output ports using fully
              shielded 1-5/8" EIA connections to rigid line coax.  The unit
              contains motorized input, shunt and output controls and interfaces
              to a KAI control and tuning software package.

This is function is developed by the integration of a number of commercial
components.

Computer:     Industrial Computer Source rack mounted system with 80386 and
              80387 processors, 8 MB RAM, 240 MB hard disk with GPIB and
              modem interfaces.

Software:      The data acquisition software is a customized and proprietary
              package of capabilities developed for real time control and
              specialized diagnostic measurements.

Switching:     HP 3488A switch controller with five interface modules to
              provide contact closures, coaxial switching and TTL sensing/logic
              interfaces. The unit is interfaced to the RF  generator, tuner and
              RF switches as well as system annunciators  and safety monitors.
Diagnostics:
                                 Communications with the system is via a high speed error
                                 correcting FAX/modem suitable for wireline or cellular
                                 communications. The unit is capable of sending a data message
                                 to a host computer, a digital display radio pager or a FAX
                                 machine.  The system also communicates via a UHF radio data
                                 voice message link to signal the operators hand held radio or
                                 scanner of a system status message.
This function provided by a number of commercial components. The items
listed here acquire data that is logged by the control computer in a data
acquisition mode.  Software setup files define if a channel is to be used for
control processing for limit alarms, warning or control actions.

Sensing:       Two HP 3457A scanning digital multimeters (DMM) with 22
              input channels are used to monitor system voltages, temperatures,
              pressures, and power levels

Temperature:   Luxtron 790 floroptic thermometer using four fiber optically
              coupled sensor probes to monitor the Heating Zone.

AC Power:    Ohio Semitronics PC5 and MVT 3-phase Wattmeter and Voltage
              transducers interfaced to the HP3457A DMM.

Vector        HP 8508A with frequency coverage from 0. 1 to 2000 MHZ with
Voltmeter:     a phase locked sensing channel sensitivity of down to 10 uV (-87
              dBm).
                                             139

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                   Signal        HP 8656B with coverage from 0.1 to 990 MHZ and output levels
                   Generator:     of up to + 13 dBm.

                   Network      HP 3577B network analyzer with 0.1 to 200 MHZ coverage with
                   Analyzer:      an HP 35677A S-parameter test set.

                   TDR:         Tektronix 1503C time domain reflectometer

                   Megger:       Biddle model 218650CL with 500 to 5,000 VDC test voltages.

Environmental       These items are used to measure site conditions, above and below ground. The
monitors:           isotropic probe is used to monitor site safety conditions for USAF ad OSHA
                   compliance. The spectrum analyzer is used to measure RF harmonic emissions
                   for FCC compliance.

                   Spectrum  Analyzer:      HP 8591E analyzer with EMC personality modules.

                   Biconical  antenna:        EMCO 3104A calibrated antenna and insulated tripod.
                                          20 to 200 MHZ calibration.

                   Isotropic probe:          Holiday model HI-3012 with MSB and HCH probes.
                                          A foam spacer ball for 0.1 m near contact
                                          measurements (FCC  defined specification).

                   Thermocouple
                   readout/calibrator:        Omega CL 23 type T digital readout used for all on
                                          site temperature measurements of thermocouples.

                   Weather:                Davis Instrument Weather station II with dewpoint and
                                          rainfall sensors.

                   IR Probe:                Omega model OS36-T-240 passive IR thermocouple
                                          unit with type T output mounted on a PVC extension
                                          probe.

2.1.3   Key System Components Outside of the Shelter

       These components are  listed in the  diagrams of Section 2.1. The use of these components
will vary greatly with the site configuration.

Transmission lines:  1-5/8" rigid copper coaxial lines were used throughout system for system
                   interconnections and to transfer power to the heating antennas. The transmission
                   lines  were pressurized with 5 to 15 PSI nitrogen and delivered power to either,
                   heating antenna through a computer controlled, motorized RF switch. Delivery
                   of power to the antenna is typically > 98% efficient for these transmission
                   components.
                                            140

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RF Switch #3:
Applicators:
Guide tubes:
(Sleeves)


Ground planes:
Towers:
Dielectric model A 50000-203, pressurized, heated, 1-5/8" EIA flange
connections. The switch is housed in a weatherproof, secure housing with
adjustable legs and universal joints on each of the ports connections.

Two KAI 3.5" antenna assemblies designed for subsurface RFH applications
(KAI-0690-30).

Frequency:    design centers of 13.56, 27.12 or 40.68 MHZ can be configured.
Power:        25,000 Watts
Diameter:      3.5"  OD  w/o centralizing spacers
Length       7.38' to 11.38' span set for soil conditions (27.12 MHZ)
VSWR:       Set by adjustments of length, typically < 1.5, working max is set
              by the power level, frequency and nitrogen pressurization level.
Feedline:      1-5/8" EIA flange
Details:       The antennas are adjustable length, dipole-type, end-feed
              structures with 1-5/8 in. EIA feedlines. The standard design
              employs aluminum radiating elements with  Teflon insulating
              components.   The use of Teflon limits its to operation to an
              ambient temperature of 200 degrees  C (392 deg. F). Operation
              can be extended above this temperature by the use of ceramic
              insulating  components and/or localized cooling of the applicator
              assembly by compressed air.

The applicators were vertically emplaced in a vertical boreholes lined
with 4.5 inch ID high temperature fiberglass liners. The liner wall thickness was
nominally 0.25 in. and the outside diameter was 5 inches.

The antenna counterpoise/ground plane at the soil surface consists a 8 ft. x 22 ft.
x 0.062 in. expanded aluminum mat pattern mat, extended around and between
the  3 ft. x 3 ft. x 0.25 ft.  thick aluminum ground plane base plates are located
around each borehole  sleeve liner.  An 18  ft. diameter pattern of twelve
aluminum radials of #2 insulated aluminum cable extend from each base plate.
The perimeter cables are terminated to form an  18-foot diameter aluminum
radial pattern of #2 Aluminum cable terminated by 5/8 inch OD x 4 foot copper-
clad steel ground rods driven about 45 inches into the soil. The radials are
centrally capped by an aluminum screen mat that is  bonded to the radials. The
antenna transmission lines and supporting structures are bonded to the ground
plane at multiple points.  NOTE: This structure can  be simplified for  many
installations and could have been in this case since the electromagnetic emission
levels were well below all safety and harmonic emission requirements.

The emplacement towers are mounted to the 3 ft. x 3 ft. aluminum base plates.
The towers are constructed from 10-foot lengths of aluminum antenna mast
sections. The masts are jointed to form 10 ft., 20  ft. or 30 ft. emplacement
towers. The towers are supported with four aluminum extension tubes with
anchored base pads suitable to make the towers self supporting without the use of
guy lines. The complete  tower includes a  1,500 Ib. winch and two rope pulley
lines.
                                             141

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3.0    REVIEW OF SOIL CHEMICAL ANALYSIS

       Adapted from section 7.0 of the KAI appendix to the Brown and Root report.

       The soil chemical analysis scheme was originally based on the definition of a treatment zone
volume of 111 cubic yards (15 ft. x 10 ft. x 20 ft.) which was compared to a control sample region
bounding the sides of the volume with sample depths of up to 10 feet below the region. The soil
analysis for Total Recoverable Petroleum Hydrocarbons (TRPH) was based on the analysis of 40
sample pairs within this region.

       Due to changes in the heating system configuration, a heating zone of 15 ft. x  10 ft. x  10 ft.
was defined inside of the treatment zone.  The top of the zone starts  at a depth of 4 feet and ends at a
depth of 14 feet. This  zone was further subdivided for analysis into two halves. The halves are
centered  about each of the heating wells (Al and A2).   Figure 5 is an isometric view of the zones
with the heating applicator wells  (Al and A2) and the screened S VE wells (El to E8).  Note that the
open, non-black, regions of the SVE well representations are screened sections of pipe that allow air
input or extraction from the treatment zone. Figure 6 is a similar view with the monitoring wells (Fl
to F5) shown in addition to the heating wells and three of the temperature monitoring thermocouple
strings (TC-1 to TC-3).
5 Isometric view of applicator and SVE wells with piping.
                                            142

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                                  TC-3
                      HEATING
                        ZONE
                                                                                       TREATMENT
                                                                                          ZONE:
i Isometric view of applicator     monitoring wells.


       The TRPH analysis of these zones, with a > 80% confidence level correlates with the energy

       to the      and the period of the applied energy (heating).

Treatment Zone
Heating Zone
Volume
(en. yds)
111
55.5
TRPH
(%)
29
49
Energy
15,549
15,549
Days Spanned
49,92
49.92
Heating Zone by Applicator, Al + A2 == Heating Zone Volume
,.
Al Beating Zone
A2 Heating Zone
27,7
27.7
NA
44
4,348
11,201
8.15
41.77*
   2 spans, 28.9 and 1.2,87, with a cooling period between cycles.
                                                 143

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       The A2 heating zone, driven by applicator #1, is suggestive of an anticipated recovery rate
for the energy applied. Ideally this zone and the Al zone would have each received 10,000 KWH in
a 42 day period.  It is projected that this type of heating program would have been more effective
than the slow heating period with cooling cycles that this sequence experienced. It is also expected
that if a second generator were used, the simultaneous, phased-array heating would have produced an
even stronger and more rapid heating effect that would have further improved recovery. Finally,
changes to the SVE system design would also be a source of significant recovery improvement.

3.1    Impact of Changes in the Heating System Configuration

       Changes in the heating program's planned operating time and its ISM operating frequency
required that the heating zone be defined as approximately the upper half of the treatment zone.  This
change occurred when an ISM operating frequency of 27.12 MHZ was chosen in contrast to a 13.56
MHZ frequency.  The 27.12 MHZ frequency was chosen to allow a faster heating of two smaller
adjacent volumes within the treatment zone as opposed to a larger heating zone with a slower heating
rate.

       The 13.56 MHZ applicator would have had a nominal heating span of 18 feet, as opposed to
the 9 foot, span of the 27.12 MHZ applicators and could have been positioned within the center of the
treatment zone. Two,  more rapidly heating, 27.12 MHZ applicators were chosen to be  driven in a
time-multiplexed heating mode by a single 25 kW RF generator to approximate the performance of a
more optimally configured dual RF generator system. This configuration allowed data to be gathered
that would be predictive of how a dual RF generator phased-array* RF system might perform.

       A additional impact of the thinner, vertical profile, heating span occurred when the applicator
was  fixed in the upper half of the treatment volume. This upper half favored the heating of VOCs as
opposed to SVOCs in the lower half of the treatment zone.

3.2    Other Operating Details With Soil Analysis Influence

       The SVE system typically operated in a "deep extract on" mode that pulled vapors down from
the bottom of the heating zone into the extraction wells screened from  10 ft to 20-ft. depths (see
Figure 5).  The effect of this downward vapor "draw" may be responsible for some contaminant
migration from the heating zone into the treatment zone and is likely to make it difficult to
quantitatively evaluate contaminate  concentration  changes.

       Several of the statistically defined TRPH sample sets were complete enough at test well
locations to be examined as a concentration profile. A review of some TRPH sample sets suggest that
contaminants condensed between the 0-foot and 4-foot levels where the SVE efficiency was low.
Condensation also appears to have occurred where soil heated and cooler ambient soil air mixed near
the screened entrance to an extraction well.  The following data listings are of three sets  of soil
samples.  Missing depths were due to the statistical sampling scheme used to distribute the 40 sample
pairs, no data exists at these  points.
   * A 2-element phased applicator array actually has a heating rate and intensity advantage over what can be produced by
two, non-phase-controlled applicators and RF generators. This testing approach provided data to evaluate how well the base
heating rate could be predicted for the non-phased applicators. The test also demonstrated the electromagnetic field coupling
levels that could be achieved between the two applicators.

                                              144

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A2 - Location- of applicator #1 with the majority of applied energy — The 0 to 4
foot locations show significant increases in concentration. The heating zone volume
near the applicator shows a strong removal trend. The 10 to 12 foot location that
corresponds to the highest heating temperature profile shows significant removal.
Location A2
          Pretreatment
          Concentration
             (ppm)
0-2ft.              2,330
2-4ft.              203
 	 heating zone boundary —
4- 6ft.
6-  8ft.
8- 10ft.
10-12 ft.
12 - 14 ft.
622
           1,530
1,290
106
      heating zone boundary  —
 14-16 ft.
 16-18 ft.
 18-20ft
          79,700
          39,300
                           Post treatment
                           Concentration
                              (ppm)

                           8,850  [suggested condensation]
                           2,570  [suggested condensation]

                           154
                                     33.3 [removal to quantitation limit]
                           20,800
                           28,300 [removal by ambient air SVE
                                    only]
E5 - Extraction well located on center line near A2 — Extraction is enhanced in the
heating zone. The 12 to 14 foot level appears to a condensation boundary were cool
air meets the downward flow of hot vapor.
Location E5
          Pretreatment
          Concentration
             (ppm)
0-2ft.
2-4ft.
 	 heating zone boundary  —
4-6ft.              2,710
6-8ft.               1,530
8-10 ft.
 10-12 ft.            668
 12 - 14 ft.            739

 	 heating zone boundary  —
 14-16 ft.
 16-18 ft.
 18-20ft
          105,000
                           Post treatment
                           Concentration
                               (ppm)
                                     673
                                     587

                                     330
                                     1,450 [suggested condensation at
                                            extraction well]
                           35,800 [removal by ambient air SVE
                                    only]
                                      145

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       F3 - Monitor hole for IR temperature profiles centered between Al and A2 at 5
       feet — Strong removal is suggested in the top of the heating zone where the maximum
       temperature profiles were recorded between 6 and 10 foot. The temperature dropped
       off sharply in the 10 to 12 foot zone and could be seen to match the region of
       increased concentration.
       Location F3
Pretreatment
Concentration
   (ppm)
Post treatment
Concentration
    (ppm)
       0-2ft.
       2-4ft.
        	 heating zone boundary —
       4-6ft.                   4,920
       6-8ft.
       8-10 ft.
        10-12 ft.                336
       12 - 14 ft.
       	 heating zone boundary  —
       14-16 ft.
       16-18 ft.
       18-20ft
                           702 [strong removal suggested]
                           4,510  [suggested condensation between
                                 extraction wells screened from
                                 10ft. to 20 ft]
4.0    REVIEW OF SOIL VAPOR EXTRACTION DATA

       Adapted from section 8.0 of the KAI appendix to the Brown and Root report.

       The soil vapor extraction system flow characteristics do not appear to have been optimum to
extract from the chosen heating zone in the upper level of the site treatment zone (see screened well
configuration shown in Figure 5 of Section 3.0 of this document).  However, it appears that they
were adequate to  demonstrate significant VOC removal from the heated zone.

       The downward "draw" of the SVE system on the heated zone has been observed to produce a
number of thermal profile measurement distortions that require careful analysis for interpretation. In
general, the downward flow caused the deep portions of the thermal patterns to have lower relative
temperature values and truncated profile patterns with minimal lateral flow and limited "draw" from
the higher levels of the zone.  It is also very possible that condensation occurred for some volatiles as
they mixed with cooler air as they  were drawn to the extraction wells.

       The SVE  system output temperatures, measured at the control valves next to the vacuum
manifold, were generally lower than anticipated. Temperatures within the heated zone suggested that
the high temperature soil vapors could be estimated to range from 100 degrees C to well over 180
                                            146

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degrees C (+230 degrees is likely). These vapors were mixed with a significant volume* of cool
subsurface air that maintained the extraction well output temperatures well below 100 degrees C (as
measured by average reading temperature probes).

       Figure 7 is a simplified representation of the conditions within the RFH zone. The sensor
well is a monitoring well such as Fl which was located three feet from a heating applicator well.
The RF energy incident on the soil from the heating antenna directly interacts10 with water droplets,
hydrocarbon deposits and sand represented  in this figure. The RF interaction causes each of these
items to heat as an isolated point source.  The heating rates differ for each of the items.  At a given
point in the heating program the hydrocarbon deposit points my be heated to a temperature of perhaps
200 degrees C while the water droplets are just approaching 90 degrees  C. The sand at this point
may only be heated 5 degrees above an ambient temperature of 23 degrees C to perhaps 28 degrees C
(unless the sand particle has a hydrocarbon  or water droplet on its surface and it then is heated by
conduction to a higher average temperature).

       The underground SVE air flow pattern draws ambient, 23 degree C, soil air into the heating
zone. The RF illuminated soil heats the 23 degree ambient air passing through the soil matrix to a
higher temperature. However, this temperature is still well below the highest point source
temperature of 200 degrees Cfor this example.

In Figure 7 the soil-heated air flows past the fiberglass wall of the sensor well.  The air heats the wall
to a temperature that approximates that of the air but is typically much lower in temperature than the
point sources that heated the air. The probes within the sensor well measure the wall temperature.
The infrared (IR) probe is the most accurate measurement since it optically focuses on a small spot
and does not average its  thermal mass with that of the contact point on the wall. This kind of probe
is best for rapid temperature profiling but does not provide and absolute measurement of the average
wall temperature.  Movement of the probe mixes air within the well and further diminishes the
absolute accuracy of the measurement.  The contact probe can provide more accurate measurement of
the wall temperature if the volume behind the probe is filled with a barrier that stops air from flowing
near the probe.  The probe needs to be in contact with the wall in excess of 5 minutes to obtain an
accurate reading.

       It is important to note that for the Kelly program, all of the sensor wells were also surrounded
with 0.5 to 2 inches of dry sand. This sand layer further separated the fiberglass wall from the
heated soil matrix and enhanced the air flow in this region.  It is on this basis that all ZR temperature
measurements were considered low by a conservative 10 to 20 degrees and in reality may have been
40 to 100 degrees below the actual point source heating temperatures.
   9 This conclusion is arrival at by estimating that the top 1/3 of each extraction well (1,0 ft. to 13 ft, ) received hot
vapors and iiws balance of the well (13 ft. to 20 ft.) contributed cooler subsurface air to the extracted air stream. In cases
'where multiple extraction wells were connected, the dilution ratio was still higher.

   w Radio frequency (RF) energy desorbs and mobilizes the contaminants more effectively than heat conduction by steam
or hot air because thermal activation of the contaminant occurs al the molecular level throughout the RF treatment volume.
The dipoie-dipoie bonding between contaminant molecule and soil particle is thermally agitated at the bonding site by the RF
energy,


                                               147

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                                                         TO
                                                       METER
                                                   CONTACT
                                                TEMPERATURE
                                                    PROBE
                                                     IR
                                                 OPTICAL
                                                  PROBE
                                            FOCAL  PATTERN
                                             OF IR  SENSOR
                                                   SENSOR  WELL
                   SOIL  HEATED
                BY  RF ACTION  ON
           HYDROCARBONS AND  WATER
                        HYDROCARBON
                          SAND
                          PARTICLE
                        WATER
                        DROPLET
— FIBERGLASS
   WALLS
 (WELL  LINER)
 7 Simplified diagram of indirect temperature measurements of soil temperature in the heating zone
 under SVE influence.
                                   11
       The peak measured temperature  of 233.9 degrees C by a point sensor on the outside of a
fiberglass well liner suggested that a hot liquid flowed into the vicinity of the sensor and blocked all
air flow into the region of the sensor.  The liquid zt>0s heated to a temperature of perhaps 240 degrees
or more within the heating zone near the sensor well. This is likely to be the temperature of many of
the isolated hydrocarbon contaminant heating sites distributed throughout the heating zone.
       There is are three important trends to consider in interpreting temperature data for this
program.
           Increasing permeability increases air flow and lowers measured temperatures - When
           contaminants and water are removed from the region surrounding the heating applicator
           wells, the permeability of the soil increases.  Increased permeability increases the SVE
           air flow volume within the heated region. This trend lowers the measured temperature in
           the monitoring wells due to increased flow and air mixing.
   11 This peak was part of a slow trend that stayed above 200 degrees for several hours for this well and corresponded in a
high reading at an adjacent well sensor at the same depth.
                                            148

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           Contaminant removal lowers the heating rate near sensor well regions - As water and
           RF heated contaminants are removed from the heating zone near the applicator wells and
           the sensor wells, the heat generation rate drops to a lower "sand-like" heating rate.  The
           regions with removed contaminants become somewhat "cooler" than the regions on the
           outer boundaries of the heating pattern that continue to have strongly heating
           contaminants.

           The expansion of the heating pattern beyond the sensor wells will lower the
           measured temperatures at the interior well locations - The increased permeability,
           contaminant/water removal, increased available soil air mixing volume and the increasing
           distance of the heating front from the sensor wells may all contribute to the measurement
           of lower relative temperatures as the heating program progresses.
5.0    COST PROJECTIONS FOR AN RFH SYSTEM

       Adapted from section 9.0 of the KAI appendix to the Brown and Root report.

       The Kelly RFH program was essentially executed as an investigative pilot program that
addressed a number of site configuration items (e.g. SVE) in addition to the RFH system installation
and operation.  The site was operated with more personnel than would normally be required for even
a larger heating site.  The program and site conditions did not allow for the progressive expansion of
the heating zone or full automatic operation of the heating system. These two factors make it difficult
to directly scale the costs of the Kelly program to a commercial embodiment of an RFH system.

       However, there are some cost and resource utilization numbers available, directly from the
program data, that can be used to generally characterize the application of RFH for thermally
enhanced SVE programs.  These numbers were based on the last 21.3 day period12 of the heating
program. These planning numbers are:

       •   RF Energy Generation rate:                           19.93 kW/hour
           This rate is dependent on the available
           3-phase AC utility voltage level. AC line
           voltage set a 22 kW peak power operating
           level for this site.

       •   Cost per hour of RF generated:                        $3.88/hour
           This cost is based on a 19.93 kW/hr
           generation rate with a 58.9% system 3-phase
           AC power conversion efficiency plus 5 kWh
           overhead with a utility rate of $0.10/kWh.

       •   RF system operation within on-site span:                94.54%
           This operation period includes breaks
           for measurements and maintenance checks
           over a span of 10 days or more.
   12 This period follows the repairs to the 3-phase power system splices and replacement of the power line.

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5.1    Outline for Costing of a 200-kW System

       A 200-kW system could be developed by using eight 25-kW RF generators with the capability
of driving either 2-element or 4-element applicator arrays.  The system would employ a minimum of
16 switched applicator positions to allow continuous operation of the system as applicators are
removed from heated areas and installed in new areas. The exact definition of a 200-kW system will
depend on the site characteristics. Some of the principal determinates of the system configuration
would be:

       •   Contaminant plume thickness,  extent and nominal depth defines if the preferred access is
           through either vertical or horizontal drilling techniques.

       •   The preferred heating dimensions of the plume will determine if the RFH system's
           operating frequency should be  13.56 MHZ with a nominal heating span of 18 ft. or 27.12
           MHZ with a nominal span of 9 feet.  It is also possible to operate with a 6 foot span if a
           40.68 MHZ frequency is used.  In some cases the heating rate of the plume will be a
           factor in contrast to SVE flow requirements.  An ISM heating frequency of 40.68 MHZ
           heats the smallest volume most rapidly and 13.56 MHZ heats the  largest volume more
           slowly.

       •   The need or option to access large volumes of the contaminant plume also determines  if
           the system needs large numbers of installed applicators with switching networks to allow
           efficient, automated operation.  Alternately a limited number of applicators, with
           computer controlled mechanical positioning equipment, can  incrementally heat large
           volumes of the plume from a few boreholes (e.g., horizontal).

5.2    A 200-kW System Description

       The following system would be defined as  a wide coverage 13.56 MHZ system configured for
horizontal drilling emplacement. It would have the following components:

       2   RF Master control and instrument trailers with an internally mounted 25 KW, 13.56
           MHZ RF generator and tuner (the units would be similar in size and design to the KAI
           pilot Rig #1  used for this program). Each master control trailer would also carry control
           and diagnostic instrumentation. The master control systems would be linked with the
           slave systems through fiber optic cables. Each master control system would be fully
           automated and respond to both  local  and remote control computer commands.

       2   Slave RF systems with three 25 kW, 13.56 MHZ RF generators and tuners per trailer.
           Each slave trailer would include a common cooling system and 3-phase AC power
           distribution system.  Flexible and rigid RF transmission lines suitable for the operating
           frequency would be used to reach the 16 heating locations from the two trailer groups  of
           master and slave units.

       16  Flexible horizontal applicators with an  emplacement system allowing controlled  motion
           during heating of up to 45  ft. per setup.

       8   Motorized RF switches to select between two installed applicators that are to be selected
           by each RF generator/tuner group.


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       1   3-phase AC power utility or Diesel generator service capable of providing a minimum of
           500 kVA for the site.  Additional power requirements would dependent on the
           requirements of the SVE and off gas treatment systems.

       A heating system of this scale and capital investment13 can be expected to operate in the field
with utility power costs, full automation, and programmed personnel support for configuration
changes at a cost of much less than $100 per cubic yard over a multi-year operating period.  This
figure is exclusive of horizontal drilling costs, SVE system installation, off gas treatment and non-RF
site operating costs.

5.3    Recommendations on System  Strategies

       The costing of RF thermally  enhanced SVE programs is very dependent on the use of the
following key strategies:

       •   Select the ISM heating frequency based on the optimum heating rate, soil penetration
           depth, and contaminant thickness.

       •   Select a drilling technique (vertical, slant or horizontal) that provides the most access to
           the contaminated zone for each borehole position and applicator heating span.

       •   Use each heating applicator in multiple positions along the length of the guide tube or
           slowly "scan" the heating zone with the applicator's heating span.

       •   Use each RF generator to sequentially drive two or more applicators.

       •   Use multiple RF generators in groups of two or four as phased arrays to focus and steer
           the heating pattern.

       •   Use automated and remote control operation to minimize the need for highly skilled on-
           site labor.

       The application of RF thermal enhancement also needs to be characterized in terms of the
time savings it represents over conventional treatment projections using non-thermal SVE technique at
the same site (assuming the targeted  contaminants are removable on a realistic time scale by non-
thermal methods). Key points for consideration are:

       •   RF thermal enhancement can be applied as a rapid response tool for stopping the
           migration of contaminant plumes at depths of over 750 feet.

       •   RF thermal enhancement may be selectively applied to high concentration, "hot spot"
           regions within a general site remediation strategy using passive SVE, bio-venting or bio-
           remediation.

       •   Thermally enhanced SVE may allow extraction of contaminates from some sites that
           normally would require  excavation.
   13 Assuming a 5 year pay pack period.

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