United-States
          Environmental Protection
          Agency
Office of Research and
Development
Washington DC 20460
EPA/540/R-95/503
April 1999
&EPA    ZENON Environmental, Inc
          ZenoGem® Biological and
          Ultrafiltration Technology

          Innovative Technology
          Evaluation Report
                SUPERFUND INNOVATIVE
               TECHNOLOGY* EVALUATION

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                                  EPA/540/R-95/503
                                     April 1999
   Zenon Environmental Inc.
   ZenoGem® Biological and
   Ultrafiltration Technology
Innovative Technology Evaluation Report
         National Risk Management Research Laboratory
            Office of Research and Development
            U.S. Environmental Protection Agency
              Cincinnati, Ohio 45268
                                Printed on Recycled Paper

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                                                Notice
The informadon in this document has been funded by the U. S. Environmental Protection Agency (EPA) under Contract No.
68-C5-0037 to Tetra Tech EM Inc. It has been subjected to the Agency's peer and administrative reviews and has been
approved for publication as an EPA document.  Mention of trade names or commercial products does not constitute an
endorsement or recommendation for use.

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

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

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

                                                        National Risk Management Research Laboratory
                                                        in

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                                                 Abstract
Zenon Environmental Inc.  (Zenon), of Burlington, Ontario,  Canada has developed an innovative wastewater treatment
technology called the ZenoGem® technology.  The ZenoGem® technology integrates biological treatment with membrane-
based ultrafiltration to treat wastewater with high concentrations of organic contaminants that cause elevated concentrations of
chemical oxygen demand (COD).  The system reduces organic contaminants in  wastewater to below  regulatory  limits,
improves effluent quality, reduces sludge production, resists contaminant shock-loading, and, by maintaining a long  sludge
retention time, reduces the size of the bioreactor necessary for performing bioremediation.

The Superfund Innovative Technology Evaluation (SITE) demonstration occurred between September and December 1994 at
the Nascolite Superfund site (Nascolite) in Millville, Cumberland County, New Jersey. In 1985, a remedial investigation and
feasibility study at the Nascolite site revealed that groundwater was contaminated with methyl methacrylate (MMA), volatile
organic compounds (VOC), and heavy metals.

The basic components of the ZenoGem® system are an influent-holding equalization tank, a bioreactor, an air blower, a pH
buffer tank, a nutrient solution tank, an ultrafiltration module, optional off-gas carbon filters, optional permeate carbon  filters,
and feed, process, and metering pumps. The system components are computer-controlled and equipped with alarm indicators
to notify the operator of mechanical and operational problems.

During the SITE demonstration, critical and noncritical measurements were evaluated.  Critical measurements consisted of
sample analyses  and process measurements that directly impacted meeting the project's primary technical objective. Critical
measurements included collection of liquid and air samples for MMA and VOC analyses; liquid samples to evaluate COD; and
flow rate measurements of the influent and effluent liquid streams.  Noncritical, or system condition measurements, provided
information on  operating ranges,  reliability,  variability,  cost-effectiveness, and  full-scale remediation potential  of  the
technology.

The results of the sample analyses indicated that the technology consistently surpassed the demonstration goal of 95 percent
reduction for MMA  (99.99 ± 0.01 percent) and COD (96.8 ± 5.0 percent).  The  high removal  efficiency for MMA and
reduction of COD was maintained after a 3-fold concentration was delivered to the system (shock-loading test), suggesting that
a sudden increase in influent MMA and COD concentration had little noticeable effect on the technology's performance.
Reductions of greater than 97 percent were noted in all VOCs reported (methylene chloride, trichloroethene, benzene, toluene,
and o+p xylenes).   Based on extrapolation from the air sample concentration data and the flow meter readings, the total
volatilization of MMA and VOCs from the system calculated less than 0.10 percent of the total MMA and VOC mass  treated
during the demonstration. No major operating problems  occurred during the  SITE demonstration period;  no significant
changes in technology performance were observed during the SITE demonstration.

EPA SITE Program personnel prepared this Innovative Technology Evaluation Report  (ITER) to present the results of the
SITE Program demonstration. The ITER evaluates the ability of the ZenoGem® technology to treat contaminated groundwater
based on the demonstration results. Specifically, this report discusses performance and economic data collected by SITE
Program personnel, and also presents case studies and additional information about the technology provided by Zenon.
                                                        IV

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                                        Contents
Acronyms, Abbreviations, and Symbols	x
Conversion Factors	xii
List of Figures	viii
List of Tables	ix
Acknowledgments	xiii
Executive Summary	1
Introduction	6
    1.1  Description of SITE Program and Reports	6
        1.1.1    Purpose, History, and Goals of the SITE Program	6
        1.1.2    Documentation of SITE Demonstration Results	7
    1.2  Description of Bioremediation	7
    1.3  The ZenoGem® Technology	8
    1.4  Overview and Objectives of the SITE Demonstration	11
        1.4.1    Description of Nascolite Site	11
        1.4.2    SITE Demonstration Objectives	 11
        1.4.3    Demonstration Procedures	12
    1.5  Key Contacts	15
2   Technology Effectiveness  Analysis	16
    2.1  SITE Demonstration Results	16
        2.1.1    Objective P-l: Removal Efficiencies	16
        2.1.2    Objective S-2: Total Metals, TSS, VSS, TOC, ORP, sg, DO, Temperature,
                pH, Nutrients	21
3   Technology Applications Analysis	30
    3.1  Applicable Waste	,	,	30
    3.2  Factors Affecting Performance	31
    3.3  Site-specific Factors Affecting Performance	31
        3.3.1    Site Area	31
        3.3.2    Climate	32
        3.3.3    Utilities	32
        3.3.4    Maintenance	32

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                               Contents (continued)
        3.3.5   Support Systems	32
        3.3.6   Personnel Requirements	32
    3.4  Material Handling Requirements	33
    3.5  Technology Limitations	33
    3.6  Potential Regulatory Requirements	33
        3.6.1   Comprehensive Environmental Response, Compensation, and Liability Act	35
        3.6.2   Resource Conservation and Recovery Act	35
        3.6.3   Clean Water Act	36
        3.6.4   Safe Drinking Water Act	36
        3.6.5   Clean Air Act	36
        3.6.6   Mixed Waste Regulations	37
        3.6.7   Occupational Safety and Health Act	37
    3.7  State and Community Acceptance	37
4   Economic Analysis	39
    4.1  General Factors Affecting Costs	39
    4.2  Overview of Cost Scenarios	41
    4.3  Case 1 Analysis	41
        4.3.1   Issues and Assumptions	41
        4.3.2   Waste Characteristics and Site Features	41
        4.3.3   Equipment and Operating Parameters	41
    4.4  Case 1 Costs	43
        4.4.1    Site Preparation Costs	43
        4.4.2    Permitting and Regulatory Costs	45
        4.4.3   Mobilization and Startup Costs	45
        4.4.4    Equipment Costs	45
        4.4.5    Labor Costs (Routine Operation Labor)	45
        4.4.6    Supply  Costs	46
        4.4.7    Utility Costs	46
        4.4.8    Effluent Treatment and Disposal Costs	46
        4.4.9    Residual Waste Shipping and Handling Costs	47
        4.4.10   Analytical Services Costs	47
        4.4.11   Equipment Maintenance Costs	47
        4.4.12   Site Demobilization Costs	47
    4.5 Case 2 Analysis	48
        4.5.1    Issues and Assumptions	48
        4.5.2   Waste Characteristics and Site Features	48
                                               vi

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                               Contents (continued)
        4.5.3   Equipment and Operating Parameters	;	;	48
    4.6 Case 2 Costs	49
        4.6.1   Site Preparation Costs	49
        4.6.2   Permitting and Regulatory Costs	51
        4.6.3   Mobilization and Startup Costs	51
        4.6.4   Equipment Costs	51
        4.6.5   Labor Costs	51
        4.6.6   Supply Costs	52
        4.6.7   Utility Costs	52
        4.6.8   Effluent Treatment and Disposal Costs	52
        4.6.9   Residual Waste Shipping and Handling Costs	53
        4.6.10  Analytical Services Costs	53
        4.6.11  Equipment Maintenance Costs	53
        4.6.12  Site Demobilization Costs	53
    4.7 Conclusions of Economic Analysis	53
5   Technology Status and Implementation	4	57
6   References	58
Appendix
    A   Vendor Claims
    B   Summary of Field Data
    C   Summary of Analytical Data
                                              VII

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                                 Figures
1-1    ZenoGem® System	
1-2    Ultrafiltration Module	
1-3    Sampling Locations	'.	
2-1    Total MMA Concentrations in Influent Stream (SI)	
2-2    Removal Efficiency (MMA + VOCs) (S-4)	
2-3    MMA in Air (S-7)	
2-4    VOCs in Air (S-7)	
2-5    Air Flow in Emission Stream (S-7)	
2-6    COD Removal Efficiency (S-4)	
2-7    COD Removal Efficiency (S-10)	
2-8    Distribution of COD Removal Efficiency by Number of Samples (S-4 and S-10)
2-9    Aluminum Concentrations in the S-l, S-4, and S-10 Streams	
2-10   Cadmium Concentration in the S-l, S-4, and S-10 Streams	
2-11   Chromium Concentrations in the S-l, S-4, and S-10 Streams	
2-12   Copper Concentrations in the S-l, S-4, and S-10 Streams	
2-13   Iron Concentrations in the S-l, S-4, and S-10 Streams	
2-14   Lead Concentrations i the S-l,  S-4, and S-10 Streams	
2-15   Manganese Concentrations in the S-l, S-4, and S-10 Streams	
2-16    Mercury Concentrations in the S-l, S-4, and S-10 Streams	
2-17    Nickel Concentrations in the S-l, S-4, and S-10 Streams	
2-18    Zinc Concentrations in the S-l, S-4, and S-10 Streams	
2-19    TSS Concentrations in the S-l, S-4, and S-10 Streams	
2-20    VSS Concentrations in the S-l, S-4, and S-10 Streams	
2-21    TOC Concentrations in the S-l, S-4, and S-10 Streams	
2-22    ORP in the SI, S-4, and S-10 Streams	
4-1     Case 1 Fixed Costs	
4-2     Case 1 Annual Variable Costs	
4-3     Case 2 Fixed Costs	•	
4-4     Case 2 Annual Variable Costs	
...9
.10
.13
.17
.17
.20
.20
.20
.22
.22
.22
.24
.24
.24
.24
.25
.25
,.25
..25
..26
..26
..26
..28
..28
..28
..55
..55
..56
..56
                                      VIII

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                                         Tables
ES-l    Superfund Feasibility Study Evaluation Criteria for the ZenoGem Technology	4
1-1     Maximum Concentrations of TCL VOCs Detected in Groundwater at the Nascolite Site	12
1-2     Analytical Measurement Parameters and Relationship to Project Objectives	14
2-1     Measured TCL VOC Reductions	19
2-2     Total Metals Concentrations	23
3-1     Summary of Environmental Regulations	34
4-1     Costs Associated with the ZenoGem Technology - Case 1	44
4-2     Cost Associated with the ZenoGem Technology  - Case 2	50
                                             IX

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          Acronyms, Abbreviations, and Symbols
AEA
ACL
ARAR
BACT
bgs
BOD
CAA
CERCLA
CFR
COD
CWA
DO
DOE
GC
EPA
gpd
gpm
ITER
kWh
MCL
mg/L
MMA
MS/MSD
NAPL
NAAQS
NJDEP
NPDES
NEL,
NO3-/NO2"
NRC
O&M
ORD
Atomic Energy Act
Alternate concentration limits
Applicable or relevant and appropriate requirement
Best available control technology
Below ground surface
Biological oxygen demand
Clean Air Act
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
Chemical oxygen demand
Clean Water Act
Dissolved oxygen
Department of Energy
Gas chromatography
U.S. Environmental Protection Agency
Gallons per day
Gallons per minute
Innovative Technology Evaluation Report
Kilowatt-hour
Maximum Concentration Limit
Micrograms per liter
Milligrams per liter
Methyl Methacrylate
Matrix spike/matrix spike duplicate
Nonaqueous-phase liquid
National Ambient Air Quality Standards
New Jersey Department of Environmental Protection
National Pollutant Discharge Elimination System
Ammonia
Nitrate/nitrite
Nuclear Regulatory Commission
Operation and Maintenance
EPA Office of Research and Development

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 Acronyms, Abbreviations, and Symbols (continued)
ORP
OSHA
OSWER
POTW
PO/3
PPE
PSD
psi
QAPP
QA/QC
RCRA
RI/FS
RO
SDWA
SARA
scf
scfm
SITE
sg
STP
TCL
TER
TOC
TSD
TSS
UF
VOC
VSS
Zenon
Oxidation reduction potential
Occupational Safety and Health Administration
Office of Solid Waste and Emergency Response
Publicly owned treatment works
Phosphate
Personal protective equipment
Prevention of significant deterioration
Pound per square inch
Quality assurance project plan
Quality assurance/quality control
Resource Conservation and Recovery Act
Remedial investigation/feasibility study
Reverse Osmosis
Safe Drinking Water Act
Superfund Amendments and Reauthorization Act
Standard cubic feet
Standard cubic feet per minute
Superfund Innovative Technology Evaluation
Specific gravity
Standard temperature and pressure
Target compound list
Technical Evaluation Report
Total organic carbon
Treatment storage and disposal
Total suspended solids
Micrograms per liter
Ultrafiltration
Volatile organic compound             ;
Volatile suspended solids
Zenon Environmental Systems Inc.
                                     xi

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                              Conversion Factors
                 To Convert From
                           To
                     Multiply By
Length
Area:
Volume:
inch
foot
mile
square foot
acre
gallon
cubic foot
centimeter
meter
kilometer
square meter
square meter
liter
cubic meter
2.54
0.305
1.61
0.0929
4,047
3.78
0.0283
Mass:
pound
kilogram
                                                                      0.454
Energy:
kilowatt-hour              megajoule
                                                                      3.60
Power:
kilowatt
horsepower
                                                                      1.34
Temperature:           (°Fahrenheit - 32)           "Celsius
                                                 0.556
                                           xii

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                                        Acknowledgments
This report was prepared for U.S. Environmental Protection Agency's (EPA) Superfund Innovative Technology Evaluation
(SITE) Program by Tetra Tech EM Inc. (formerly PRC Environmental Management, Inc.) under the direction and coordination
of Mr. Daniel Sullivan, project manager for the SITE Program in the National Risk Management Research Laboratory, Edison,
New Jersey.

Special acknowledgment is given to Mr. F. Anthony Tonelli and Mr. Ake Deutschmann of Zenon Environmental Inc.,
Burlington, Ontario, Canada; Mr. Mike Merdinger of Foster Wheeler Environmental Corporation (previous SITE Program
contractor for the ZenoGem® demonstration); the site owner; and the New Jersey Department of Environmental Protection for
their cooperation and support during the SITE demonstration and during the development of this report.
                                                    XIII

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                                       Executive Summary
Zenon  Environmental  Inc.  (Zenon), of  Burlington,
Ontario, Canada has developed an innovative wastewater
treatment technology called the ZenoGem® technology.
This technology is designed to treat groundwater, landfill
leachate,  industrial  effluent, or soil-washing effluent
contaminated  with  high  concentrations  of organic
compounds.  The ZenoGem® technology uses aerobic
biological treatment to remove  biodegradable organic
compounds from the target influent and ultrafiltration to
separate residual  suspended solids from  the  treated
effluent.

The purpose of this  Innovative Technology Evaluation
Report (ITER) is  to present information that will assist
Superfund decision-makers in evaluating this technology's
suitability for remediating a particular hazardous waste
site. The report provides an introduction to the Superfund
Innovative Technology Evaluation (SITE) Program and
the ZenoGem® technology and discusses the demonstration
objectives and activities, evaluates the technology's
effectiveness,   analyzes   key   factors  pertaining  to
application of this technology, analyzes the cost of using
the technology to treat contaminated  groundwater and
leachate, and summarizes the technology's current status.

This  executive  summary  briefly   summarizes  the
information discussed  in  the ITER and  evaluates the
technology with respect to the nine criteria used in
Superfund feasibility studies.

Technology Description

The ZenoGem® technology integrates biological treatment
with membrane-based ultrafiltration to treat wastewater
with high  concentrations of organics contaminants that
cause  elevated  concentrations  of chemical oxygen
demand (COD).  Zenon claims that the process reduces
organic contaminants in wastewater to  below regulatory
limits,   improves  effluent  quality,  reduces  sludge
 production, resists contaminant shock-loading, and, by
 maintaining a long sludge retention time, reduces the size
 of the biological reactor (bioreactor) necessary  for
 performing bioremediation.

 This   system uses  ex-situ  bioremediation to  treat
 contaminated groundwater in an enclosed suspended
 growth bioreactor. According to Zenon, the ZenoGem®
 process derives an advantage over conventional wastewater
 treatment  processes  due  to   its   membrane-based
 ultrafiltration technology.  The ultrafilter not only filters
 the treated water (permeate) prior  to discharge  and
 recycles  the biological solids (concentrate), but also
 recovers  the higher-molecular-weight soluble materials
 that would otherwise pass through conventional clarifiers
 and filters. These higher-molecular-weight materials are
 returned to the bioreactor for further biodegradation prior
 to ultimate  discharge.   The  combination of biological
 treatment with ultrafiltration proves to be an effective
 means of not only degrading organic compounds, but also
 in minimizing the  amount  of waste  solids typically
 associated with biological treatment operations.

 Overview  of the  ZenoGem® Technology  SITE
 Demonstration

 The SITE demonstration of the ZenoGem® technology
 occurred  between September and December 1994 at the
Nascolite  Superfund  site  (Nascolite)  in  Millville,
 Cumberland County, New Jersey. Nascolite manufactured
 acrylic plastic sheets at the site from 1953 to 1980. The
 company used methyl methacrylate (MMA) monomer as a
raw material and operated a MMA reclamation process.
 Solid  acrylic, liquids, and resins containing MMA were
purchased from  outside sources.   This material  was
processed through depolymerization, using a molten lead
bath followed by distillation and purification.  Waste
residue from the distillation processes was  stored  in
several underground storage tanks in the northern plant

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area.  In 1985, a remedial investigation and feasibility
study at the Nascolite site revealed that groundwater was
contaminated  with  MMA, various other EPA  target
compound list (TCL) volatile organic compounds (VOC),
and heavy metals.

For  the SITE Program demonstration, a  pilot-scale
ZenoGem® system was used to treat groundwater at the
Nascolite site. For the SITE demonstration, the pilot-scale
system  was  housed in a transportable trailer,  which
required a 12-foot by 60-foot area to support the system
and its components' maximum operating weight of 45,000
pounds.  Zenon indicated that these measurements are
specific to the trailer used for the SITE demonstration, and
that Zenon's projects usually  do not include a trailer-
mounted system.

The basic components of the ZenoGem® system used in
the demonstration include: an influent-holding equalization
tank, a bioreactor,  an air blower, a pH buffer tank, a
nutrient solution tank, an ultrafiltration module, optional
off-gas carbon filters, optional permeate carbon filters,
and feed, process, and metering pumps. According to
Zenon, off-gas and permeate carbon  filters are not
standard components of the ZenoGem® system; however,
carbon filters may be used depending  on  site-specific
conditions.    The system  components are computer-
controlled and equipped with alarm indicators to notify the
operator of mechanical and operational problems.  The
entire pilot-scale system, except for the main air blower
and optional carbon filters, is mounted inside the 8-foot by
48-foot trailer.  The trailer  also is equipped with  a
laboratory that enables field personnel to evaluate system
performance.

The primary objective of the SITE demonstration was as
follows:

  •  Determine  if  the  ZenoGem® treatment  system
     (integrating the bioreactor and ultrafiltration unit as a
     whole) can achieve a 95 percent or greater removal
     efficiency for MMA and TCL VOCs and reduce COD
     at a 95 percent confidence level

 The secondary objectives of the demonstration were as
 follows:

  •  Evaluate system performance by measuring system
     parameters that will provide data on operating ranges,
     reliability, variability, cost-effectiveness, and full-
     scale remediation potential
 •   Estimate  approximate capital and  operations and
    maintenance (O&M) costs for the demonstration and
    for full-scale remediation

During the SITE demonstration, critical and noncritical
measurements were evaluated.  Critical measurements
consisted of sample analyses and process measurements
that directly  impacted meeting  the project's  primary
technical  objective.   Critical measurements included
collection of liquid and air samples for MMA and TCL
VOC analyses; liquid samples to evaluate COD; and flow
rate measurements of the influent  and effluent  liquid
streams.   Flow rate measurements were  used during
calculations of the ZenoGem® system's total reduction of
MMA, TCL VOCs, and COD concentrations between the
influent and effluent streams.

Noncritical, or system condition measurements, provided
information on operating ranges, reliability, variability,
cost-effectiveness, and full-scale remediation potential of
the technology. System measurements included sample
collection and laboratory analyses for the following: total
suspended solids, volatile suspended solids, total metals,
total organic  carbon, nutrients (ammonia, nitrate/nitrite,
and phosphate), oxygen, and carbon dioxide.  System
measurements  also  included measurements  for  pH,
dissolved  oxygen,  temperature, oxidation reduction
potential, and specific gravity.

Samples indicated that influent groundwater during the
demonstration  contained MMA  concentrations ranging
from 567 to 9,500 milligrams per liter (mg/L); methylene
chloride concentrations  ranging from 500 to  15,300
micrograms per liter (ng/L); trichloroethene concentrations
ranging from 852 to 905 u.g/L; benzene concentrations
ranging from 279 to 282 \ig/L (these were the  only two
 detections of the contaminant in the influent during the
 demonstration); and COD concentrations  ranging from
 1,490 to 19,600 mg/L. Toluene and the o- and p- forms of
 xylenes were detected only once during the demonstration
 at  concentrations  of  105  ng/L  and   14,400  jig/L,
 respectively.

 Based on SITE Program data and postdemonstration data
 obtained by Zenon,  the average  flow rates for  the pilot-
 scale unit ranged between 380  to  620 gallons per day
 (gpd).  Based on the daily flow rates, the system treated
 about 47,200 gallons of contaminated groundwater during
 the demonstration.

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SITE Demonstration Results

The following items summarize the significant results of
the SITE demonstration:

 • The permeate MMA removal efficiencies consistently
   surpassed the  demonstration  goal of 95  percent
   reduction. The average removal efficiency for MMA
   was greater than 99.98 + 0.01 percent for the 3 month
   demonstration.  MMA analyses from the treated
   effluent  stream following  the  optional permeate
   carbon  filters  improved   the  average  removal
   efficiency of the system to 99.99 + 0.01 percent.  The
   high removal  efficiency for MMA was maintained
   after  a 3-fold concentration was delivered to  the
   system (shock loading test), suggesting that a sudden
   increase in  influent MMA concentration had little
   noticeable effect on the technology's performance.

 • The permeate COD reduction efficiencies varied from
   84.7 percent to 95.6 percent, yielding an overall COD
   reduction efficiency of 88.6 + 8.4 percent. COD
   analyses from the treated effluent stream following
   the optional permeate carbon  filters improved  the
   average reduction efficiency of the system to 96.8 +
   5.0 percent. The high reduction efficiency for COD
   was  maintained  after  the shock  loading test,
   suggesting that a sudden increase in influent COD
   concentration  had  little noticeable  effect  on  the
   technology's performance.

 • Due to high MMA concentrations in the influent, the
   laboratory was unable to analyze aqueous TCL VOC
   samples at a low enough dilution factor to quantify the
   low concentrations of TCL  VOCs.   Therefore,
   detection limits were low enough in only  five of 71
   samples  collected  to  quantify  TCL  VOC
   concentrations.  Consequently, removal efficiencies
   for individual TCL VOCs could not be calculated for
   the majority of the samples collected during  the
   demonstration. Reductions of greater than 97 percent
   were  noted  in all TCL  VOCs reported (methylene
   chloride, trichloroethene, benzene, toluene, and o- and
   p- xylenes).

 • Based  on  extrapolation  from  the  air  sample
   concentration data and the flow meter readings,  the
   total volatilization of MMA and TCL VOCs from the
   system calculated  was computed to be about 411
   grams. This value represent less than 0.10 percent of
    the total MMA and TCL VOC mass treated during the
    demonstration.

 •  No major operating problems occurred during the
    SITE demonstration period; no significant changes in
    technology performance were observed during the
    SITE demonstration.

Cost Analysis

Using information obtained from the SITE demonstration,
Zenon, and other sources, a cost analysis examined 12 cost
categories for two different hypothetical applications of
the ZenoGem® technology. Case 1 assumes that a rented,
trailer-mounted system treats groundwater at  a  rate of
1,400 gpd for a  1-year period.  Case 2 assumes that  a
modular (skid-mounted) system will be purchased and
used to treat  leachate at a rate 1,400 gpd  for a 10-year
period.    The cost estimate  assumed  that  the site
hydrogeology and the general types and concentrations of
TCL VOCs were the same as those encountered during the
Nascolite demonstration. Based on these assumptions, the
total costs for Case 1 were estimated to be about $0.50 per
gallon of groundwater treated  and for Case 2 were
estimated to be $0.22 per gallon of leachate treated. The
estimated  Case 1 cost  per gallon is approximately 55
percent higher than the cost per gallon in Case 2, primarily
due to the assumed short length of the remediation period
in Case 1, which limits the volume potentially treated.
Costs for actual applications of the ZenoGem® technology
may vary significantly from these estimates, depending on
site-specific factors.

Super-fund Feasibility Study Evaluation Criteria
for the ZenoGem® Technology

Table  ES-1  briefly  discusses  an evaluation  of the
ZenoGem® technology with respect to the nine evaluation
criteria used  for Superfund feasibility  studies  when
considering remedial alternatives at Superfund sites.

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Table ES-1. Superfund Feasibility Study Evaluation Criteria for the ZenoGem® Technology
                    Criterion
                   Discussion
          Overall Protection of Human
          Health and the Environment
          Compliance with Applicable or
          Relevant and Appropriate
          Requirements (ARAR)
          Long-Term Effectiveness and
          Permanence
          Reduction of Toxicity, Mobility,
          or Volume Through Treatment
          Short-Term Effectiveness
The technology is expected to protect human health and the
environment by degrading organic contaminants in
groundwater to innocuous materials such as carbon dioxide,
methane, water, inorganic salts, microbial biomass, and other
by-products that are less hazardous than parent materials.
The technology's ability to comply with existing federal, state,
or local ARARs should be determined on a site-specific basis.
The treated effluent was accepted for discharge by the local
publicly owned treatment works during the Nascolite
demonstration.
Human health risk can be reduced to acceptable levels by
treating groundwater to site-specific cleanup levels; the time
needed to achieve cleanup goals depends primarily on
contaminant characteristics and system flow rates.
The results of a shock-loading test indicated that the
technology resisted upsets due to instantaneous increases in
MMA and COD concentrations in the influent stream. MMA
and COD removal efficiencies remained greater than 95
percent in the treated effluent.
The mixed liquor is retained in the bioreactor for sufficient time
to allow the microorganisms to degrade the biodegradable
organic contaminants into innocuous materials such as carbon
dioxide, water, inorganic salts,  microbial biomass, and other
by-products that are less hazardous than parent materials.
Zenon can reduce the volume of waste sludge for disposal by
continuously recirculating the contents through the
ultrafiltration module.  This procedure dewaters and
concentrates the sludge, yielding a smaller volume for
disposal.
The results of the demonstration indicate that the technology
degrades MMA, TCL VOCs, and reduces COD.	

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Table ES-1. Superfund Feasibility Study Evaluation Criteria for the ZenoGem® Technology (continued)
                      Criterion
              Discussion
            Implementability
           Cost
           Community Acceptance
           State Acceptance
The actual amount of space required for the ZenoGem®
system depends on the size of the system used. For
the Nascolite demonstration, the pilot-scale system was
housed in a transportable trailer. The trailer requires a
12-foot by 60-foot area to support a maximum operating
weight of 45,000 pounds.
The site must be accessible to typical construction
equipment and delivery vehicles.
Additional space (beyond the 720 square feet required
for the treatment technology) is required for optional
untreated and treated groundwater storage tanks, and a
drum staging area for generated wastes.  Additionally, a
building or shed is useful to protect supplies. Other
installation and monitoring requirements include
security fencing and access roads for equipment
transport.
The ZenoGem® technology is not designed to operate
at temperatures near or below freezing.  If such
temperatures are anticipated, the technology and
associated storage tanks should be installed in a
climate-controlled environment. In addition,
aboveground piping to the technology must be
protected from freezing.
The ZenoGem® technology requires 460-volt, 3-phase,
60-hertz, 30-ampere electrical service.
A rented system operating for a 1-year period results in
total fixed and variable costs of about $263,800. This
total results in a cost of $0.50 per gallon treated. A
purchased system operating for a 10-year period results
in total fixed and variable costs of about $1,200,000.
This total results in a cost of $0.22  per gallon treated.
This criterion is generally addressed in the record of
decision after community responses are received during
the public comment period.  However, because
communities are not expected to be exposed to harmful
levels of VOCs,  noise, or fugitive emissions, community
acceptance of the technology is expected to be
relatively high.
This criterion is generally addressed in the record of
decision; state acceptance of the technology will likely
depend on the long-term effectiveness of the
technology.	

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                                             Section 1
                                           Introduction
This  section  describes  the  Superfund  Innovative
Technology  Evaluation  (SITE)  Program  and  the
Innovative  Technology  Evaluation  Report  (ITER);
provides background information on bioremediation and
the  Zenon  Environmental   Systems  Inc.  (Zenon),
ZenoGem® biological  and ultrafiltration  technology;
provides an  overview and  objectives  of the SITE
demonstration; and provides a list of key contacts.

1.1     Description of SITE Program and
        Reports

This section provides information about (1) the purpose,
history, and goals of the SITE Program; and (2) the reports
used to document SITE demonstration results.

1.1.1  Purpose, History, and Goals of the
        SITE Program

The primary purpose of the SITE Program is to advance
the development and demonstration, and thereby establish
the commercial availability, of innovative treatment and
monitoring technologies  applicable to Superfund  and
other hazardous waste sites.  The SITE Program  was
established by the U.S. Environmental Protection Agency
(EPA) Office of Solid Waste and Emergency Response
(OSWER)  and Office of Research and Development
(ORD) in response  to the Superfund Amendments and
Reauthorization Act of 1986 (SARA), which recognized
the  need for an alternative  or  innovative  treatment
technology research and  demonstration program.  The
SITE Program is administered by ORD's National Risk
Management Research Laboratory. The overall goal of
the SITE Program is to carry out a program of research,
evaluation, testing,  development, and demonstration of
alternative or innovative treatment technologies that may
be used in response actions to achieve more permanent
protection of human  health  and  welfare  and  the
environment.

The  SITE  Program  consists of  the  following  four
programs: (1) the Emerging Technology Program, (2) the
Demonstration Program, (3) the Characterization and
Monitoring Program, and (4) the Technology Transfer
Program.  This ITER  was prepared under the SITE
Demonstration Program.

The objective of the SITE Demonstration Program is to
provide reliable performance and cost data on innovative
technologies so that potential users can assess a given
technology's suitability for specific cleanups. To produce
useful and reliable data, demonstrations are conducted at
hazardous waste sites or under conditions that closely
simulate actual waste site conditions.

Information collected during the demonstration is used to
assess the performance  of the technology,  the potential
need for pre- and posttreatment processing  of the waste,
the types of wastes and media that may be treated by the
technology,  potential  operating  problems,  and  the
approximate capital and operating costs.  Demonstration
information also can provide insight into a technology's
long-term operating and maintenance (O&M) costs and
long-term application risks.

Each SITE  demonstration evaluates a  technology's
performance  in treating waste  at  a particular site.
Successful demonstrations of a technology at one site or
on a particular waste does not ensure its success at other
sites of for  other wastes.  Data obtained  from the
demonstration may  require extrapolation to estimate a
range of operating conditions over which the technology
performs satisfactorily. Extrapolation of demonstration
data should be based  on other information  about the
technology,  such as information  available from case
studies.

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Implementation of the SITE Program  is a significant,
ongoing effort involving ORD, OSWER, various EPA
regions,  and  private  business  concerns,  including
technology developers and parties responsible for site
remediation.  The technology selection process and the
Demonstration Program together provide objective and
carefully controlled testing of field-ready technologies.
Innovative technologies chosen for a SITE demonstration
must be pilot- or full-scale applications and must offer
some advantage  over  existing technologies;  mobile
technologies are of particular interest.

1.1.2 Documentation of SITE
       Demonstration Results

The results of each SITE demonstration are reported in an
ITER and  a  Technology Evaluation  Report  (TER).
Information presented in the ITER is intended to assist
Superfund  decision-makers   evaluating  specific
technologies for a particular cleanup situation. The ITER
represents  a critical step  in  the development  and
commercialization of a treatment technology. The ITER
report discusses the effectiveness and applicability of the
technology and analyzes costs  associated  with  its
application.  The technology's effectiveness is evaluated
based on data collected  during the SITE demonstration
and from other case studies.  The applicability  of the
technology is  discussed  in terms  of  waste  and  site
characteristics which could affect technology performance,
material handling requirements, technology performance,
and other factors for any application of the technology.

The purpose of the TER is to consolidate all  information
and records acquired during the demonstration. It contains
both  a  narrative  portion and   tables and  graphs
summarizing the data.  The narrative portion includes
discussions  of demonstration  activities,  as  well  as
deviations from the  demonstration quality assurance
project  plan  (QAPP).   The data  tables and  graphs
summarize  demonstration results relative  to  project
objectives.  The tables also summarize quality assurance
and  quality control (QA/QC)  data and data  quality
objectives.  The TER is not formally published by EPA;
instead, a copy is retained as a reference by the EPA
project manager for responding to public inquiries and for
recordkeeping purposes.
1.2    Description of Bioremediation

Bioremediation is the process by which hazardous organic
materials  are degraded by microorganisms (typically,
heterotropic bacteria and fungi) to innocuous materials
such as carbon dioxide, water, inorganic salts, microbial
biomass, and other by-products that are usually  less
hazardous than parent materials. Biological treatment has
been a major component for many years in the treatment of
municipal and industrial wastewaters.  In recent years,
bioremediation concepts have  been applied  in treating
hazardous   wastes  and  remediating  contaminated
groundwater and soils.  For example, bioremediation has
been used for degrading creosote in wastes from wood
treatment, as well as petroleum hydrocarbons in refinery
wastes, oil spills, and subsurface material contaminated by
fuels from leaking underground storage tanks.

The two processes associated  with bioremediation are
natural  and  enhanced  bioremediation.     Natural
bioremediation technologies, sometimes referred to as
intrinsic bioremediation, depend on indigenous microflora
to degrade contaminants using only nutrients and other
factors that are available in situ. Enhanced bioremediation
technologies,  such  as  the   ZenoGem® technology,
increases biodegradation rates by  supplying nutrients,
oxygen, and other factors that are rate limiting. Examples
of in situ processes include, bioventing, air sparging, and
in-situ biological.   Ex situ processes include  slurry
reactors and prepared beds for soil and  sludges, pile/
composting for soil, and fluidized reactors and wastewater
treatment plants for aqueous wastes.

Generally, the capital  and operating costs  for  actual
applications of bioremediation technologies vary depending
on the types and quantity of organic compounds present,
site conditions, the volume of material to be processed,
and site-specific remediation goals.  However, the main
direct  costs associated with  bioremediation can  be
attributed to transferring the contaminated wastewater to
the  treatment  unit  (typically  a  biological  reactor
[bioreactor] or reaction zone) and supplying oxygen and
nutrients to aerobic treatment  systems.  The estimated
costs  associated  with  the  ZenoGem®  technology are
presented in Section 4.0. The ZenoGem® technology is
discussed in the following section.

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1.3   The ZenoGem® Technology

The ZenoGem® technology integrates aerobic biological
treatment with membrane-based ultrafiltration.   This
innovative system uses  ex situ bioremediation to treat
contaminated groundwater in an enclosed,  suspended
growth  bioreactor.   The  system  uses the ZENON
PermaFlow®  ultrafiltration cross-flow membrane  and
system to seperate virtually all solids from the treated
effluent.  The membrane and system are characterized by
a wide-diameter, series flow, tubular construction.  The
combination of biological treatment with ultrafiltration
proves to be an effective means of not  only degrading
organic compounds but minimizing the amount of waste
solids  that are typically  associated with  biological
treatment. According to Zenon, about 0.1 pound of sludge
is generated per pound of COD removed from the influent
stream. A simplified schematic diagram of the ZenoGem®
system is shown in Figure 1-1.

Zenon claims that the ZenoGem® technology derives an
advantage over  conventional  wastewater  treatment
processes  due to its  membrane-based ultrafiltration
technology.  The ultrafilter not only filters the treated
water prior to discharge and recycles the biological solids,
but also recovers the higher-molecular-weight,  soluble
materials that would otherwise pass through conventional
clarifiers and filters.  These higher-molecular weight
materials  are  returned  to  a  bioreactor  for  further
biodegradation prior to ultimate discharge.  Integrated
biological contactor/membrane separator technology has
developed rapidly in  recent years as improved membrane
chemistries and configurations produced modules  with
higher fluxes and lower potential fouling.

Ultrafiltration is a pressure-driven, cross-flow filtration
process in which the wastewater to be processed flows
tangentially over the  surface of a membrane filter capable
of separating both insoluble materials (bacteria, colloids,
suspended solids) and higher-molecular-weight soluble
materials from the treated water. The threshold size above
which organic compounds are retained by the membrane
and below which they pass through the membrane is called
the molecular size  cut-off.   Zenon  claims that the
molecular size cut-off for the ZenoGem®  technology
ranges from 0.003 microns (u.) to 0.1 \i and depends on the
specific membrane  chemistry.  The typical operating
pressure of an ultrafiltration system is 60 to 70 pounds per
square inch (psi). According to Zenon, the UF membranes
require replacement every 3 years and cleaning is required
when the effluent flow rate is reduced about 20 percent
when compared to the design flow rate of the system.
Additional information on replacement cost is provided in
Section 4.0 - Economic Analysis.

The basic components of the ZenoGem® technology are an
influent holding-equalization  tank, a bioreactor, an  air
blower, a pH buffer tank, a  nutrient solution tank,  an
ultrafiltration module, optional off-gas carbon filters,
optional permeate carbon filters, and feed, process, and
metering pumps.   The technology  components are
computer-controlled and equipped with audible  alarm
indicators  to notify the operator of mechanical and
operational problems.   The  entire  pilot-scale system,
except for  the main air  blower and optional activated-
carbon filters, is  mounted inside  an 8-foot by 48-foot
trailer. The trailer also is equipped with a laboratory that
enables field personnel to evaluate technology performance.

Treatment  begins by pumping wastewater into a 1,000-
gallon, polyethylene, stirred-tank bioreactor that contains
an acclimated microbial culture maintained under aerobic
conditions. The aerobic, suspended-growth environment
is maintained by  diffused aeration, which continuously
mixes  the  bioreactor's  contents,  which  are  known
collectively as mixed liquor. The mixed liquor is retained
in  the  bioreactor  for  sufficient time  to allow  the
microorganisms to metabolize the  biodegradable organic
contaminants into innocuous end-products and intermediate
by-products.

The mixed liquor is pumped from  the bioreactor into  the
pressure-driven ultrafiltration  module. The ultrafiltration
module consists of eight 1-inch-diameter tubes connected
in series and contained in a 12-foot by 4-inch-diameter
polyvinyl chloride (PVC) housing (Figure 1-2). The tubes
support the ultrafiltration membrane, which filters some
of the dissolved contaminants and all suspended solids
from the mixed liquor.

The continuous flow of mixed liquor, primarily consisting
of suspended solids, forms a gel layer on the membrane's
surface. Particles from the gel layer are detached by the
cross-flow water  movement and recirculated into  the
bioreactor. The unfiltered fraction  of the mixed liquor (the
concentrate) also is recycled into the bioreactor so that
higher-molecular-weight organic  compounds are further
degraded and the necessary microorganism concentration
 is maintained for efficient operation. The filtered effluent
(the permeate) flows through optional activated  carbon

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       WASTEWATER
                   FEED
                   PUMP
        INFLUENT
        HOLDING/
       EQUALIZATION
          TANK
              —3-
                METERING
        NUTRIENT   PUMP
        SOLUTION
          TANK
           AIR
          VENT

A             OPTIONAL
              OFF-GAS
              CARBON
           ''  FILTER
                               INFLUENT
                                              CONCENTRATE RECYCLE
       BIOLOGICAL
        REACTOR


        111111111
                       METERING
                         PUMP
pH BUFFER
  TANK
BLOWER
                            AIR
            BIOREACTOR
              EFFLUENT
                                                PROCESS
                                                 PUMP
                                                                                   TREATED
                                                                      PERMEATE     EFFLUENT
                               PERMAFLOW®     °P™™,L
                             ULTRAFILTRATION
                                MODULE
                                                                                          TRFATFD
                                                                                          pppmPMT
                                                                                          EFFLUENT

                                                                                            TANK
Figure 1-1. ZenoGem system.

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         1-INCH-DIAMETER TUBES

                           ULTRAFILTRATION MEMBRANE
                                                  POLYVINYL CHLORIDE HOUSING
                    INTERNAL SERIES FLOW RETURN IN
                       FREE-FLOATING HEADER DESIGN
                                                                       PERMEATE
                                                                      OUTLET PORT
                                                                                                     BIOLOGICALLY
                                                                                                   TREATED EFFLUENT
                                                                                                      INLET PORT
                                                                                              CONCENTRATE
                                                                                              OUTLET PORT
Figure 1-2. ZENON PermaFlow* ultrafiltration module.

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filters to remove any nonbiodegradable and trace organic
compounds before final treated effluent is discharged.

1.4   Overview and Objectives of the
       SITE Demonstration

This section provides an overview of the demonstration
site and  SITE Program demonstration  objectives and
procedures.

1.4.1 Description ofNascolite Site

The SITE  Program demonstration of  the ZenoGem®
technology was  conducted  at  the  Nascolite  site in
Millville, Cumberland County, New Jersey. Nascolite
manufactured aery late plastic sheets at the site from 1953
to 1980. The company used methyl methacrylate (MMA)
monomer as a raw material  and operated a MMA
reclamation process.  Solid acrylic, liquids, and resins
containing MMA were purchased from outside sources.
These materials were processed through depolymerization,
using a molten lead bath followed by  distillation and
purification. Waste residue from the distillation processes
was stored in several underground storage tanks in the
northern plant area. In 1985, a remedial investigation and
feasibility study (RI/FS) at the Nascolite site revealed that
groundwater was contaminated with MMA, various other
target compound list (TCL) volatile organic compounds
(VOC),  and  heavy  metals.    Table  1-1  presents
groundwater characterization data for the Nascolite site.

1.4.2 SITE Demonstration Objectives

EPA established primary and secondary objectives for the
SITE demonstration of the ZenoGem® technology.  The
objectives were based on EPA's understanding of the
technology,  SITE Demonstration  Program goals, and
input from Zenon.  Primary objectives were considered
critical for the technology evaluation, while secondary
objectives involved collecting additional  data considered
useful, but not critical to the process evaluation.   The
demonstration objectives were defined in the EPA-
approved QAPP dated November 1994 (EPA 1994). The
objectives were selected to provide potential users of the
ZenoGem® technology with technical  information to
determine  if the technology  is  applicable to  other
contaminated  sites.   The SITE demonstration  was
designed to address one  primary objective and two
secondary objectives for evaluation  of  the ZenoGem®
technology.
Primary Objective

The  following was the primary (P) objective of the
technology demonstration:

 • PI - Determine if the ZenoGem® treatment system
   (integrating the bioreactor and ultrafiltration unit as a
   whole) can achieve a 95 percent or greater removal
   efficiency for MMA and TCL  VOCs and reduce
   chemical oxygen demand (COD) at a 95  percent
   confidence level.

The primary objective addressed the biodegradation of
TCL VOCs. For the SITE demonstration, critical TCL
VOCs were MMA, vinyl chloride, benzene, toluene,
ethylbenzene,   cis-l,2-dichloroethene,  trans-1,2-
dichloroethene, trichloroethene, acetone, carbon disulfide,
and styrene. These TCL VOCs  were chosen  as critical
parameters because they have been previously detected in
the Nascolite site groundwater at significant concentrations.

Secondary Objectives

The following were the secondary (Sc) objectives of the
demonstration:

 • Scl -  Evaluate  system performance by measuring
   system parameters that will provide data on operating
   ranges, reliability, variability, cost-effectiveness, and
   full-scale remediation potential.

 • Sc2 - Estimate approximate capital and O&M costs
   for the demonstration and for full-scale remediation.

Critical measurements consisted of sample analyses and
process measurements that directly impacted meeting the
project's  primary  technical   objective.    Critical
measurements included collection of (1) liquid and air
samples for MMA and TCL VOC analyses;  (2) liquid
samples to evaluate COD; and (3) flow rate measurements
of the influent and  effluent liquid streams.   Flow rate
measurements  were used to calculate  the ZenoGem®
system's total reduction of MMA, TCL VOCs, and COD
concentrations between the influent and effluent streams.

Noncritical, or system condition measurements, provided
information on operating ranges, reliability, variability,
cost-effectiveness, and full-scale remediation potential of
the technology.  System measurements included sample
collection and laboratory analyses for the following: total
suspended solids (TSS), volatile suspended solids (VSS),
                                                   11

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Table 1-1. Maximum Concentrations of TCL VOCs Detected in Groundwater at the Nascolite Site
                                Contaminant
   Maximum Concentration
  	fog/U	
                                    MMA
                                  Benzene
                                  Toluene
                                Ethylbenzene
                            cis-1,2-Dichloroethene
                          trans-1,2-Dichloroethene
                               Trichloroethene
                        Total vinyl/methylene chloride
                                Total xylene
                                  Acetone
                               Carbon disulfide
                                   Styrene
           398,000
             400
            1,100
            7,300
             540
             540
             460
            19,200
             150
          1,900,000
            1,200
             150
total  metals  (metals), total  organic  carbon  (TOC),
nutrients (ammonia [Nty, nitrate/nitrite [NO3VNO2-], and
phosphate [PO4'3]),  oxygen (O2), and carbon  dioxide
(CO2). System measurements also included measurements
for pH, dissolved oxygen (DO), temperature, oxidation/
reduction potential (ORP), and specific gravity.

To  monitor  the   ZenoGem®  technology,   process
measurements were collected from various points in the
system. The process measurements included flow rates of
aqueous and  gaseous streams, tank levels within the
system and outside the system, and power consumption
readings.   Gaseous  and  aqueous flow  rates  were
considered critical parameters.    All other  process
measurements were considered noncritical. Figure 1-3
presents a schematic showing sampling and measurement
locations for the ZenoGem® technology.

Information regarding the specific purpose  of each
demonstration objective, and a summary of the sampling
locations and analytical parameters used to support each
objective, are presented hi Table 1-2.

1.4.3 Demonstration Procedures

The SITE Program evaluated the treatment technology's
effectiveness over a period of about 3 months by collecting
independent data.   Data collection procedures for the
demonstration were specified in the EPA-approved QAPP
written  specifically  for  the ZenoGem®  technology
demonstration (EPA 1994).

Predemonstration activities included drilling of four soil
borings  and  subsequent  installation of  groundwater
recovery wells to pump contaminated groundwater to the
ZenoGem® system.  The wells  were equipped  with
individual peristaltic pumps for evacuating and transferring
groundwater from the  wells to  a equalization tank.
Groundwater in the equalization tank was periodically
sampled  during pumping operations and analyzed for
MMA concentration using an on-site gas chromatograph
(GC). The analytical results were used to determine if the
groundwater required dilution to achieve the influent
target MMA concentration of 2,500 milligrams per liter
(mg/L).  When analytical results confirmed that the MMA
concentration was slightly greater than 2,500 mg/L, the
groundwater was pumped to a 5,000-gallon tanker, and
through a piping network into the system for treatment.

After the  ZenoGem®  system was  installed, Zenon
performed a series of technology checks which included
(1) conducting a leak test of technology components and
process  pipes,  (2) verifying that component  safety
switches were operating accurately, and (3) calibrating
flow meters and metering pumps. For the leak test, Zenon
initially filled the bioreactor with about 600 gallons of
potable  water which was pumped through the entire
treatment process to ensure the technology was operating
                                                   12

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                                              AIR
                                              VENT
          WASTEWATER
OPTIONAL
OFF-GAS
CARBON
 FILTER
                                                    CONCENTRATE RECYCLE
            INFLUENT
            HOLDING/
          EQUALIZATION
              TANK
         METERING
           PUMP
                                           BIOLOGICAL
                                            REACTOR
         pH BUFFER
           TANK
                                                BIOREACTOR
                                                  EFFLUENT
   PROCESS
    PUMP
            NUTRIENT   PUMP
            SOLUTION
             TANK
                                 AIR
                         PERMAFLOWr
                       ULTRAFILTRATION
                           MODULE

(S)  SAMPLING LOCATION

(M)  PROCESS MEASUREMENT LOCATION
                                                                                          TREATED
                                                                                         EFFLUENT
                                                                                                -*
                                                                                    OPTIONAL
                                                                                    CARBON
                                                                                     FILTER
                                               TREATED
                                               EFFLUENT
                                               HOLDING
                                                TANK
Figure 1-3. Sampling locations.

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Table 1-2. Analytical Measurement Parameters and Relationship to Project Objectives
            Matrix
 Sampling
 Location
          Parameter
  Class     Objective
        Feed Influent     S-1
        Bioreactor
        Effluent
        Concentrate
        Recycle
        Permeate
        Effluent
S-2
S-3
S-4
        Treated Effluent   S-10
        Nutrient Feed     S-5
        Bioreactor Inlet   S-6
        Gas

        Bioreactor       S-7
        Outlet Gas

        Bioreactor       S-9
        Outlet Gas
        (after carbon)
        Air Inlet         S-8
                                                                   Critical
            TCL VOCs+MMA, COD, Flow Rate   Critical
pH, TSS, VSS, DO, temperature,
metals, TOC, ORP, sg, NO3VNO2-,
NH3, P04"3

TCL VOCs+MMA, COD

pH, TSS, VSS, DO, temperature,
metals, TOC, ORP, sg, NO3VNO2-,
NH3, PO^, Flow Rate

TCL VOCs+MMA, COD

pH, TSS, VSS, DO, temperature,
metals, TOC, ORP, sg, NO3VNO2-,
NH3, POf, Flow Rate
           P1,Sc1,
           Sc2
Noncritical   Sc1, Sc2
           P1,Sc1
Noncritical  Sc1
Critical     P1

Critical     P1, Sc1

Noncritical  Sc1
TCL VOCs+MMA, COD, Flow Rate   Critical
            pH, TSS, VSS, DO, temperature,
            metals, TOC, ORP, sg, NO3YNO2-,
            NH3, PO^

            TCL VOCs+MMA, COD
            pH, TSS, VSS, DO, metals, TOC,
            ORP, sg, N03YN02-, NH3, PO/3

            NO3YNO2-, NH3, PO4'3, sg, Flow
            Rate

            TCL VOCs+MMA, Flow Rate
            02, C02

            TCL VOCs+MMA, Flow Rate
            02, C02

            TCL VOCs+MMA, Flow Rate
             TCL VOCs+MMA, O2, CO2, Flow
             Rate
            P1,Sc1,
            Sc2
Noncritical   Sc1
                                Critical      P1,Sc1
                                Noncritical   Sc1
                                                                   Noncritical   Sc1,Sc2
                                                                   Critical
                                           P1,Sc1
                                Noncritical   Sc1
                                Critical      P1,Sc1

                                Noncritical   Sc1
                                Critical      P1,Sc1
                                Noncritical   Sc1
                                                14

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properly. During the test, SITE Program personnel did not
observe  any  leaks  and Zenon  confirmed that the
component safety switches were operating correctly.

Zenon seeded the  bioreactor by pumping into it 500
gallons of sludge obtained from the local publicly owned
treatment works (POTW). Zenon then added 5 gallons of
MMA-acclimated  sludge to  the  bioreactor.   Zenon
cultivated the biomass to obtain a maximum microbial
growth while maintaining a minimum toxic shock to the
microorganisms. In addition, Zenon periodically added
powdered milk and wheat flour as food sources for the
microorganisms until the contaminated groundwater was
available for treatment.

A start-up run was conducted prior to beginning the
demonstration run.  The purpose of the start-up run was to
identify  and resolve  any problems that  arose  from
technology operation or sampling and field protocols. No
samples were sent for off-site analysis during the start-up
run.  The initial effluent flow rate of the treatment system
established for the entire demonstration was 720  gallons
per day.

1.5    KEY CONTACTS

Additional information on the ZenoGem® biological and
ultrafiltration technology, Zenon, the SITE Program, and
the Nascolite site is available from the following sources:

EPA Project Manager
Daniel Sullivan
U.S.  Environmental  Protection   Agency  (MS-104)
National Risk Management Research Laboratory
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
908/321-6677

Technology Developer
F. Anthony Tonelli
Zenon Environmental Inc.
845 Harrington Court
Burlington, Ontario, Canada L7N 3P3
905/639-6320
Information on the SITE program is available through the
following on-line information clearinghouse: the Vendor
Information System for Innovative Treatment Technologies
(VISITT)  (Hotline:  800-245-4505)  database  contains
information on 154 technologies offered by 97 developers.

Technical reports may be obtained by contacting U. S.
EPA/NCEPI, P. O. Box 42419, Cincinnati, Ohio 45242-
2419, or by calling 800-490-9198.
                                                   15

-------
                                             Section 2
                           Technology Effectiveness Analysis
This section addresses the effectiveness of the ZenoGem®
technology for treating groundwater contaminated with
MMA  and  TCL  VOCs.   This evaluation of  the
technology's effectiveness is based on the results of the
SITE demonstration at the Nascolite site.

Vendor claims and case studies regarding the effectiveness
of the ZenoGem® biological and ultrafiltration technology
are presented in Appendix A.  Tables summarizing the
field and laboratory analytical data for samples collected
during the demonstration are included in Appendices B
and C, respectively.

2.1    SITE Demonstration Results

This section summarizes the  results  from the  SITE
demonstration of the ZenoGem®  technology for both
critical and noncritical  parameters,  and is organized
according to the project objectives stated in Section 1.4.2.
Section 2.1.1 addresses the primary objective, and Section
2.1.2 address secondary objectives.

The ZenoGem® technology treated about 47,200 gallons
of groundwater contaminated with MMA, at flow rates
ranging from 380 to 620 gpd. As shown in tables B-4 and
B-5 in Appendix B, the total inflow to the treatment system
was significantly less than the total outflow from the
system.  According  to Zenon, the difference in these
values may be due to the effluent flow meter recording the
permeate that was at times being recirculated back to the
bioreator. Zenon periodically recirculates the permeate
when making process adjustments prior to discharge from
the system.  The demonstration consisted of continuous
operation over a 3-month period, during which influent
MMA concentrations varied from 567 mg/L to
9,500 mg/L.

For the last 3 weeks of the demonstration, the technology
was evaluated under an approximate three-fold increase in
contaminant concentration shock-loading, which increased
the influent MMA concentration from 2,360 mg/L to
7,140 mg/L (Figure 2-1). During the first 4 hours of the
test, the influent MMA concentrations were increased
while the feed rate remained at 720 gpd, creating a short-
term organic shock-load to the microorganisms in the
bioreactor. After 4 hours, the feed flow rate was decreased
to 50 gpd, and then increased to 140 gpd to maintain a
constant volumetric  organic  loading throughout the
remainder of the demonstration.

2.1.1  Objective P-1: Removal
       Efficiencies

This section describes demonstration removal efficiencies
for MMA, TCL VOCs, and COD. Removal efficiencies
for each compound or parameter was evaluated over the 3-
month  demonstration  (September,  October,  and
November). In cases  where effluent concentrations of a
compound were nondetectable, the detection limit value
(for example  0.01 mg/L for MMA), rather than an
assumed concentration of 0.00 mg/L, was used to calculate
the minimum  removal efficiency.  This  conservative
practice was adopted to ensure that the removal efficiency
would not be overestimated, and assumes that a compound
not detected in the effluent at 0.01 mg/L may have  been
present at a concentration between 0.00 mg/L and 0.01
mg/L.  For this reason, the removal efficiencies values for
the compounds and parameters are the minimum possible
values and may be  lower  than the actual  removal
efficiencies achieved by the system.

MMA  Results

Effluent MMA concentrations during the demonstration
varied from less than the detection limit of 0.01 mg/L to
 16.8 mg/L in the permeate stream (S-4).   As shown in
Figure 2-2, the permeate MMA  removal efficiencies
during the demonstration  consistently surpassed the
                                                   16

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                      02-Sep   12-Sep   23-Sep  03
-------
and (2) the goal of a 95 perent reduction was maintained by
the system throughout the 3-month demonstration.

TCL VOC Results

TCL VOCs analyzed in samples collected from  the
influent and effluent streams during the demonstration
included vinyl chloride, benzene, trans- 1 ,2-dichloroethene,
trichloroethene, acetone, carbon disulfide, ethylbenzene,
toluene, and styrene. The laboratory reported all other
quantified analytes from the TCL; however, tentatively
identified compounds were not reported.

Due to the high MMA concentrations in the influent, the
laboratory was unable  to  analyze aqueous TCL VOC
samples at a low enough dilution factor to quantify the low
concentrations of TCL VOCs without overloading the GC.
Most TCL VOC detection limits in the influent ranged
from about 2,500 to 500,000 micrograms per liter Og/L),
depending  on the dilution ratio.  In samples that  had
detection limits this high, no targeted TCL VOCs were
above  detection  limits  in the  influent stream (S-l).
Detection limits were low enough in only five of the 71
samples collected to quantify TCL VOC concentrations.
Consequently, removal efficiencies for individual TCL
VOCs could not  be calculated for the majority of the
samples collected during the demonstration.

Table  2-1 compares  the five  influent samples with
reportable TCL VOC concentrations in samples collected
from sampling port S-l to the corresponding TCL VOC
concentrations in samples collected from sampling port S-
4. Reductions of greater than 97 percent were noted in all
TCL VOCs reported.

 Mass Balance

The primary objective (PI) of the demonstration was to
 show that the ZenoGem® process was able to achieve 95
 percent removal efficiency of the  total influent mass of
 MMA and TCL VOCs (EPA 1994), using the following
 equation:
%RE =
                            i - nviMA+voa x 100
                      (MMA+VOC),
 where:
        %RE = Removal efficiency
        (MMA + VOC),= Total mass in influent stream
        (MMA + VOC) = Total mass in effluent stream
                                            Total influent mass was calculated from the daily MMA
                                            and TCL VOC concentrations in the influent stream (S-l)
                                            and the average of the three daily flow measurements,
                                            collected at measurement location M-l, multiplied over a
                                            24-hour period, accounting for periods when the system
                                            was not operating. Effluent mass was calculated from the
                                            S-4 and S-10 streams in the same manner.

                                            The following equation was used to calculate the total
                                            mass of MMA and TCL VOCs for both the influent and
                                            effluent streams:
                                                               83
                                                    M.
                                                     •(MMA+VOC)
                                             where:
       M, M4 vnm = Total mass of MMA and TCL VOCs
         (MMA+VUCJ
       Q.= Average daily flow, in liters
       [x] = Daily MMA+TCL VOC
       concentration (mg/L)
       83 = Number of samples

Based on extrapolation from the sample concentration
data and flow meter readings, the total mass of MMA and
TCL VOCs entering the system during the demonstration
was about 561,000 grams and the mass of MMA and TCL
VOCs leaving the system after treatment was about 196
grams. Therefore, total mass of MMA and TCL VOCs in
the effluent prior to carbon polishing was reduced at least
99.96 percent. The actual mass reduction may have been
greater, but was indeterminable because the total mass of
TCL VOCs entering the system could not be determined
due to the elevated detection limits.  Table 2-1 indicates
that the average TCL VOC concentration in the influent
was likely to be several orders of magnitude lower than the
MMA  concentration, and thus should have contributed
only a negligible amount to the total influent mass of the
contaminants.

To  determine   if volatilization  to  air  contributed
significantly to the observed mass  reduction efficiency,
the quantity of MMA (Figure 2-3) and TCL VOCs
 (Figure 2-4) lost through the emissions stream (S7) were
determined using the daily air flow measurements
(Figure 2-5) collected at measurement location M7 and the
analytical results of the biweekly air sample. As shown in
Figures 2-3 and 2-4, an increase in MMA and TCL VOCs
concentrations occurred  on the first day of the shock-
loading test and then decreased throughout the remainder
of the demonstration.
                                                   18

-------
Table 2-1. Measured TCL VOC Reductions
Sampling
Date
9/5/94


9/6/94



9/16/94
10/1/94
10/11/94
TCL VOC
Compound
Methylene
chloride
Trichloroethene
Benzene
Methylene
chloride
Trichloroethene
Benzene
Toluene
Methylene
chloride
Methylene
chloride
Xylenes
Influent
Concentration
(S-1)
636
852
282J
618
905
279J
105J
500J
15,300
14.400J
Permeate
Concentration
(S-4)
8.85
1.75J
5.0U
11.6
5.0U
5.0U
5.0U
11.2
5.0U
5.0U
Percent
Reduction8
98.6
99.8
>98.2
98.1
>99.4
>98.2
>95.2
97.8
>99.3
>99.9
             Notes:
                    a Percent reduction measured from permeate stream prior to carbon polishing.
                    All concentrations in micrograms per liter (/^g/L).
                    J = Compound concentration is estimated. Value is below sample detection limit.
                    U = Compound was not detected. Associated number is the sample detection limit.
                                                                   83
Figure 2-5  shows that the daily air flow measurement
remained relatively  low (less  than  5  scfm) during
Sepetember compaired  to  the   remainder  of the
demonstration (about 12 scfm). Although the cause of the
fluctuation  in air flow is unknown, Zenon has process
capability to control the amount of oxygen supplied to the
bioreactor to maintain organism growth and degradation
of the organic compounds. This finding is not considered
significant since the goal of a 95 perent reduction was
maintained  by the system throughout the  3-month
demonstration.

The  total  mass loss for  each  compound over the
demonstration was calculated by the following:
where:
                   22.4
       M(x) = Total mass of compound x in grams
       Q;=Air flow for i* day, in standard cubic feet (scf)
       [x.] = Volumetric concentration of
              compound x in liters
       mx = Molecular weight of compound x
              in grams/mole
       k = Conversion factor
       83 = number of samples
                                                   19

-------
           14-Sep-94           28-Sep-94



Figure 2-3.  MMA in air (S-7).
                                          12-Oct-94          25-Oct-94
                                                     Date
                                                                                     08-Nov-94          21-Nov-94
   a
    ri
2000


1500


1000


 500


   0
-•- Acetone
-*- Benzene
-±- Meth. Chloride
-g- Toluene
           14-Sep-94      28-Sep-94      12-Oct-94      25-Oct-94      08-Nov-94      21-Nov-94
                                                 Date
Figure 2-4. VOCs in air (S-7).
      20
       15
       10
         02-Sep-94  ll-Sep-94   20-Sep-94  29-Sep-94   08-Oct-94  17-Oct-94   26-Oct-94  04-Nov-94  13-Nov-94  22-Nov-94
                                                           Date


 Figure 2-5. Air flow in emission stream (S-7).
                                                           20

-------
Mass was computed  for  an ideal gas  at  standard
temperature and pressure (STP). Daily flow volume was
determined by using the average of the three daily air
measurements (in standard cubic feet per minute [scfm])
and multiplying over a 24-hour period, accounting for
periods when the system was temporarily shutdown. The
daily volumetric concentration of each compound was
calculated by interpolation from the biweekly analytical
results.

Based on extrapolation from the air sample concentration
data and the flow meter readings, the total volatilization of
MMA and TCL VOCs from the system was calculated at
about 411 grams.   This values represents less than 0.10
percent of the total MMA and TCL VOC mass treated
during the demonstration.

COD Results

During the course  of the demonstration, influent COD
concentrations varied from 1,490 mg/L to 13,600 mg/L.
COD concentrations  in the  permeate (S-4)  varied from
10.3 mg/L to 1,880 mg/L, and COD concentrations in the
treated effluent stream (S-10) ranged from 56.0 mg/L to
1,090 mg/L. Figure 2-6 shows the removal efficiencies for
the permeate stream (S-4). Based on these data, reduction
efficiencies for COD calculated for the permeate stream
(S-4) varied from 84.7 percent to 95.6 percent, yielding an
overall COD reduction efficiency of 88.6 + 8.4 percent.
Data for the S-10 treated, or final, effluent stream was not
generated until week 7. of the demonstration. Figure 2-7
shows the reduction efficiencies for the treated effluent
stream (S-10). During 4 out of the 5 weeks, the reduction
efficiencies in the  effluent  were above the 95 percent
demonstration goal and averaged 96.8 + 5.01 percent.

Figure 2-8  compares the reduction efficiencies for  the
permeate stream (S-4) with those observed in the treated
effluent stream (S-10).

During the  last 3 weeks of the demonstration, the system
was evaluated under an approximate three-fold increase in
contaminant   concentration   shock-loading,  which
instantaneously increased the influent COD concentrations
from 6,400 mg/L to 19,600 mg/L. During the first 4 hours
of the test,  the  influent  COD  concentrations  were
increased while the feed rate remained at 720 gpd, creating
a short-term, organic shock-load to the microorganisms in
the bioreactor.   After 4 hours, the flow  rates were
decreased to 50 gpd, and then increased to 140 gpd to
maintain  a  consistent volumetric  organic  loading
throughout the  remainder  of the demonstration.   The
treated effluent (S-10) reduction  efficiency for  COD
following the shock loading was calculated at 98.8 + 0.64
percent.

2.1.2 Objective S-1: Total Metals, TSS,
       VSS, TOO, ORP, sg, DO,
       Temperature, pH, Nutrients

This section presents the results of measurements for
secondary parameters of interest for the demonstration.

Metals

Table 2-2 summarizes the average aluminum, cadmium,
chromium, copper,  iron,  lead, manganese, mercury,
nickel, and zinc concentrations detected in the influent
(S-1), permeate (S-4), and treated effluent (S-10) streams.
As shown in Figures 2-9 through 2-18, the concentration
of metals in the S-1 stream exhibited substantially higher
concentrations than that detected in the S-4 and S-10
streams, with the exception of some sample results that are
anomalous.  Metal concentrations increased throughout
the demonstration in the bioreactor effluent (S-2) and the
concentrate stream (S-3). This indicates that the majority
of metals in the S-1 stream were retained and accumulated
throughout the demonstration with the  exception  of a
small percentage of the metals that passed through the
ultrafiltration module and were detected  in the permeate
and treated effluent streams. At these concentrations, the
metals did not appear to  inhibit the microorganisms
degradation rate for MMA and TCL VOCs. Depending on
wastewater   characteristics,  pretreatment  can  be
incorporated into  the treatment train to reduce metal
accumulation in the system.

TSS

Figure 2-19 shows the TSS concentrations measured in the
influent (S-1), permeate (S-4), and treated effluent (S-10)
streams during the demonstration. The TSS concentration
in the influent stream exhibited higher concentrations than
that detected in the permeate and treated effluent streams.
On November 12,  the  influent  TSS concentration
increased from 43 mg/L to 19,000 mg/L. Although the
cause of this anomalous value is unknown, the increase in
concentration may be due to not thoroughly mixing the
groundwater in the holding tank prior to transferring to the
                                                   21

-------
    120


 §  100


 o:   80


 a>   60
                      Demonstration Goal
                                  ;ox
       02-Sep-94     15-Sep-94    29-Sep-94    11-Oct-94    24-Oct-94
                                              Date
                                                                          04-Nov-94    17-Nov-94
Figure 2-6. COD removal efficiency (S-4).
105


100

 95

 90

 85

 80
      1
          75
                  Demonstration Goal
                                 95%
            02-Sep-94
15-Sep-94       29-Sep-94
                                                  11-Oct-94
                                                Date
                                                                           24-Oct-94
14-Nov-94
Figure 2-7.  COD removal efficiency (S-10).
     i
         2
      3.  o


II 1 1
i i 1 illHmM


i,





In


1




••S-4
S-10

   50.00        60.00        70.00        80.00        90.00
                                      Percent Removal
                                                                         100.00
Figure 2-8. Distribution of COD removal efficiency by number of samples (S-4 and S-10).
                                                     22

-------
        Table 2-2. Total Metals Concentrations
to
Metal
Aluminum
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel .
Zinc
Influent Stream
S-1
514
82.7
8.3
6.86
21,400
222
170
0.11
19.3
2,120
Permeate
Stream
S-4
106
1.62
2.9
4.8
149
10.5
32.2
1.18
8.7
131
Treated
Effluent Stream
S-10
65.7
—
—
3.9
28.6
11.1
10.2
—
2.6
29.0
Influent Stream
S-1
Concentration
Range
220-1,100
40-150
3.5-16
3.1-8.5
9800-36,500
110-330
84-290
0.055-0.13
10-31
810-4,100
Permeate
Stream S-4
Concentration
Range
12.8-160
1.1-2.9
0.08-5.6
0.9-9.8
40-220
3.6-16
7.9-60
0.075-3.3
0.04-36
71-240
Treated
Effluent Stream
S-10
Concentration
Range
0.07-120
0.8
5.3
0.01-9.7
0.04-59
9.1-13
0.01-27
0.042
0.01-5.1
0.01-51

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          100000

           10000

            1000
     g
     g .-;.    100

     I I    10

     «        1

             0.1

            0.01
                                                     _Q
                                                                                                      1000
Date
a SI
• b-4
Db-10
02-Sep
9,800
40
NA
16-Sep
17,100
64
NA
30-S«p
15,400
200
NA
14-Oct
21,500
218
NA
20-Oct
NA
NA
0.2
27-Oct
NA
NA
0.04
28-Octj08.Nov
18,60036,500
130 I 160
69 | 46
09-Nov
34,000
63
120
23-NOV
NA
78
NA
28-Nov
NA
NA
600
Date
• S-i
• S-4
OS-It)
02-Sep
140
ND
NA
16-Sep
160
9.4
NA
30-Sep
220
ND
NA
ira«i
200
3.6
NA
20-Oct
NA
NA
NO
27-Oct
NA
NA
ND
2B-Oct
180
16
ND
JB-Nov
300
ND
9.1
99-Nov
330
ND
ND"
23410V
NA
ND
NA
21-Nov
NA
NA
ND
to
Figure 2-13. Iron concentrations in the S-1, S-4, and S-10 streams.
                                                                                           Figure 2-14.  Lead concentrations in the S-1, S-4, and S-10 streams.
                       300
                  o    200

                  1?

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                  I    10°
             TSafe"
              rsr
                                               "RA"
                            02^ep|16.SeppO.Sep]14Oct|20-Oct|27Oct|28OctBB.Novi09-Novl23-Nov)25.Nov
                                                    TR"
                                                    TR"

                                                                           TCT
                                                                                                        10
                                                                                  Date
                                                                                  WSFT
                                                                                    •g3~
                                                                                  oS-10
                                                                                                      0.01
                                                                                                              I
                                                                                                            02-Sep
 ~m
"OJ57B"
                                                                                                             T1A~
                                                                                                                 16-Sep|30-Sep|14-Oct|20gct
                                                                                                                  0.130
      "S/fSS
       m
                                                                                                                       OTW
UD^
"W
                                                                                                                            0/130
                                                                                                                            3.300
                                                                                                                            TOT
                                                                                                                                 •R7T
TCT
~ND'
                                                                                                                                      27-Oct|28-Oct|08-Nov
                                                                                                                                       NA
W
"ND
                                                                                                                                           0.055
                                                                                                                                           Tnr
                                                                                                                                                 ND
                                                                                                                                                ND
                                                                                                                                                     0;140
                                                                                                                                                     0.045
                                                                                                                                                 1
                                             |23-Nov|28-Nov
                                                                                                                                                           NA
                                                                                                                                                          0.052
                                                                                                                                                                NA
                                                                                                                                                                NA
         Figure 2-15. Manganese concentrations in the S-1, S-4, and S-10 streams.     Figure 2-16.  Mercury concentrations in the S-1, S-4, and S-10 streams.

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-------
 bioreactor using a submersible pump. This finding is not
 considered significant since (1) the temporary increase in
 TSS concentration was maintained for only one day, and
 (2) the increase in concentration was not reflected in the
 effluent stream. TSS concentrations increased throughout
 the demonstration in the bioreactor effluent (S-2) and the
 concentrate stream (S-3). This indicates that the majority
 of suspended solids in the influent stream were retained
 and  accumulated  in   the   system  throughout  the
 demonstration.   The technology demonstrated that the
 ultrafiltration module was effective in reducing TSS from
 an average concentration in the influent stream of 507
 mg/L to  less than 2 mg/L (the detection limit) in the
 permeate and treated effluent streams, respectively. The
. TSS removal efficiency was calculated to be 99.7 percent.

 vss

 Figure 2-20 shows the VSS concentrations measured in
 the influent (S-l), permeate (S-4), and treated effluent
 (S-10)  streams during  the demonstration.   The VSS
 concentration in the influent stream exhibited higher
 concentrations than  that detected in the permeate and
 treated effluent streams.  On November 12, the influent
 VSS concentration increased from 34 mg/L to 17,000
 mg/L.  Although the cause of this  anomalous value is
 unknown, the increase in concentration may be due to not
 thoroughly mixing the groundwater in the holding tank
 prior to transfering to the bioreactor using a submersible
 pump.  This finding is not considered significant since (1)
 the temporary  increase  in  VSS  concentration  was
 maintained for only one day, and  (2) the increase in
 concentration was not reflected  in the effluent stream.
 VSS concentrations increased throughout the demonstration
 in the bioreactor effluent (S-2) and the concentrate stream
 (S-3).   This indicates that the majority of VSS in the
 influent stream were retained and  accumulated in the
 system during the  demonstration.  The   technology
 demonstrated that the ultrafiltration module was effective
 in reducing VSS   from an average concentration in the
 influent stream of 452 mg/L to less than 2 mg/L in the
 permeate  and treated effluent streams, respectively.  The
 VSS removal efficiency was calculated to be 99.7 percent.

 TOC

 Figure 2-21 shows the TOC concentrations measured in
 the influent (S-l), permeate (S-4), and treated effluent
 (S-10)  streams during the demonstration.   The  TOC
 concentrations  in the influent stream exhibited higher
 concentrations  than that  detected in the S-4 and  S-10
 streams, indicating that the concentration of organic
 matter was reduced in the  system. The average TOC
 concentrations for the S-1, S-4, and S-10 stream was about
 1,160 mg/L, 280 mg/L, and 83 mg/L, respectively.  The
 TOC removal efficiencies was calculated for the permeate
 stream to be 75.9 percent and for the treated effluent
 stream to be 92.8 percent.

 ORP

 Figure 2-22 shows the values measured in the influent
 (S-l),  bioreactor  effluent  (S-2),  concentrate  (S-3),
 permeate (S-4), and treated effluent (S-10) streams. A
 difference  in ORP  values occurred in  the  system as
 influent groundwater went from an oxidizing to a reducing
 environment during treatment.  This resulted in positive
 values in the influent (S-l), permeate (S-4), and treated
 effluent  (S-10) streams  and negative values for the
 biological effluent (S-2) and concentrate (S-3) streams.
 Positive  values in the influent,  permeate, and  treated
 effluent streams are due to an oxygen rich environment in
 the absence of a microorganism population. Negative
 values in the bioreactor effluent and concentrate stream
 are  due to microorganisms  consuming  the  oxygen
 necessary to maintain biological degradation.

 Specific Gravity

 The specific  gravity  of the groundwater remained
 unchanged  during the  demonstration.   The average
 specific gravities calculated  for the influent (S-l), the
 permeate (S-4), and the treated effluent (S-10) streams
 were about 1.0. Specific gravity is temperature dependent
 and will vary with the concentration of total solids in the
 wastewater.
DO
The  average concentration of DO in  the groundwater
during the demonstration was measured as 3.92 mg/L for
the influent (S-l) stream and 3.12 mg/L for the permeate
(S-4) stream.  Data for the treated effluent (S-10) stream
were only sampled  during  the last  month  of  the
demonstration; the average concentration of DO in this
stream was determined to be 3.93 mg/L.

Temperature

The  average temperature of the groundwater during the
demonstration was measured at 24.4° C for the influent (S-
1) stream and 33.6° C for the permeate (S-4) stream. The
                                                    27

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           a
100
 90
 80
 70

 50
 40
 30
 20
 10
  0
9/02/94
                                                                                                              SI
                                          9/23/94
                                       10/14/94
                                    Sampling Dates
                                                                        11/4/94
                                                                     11/25/94
Figure 2-20. VSS concentrations in the S-1, S-4, and S-10 streams. Sample concentrations for S-1 and S-10 significantly
exceeded the upper limit scale in November. Values are presented in Table B-13 in Appendix B.
            1
                     9/2/94        9/23/94         10/14/94         11/4/94
                                                      Date
 Figure 2-21. TOG concentrations in the S-1, S-4, and S-10 streams.
                                                                  11/25/94
              600
                                                               Date
                                                   i S1   c=j S2
                                                 i S3
                                                i S4
                                                                                    S10
 Figure 2-22.  ORP in the five streams.
                                                          28

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treated effluent (S-10) stream was determined for the last
month of the demonstration; the average temperature was
21.1° C.  Optimum temperatures for bacterial activity
range from 25 to 35° C.
PH
The average pH values in the influent (S-l), the permeate
(S-4),  and the  treated effluent (S-10)  streams  were
measured at 6.3, 7.0, and 7.9, respectively.  The treated
effluent stream was only measured during the final month
of the demonstration. The pH values in the influent (S-l)
are adjusted in the bioreactor and the pH values in the
permeate  (S-4) and treated effluent (S-10) streams are
unadjusted values and a function of the biodegradation
process.

Nutrients
Concentrations of  NO3-/NO2%  NH,,  PO4'3,  increased
slightly in the system. The average concentration of NR3
increased from 0.13 mg/L in the influent (S-l) stream to
0.34 and 0.59 mg/L for the permeate (S-4) and the treated
effluent (S-10) streams, respectively. The treated effluent
average  was  calculated  with the  exclusion of  an
anomolous value obtained on November 16.
The average concentration of   NO3'/NO2' increased
slightly in the influent (0.48 mg/L) and treated effluent
(1.65 mg/L) streams. However, the average value of the
NO3-/NO2" concentration in the S-4 stream, which was less
than the detection limit (0.05 mg/L), was below the values
collected from the combined S-4 and the S-10  streams.
The two values collected for S-10 were 1 .6 mg/L, and less
than 0.05 mg/L,  indicating that the concentration of the
sample was below detection limits.

The average concentration of PO4'3 increased throughout
the system as shown in the treated, permeate, and treated
effluent streams.   The  average  PO4~3 concentration
increased from 0.08 mg/L in the influent, to 0.64 mg/L in
the permeate, to 0.94 mg/L in the treated effluent.
                                                   29

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                                             Section 3
                           Technology Applications Analysis
This section discusses  applicability of the ZenoGem®
technology, including the following: applicable waste,
factors affecting performance, site characteristics and
support requirements, material handling requirements,
technology limitations, potential regulatory requirements,
and state and community acceptance. The information in
this  section  is  based on  the results  of the  SITE
demonstration, as well as additional information provided
by Zenon and other parties.

3.1    Applicable Waste

Zenon claims that the technology is designed to remove
biodegradable organics from wastewater streams, leachates,
impoundments, and  underground storage tanks.   The
typical  wastewater stream consists of high organic,
biological oxygen demand (BOD), and COD concentrations
that  may  contain  oils,   solvents,  surfactants,  and
detergents. According to Zenon, the feed streams that the
technology has  successfully treated  contained  COD
concentrations of 50,000 mg/L, BOD concentrations of
6,000 mg/L,  suspended  solids  of 4,000 mg/L, and
emulsified grease of 2,500 mg/L. Zenon indicated that the
ideal COD to BOD ratio in the wastewater should be 2 to
1. The effluent stream typically has COD concentrations
of 500 mg/L, BOD concentrations of 15 mg/L, suspended
solid concentrations of 10 mg/L, and emulsified total oil
and grease concentrations of 20 mg/L. The waste sludge
stream from the system typically contains a total  solids
concentration of about 30,000 mg/L.

Based on the results  of the SITE demonstration, the
ZenoGem®  technology   is  capable   of  reducing
concentrations of MMA other TCL VOCs, and COD in
 contaminated groundwater.  Appendix  C presents the
 influent concentrations for MMA (tables C-l through
 C-3), COD (tables C-4 through C-6), and VOCs (C-7
 through C-9) for the demonstration.
The permeate MMA removal efficiencies consistently
surpassed the demonstration goal of 95 percent reduction.
The average removal efficiency for MMA was greater
than 99.98 + 0.01 percent for the 3-month demonstration.
MMA analyses from the treated effluent stream following
the optional permeate carbon filters improved the average
removal efficiency of the system to 99.99 + 0.01 percent.
The high removal efficiency for MMA was maintained
after a 3-fold concentration was delivered to the system
(shock loading test), suggesting that a sudden increase in
influent MMA concentration had little noticeable effect on
the technology's performance.

The permeate COD reduction efficiencies varied from
84.7 percent to 95.6 percent, yielding an overall COD
reduction efficiency of 88.6 ±8.4 percent.  COD analyses
from the treated effluent stream following the optional
permeate carbon filters improved the average reduction
efficiency of the system to 96.8+  5.0 percent The high
removal efficiency for COD was maintained after a shock
loading test, suggesting that a sudden increase in influent
COD concentration had little noticeable effect  on the
technology's performance.

Due to high MMA concentrations  in the influent, the
laboratory was unable to analyze aqueous TCL VOC
samples at a low enough dilution factor to quantify the low
concentrations of TCL VOCs. Therefore, detection limits
were low enough in only five of 71 samples collected to
quantify  TCL  VOC concentrations.   Consequently,
removal efficiencies for individual TCL VOCs could not
be calculated for the majority of the samples collected
during the demonstration. Reductions of greater than 97
percent were noted in all TCL VOCs reported (methylene
chloride,  trichloroethene,  benzene, toluene,  and o+p
xylenes).
                                                    30

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 3.2    Factors Affecting Performance
                                  A

 Based  on  information  provided by the  developer,
 operating parameters that may affect system performance
 include (1) temperature, (2) pH, (3) inorganic nutrients,
 and (4) oxygen supply.

 Temperature

 During  the  SITE  demonstration,  Zenon   used
 microorganisms   that  typically  grow  best  in  the
 temperature range of 20 to 40° C. A high wastewater
 temperature increases biological activity but rarely causes
 any severe operating problems.  However, the increased
 metabolic rate during high  contaminant loading periods
 with elevated temperature deplete DO, which may inhibit
 microorganism growth.  A  low wastewater temperature
 can reduce  the microbial reaction rate, resulting in a
 slower degradation. In most cases, temperature changes
 occur gradually, so modifications in the process operation
 can be adjusted accordingly.
PH
The hydrogen  ion concentration of  the  groundwater
influences microbial growth. Based on SITE demonstration
results,  the  ZenoGem® technology operated best in a
neutral or slightly alkaline pH environment. The optimum
pH range in the bioreactor is typically maintained between
6.5 and 8.5. Treatment effectiveness does not appear to be
affected  by  changes within this range; however,  pH
outside of this range can lower treatment performance.
For example, based on general microbiology, microbial
activity may be inhibited at a pH above 9.0.  A pH below
6.5 favors an environment where fungi can overcome
microorganisms for food supply.  The effects of varying
pH, and other geochemical parameters (such as DO and
ORP) in the  influent groundwater, were not evaluated in
detail  during the  SITE  demonstration,  as  influent
groundwater pH was relatively constant throughout the
demonstration period.

Inorganic Nutrients

Inorganic nutrients, primarily nitrogen and phosphorus,
are essential for the biological  process.  Insufficient
amounts  of nutrients will  slow the degradation rate of
organic  compounds.  Nitrogen  may be provided in  a
variety of forms, such as  nitrate and ammonium salts.
Zenon typically performs treatability studies to determine
 the  ideal  nutrient  requirements  for  treatment.   The
 ZenoGem® technology typically does not require high
 nutrient concentrations since the biomass is recycled and
 retained in the system.

 Oxygen

 An adequate supply of oxygen is critical to an aerobic
 environment in which organisms can grow and degrade
 the organic contaminants.  If the supply of oxygen is
 insufficient, it becomes a limiting factor.  Zenon supplies
 oxygen through air diffusers installed along the bottom of
 the bioreactor.

 3.3    Site-specific Factors Affecting
        Performance

 Site-specific  factors can impact the application of the
 ZenoGem® technology,  and these  factors  should  be
 considered before selecting the technology for remediation
 of a specific site. Site-specific factors addressed in this
 section are site area,  climate, utilities, maintenance,
 support systems, and personnel  requirements.   This
 section presents supportrequirements based on information
 collected during the  SITE demonstration.

 3.3.1  Site Area

 The actual amount  of space required  for a ZenoGem®
 system depends on the size of the system used.  For the
Nascolite  demonstration,  the  pilot-scale  system was
housed in a transportable trailer. The trailer requires a 12-
foot by 60-foot area to  support a maximum operating
weight of 45,000 pounds. The trailer also requires 14 feet
of overhead  clearance.   About 1,000 square feet are
necessary  to operate and unload equipment.  Once the
trailer  is set up, the  system can be operational within 2
weeks  if all necessary utilities, production  wells, feed
lines, and supplies are available.

According to Zenon, the system can be constructed in a 40-
foot internationally accepted container or mounted on a
modular skid. The 40-foot container can  be modified to
provide shelter, where the skid-mounted unit needs to be
housed inside a building.

Additional space in a bermed area is required for optional
untreated and treated groundwater storage tanks, and a
drum staging  area for generated wastes. Additionally, a
                                                   31

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building  or  shed is  useful to protect supplies. Other
installation and monitoring requirements include security
fencing and access roads for equipment transport.

3,3.2 Climate

The ZenoGem®  system is  not designed to operate at
temperatures near or below freezing. If such temperatures
are  anticipated,  the  ZenoGem®  full-scale unit  and
associated storage tanks should be installed in a climate-
controlled  environment  (for example,  operating  the
system in a heated warehouse). In addition, aboveground
piping to the system must be protected from freezing.

3.3.3 Utilities

Use of  the ZenoGem® system  requires  water  and
electricity. Water is required for  a safety shower, an eye
wash station, personnel decontamination, and bioreactor
cooling.  For bioreactor cooling, the water supply must be
capable of providing 60 psi pressure and a flow rate of 30
gpm. According to Zenon, the cooling water is specific to
the trailer mounted unit used for the SITE demonstration
and may not be necessary at all sites. Information such as
degradation rates, influent COD concentrations, bioreactor
size, permeate flow rate, feed flow rate, site location, and
general  heat balance  are  some of the factors Zenon
considers when  determining the  need for bioreactor
cooling.  If water is  unavailable, arrangements must be
made to deliver, store, and pump water. In addition, about
200 gallons of water are required for equipment washing
and decontamination.

Electricity is used to run the pumps and blowers, and to
power   the  computer-controlled  operating  system.
Electricity is required for heating and air conditioning, and
running on-site analytical equipment. Electrical power for
the ZenoGem® system  can  be provided  by portable
 generators  or 460-volt, 3-phase, 60-Hz,  30-ampere
 electrical service. Based on observations made during the
 SITE demonstration and estimates provided by Zenon, the
 trailer-mounted unit operating for  24 hours draws about
 225 kilowatt hours (kWh) of electricity; this extrapolates
 to  annual  electrical energy  consumption  of about
 82,000 kWh.

 3.3.4  Maintenance

 The use of the ultrafiltration  module in the  system
 eliminates problems associated  with typical wastewater
treatment systems that rely on settling characteristics to
remove suspended solids from treated effluent.  Major
problems  associated  with  conventional  wastewater
treatment processes is sludge bulking, sludge rising, and
sludge wasting rate. With the ZenoGem® system, these
problems  are eliminated with  the addition  of  the
ultrafiltration module.

Periodic cleaning of the ultrafiltration membrane may be
required when a  significant pressure loss (20 percent) is
observed in the  ultrafiltration module.  The cleaning
procedure requires filling a 50 gallon clean-in-place tank
with clean water, adding a proprietary chemical cleaner,
and recirculating the liquid through the membrane and
back  into the clean-in-place tank.  The  spent liquid is
biodegradable and therefore can be transferred to  the
bioreactor for treatment.

During operation, it is typical to remove solids (or sludge)
from  the bioreactor when the TSS are in the range of
25,000 to 30,000 mg/L, or the VSS exceed 25,000 mg/L.
Typically,   the  ZenoGem®   system  is  capable   of
maintaining a solids retention time of 50 days. The result
is extended use of the microorganisms and reduced waste
disposal. Solids or sludge are removed by connecting a
hose to an outlet  port and removing the desired amount of
waste from the system.

3.3.5 Support Systems

A piping network from the source of the contaminated
groundwater  to  the   ZenoGem®  system  must   be
constructed. However, a tanker truck may be used to
transport contaminated groundwater to the system.  The
ZenoGem® system operates in a continuous flow-through
mode during remediation. An equalization tank is usually
required to  contain the groundwater if flow rates to the
 system are too low.

 3.3.6 Personnel Requirements

 Once the system is functioning, it generally operates
 unattended  except for periodic monitoring and routine
 maintenance.  An on-site  operator (trained by Zenon
 during the startup phase) should periodically monitor the
 system to ensure safe, economical, and efficient operation,
 and to conduct  sampling activities. Remote monitoring
 and alarm systems notify Zenon and the on-site operator of
 malfunctions in the system.  Under normal operating
 conditions, the operator is required to monitor the system
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 for about 7 hours per week. Time for sampling the influent
 and effluent, testing the samples for field parameters
 (temperature, pH, DO, COD, TSS), and packaging and
 shipping samples off site for TCL  VOC analyses is
 included in this estimate. Zenon performs periodic routine
 maintenance activities for the treatment equipment.

 3.4    Material Handing Requirements

 The primary residual generated by the ZenoGem® system
 is biological waste sludge produced as a by-product of the
 biological degradation of the waste  constituents.  The
 quantity of sludge varies with the type of waste degraded;
 however, typical values are about 0.1 pound of sludge per
 pound of COD removed from the influent stream.

 Zenon can reduce the volume of waste sludge for disposal
 by continuously recirculating the contents  through the
 ultrafiltration module.   This procedure dewaters  and
 concentrates the sludge, yielding  a smaller volume for
 disposal.     During  the  SITE   demonstration,  the
 ultrafiltration module reduced the volume of sludge in the
 bioreactor from  700 gallons to 400 gallons in about 4
 hours. Waste sludge can be stored in 55-gallon drums for
 off-site transport and disposal. The waste sludge may be
 subject to Resource  Conservation and Recovery Act
 (RCRA) regulations as a hazardous waste.

 Secondary waste streams generated by the ZenoGem®
 technology  consist of proprietary membrane cleaning
 solution, spent carbon filters, and decontamination water.
 During the SITE demonstration, Zenon generated about
 100 gallons of membrane cleaning solution, which was
 treated in the bioreactor near the end of the demonstration.
 Spent carbon used for TCL VOC removal in the permeate
 and off-gas  stream may be disposed of or regenerated.
 Decontamination water may be stored in 55-gallon drums
 for off-site disposal. Disposal options depend on local
 requirements and the presence or absence of contaminants.
 Disposal options may range from on-site disposal  to
 disposal in a hazardous waste or commercial landfill.

 Installation  of production wells may be necessary  to
provide groundwater to the system. During production
well drilling, drill cuttings and well development water are
generated.   During the SITE   demonstration,  four
production wells  were drilled to a depth of about 25 feet
which produced drill cuttings and development water. The
drill cuttings can  be stored in 55-gallon drums or in lined,
covered, roll-off boxes, or other receptacles. Development
 water may be stored in 55-gallon drums. Disposal options
 for this waste depend on local  requirements  and the
 presence or absence of contaminants. The options may
 range from on-site disposal to incineration.

 3.5   Technology Limitations

 Elevated oil  and  grease  concentrations,  inorganic
 suspended solids, and metals may reduce the treatment
 efficiency  of the system.   Elevated oil and  grease
 concentrations can inhibit the growth of microorganisms,
 resulting  in  a  slower   contaminant  degradation.
 Unemulsified oil and grease concentrations may also foul
 the ultrafiltration membrane surface, reducing the amount
 of permeate discharge from the module.

 Inorganic suspended solids that are not degraded in the
 bioreactor accumulate in the mixed liquor and may limit
 the process pumps'  efficiency  to  recirculate  the
 concentrate, and may cause fouling of the ultrafiltration
 membrane. In addition, metal concentrations can be toxic
 to microorganisms, reducing biological growth enough to
 interupt treatment.

 Depending on wastewater characteristics, pretreatment
 can be incorporated into a treatment train to prevent these
 problems.  Pretreatment options include sedimentation,
 flotation,  chemical precipitation,  and microfiltration.
 Zenon  manufactures pretreatment  systems  for  any
 necessary application.

 3.6   Potential Regulatory Requirements

 This section discusses regulatory requirements pertinent
to using the ZenoGem® technology at  Superfund, RCRA
corrective action, and other cleanup sites. The regulations
pertaining to  applications of this technology depend on
site-specific conditions; therefore, this section presents a
general overview of the types of federal regulations that
may apply  under various conditions.  State and local
requirements  also should be considered; because these
requirements  vary, however, they are not presented in
detail in this  section.   Table  3-1   summarizes  the
environmental laws and associated regulations discussed
in this section.
                                                   33

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Table 3-1. Summary of Environmental Regulations
    Act/Authority    Applicability        Application to the ZenoGem® Technology	Citation
    CERCLA
    RCRA
    CWA
    SDWA
    CAA
    AEAand
    RCRA
     OSHA
     NRC
Cleanup at
Superfund sites
Cleanups at
Superfund and
RCRA sites
Discharges to
surface water
bodies
Water discharges,
water reinjection,
and sole-source
aquifer and
wellhead
protection


Air emissions
from stationary
and mobile
sources
 Mixed waste
 All remedial
 actions
 All remedial
 actions
This program authorizes and regulates the
cleanup of releases of hazardous substances.
It applies to all CERCLA site cleanups and
requires consideration of other environmental
laws as appropriate to protect human health
and the environment.

RCRA regulates the transportation, treatment,
storage, and disposal of hazardous wastes.
RCRA also regulates corrective actions at
treatment, storage, and disposal facilities.

NPDES requirements of CWA apply to both
Superfund and RCRA sites where treated
water is discharged to surface water bodies.
Pretreatment standards apply to discharges to
POTWs.

Maximum contaminant  concentrations and
contaminant concentration goals should be
considered when setting water cleanup levels
at RCRA corrective action and Superfund sites.
Sole sources and protected wellhead water
sources would be subject to their respective
control programs.

If VOC emissions occur or hazardous air
pollutants are of concern, these standards may
be applicable to ensure that use of this
technology does not degrade air quality. State
air program requirements also should be
considered.

AEA and RCRA requirements apply to the
treatment, storage, and disposal of mixed
waste containing both hazardous and
 radioactive components. OSWER and DOE
 directives provide guidance for addressing
 mixed waste.

 OSHA regulates on-site construction activities
 and the health and safety of workers at
 hazardous waste sites. Installation and
 operation of the ZenoGem® biological and
 ultrafiltration process must meet OSHA
 requirements.

 These regulations include radiation protection
 standards for NRC-licensed activities.
40 CFR part
300
40 CFR parts
260 to 270
40 CFR parts
122 to 125, part
403
40 CFR parts
141 to 149
 40 CFR parts
 50, 60, 61, and
 70
 AEA (10 CFR
 part 60) and
 RCRA (see
 above)
 29 CFR parts
 1900 to 1926
                                                                                  10 CFR part 20
                                                    34

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 3.6.1  Comprehensive Environmental
        Response, Compensation, and
        Liability Act

 The  Comprehensive   Environmental  Response,
 Compensation, and Liability Act (CERCLA), as amended
 by SARA of 1986, authorizes the federal government to
 respond to releases of hazardous substances, pollutants, or
 contaminants  that  may present  an imminent and
 substantial danger to public health or welfare. CERCLA
 pertains to the ZenoGem® technology by  governing the
 selection and application of remedial technologies at
 Superfund sites.  Remedial alternatives that significantly
 reduce the volume,  toxicity, or mobility of hazardous
 substances and provide long-term protection are preferred.
 Selected remedies must be cost-effective, protective of
 human health and the environment, and must comply with
 environmental regulations to protect human health and the
 environment during and after remediation.

 CERCLA  requires identification and consideration  of
 environmental requirements  that are ARARs  for site
 remediation  before  implementation of  a  remedial
 technology at a Superfund  site.  Subject  to  specific
 conditions, EPA allows ARARs  to be  waived  in
 accordance with Section 121 of CERCLA. The conditions
 under which an ARAR may be waived are the following:
 (1) an activity that does not achieve compliance with an
 ARAR, but is part of a total remedial action that will
 achieve  compliance  (such  as  a   removal  action);
 (2) achievement of an equivalent standard of performance
 without complying with an ARAR; (3) compliance with
 an ARAR will result in a greater risk to health and the
 environment than will noncompliance; (4) compliance
 with an ARAR is technically impracticable; (5) a state
 ARAR has  not been consistently  applied;  and (6)
 compliance with the ARAR for fund-lead remedial actions
 will result in expenditures that are not justifiable in terms
 of protecting public health or welfare, given the needs for
 funds at other sites. The justification for a waiver must be
 clearly demonstrated (EPA 1988a). Off-site remediations
 are ineligible for ARAR waivers,  and all applicable
 substantive and administrative requirements must be met.
 CERCLA  requires  on-site  discharges  to  meet  all
 substantive state  and federal  ARARs, such  as  effluent
standards.  Off-site discharges must comply not only with
substantive  ARARs,  but   also state   and  federal
administrative ARARs, such as permitting, designed to
facilitate implementation of the substantive requirements.
 3.6.2  Resource Conservation and
        Recovery Act

 RCRA, as amended by the Hazardous and Solid Waste
 Disposal Amendments of 1984, is the primary federal
 legislation governing  management and disposal  of
 hazardous waste. Although a RCRA permit is not required
 for  on-site  remedial  actions at Superfund  sites, the
 ZenoGem®  technology  must  meet  all  substantive
 requirements when treating hazardous wastes.

 A  RCRA  hazardous  waste  maybe  defined  as  a
 characteristic or listed waste.  Criteria for identifying
 characteristic hazardous wastes are listed in Title 40 of the
 Code of Federal Regulations (CFR) Part 261 Subpart C.
 Listed wastes from  nonspecific and specific  industrial
 sources, off-specification products,  spill  cleanups, and
 other industrial sources are specified in 40 CFR Part 261
 Subpart D. Subtitle C of RCRA contains requirements for
 generation,  transportation,   treatment,   storage,  and
 disposal of hazardous wastes.  Compliance with these
 requirements is mandatory for CERCLA sites generating,
 storing, or treating hazardous waste on site.

 If the influent groundwater to the technology is  classified
 as hazardous waste, the substantive requirements of a
 RCRA Subtitle C treatment, storage, and disposal (TSD)
 permit must be  met.   If the effluent groundwater is
 determined to be hazardous  and is shipped off site for
 disposal, a Uniform Hazardous Waste Manifest must
 accompany the shipment. Air emissions from operation of
 the ZenoGem7 system are subject to RCRA regulations on
 air emissions from hazardous waste TSD operations and
 are addressed in 40 CFR Part 264 and 265, Subparts AA
 and BB. The air emission standards are applicable to TSD
 units subject to the RCRA permitting requirements of 40
 CFR part 270 or hazardous waste recycling units that are
 otherwise subject to the permitting requirements of 40
 CFR Part 270.

 Transportation  of all hazardous material  must comply
 with U.S. Federal Department of Transportation (DOT)
 hazardous  waste packaging, labeling, and transportation
 regulations. The receiving TSD facility must be permitted
 or similarity authorized and in compliance with RCRA
 standards.  The RCRA land disposal restrictions  (LDR) in
40 CFR 268 preclude the land disposal of hazardous waste
that fail to meet stipulated treatment standards. The LDR
treatment standards applicable to extracted groundwater,
soil cuttings, and residuals from groundwater treatment
                                                 35

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depend on the process that generated the waste or on the
types and concentrations of the contaminants present in
these wastes. Wastes that do not meet these standards
must receive additional treatment to bring the wastes into
compliance with the standards prior to land disposal, or be
issued a variance.

3.6.3  Clean Water Act

The Clean Water Act (CWA) is designed to restore and
maintain the chemical, physical, and biological quality of
navigable surface waters by establishing federal, state, and
local discharge standards. Treated effluent water from the
ZenoGem® system may be regulated  under the CWA if it
is discharged to surface water bodies or a POTW. On-site
discharges to surface water bodies must meet substantive
National  Pollution   Discharge  Elimination  System
(NPDES) requirements, but do not require a NPDES
permit. Off-site discharges to a surface water body require
an  appropriate NPDES permit and  must meet NPDES
permit limits. Discharge to a POTW is considered an off-
site activity, even if an on-site sewer is used. Therefore,
compliance  with  substantive  and  administrative
requirements of the national pretreatment program is
required. General pretreatment regulations are included in
40 CFR Part 403. Any local or state requirements, such as
state antidegradation requirements, must be identified and
satisfied.

 3.6.4 Safe  Drinking Water Act

 The Safe Drinking Water Act (SDWA), as amended in
 1986, requires EPA to establish regulations to protect
 human health from contaminants  in drinking water. The
 legislation authorizes national drinking water standards
 and a joint federal-state system for ensuring compliance
 with  these  standards.   The SDWA also regulates
 underground injection of fluids and sole-source aquifer
 and well head protection programs.

 TheNational Primary Drinking Water Standards are found
 in 40 CFR Parts  141 through  149.  SDWA primary or
 health-based,  and  secondary or  aesthetic maximum
 contaminant  levels  (MCL), will  generally apply as
 cleanup standards for water that is, or may be, used for
 drinking water supply.  In some cases, such as when
 multiple contaminants are present, alternate concentration
 limits  (ACL)  may  be used.   CERCLA  and   RCRA
 standards and guidance should be used in establishing
 ACLs.
If treated effluent water from the ZenoGem® technology is
reinjected into the subsurface environment it will  be
regulated by the underground injection control program
found in CFR 40 Parts 144 and 145. Injection wells are
categorized as Class I through  V, depending on their
construction and  use.   Reinjection of treated water
involves Class IV (reinjection) or Class V (recharge) wells
and  should  meet requirements for well construction,
operation, and closure.    If the groundwater, after
treatment,  still  contains  hazardous  waste,  then   its
reinjeced into the upper portion of an aquifer would be
subject to 40 CFR Part 144.13, which prohibits Class IV
wells.

The sole-source aquifer and wellhead protection programs
are designed to protect specific drinking water supply
sources. If such a source is to  be remediated using the
ZenoGem® system, appropriate program officials should
be notified, and any potential  regulatory requirements
should be identified. State groundwater antidegradation
requirements and water quality standards may also apply.

3.6.5 Clean Air Act

The Clean Air Act (CAA), as amended in 1990, establishes
primary and secondary ambient air quality standards for
protection of public health and emission limitations for
 certain hazardous air pollutants.  Permitting requirements
under CAA are administered by  each state as part of State
 Implementation Plans developed to bring each state into
 compliance with National Ambient Air Quality Standards
 (NAAQS).

 The ambient air quality standards for specific pollutants
 apply to the ZenoGem® technology because of emissions
 from a point source to the ambient air. Allowable emission
 limits  for  operating  a  ZenoGem®  system will  be
 established on a case-by-case basis depending on the type
 of waste treated and whether  or not the site is  in an
 attainment  area  of the NAAQS.  Allowable emission
 limits may be set for specific  hazardous air pollutants,
 particulate matter, or other pollutants. If the site is in an
 attainment area, the allowable emission limits may still be
 curtailed by the increments available under Prevention of
 Significant Deterioration  (PSD)  regulations.  An  air
 abatement  device,  such as  a carbon absorption unit, is
 typically required to remove VOCs from the process air
  stream before discharge to the ambient air.
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 The ARARs pertaining to the CAA can only be determined
 on a site-by-site basis. Remedial activities involving the
 ZenoGem® technology may be subject to the requirements
 of Part C of the CAA for the prevention of significant
 deterioration of air quality in attainment (or unclassified)
 areas. The PSD requirements will be applicable when the
 remedial activities involves a major source or modification
 as defined in 40 CFR part 2.21.  The PSD significant
 emission rate for VOCs is 40 tons  per year.  Activities
 subject to PSD review must ensure application of best
 available control technologies (BACT) and demonstrate
 that the activity will not adversely impact ambient air
 quality.

 3.6.6  Mixed Waste Regulations

 Use of the ZenoGem® system at sites with radioactive
 contamination might involve treatment of mixed waste.
 As defined by the Atomic Energy Act (ABA) and RCRA,
 mixed waste contains both  radioactive and hazardous
 waste  components.   Such waste  is  subject to the
 requirements of both acts. However, when application of
 both AEA and RCRA regulations results in a situation that
 is inconsistent with the AEA (for example, an increased
 likelihood of radioactive exposure), AEA requirements
 supersede RCRA requirements (EPA 1988a). OSWER, in
 conjunction  with the Nuclear Regulatory Commission
 (NRC), has  issued several directives to  assist  in
 identification, treatment,  and  disposal of  low-level
 radioactive mixed  waste.  Various OSWER directives
 include guidance on defining, identifying, and disposing
 of commercial, mixed,  low-level  radioactive,  and
 hazardous waste  (EPA  1988b).   If the ZenoGem®
 technology is used  to treat groundwater containing low-
 level mixed waste, these directives should be considered.
 If high-level mixed waste or transuranic mixed waste is
 treated, internal Department of Energy (DOE) orders
 should  be  considered when developing  a protective
 remedy (DOE 1988). The SDWA and CWA also contain
 standards for maximum allowable radioactivity levels in
 water supplies.

 3.6.7  Occupational Safety and Health
       Administration Requirements

The Occupational  Safety  and  Health  Administration
OSHA requires  personnel employed in hazardous waste
operations to receive training and comply with specific
working procedures while  at hazardous  waste sites.
 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.   On-site construction
 activities at Superfund or RCRA corrective actions sites
 must be performed in  accordance with  Part 1926 of
 OSHA, which provides safety and health regulations for
 construction sites.  State OSHA requirements, which may
 be significantly stricter than federal standards, must also
 be met.

 All technicians  operating  the ZenoGem® system  are
 required to have completed an OSHA training course and
 must be familiar with all OSHA requirements relevant to
 hazardous waste sites. For most sites, minimum personal
 protective equipment (PPE) for technicians will include
 gloves,  hard  hats,  steel-toed boots,  and  coveralls.
 Depending  on contaminant types and  concentrations,
 additional PPE may be required. Noise levels should be
 monitored to ensure that workers are not exposed to noise
 levels above a time-weighted average of 85 decibels over
 an 8-hour day.

 3.7   State and Community Acceptance

 State regulatory agencies will likely be involved in most
 applications of the ZenoGem® system at hazardous waste
 sites. Local community agencies and citizens' groups are
 often actively involved in decisions regarding  remedial
 alternatives.

 Because few applications of the ZenoGem® technology
 have been completed, limited information is available to
 assess  long-term  state  and  community acceptance.
 However, state and community are  generally expected to
 accept this technology, because (1) the technology does
 not involve combustion processes,  and (2) the system is
 capable  of significantly reducing  concentrations  of
 hazardous substances in groundwater.

 The New Jersey Department of Environmental Protection
 (NJDEP) oversees investigation and remedial activities at
the Nascolite site. State personnel were actively involved
 in the preparation of the work plan for the demonstration
of  the   pilot-scale  system  and   monitored system
 installation and performance. NJDEP will also be actively
 involved in planning for any full-scale systems installed at
the site.  The role of states in selecting and applying
remedial technologies will likely increase in the future as
                                                  37

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state environmental agencies increasingly assume many
of the oversight and enforcement activities previously
performed at the EPA regional level. For these reasons,
state regulatory requirements that are  sometimes more
stringent than federal requirements may take precedence
for some  applications.   As  risk-based  closure and
remediation become more common, site-specific cleanup
goals determined by state agencies will drive increasing
numbers of remediation projects, including applications
involving the ZenoGem® technology.
                                                     38

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                                               Section 4
                                        Economic Analysis
This  section  presents  cost estimates  for using  the
ZenoGem® technology to treat groundwater contaminated
with VOCs. The cost estimates are based on data compiled
during the SITE demonstration at the Nascolite site and
information obtained from Zenon, independent vendors,
and current environmental  restoration cost estimating
guidance.

Costs for actual applications of this technology may vary
depending on  the types  and  concentrations of  the
contaminants present, regulatory cleanup requirements,
and other site-specific factors. This section presents costs
for two hypothetical  applications  of the ZenoGem®
technology to demonstrate how costs may vary between
sites with different design and operating requirements.

The cost estimates required a number of assumptions to
account for variable site- and waste-related  parameters,
and to simplify  situations that would require  complex
engineering or financial functions in actual applications.
Assumptions regarding the type of system used, flow rate,
duration of the remedial project, volume treated, and other
factors significantly affect the total estimated cost and cost
per gallon of water treated in each scenario.

It is also important to note that the system demonstrated at
the  Nascolite  site  was  operated at  pilot-scale  to
demonstrate that the system could remove MMA, TCL
VOCs, and COD  from contaminated groundwater. The
cost estimates  in this  report are  partially based  on
extrapolation of the pilot-scale data to longer periods and
higher flow rates.  Costs for systems designed for optimal
full-scale performance at  full  capacity  may  vary
significantly from the cost scenarios in this report.

Section 4.1 discusses general factors affecting costs for
any application of the ZenoGem® technology; Section 4.2
describes the two scenarios.  Section 4.3 summarizes the
 significant issues and assumptions for the Case 1 analysis,
 and Section 4.4 discusses the associated costs, Section 4.5
 discusses Case 2, and Section 4.6 presents Case 2 costs,
 Section  4.7  presents  conclusions  of the  economic
 analyses.

 To facilitate comparison with conventional remediation
 technologies, costs are distributed among  12 categories
 applicable to typical cleanup activities at Superfund and
 RCRA sites. These cost categories are (1) site preparation,
 (2) permitting  and  regulatory, (3) mobilization  and
 startup, (4) equipment, (5) labor, (6) supplies, (7) utilities,
 (8) effluent treatment and  disposal, (9) residual waste
 shipping and  handling,  (10) analytical  services,
 (11) equipment maintenance, and (12) site demobilization
 (Evans 1990). Costs are rounded to the nearest 100 dollars
 and considered order-of-magnitude estimates.

 4.1   General Factors Affecting Costs

 This economic  analysis presents estimated costs for two
 scenarios (Case 1 and Case 2) in which the ZenoGem®
 system is applied to sites with different characteristics and
 operating requirements.  The selected system must be
 configured to  meet site-specific  conditions.    These
 conditions will therefore affect overall costs for any
 application of  the ZenoGem®  system by determining
 operating parameters and  implementation costs.  It  is
 important to note that the general types of site-specific
 conditions discussed  below  will  influence costs for
virtually  any type of  groundwater or aqueous waste
remediation system.

The regulatory status of the site, which is often determined
by the type of waste management activities that occurred
on  site,  the relative  risk to nearby  populations  and
ecological receptors, and other factors, affects costs by
mandating ARARs and remediation goals.  ARARs and
                                                    39

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remediation goals ultimately determine the type and
configuration  of  the system,  operating  parameters,
duration of the remediation project, effluent management
procedures,  and other factors affecting costs.  Certain
types of sites may also have more stringent monitoring
requirements than others, depending on regulatory status.

Other site-specific factors affecting costs can generally be
divided into waste-related factors  and site features.
Waste-related  factors affecting costs include  waste
volume, contaminant types  and concentrations, and
regulatory agency-designated treatment goals.

Waste volume affects total project costs because a larger
volume takes longer to  remediate or requires a higher
treatment system capacity. However, economies of scale
can be realized with a larger-volume project because the
fixed costs,  such as equipment costs, are distributed over
the larger volume.

The types and concentrations of contaminants to be treated
and the  treatment  goals for the site  determine the
appropriate size and configuration of the treatment system
components, which  affects  capital equipment costs.
Contaminant concentrations can also influence costs by
determining the flow rate at which treatment goals can be
met.  For example, high concentrations of contaminants or
nonaqueous phase liquids (NAPL) may be toxic to  the
microorganisms in the system  at high feed rates, and
therefore may require a slower feed rate to the system. The
presence  of NAPL may also limit  the rate at which
groundwater may be pumped from an aquifer, and require
specialized types of pumps for some applications. Some
types of contaminants may create greater oxygen demand
 in  the bioreactor, which may  result in  higher power
 consumption and significantly affect electrical costs over
 a long-term project.  Contaminant characteristics will
 affect sampling requirements and analytical costs, and will
 determine  health and   safety  procedures and PPE
 requirements for all site activities.  Overall, higher costs
 will be incurred at sites requiring work at higher health and
 safety/PPE levels.

 Site   features   affecting costs  include  site  location,
 accessibility, and infrastructure; hydrogeologic factors;
 and groundwater chemistry.  Site location, accessibility,
 and infrastructure affect equipment and operating costs,
 site preparation costs, and  mobilization costs.  For sites
 posing a significant risk to nearby potential receptors,
 remediation goals may be more stringent and require more
aggressive treatment programs than situations where a site
is  relatively isolated  from potential receptors.  High-
visibility sites in densely populated areas may require
higher security  and the  need to minimize obtrusive
construction activities, noise,  dust, and  air emissions.
Mobilization and demobilization costs are affected by the
relative distances that equipment must travel to the site.
Site preparation costs are influenced by the availability of
access roads and utility lines and by the need for additional
equipment to withstand freezing temperatures in colder
climates.  In cold climates, the system may need to be
housed in a heated structure, and piping may require sub-
grade  placement or heat tracing to prevent freezing.
Within the U.S.,  there  can  be significant regional
variations in costs for materials and equipment,  and
utilities.

Assumptions regarding site hydrogeology are critical in
determining overall project costs. Hydraulic conductivity
and saturated thickness will determine the withdrawal rate
necessary to  capture or control the migration  of a
contaminant plume, which affects the rate of flow to (and
through) the system and the duration of the remediation
project. These factors in turn determine design parameters
and costs for the ZenoGem® system and the supporting
groundwater extraction and effluent management systems.
For example, higher flow rates may require use of a series
of filtration modules in parallel and increase the amount of
oxygen supplied to the bioreactor. Extraction wells may
provide the desired hydraulic control and flow rate in some
situations; however, for low-yielding, shallow aquifers, a
passive collection system (trench with french drain) may
be more effective and  economical to construct and
operate.

In addition to contaminant characteristics, non-contaminant
chemical characteristics  of the groundwater or aqueous
waste can affect costs in several ways.  Groundwater
temperature, pH, TSS, DO, and inorganic constituents
may impact the metabolic rate within the bioreactor, and
 determine the need for pretreatment of influent water.
 High  concentrations  of suspended solids may foul the
 filtration membranes.  Some soluble metals may be toxic
 to the organisms in the bioreactor, necessitating additional
 pretreatment to remove the metals or more frequent sludge
 disposal.  These factors  could affect equipment costs,
 consumable  and  time-related   variable  costs,  and
 maintenance  costs.  Groundwater chemistry may also
 affect the amount of oxygenation required for feed waste
 entering the bioreactor,  affecting utility costs, and may
 also influence the management of effluent.
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 Electricity consumption can vary considerably depending
 on  the  total number of  pumps  and other electrical
 equipment  operating.   Treatment  systems requiring
 extraction wells will operate pumps that will incur slightly
 higher electricity costs depending on the pump sizes. Sites
 requiring a higher oxygen feed rate for the bioreactor will
 incur higher electricity costs.

 4.2   Overview of Cost Scenarios

 Costs were estimated for cases involving two different
 hypothetical applications of the ZenoGem® system. Case 1
 assumes  that a rented,  trailer-mounted  system treats
 groundwater at a rate of 1,400 gpd for a 1-year period.
 Case 2 assumes that a modular (skid-mounted) system will
 be purchased and used to treat leachate at a rate 1,400 gpd
 for a 10-year period.

 Both cases assume a higher flow rate than the 480 gpd rate
 used during the SITE demonstration. The higher flow
 rates may be more representative of full-scale applications
 of the ZenoGem® technology.   Based on information
 provided  by Zenon,  the higher flow rates are feasible;
 however,  system performance at these higher flow rates
 was not evaluated during the SITE demonstration. The
 timeframes assumed for the cost estimates were selected
 for consistency with cost evaluations of other innovative
 technologies evaluated by the EPA SITE Program, and
 because  they facilitate  comparison  to  typical costs
 associated with conventional, remedial options. However,
 neither timeframe reflects estimates of the time that may
 actually be  required  to remediate groundwater at the
 Nascolite  site.

 Case 1 is based on a system similar to the trailer-mounted
 system used during the SITE demonstration, operating for
 a relatively  short operating period.  Renting Zenon's
 mobile, trailer-mounted  system  may  be  especially
 applicable for  short-term, aggressive remedial programs
 where rapid mobilization and startup  with minimal site
 preparation are desired. For example, the trailer-mounted
 system could be rapidly deployed and set up at a spill site
 when  a  nearby water  supply source is threatened.
 Depending on  the magnitude of the problem, the system
 could either be part of the permanent remedial solution, or
 an  interim  measure  associated with  a containment
program while the scope of the problem and a permanent
 solution are determined. The short operating period limits
the total volume of groundwater potentially treated in Case
 1, resulting in a higher estimated cost per gallon of water
 treated than in Case 2.  However, short-term treatment
 costs per gallon would be comparatively high (relative to
 long-term costs) for many types of groundwater treatment
 systems.  In emergency response situations, technical
 feasibility, proven reliability, and speed of deployment are
 often primary considerations.

 In Case 2, the ZenoGem® technology is used for a long-
 term project to treat landfill leachate containing VOCs and
 high BOD. The primary goal of the remedial project in
 Case 2 is containment and treatment of leachate as it is
 generated, rather than a situation such as Case 1, where an
 aquifer is already contaminated and  a more aggressive
 remedial program is necessary. For this reason, timeframe
 for deployment is not assumed to be as critical as in Case
 1.   Case 2 assumes that time for more  extensive  site
 support  facilities  (such as a building to house the less-
 expensive, skid-mounted system) to be constructed.  The
 system operates for a 10-year period, and treats  a much
 larger volume than the system in Case 1. Although total
 costs are higher than in  Case 1, the estimated cost  per
 gallon  is  significantly  lower because  all costs  are
 distributed over a larger treatment volume.

 4.3    Case 1  Analysis

 Case 1 is presented to demonstrate application of  the
 ZenoGem® system to a short-term groundwater remediation
 project requiring a mobile  system  capable  of rapid
 deployment with minimal site preparation. Section 4.3.1
 presents the key issues and assumptions considered for the
 Case 1  cost estimate;  Section 4.3.2 discusses  waste
 characteristics and site features; and Section 4.3.3 presents
 equipment and operating parameters.

 4.3.7 Issues and Assumptions

 This section summarizes major issues and assumptions
 regarding  site-specific   factors  and  equipment  and
 operating parameters for Case 1. In general, ZenoGem®
 equipment operating assumptions are based on information
 provided by Zenon and observations made during the
 SITE demonstration.  Other assumptions  are based  on
 current engineering cost guidance.

 4.3.2 Waste Characteristics and Site
       Features

Assumptions regarding  waste characteristics  and site
features are the following:
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 The site is a Superfund site; site hydrogeology and
 contaminant characteristics are well-characterized.

 The system  will be used as an interim, short-term
 containment measure to limit off-site migration of a
 small contaminant plume while a permanent remedial
 solution  is  being  selected.   The  project requires
 removal and treatment of about 500,000 gallons of
 groundwater over a 1 year period.

 The influent stream is groundwater contaminated with
 MMA at an average concentration of 3,000 mg/L.

 All contamination  is in dissolved phase (no NAPL is
 present).

 Level D (minimal) or E (no specific requirements)
 health and safety/PPE requirements will apply to all
 site activities.

 No pretreatment is required.

 Contaminated groundwater will be extracted from a
 moderate-yielding sand and gravel aquifer. The top of
 the sand and gravel zone is about 5 feet bgs. The depth
 to water is about 15 feet bgs, and the base of the aquifer
  is about 25 feet bgs.

 The  groundwater plume is relatively small;  one
  extraction well will provide the desired feed rate to the
  system (1,440 gpd total or about 1 gpm).

 No  sewer lines exist on site, and no POTWs  are
  located  in the area.  Because contaminants will be
  treated to nondetectable levels, effluent groundwater
  can be returned to the aquifer through an injection well
  located adjacent to the treatment system, upgradient
  from the extraction well.

•  The site  is located in a rural area in the northeastern
  U.S. Regional winter temperatures are below 0° C for
  several days in arow, requiring antifreezing measures.

•  The site is located  in a rural area, but has existing
  electrical lines, access roads, and a security fence.

•  The ZenoGem® system is mobilized from within 500
  miles of the site.
4.3.3 Equipment and Operating
       Parameters

Some assumptions regarding the equipment for Case 1 are
based  on  SITE demonstration  data for the system
demonstrated at the Nascolite site, extrapolated to a 1 -year
operating period.  Different operating parameters  (most
significantly flow rate) were assumed to more closely
approximate  operating  conditions  for  full-scale
applications.

Assumptions  regarding  equipment  and  operating
parameters for Case 1 are the following:

 •  The  ZenoGem® treatment system is mounted in a
    mobile, 46-foot, refrigerated and heated semitrailer.

 •  The  system will be rented for a period of 1 year.
    Depreciation and salvage value  is assumed to be
    incurred by Zenon and reflected in the rental costs.

 •  The  system is mobilized to the site and assembled by
    Zenon. Zenon will also perform periodic maintenance
    and modification activities paid by the client.

 •  Groundwater will be treated to meet MCLs.

 •  The treatment system is operated 24 hours per day, 7
    days per week, for 1 year.  Downtime for routine
    maintenance is assumed to be minimal and is not
    considered in this estimate.

  •  The system operates  at  a flow rate of 1,440 gpd,
    treating a total of 530,000 gallons during the year.

  •   System effluent  will require carbon  polishing  to
     achieve  nondetectable target  cleanup goals.  Air
     emissions will also be cleaned by  carbon prior to
     release to the atmosphere; air discharge permits and
     air sampling are assumed to not be required.

  •  The treatment system operates automatically without
     the  constant attention of an operator and will shut
     down in the event of system malfunction.

  •  One technician will be needed part time to inspect the
     equipment, collect weekly  samples, and conduct
     routine maintenance on the system.  Initial operator
     training is provided by Zenon.
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  •  Sampling and  analytical  QA/QC  requirements  for
    system performance monitoring  will  not  be  as
    stringent  as  those  followed  during  the   SITE
    demonstration.   One treated and  one  untreated
    aqueous sample will be collected weekly and analyzed
    by  an off-site  laboratory for VOCs.  Treated and
    untreated aqueous samples will also be collected
    periodically and analyzed on site for temperature, pH,
    COD, and DO to monitor system performance.

4.4    Case 1 Costs

This section presents the costs associated with Case 1.
Subsections are organized to correspond with the 12 cost
categories typical to Superfund sites. Table 4-1 shows a
breakdown of the Case 1 costs by category, and Figure 4-
1 shows the cost percentage distribution for each category.

4.4.1  Site Preparation Costs

Site preparation  costs  include  a  treatability  study,
administrative costs,  treatment area preparation, and
design costs. For this analysis, administrative costs, such
as costs for legal searches, access rights, and site planning
activities, are estimated to be minimal as the system will
be deployed rapidly and set up at a site that has been
extensively investigated.  Total administrative costs are
assumed to be about $10,000.

Zenon will conduct a treatability study to determine if the
ZenoGem® technology is suitable for remediation, and to
determine the design specifications for the site. Zenon
estimates a typical treatability study to cost about $5,000,
including labor and equipment costs.

Treatment area  preparation  includes  constructing  an
extraction*well, installing the pump, valves, and piping to
carry the groundwater to the ZenoGem® treatment system,
and constructing an injection well for returning treated
water to the aquifer.  This analysis assumes that one 25-
foot-deep, 4-inch-diameter extraction well will be needed,
and that the well can be installed using hollow-stem auger
drilling methods. The well can be drilled, constructed, and
developed for about $70 per foot plus maximum drill rig
mobilization costs of $ 1,000 (assuming driller mobilization
from within 100 miles of the site) for a total estimated cost
of about $2,900. Alternatively, if groundwater monitoring
wells already exist in the plume area, it is possible that they
may modified to serve as extraction wells (provided the
yield is sufficient), eliminating the need to construct a new
extraction well.
 A submersible pump will maintain the flow rate necessary
 for  this case.   The estimated  pump cost,  including
 electrical controls and  installation, is about  $3,000.
 Insulated, heat-traced piping and valve connection costs
 are estimated to be about $25.00 per foot for a total cost of
 $5,000, assuming the well will be located less than 200 feet
 from the treatment system. The total costs for pumps and
 piping are estimated to be about $8,000.

 The system will require continuous  management of the
 treated groundwater.  If groundwater monitoring wells
 exist in the treatment area, they may be modified to serve
 as injection wells,  and construction of a groundwater
 recharge system may not be required. This cost analysis
 assumes that construction of an injection well will be
 required. The ZenoGem® treatment system will be located
 upgradient from the extraction well in this case. For this
 reason, the injection well could be located adjacent to the
 treatment system,  allowing  injected, treated  water to
 continuously recirculate through the  contaminated zone.
 An injection well would have the same general design
 specifications as the extraction well, with the exception
 that no pump would be required, and could be installed at
 the same time as the extraction well, without requiring a
 separate mobilization. The cost for this well is estimated
 to be $1,500.

 Design costs include engineering designs for extraction
 and injection well placement and construction, electrical
 power supply and piping configurations, site layout, and
 any other necessary engineering services. Case 1 assumes
 that  site hydrogeology and contaminant characteristics
 have  been  defined through  RI/FS activities,  so  the
 extraction and injection well designs will require minimal
 effort. Treatment equipment design is included in this
 calculation to account for any design modifications Zenon
 may make prior  to mobilizing the system. However,
 because the rented, mobile system will be used, treatment
 equipment design will generally be limited to determining
 optimal operating parameters based on the results of the
treatability study. For these reasons, design costs for Case
 1 are assumed to be minimal.  Design costs are estimated
to be about  10 percent  of the combined costs  of
construction (described above) and first-month rental of
the treatment system.  Based on these assumptions, total
 design costs are estimated to be about $2,500.

Total site preparation costs for this case are estimated to be
about $29,900.
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Table 4-i. Costs Associated with the ZenoGem® Technology - Case 1
                                     Cost Categories
Itemized Costs
Total Cost
          FIXED COSTS:    Site Preparation Costs:
                                 Administrative
                                 Extraction and Injection Wells
                                 Pump and Piping
                                 Treatability Study
                                 Design Costs
                           Permitting and Regulatory Costs
                           Mobilization and Startup Costs:
                                 Treatment Equipment
                                 Labor
                                 Utility Connection
                           Site Demobilization Costs:
                                 Disassembly and
                                 Treatment Equipment
                                 Site Restoration
                           Total Estimated Fixed Costs
        VARIABLE:        Equipment Costs:
                                 Treatment Equipment
                                 Monitoring Equipment
                           Labor Costs (routine operating labor)
                           Supply Costs:
                                 Chemical Additives
                                 Carbon Columns
                                  PPE
                                  Sampling Supplies
                           Utility Costs (electricity)
                           Residual Waste Treatment and
                           Analytical Services Costs
                           Equipment Maintenance Costs:
                                  Equipment
                                  Maintenance Labor
                           Total Variable Costs
        TOTAL ESTIMATED FIXED AND VARIABLE COSTS"
        Total cost per gallon treated"
                   $29,500
      $10.000
        4,000
        8,000
        5,000
        2,500
        1,400
        2,800
        2,200

        1,700
        1,400
         2000
      159,200
        7,000
          300
        6,000
          200
          300
        4,800
        5,200
                     5,000
                     6,400
    5,100
  $46,000
 $166,200


   12,700
    6,800
    7,400
    4,200
   10,100
   10,000


 $217,400
 $263,400
    $0.50
        Notes:
              * Total over a 1-year period.
              b Total of 530,000 gallons treated.
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 4.4.2  Permitting and Regulatory Costs

 Remedial actions at Superfund sites must be consistent
 with  ARARs  of  environmental  laws,   ordinances,
 regulations, and statutes, including federal, state, and local
 standards and  criteria.   In general,  permitting  and
 regulatory costs are highly variable as ARARs must be
 determined on a site-specific basis. Remediation at RCRA
 corrective action sites requires additional monitoring and
 recordkeeping, which can increase regulatory costs. Sites
 requiring permits for effluent discharge to sewers or
 surface water bodies may incur significant permitting fees
 and associated administrative costs.

 For estimating purposes, permitting and regulatory costs
 for Case 1 are assumed to be minimal since the primary
 goal is rapid mobilization and protection of a public water
 supply.   Permitting costs would primarily be related to
 obtaining permits or waivers to allow reinjection of treated
 water, and are estimated to be $5,000.  No air discharge
 permits are assumed to be required.

 4.4.3  Mobilization and Startup Costs

 Mobilization  and startup  costs  include the costs  for
 transporting  the  ZenoGem®  system   and auxiliary
 equipment to the  site, assembly and shakedown of the
 system, electrical power supply hookup, and connection to
 the piping systems.

 Transportation costs are site-specific and vary depending
 on distance between the site and the point of mobilization.
 For this analysis, the ZenoGem® equipment is assumed to
 be transported 500 miles.  A cartage company will  be
 retained to transport the trailer-mounted treatment system.
 Mobilization and transport costs are about $2.80 per mile,
 for a total cost of $1,400. No oversized vehicle highway
 permits are assumed to be needed.

Assembly costs  include the costs  of securing the trailer,
 assembling the  ZenoGem®  system,  and  connecting
 extraction well piping, and hooking up electrical lines.
Zenon provides trained  personnel  to  assemble  and
 shakedown the ZenoGem® system. Zenon personnel are
 assumed to be trained in hazardous waste site health and
 safety procedures, so health and safety training costs are
not included as a direct startup cost. A two-person crew
 charged at $70 per hour will work five 8-hour days to
 assemble the system and perform the initial shakedown.
Electrical connecting  costs  are assumed to be about
 $2,200.  The total assembly  costs are about $5,000,
 including labor and connection costs.

 Zenon personnel will also train an on-site operator to
 perform routine  system monitoring necessary to ensure
 optimal performance.   The monthly equipment rental
 costs include the cost of this training, so no additional
 training costs are incurred.

 Total mobilization and startup  costs for Case  1  are
 estimated to be $6,400.

 4.4.4 Equipment Costs

 Equipment  costs  include  the  costs  of  renting  the
 ZenoGem® treatment system, auxiliary equipment, and
 monitoring equipment. For Case  1, Zenon will provide a
 trailer-mounted system that includes the following major
 components:  an influent holding-equalization tank,  a
 bioreactor,  an ultrafiltration module, an air blower, a pH
 buffer tank, a nutrient solution tank, off-gas carbon filters,
 permeate carbon filters, and feed, process, and metering
 pumps.  Zenon will rent the trailer-mounted system for
 $13,300 per month. Fora 1-year term, the total ZenoGem®
 system rental costs will be $159,200.

 Monitoring  equipment   includes   a  pH  meter,
 spectrophotometer, and other miscellaneous analytical
 equipment. The assumed cost for renting this equipment is
 $7,000 for the remedial effort.

 Total equipment costs for Case 1 are $166,200.

 4.4.5 Labor Costs (Routine Operating
       Labor)

 Once the system  is functioning, it will generally operate
unattended  except for periodic monitoring and routine
maintenance.  An on-site operator (trained  by Zenon
during the startup phase) should periodically monitor the
system to ensure safe, economical, and efficient operation,
and to conduct sampling activities.  Remote monitoring
and alarm systems notify Zenon and the on-site operator of
malfunctions in the system.  Under normal operating
conditions, the operator is required to monitor the system
for about 7 hours per week. Time for sampling the influent
and effluent, testing the samples for field parameters
(temperature, pH, DO, COD, TSS), and packaging and
shipping samples for off-site VOC analysis is included in
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this estimate. Assuming a labor charge of $35 per hour,
total labor costs are estimated to be $12,700 over a 1-year
period.

Zenon performs periodic routine maintenance activities
for the treatment equipment.   These  activities  and
associated  costs  are  discussed  hi  Section  4.4.11,
Equipment Maintenance Costs.

4.4.6  Supply Costs

Supplies required  for this analysis of the ZenoGem®
treatment system include standard operating supplies such
as  treatment  chemicals,  carbon columns,  disposable
personal protective  equipment  (PPE),  and  sampling
supplies. Treatment chemicals include MC-1 cleaner (to
clean the ultrafiltration membranes), available at $6.89 per
kilogram (kg), and phosphorous  nutrient available for
$0.25 per kg.  Based on observations made during the
SITE demonstration, about 24 kilogram of MC-1 cleaner
and 465 kilogram of phosphorous nutrient will be required
to  treat 530,000  gallons of water.  Total  treatment
chemical costs are estimated at $300.

The system  may  require carbon adsorption for final
polishing of treated effluent to achieve nondetectable
contaminant concentrations, and for treating off-gases.
The number of carbon columns required is highly  site-
specific and  will depend on  the  flow rate,  influent
contaminant concentrations, and other factors. Based on
the results of the SITE demonstration extrapolated to a 1-
year period and a higher flow rate, this estimate assumes
that effluent polishing will require two carbon columns
that will need  be replaced every 3  months.  Off-gas
treatment will require two additional columns that will
require replacement every 6 months.  Based on these
assumptions, a total of 12 carbon columns  will be  used
during the 1 year-long  project.  Assuming replacement
columns cost about $500 each, total carbon column costs
 are about $6,000.

 Supply costs also include costs for Level D disposable PPE
 and other sampling supplies. Disposable PPE typically
 consists of Tyvek™ suits, latex inner gloves, nitrile outer
 gloves, and safety glasses. Disposable PPE for this case is
 assumed to cost about $200 for the  1-year period. Other
 sampling supplies consist of sample bottles and shipping
 containers. For routine monitoring, laboratory glassware
 is also needed.  The numbers and types  of sampling
 supplies needed are based on the analyses to be performed.
For this case, sampling supply costs are assumed to be
about $300 for the 1-year period.

Total supply costs for Case 1 are estimated to be $6,800.

4.4.7  Utility Costs

Electricity is the only utility  used  by the ZenoGem®
system. Electricity is used to run the pumps and blowers of
the  treatment system, and  to power the computer-
controlled operating system, heating and air conditioning,
and on-site analytical equipment. Electricity costs may
vary considerably depending on the geographic location of
the site and local utility rates.  Costs for connection to
existing electrical  lines  were included  under "Site
Preparation."

Based on observations during the SITE demonstration and
estimates provided by Zenon, the trailer-mounted system
operating for 24 hours draws about 225 kWh of electricity;
this extrapolates to annual electrical energy consumption
82,125 kWh.  Electricity is assumed to cost $0.09 per
kWh, including demand and usage charges, resulting in
total estimated electricity costs of about $7,400.

4.4.8  Effluent Treatment and Disposal
        Costs

Cleanup goals are assumed to  be MCLs.  Monitoring is
routinely conducted by the operator to ensure that effluent
meets  MCL criteria before  exiting  the  system (see
Section 4.4.10). As a result, the effluent can be returned to
the  aquifer through an infiltration  gallery.   Costs for
constructing the  infiltration gallery were presented  in
Section 4.4.1, Site Preparation Costs.  The ZenoGem®
system produces air emissions  that pass through a carbon
column prior to release to the atmosphere, and carbon
adsorption  is used to polish the effluent water before
 discharge.  The costs for  the  carbon columns were
 presented hi Section 4.4.6.  For these reasons, this estimate
 assumes no additional costs  will be  incurred for  the
 treatment or disposal of the effluent.

 4.4.9 Residual Waste  Shipping and
        Handling Costs

 The only  residual waste  directly produced by  the
 ZenoGem® process is a waste sludge, which consists of
 microorganisms  and  unfiltered wastewater  from  the
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bioreactor.  The  sludge generation rate is  highly site-
specific; for this reason, costs for residual waste disposal
may vary significantly from estimates presented in this
document.  The volume of sludge can be reduced by
continuously recirculating it through the ultrafiltration
module.  This procedure which partially dewaters the
sludge, reduced the total sludge volume by about 40
percent during the SITE demonstration. This dewatered
material is assumed to be a hazardous waste  and must be
managed in accordance with applicable regulations.  For
this analysis,  Zenon estimates that about 3.6 wet tons
(about twelve 55-gallon drums) of sludge  will require
disposal after the groundwater remediation project has
concluded.  Case 1  assumes that this material can be
removed, transported, and disposed of for about $400 per
ton, resulting in a cost of about $1,400.

Peripheral  treatment systems may generate  residual
wastes. For this cost estimate,  carbon polishing of the
effluent and air emissions is assumed to generate about 12
spent carbon canisters over the course of  the project.
These  canisters  require management  as  potentially
hazardous wastes. Off-site transport and disposal costs for
the spent carbon canisters are assumed to be about $175
per canister, resulting in atotal disposal cost of $2,800 for
the 1-year project. Total costs for disposal of spent carbon
will be highly site-specific, depending on the amount of
carbon required to achieve target cleanup levels.

Total residual waste management costs for Case 1 are
assumed to be about $4,200.
4.4.70
Analytical Services Costs
Sampling frequency and number of samples are site-
specific and will depend on treatment goals, contaminant
concentrations,  and ARARs of applicable federal, state,
and local regulations. This analysis assumes that weekly
samples of untreated water and treated effluent will be
analyzed at an off-site laboratory for VOCs by Method
8240 at a cost of $195 per sample. Case 1 assumes that
standard laboratory batch QA/QC samples (laboratory
blanks, trip blanks, blank spike, and matrix spike/matrix
spike duplicate  [MS/MSD] samples) will be analyzed at
no additional cost, and therefore no additional QC sample
analytical costs will be incurred. (Cases requiring site-
specific, field-prepared MS/MSD, field duplicate, and
blank samples will incur higher analytical costs. Also -
this cost estimate includes only those samples required for
system performance monitoring. Additional groundwater
                                        samples  may  be required  to  monitor  the  overall
                                        effectiveness of  the  remedial program,  resulting in
                                        additional  costs.)      Additional  on-site  analyses
                                        (temperature, pH, DO, COD, and TSS) are performed
                                        using in-line or  field instrumentation, and  incur  no
                                        additional costs other than labor and equipment rental,
                                        which were addressed in other sections. Based on these
                                        assumptions, the analytical costs over a 1-year period are
                                        about $10,100.

                                        4.4.11        Equipment Maintenance
                                                       Costs

                                        Zenon   will provide periodic  routine  equipment
                                        maintenance.  Annual equipment maintenance costs,
                                        excluding labor, are estimated to be about 3 percent of the
                                        capital  equipment costs, for a total of $4,800. Routine
                                        maintenance labor requires about 1 hour per week,  and
                                        occasional backflushing maintenance labor requires about
                                        1 day per month. This results in a total of 148 labor hours
                                        per year.  Billed at $35 per hour, maintenance labor costs
                                        are about $5,200. Total equipment maintenance costs for
                                        Case 1 are estimated to be about $10,000.
                                        4.4.12
               Site Demobilization Costs
Site demobilization includes treatment system shutdown,
disassembly, and decontamination; transportation of the
ZenoGem® equipment and auxiliary equipment off site;
and site cleanup and  restoration.   A two-person crew
earning a total of $70 per hour will work about three 8-hour
days to disassemble and decontaminate the system. This
labor will cost about $1,700. This analysis assumes that
the ZenoGem® equipment will be transported 500 miles at
$2.80 per mile for a total cost of $ 1,400.

Site cleanup and restoration involves decommissioning
piping  and the treatment gallery and optional grading and
reseeding of the treatment area. The extraction well  and
the injection  well will  be left in place for possible
incorporation into long-term monitoring or remediation
programs. The piping between the extraction well and the
treatment  system will be  decontaminated before  the
treatment system is shut down, and will then be removed
and disposed  of as nonhazardous material or scrap.
Minimal regrading and reseeding will be required, as no
permanent concrete pads or structures were used. Total
site restoration costs are estimated to be about $2,000.
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The total assumed cost of demobilization is about $5,100
for Case 1.

4.5    Case 2 Analysis

For Case 2 analysis, the ZenoGem® treatment system is
modular and semipermanent. The system is used to treat
landfill leachate and will be operated for 10 years. Case 2
is presented in order to analyze a purchased system
operating as a long-term wastewater treatment facility.

4.5.1 Issues and Assumptions

This section summarizes major issues and assumptions for
Case 2. Due to the long-term nature of the project, Case 2
required several assumptions to simplify the cost estimate,
consisting of (1) unit variable costs will remain constant
for the 10-year life of the project; (2) costs are not adjusted
for inflation; and (3) depreciation and salvage value were
not included in the cost estimates and do not appear to
significantly affect the overall cost per gallon in this case.
In general, ZenoGem® equipment operating issues and
assumptions are based on information provided by Zenon
and observations made during the SITE demonstration.

4.5.2  Waste Characteristics and Site
        Features

Significant assumptions for site-specific conditions in
Case 2 are the following:

  •  The site is a Superfund site located in the northeastern
    U.S.

  •  The  site is a  landfill  that generates approximately
     1,440 gallons of leachate per day.

  •  A functioning leachate collection system and sump
    exist on  site; however,  no functioning  leachate
    treatment system exists on site.

  •  Contaminants in the leachate can be degraded using
    the ZenoGem* process but will not be toxic to  the
     organisms in the bioreactor.  Contaminants include
     total VOC concentrations of 5,000 mg/L, and COD of
     7,000  mg/L.   Contaminant characteristics remain
     constant over the life of the project.

  •  Health and safety/PPE Level D (minimal) or E  (no
     specific requirements) criteria will apply to  all  site
     activities.
•  The leachate has an initial pH ranging from 8 to 10 that
   needs to be adjusted to 7.5 during treatment.

•  No other pretreatment, such as oil separation or solids
   removal, is necessary.

•  The total volume of leachate to treat is nearly 5.3
   million gallons.   This volume corresponds to the
   volume treated  by  the  modular unit operating
   continuously for 10 years at a flow rate of 1,440 gpd.

•  The site is located in a rural area.

•  Infrastructure  existing on or adjacent to  the  site
   consists of electricity lines,  access roads,  sanitary
   sewer lines, water lines, and a security fence.

•  The ZenoGem® system is mobilized to  the site  from
   within 500 miles of the site in two semitrailers.

4.5.3 Equipment and  Operating
       Parameters

Assumptions   regarding   equipment  and operating
parameters for Case 2 are the following:

 •  The treatment system is operated on a continuous flow
   cycle 365 days per year for a period of 10 years.

 •  The treatment system operates at a flow rate  of 1 gpm
   for a total of about 1,440  gpd or 530,000 gallons per
   year.

 •  The treatment system operates automatically without
   the constant  attention of an operator and  will shut
    down in the event of system malfunction.

 •  One technician will be needed part time to inspect the
    equipment,  collect weekly  samples,  and  conduct
    routine maintenance on the system.

 •  Zenon  performs  additional   maintenance  and
    modification activities paid by the customer.

 •  Initial operator training is provided by Zenon.

 •  Sampling requirements include monthly influent and
    effluent samples, analyzed at an off-site laboratory for
    VOCs, COD, BOD, TOC and metals.   DO, pH, and
    TSS will be  monitored daily through on-site sample
    analysis or in-line instrumentation.
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  •  The system is mobilized to the site and assembled by
     Zenon.

  •  Air emissions will pass through  carbon prior to
     discharge to the atmosphere; air discharge permits and
     air sampling are not assumed to be required

  •  Leachate will be treated and discharged to a sanitary
     sewer for eventual treatment at a local POTW.

 4.6   Case  2 Costs

 This section discusses costs associated with Case 2. The
 subsections below are organized by the same 12 general
 cost categories used in the Case 1 analysis, and correspond
 with the 12 general  categories in Table  4-2, which
 summarizes the cost data.

 4.6.1  Site Preparation Costs

 Site preparation costs include administrative, permitting,
 treatment area preparation, and design costs.  For Case 2,
 administrative costs will be higher than Case  1 due to the
 longer remedial period and scale  of the  project, more
 extensive construction activities,  higher contaminant
 concentrations,  the need for off-site  management of
 treated  effluent,  and  setting  up  standard operating
 procedures for long-term activities (for example, O&M,
 sampling,  and   recordkeeping).    For  this  reason,
 administrative costs related to site preparation for Case 2
 are assumed to  be $20,000.  (Long-term recordkeeping
 costs are discussed in Section 4.6.5, "Labor Costs.")

 Treatment area  preparation  includes  constructing a
 concrete pad and shelter for the unit. It also includes a
 leachate collection system, installing piping, a flow meter,
 and a sewer box for disposal of treated effluent, as well as
 electrical connections.

 The  skid-mounted system is not housed in a protective
 enclosure, so a building with a concrete floor must be
 constructed. The building must be large enough to house
the complete system, including the bioreactor, and should
have additional space for storage of treatment chemicals,
 sampling equipment, and other items. The building should
be temperature-controlled, and have potable water and
electricity available. This estimate assumes that a 500-
square-foot, prefabricated metal building, equipped with a
heating,  ventilation,   and  air  conditioning   system,
electrical power and water supply, could be constructed on
site for $50 per square foot, not including the concrete pad.
 The concrete pad consists of a 500-square-foot, 6-inch-
 thick pad sealed with an epoxy coating, and equipped with
 berms and sumps to contain potentially hazardous spills.
 An unreinforced concrete pad can be built for $25  per
 square foot. Based on these unit costs, total cost for the
 building and concrete slab is estimated to be $37,500.

 State  and federal hazardous waste regulations typically
 require leachate management systems, where applicable,
 for landfills constructed after 1980.  Because this cost
 estimate assumes that the landfill is relatively new, a
 functioning leachate collection system  is assumed to
 already be present on site.  (Costs for leachate collection
 systems are highly site-specific and can vary by several
 orders of magnitude, depending on the size and depth of
 the landfill, volume and characteristics of the leachate to
 be managed, applicable regulations, and other factors.)
 The system is  assumed to consist of a subgrade french
 drain and a 2,000-gallon collection sump with a pump and
 float-level control at the downstream end.  In this case, the
 treatment system will be located near the collection sump,
 so minimal additional piping (100 feet) is required to
 transfer the leachate to the ZenoGem® system.  Costs for
 piping and configuring  the  connection  to the indoor
 treatment system are assumed to be $5,000.

 The  system   will  operate  continuously,   requiring
 continuous management of treated effluent.  This cost
 estimate assumes that injection of the treated effluent is
 practical because the feed waste did not originate in  an
 aquifer.   Assuming the effluent  will meet criteria for
 treatment at a local POTW, discharge to a local sewer
 system may prove to be practical and  economical if
 existing sewer lines and a POTW are nearby. If a sewer
 line does not exist near the site, the effluent may be stored
 and transported to a POTW in tankers; however, over a
 long-term project, this method of effluent management
 would  incur higher costs. This estimate assumes that the
 area near the landfill is serviced by a municipal sanitary
 sewer  line, and that the  line is within 200 feet of the
 treatment system, and the local POTW accepts industrial
 wastewater  into  the system.    Combined costs for
 constructing piping from the system to the sewer  line,
 constructing a junction box with a manhole and flow
 meter,  and connecting the effluent line to the sewer  line,
 are estimated to be about $ 10,000. The local sewer district
may also require a one-time sewer connection fee, which is
 included  under "Permitting and  Regulatory Costs"
(Section 4.6.2).
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Table 4-2. Costs Associated with the ZenoGem® Technology - Case 2
                                    Cost Categories
Itemized Costs
                                                                              Total Cost
          FIXED COSTS:    Site Preparation Costs:
                                 Administrative
                                 Building and Concrete Pad
                                 Connect to Existing Leachate
                                 Effluent Connection to Sewer
                                 Treatability Study
                                 Design Costs
                           Permitting and Regulatory Costs
                           Equipment Costs:
                                 Treatment Equipment
                                 Auxiliary Equipment
                                 Monitoring Equipment
                           Mobilization and Startup Costs:
                                 Treatment Equipment
                                 Labor
                                 Utility Connections
                           Site Demobilization Costs
                           Total Estimated Fixed Costs
        VARIABLE:        Labor Costs (Operating, Admin., and

                           Supply Costs:
                                 Replacement Membranes
                                 Treatment Chemicals
                                 Carbon Columns
                                 PPE
                                 Sampling Supplies
                           Utility Costs (electricity)
                           Effluent Treatment and Disposal
                           Residual Waste Treatment and
                           Analytical Services Costs
                           Equipment Maintenance Costs:
                                  Equipment
                                  Maintenance Labor
                           Total Annual Variable Costs
         TOTAL ESTIMATED FIXED AND VARIABLE COSTS*

         Total Cost per gallon treated"
                   $98,900
      $20,000
       37,500
        5,000
       10,000
        7,500
       18,900
      136,000
        5,300
        7,000

        2,800
        3,900
        3,100
          800
        2,100
        2,000
          200
          300
         4,100
         5,200
                    12,900
                   148,300
9,800
                      1,700
                  $271,600
                   $17,100

                      5,400
                     28,000
                      1,600
                     12,700
                     14,300
                      9,300
                    $88,400
                 $1,155,600

                      $0.22
        Notes:
              • Total over a 10-year period.
              b Total of 5,300,000 gallons treated.
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 As in Case 1, Zenon will conduct a treatability study
 before determining the appropriate design specifications.
 However, for Case 2, the nature of the feed waste is more
 complex than Case 1. For this reason, the treatability study
 is assumed to cost $7,500, including labor and equipment
 costs.

 Design costs include engineering designs for overall site
 layout, building and concrete pad specifications, effluent
 management system, and any other necessary engineering
 services. Treatment equipment design is also included in
 this calculation to account for design modifications Zenon
 may make prior to mobilizing the system.  Total design
 costs for Case 2  are estimated to be 10 percent of the
 combined treatment  area construction costs  (described
 above) and treatment equipment costs. Total design costs
 are estimated to be about $18,900.

 Total site preparation costs for this case are estimated to be
 $98,900.

 4.6.2 Permitting and Regulatory Costs

 Assumed  site-specific  factors that  result  in higher
 permitting  costs  for Case 2  include more  extensive
 construction  activities  and the  need  for  obtaining
 discharge  permits for treated  effluent.   For Case 2,
 permitting costs are estimated to be 8 percent of the capital
 equipment costs (about  $10,900), plus a $2,000 sewer
 connection fee, for a total of $12,900.

 4.6.3 Mobilization and  Startup Costs

 Mobilization and  startup  costs  include the costs of
 transporting the ZenoGem® treatment equipment to  the
 site, assembling the system, connecting up to the leachate
 collection  and  effluent  management  systems  and
 electricity.

For Case 2, the ZenoGem® equipment is  assumed to be
transported 500 miles. A cartage company will be retained
to  transport  the  equipment  hi   two  semitrailers.
Mobilization costs are about $2.80 per  mile for each
trailer, for a total  cost of $2,800. No oversized vehicle
highway permits are assumed to be needed.

As in Case  1,  Zenon will provide  health- and safety-
trained personnel to unload the  equipment, assemble the
ZenoGem® system, connect piping  and electricity, and
shake down the system. A two-person crew charged at a
 total of $70 per hour will work seven 8-hour days to
 assemble the system and perform the initial shakedown.
 The total assembly costs are assumed to be about $7,000,
 including labor and connection costs.

 Total  mobilization and startup costs for  Case  2 are
 estimated to be $9,800.

 4.6.4 Equipment Costs

 Equipment costs include  the costs of purchasing the
 ZenoGem® treatment system, auxiliary equipment, and
 monitoring equipment.  According to Zenon, the  skid-
 mounted treatment system configured for a 1,440 gpd flow
 rate will cost $136,000.

 Auxiliary equipment includes a  6,000-gallon reserve
 holding tank. This tank will serve as a contingency in the
 event  that the  POTW discharge must be  temporarily
 discontinued or the leachate holding sump's capacity is
 exceeded for several days. The cost of this tank is assumed
 to be $5,300.

 Monitoring  equipment  includes  a  pH  meter,
 spectrophotometer, and other miscellaneous analytical
 equipment. This equipment can be purchased for a total
 cost of $7,000.

 Total equipment  costs for Case 2 are assumed to be
 $148,300.

 4.6.5  Labor Costs

 Routine operating labor requirements for Case 2 are
 assumed to be about the same as for Case 1 at 7 hours per
 week. As in Case 1, remote monitoring and alarm systems
 notify Zenon and the on-site operator of malfunctions in
 the system. The more complex nature of the feed waste
 and effluent management system  in Case 2   may
 necessitate more frequent sampling and on-site analytical
 activities. This estimate assumes that these activities will
 require an additional 8 hours per month. Assuming a labor
 charge of $35 per hour, total labor costs  for system
 operation and sampling are estimated to be $ 16,100 over a
 1-year period.  Recordkeeping typically associated  with
remedial actions and POTW discharge limit reporting is
 assumed to require an additional 4 hours per month; these
tasks could be performed by administrative  staff,  at an
average rate of $20 per hour, yielding a total cost of about
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$1,000 each year.  Based on these criteria, total annual
labor costs are assumed to be about $17,100.

4.6.6 Supply Costs

Supplies required  for this  analysis of the ZenoGem®
treatment system include replacement filter membranes
for ultrafiltration (UF) and reverse osmoses (RO) modules
(Case 1 did not require RO modules), treatment chemicals,
carbon columns, disposable PPE, and sampling equipment.
According to Zenon, two UF and four RO membranes will
be replaced every 3 years, equaling a cost of about $550
per year for the UF membranes and $250 per year for the
RO membranes,  or a total of $800 per year.

According to Zenon, annual chemical supply requirements
include 500 liters of pH control (acid) at $0.30 per liter and
2,225  kilograms of caustic pH control at  $0.42 per
kilogram; 40 kg of MC-1 cleaner at $6.89 per kilogram, 60
kilograms of MC-4 cleaner at $ 12.35 per kilogram, and 54
kilograms of phosphorous nutrient at $0.25 per kilogram.
Total estimated annual treatment chemical costs for Case
2 are about $2,100.

Annual carbon  canister requirements for air emission
filtering are assumed to be the same as for Case 1; four
canisters at $500 each, for a total cost of $2,000. The
system demonstrated at the  Nascolite  site indicated
generally high COD removal efficiency (greater than 85
percent) throughout most of the demonstration without
carbon polishing.  For this reason,  this cost estimate
assumes that effluent polishing will not be required to
 meet POTW discharge standards.

 Supplies that will be needed as part of the overall
 groundwater  remediation   project include  Level D
 disposable PPE and sampling and field analytical supplies.
 Disposable PPE typically consists of Tyvek suits, latex
 inner gloves, nitrile outer gloves, and safety glasses. This
 PPE is needed during periodic sampling and maintenance
 activities. Annual disposable PPE costs for this case are
 assumed to be about $200.

 Sampling supplies consist of sample containers, ice,  and
 shipping containers.  For routine on-site monitoring,
 laboratory glassware is also needed. For this case, annual
 sampling supply costs are assumed to be $300.

 Total annual supply costs for Case 2 are estimated to be
 $5,400.
4.6.7 Utility Costs

Electricity is used to run the pumps and blowers of the
treatment system, and for heating, cooling, and lighting in
the treatment system shelter building.  Water is used for
routine cleaning, on-site analyses, and other purposes.
This analysis assumes that electrical power lines and water
lines are available at the site.

Electricity costs can vary considerably depending on the
geographical location of the site and  local utility rates.
This  analysis  assumes a constant rate  of electricity
consumption based on the electrical requirements of the
pumps, mixer, and  blowers.  According to Zenon, the
system assumed for Case 2 would typically require about
800 kWh per day, or 292,000 kWh per year. Electricity is
assumed to cost $0.09 per kWh, including demand and
usage charges.   The total  annual electricity  costs
(excluding lighting and HVAC for the building) for Case 2
are about $26,3 00.  Lighting, heat, and water costs for the
building are assumed to be  about $150 per month,  for a
total cost of $1,800 per year.  These costs result in total
assumed utility costs of about $28,000.

4.6.8  Effluent  Treatment and Disposal
        Costs

For Case 2, cleanup goals are assumed to be acceptable for
disposal at a POTW without carbon polishing.  Based on
data from the SITE demonstration and current engineering
cost guidance, costs for discharge to the sewer and POTW
 are  assumed to be about  $3.00 per thousand gallons.
 Assuming a treatment rate  of 530,000 gallons per year,
 total costs for effluent treatment and disposal are assumed
 to be $1,600.

 The ZenoGem® system produces air emissions that pass
 through  a  carbon  column  prior  to  release to the
 atmosphere. The cost of the carbon column was presented
 in Section 4.6.6. As a result, no cost for air emissions
 treatment is incurred.

 4.6.9 Residual Waste Management
        Costs

 The only  residual waste directly produced  during
 ZenoGem® system operation is a  dewatered sludge.
 Sludge  generation rates are  highly site specific, and
 management  costs can vary  significantly depending on
                                                     52

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 frequency  of  off-site  removal,   characterization,
 transportation costs, disposal requirements, and  other
 factors. For this reason, costs for residual waste disposal
 can vary by orders of magnitude.

 Based on data from the SITE demonstration and additional
 information provided by Zenon, this estimate assumes that
 about 30 tons of dewatered sludge will require disposal
 each  year. This material may require management as a
 hazardous waste. For Case 2, sludge disposal costs are
 assumed to be about $400 per ton, assuming that the sludge
 can be stabilized and landfilled, for a total cost of $ 12,000
 per year.

 Treatment of air emissions is assumed to generate four
 spent carbon columns per year. As in Case 1, spent carbon
 canister disposal costs are assumed to be $ 175 per canister,
 resulting in total annual estimated residual waste disposal
 costs  of $12,700.
4.6.70
Analytical Services Costs
Sampling frequency and number of samples are site-
specific and will depend on treatment goals, contaminant
concentrations, and ARARs of applicable federal, state,
and local regulations. This analysis assumes that weekly
samples of the treated effluent, and monthly samples of the
influent leachate, will be collected and analyzed at an off-
site laboratory. Analyses will include VOCs at a cost of
$180 per sample; total metals at $140 per sample; COD at
$25 per sample; and TOC at $30 per sample. As in Case 1,
Case 2 assumes that standard laboratory batch QA/QC
samples will  be  analyzed at no additional cost, and
therefore no additional QC sample analytical costs will be
incurred. (If required, additional site-specific QC samples
would incur additional costs.) Additional on-site analyses
(temperature, pH, DO,  COD, and TSS) are performed
using in-line  or  field  instrumentation during routine
operations and incur no additional costs other than labor
and equipment rental,  which were  addressed in other
sections.   Based  on these assumptions, the  annual
analytical costs are estimated to be about $14,300.

4.6.11        Equipment Maintenance
               Costs

Annual equipment maintenance costs,  excluding labor,
are assumed to be about 3 percent of the capital equipment
costs, for a total of $4,100. Routine maintenance labor is
assumed to requires about 1 hour per week, and occasional
                                        backflushing requires about 1 day per month, yielding a
                                        total of 148 labor hours per year. At a rate of $3"5 per hour,
                                        maintenance labor costs are about $5,200. Total annual
                                        equipment maintenance costs for Case 2 are $9,300.
                                        4.6.12
               Site Demobilization Costs
 Due to long-term requirements for post-closure care and
 monitoring, Case 2 assumes only minimal demobilization
 activities. Site demobilization includes treatment system
 shutdown, disassembly, and decontamination; treatment
 equipment removal; and site cleanup and restoration.

 A two-person crew earning a total of $70 per hour will
 work  about three  8-hour days to disassemble  and
 decontaminate the system. This labor will  cost about
 $ 1,700. Case 2 assumes that the equipment has no salvage
 value, and no costs for removal or disposal are included.
 However, potential options include resale, scrapping, or
 long-term storage on site as a contingency for future use, if
 the need arises.  For example, RCRA post-closure care
 requires 30-year site maintenance and monitoring in many
 cases. Case 2 also assumes that the influent lines and sewer
 discharge  lines  will  be  plugged  and  temporarily
 abandoned; however, the lines will be left in place in the
 event that they are needed in the future. The building will
 be left on site as a staging and storage area for other site
 activities, such as long-term monitoring and maintenance
 activities.

 Based on these  criteria, total demobilization costs are
 assumed to be about $1,700 for Case 2.  Sites requiring
 more extensive site restoration could  incur significantly
 higher demobilization costs.

 4.7   Conclusions of Economic Analysis

 For Case 1, a rented system operating for a 1 year period
 resulted  in  total fixed and  variable costs  of  about
 $263,800, based on the assumptions described in Section
 4.3.1.  This total results in a cost of $0.50 per gallon of
 groundwater treated. Figure 4-1 and Figure 4-2 shows the
distribution of fixed costs and variable cots for Case 1,
respectively.

For Case 2, the total estimated  costs for the 10-year
 leachate treatment period resulted in  total and variable
costs  of  about $1,200,000, based on the assumptions
described in Section 4.5.1.  This total results in a cost of
$0.22 per gallon of leachate treated. Figure 4-3 and Figure
                                                   53

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4-4 shows the distribution of fixed costs and variable costs
for Case 2, respectively.

For any particular site remediation project, some cost
categories, such as utility and supply costs, are heavily
dependent on the type of remediation system selected.
However, costs for  other  items (such as  groundwater
extraction systems) would be about the same regardless of
the type of system selected. Some site preparation costs
may not be incurred at all sites. Both Case  1 and Case 2
include costs for feed waste retrieval systems (wells or
leachate collection systems); at many sites, these features
may already exist, or alternate collection systems may be
used, resulting in lower costs.  For this reason, costs that
are significantly affected by operation and use of the
ZenoGem® technology are shown in bold in Tables 4-1 and
4-2, and are termed direct costs. Costs are bolded in order
to segregate the direct costs of procuring and operating the
treatment equipment from the total costs associated with a
complete groundwater or leachate treatment project.
                                                      54

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                      $29,500 (64.1 %) Site Preparation
                             $5,000 (10.9%) Permitting
                                                                                     $5,100 (11.1 %) Site Demobilization
$6,400 (13.9%) Mobilization and Startup
    Total estimated fixed costs are $46,000.
Figure 4-1.  Case 1 fixed costs.
              $166,200 (76.4%) Equipment
                                                                                 $10,000 (4.6%) Equipment Maintenance


                                                                               $10,100 (4.6%) Analytical Services

                                                                            $4,200 (1.9%) Residual Waste Disposal
                                                                          $7,400 (3.4%) Utilities
                                                                      $6,800 (3.1%) Supply
                                                                $12,700 (5.8%) Labor
Total estimated variable costs for 1-year period are $217,400.
Figure 4-2.  Case 1 variable costs.
                                                          55

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                                     $1,700 (0.6%) Site Demobilization
               $148,300 (54.6%) Equipment
                                                                                            $98,900 (36.4%) Site Preparation
                                                                                     $12,900 (4.7%) Permitting
                                                                               $9,800 (3.6%) Mobilization and Startup
            Total estimated fixed costs are $271,600.
Figure 4-3. Case 2 fixed costs.
                              $9,300 (10.5%) Equipment Maintenance
                  $14,300 (16.2%) Analytical Services
                $12,700 (14.4%) Residual Waste Disposal

                                 $1,600 (1.8%) Effluent Disposal
                                                                                       $17,100 (19.3%) Labor
                                                                                                 $5,400 (6.1%) Supplies
$28,000 (31.7%) Utilities
                  Total estimated variable costs are $88,400 per year, based on an assumed 10-year operating period.
 Figure 4-4. Case 2 variable costs.
                                                                    56

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                                              Section 5
                                       Technology Status
 Since the development of the ZenoGem® technology in
 1987, Zenon has performed pilot tests and implemented
 full-scale operational systems for government and private
 clients on several different types of wastewater, including
 oily wastewater, metal finishing wastes, aluminum die
 casting wastewater, circuit board finishing rinse, cleaning
 solutions containing detergents, alcohol-based cleaning
 solutions,  landfill  leachate,   aqueous  paint-stripping
 wastes, tannery wastewater, pharmaceutical production
 washdown wastewater,  chemical  and  petrochemical
 manufacturing and process solution wastewater, industrial
 waste transfer station wastewater, glycol deicing fluids,
 and beverage bottling production wastewater.

 In addition, information is available on two demonstrations
 conducted  in Canada and the U.S.  At the Canadian
 Department of National Defense fire fighting school, the
 ZenoGem®  biological  unit   was  demonstrated  on
 wastewater containing burned and unburned fuel residue.
 The system successfully demonstrated the biodegradation
 of aqueous foam  formulation compounds (AFFF) and
 simultaneous removal  of oil and grease, petroleum
 hydrocarbons, and suspended solids.  The system also was
 demonstrated at the Army Material Command Watervliet
 Arsenal, where the  ultrafiltration module treated oily
 wastewater.  Results indicated that the ultrafiltration
 module reduced waste  disposal by  70 percent at a
 significant cost savings.

Each of these processes have one common problem; high
 strength organic contamination. The technology has been
 applied to wastewater streams  ranging from 5,000  mg/L
 COD to 100,000 mg/L COD, and flows which range from
 100 gpd to 250,000 gpd. The effluent from the ZenoGem®
process has met sewer discharge criteria, direct surface
water discharge criteria, and for direct recycle to the plant
in some cases. In instances where direct recycle and reuse
are   important and   the  effluent  requires  polishing,
 additional Zenon technologies can be added to achieve the
 specific recycle objectives.

 Zenon continues  to develop the technology and the
 process.  Recently, Zenon has developed an innovative
 Zee Weed® hollow fiber member as an alternative to the
 PermaFlow® tubular membrane. Unlike the conventional
 skid mounted PermaFlow® tubular membrane system, the
 follow fiber Zee Weed® membrane is designed for direct
 installation within  existing equalization,  aeration  or
 clarification systems.  The elimination of skid mounted
 capital equipment reduces capital expenditures as well as
 valuable plant floorspace. The Zee Weed® membrane is an
 absolute barrier to the passage of biomass and TSS, like
 the Zenon PermaFlow® tubular membrane,  but requires
 only a fraction of the horsepower for the  same flowrate.
 This membrane has been installed in many industrial and
 municipal  wastewater  treatment  plants,  providing
 significant operational savings. Its ability to be installed
 within existing clarification systems and aeration lagoons,
 along with it's low power consumption requirements, has
 launched its use into large-scale  municipal wastewater
treatment plants.

The use of the patented ZenoGem® technology in place of
conventional biological treatment technologies is expected
to increase.   The technology has been proven to be
effective, and economically viable in a  wide range  of
applications and markets.  As industry changes to meet
new demands for product, new and more  complicated
wastewater treatment problems will continue to emerge.
The ZenoGem® technology  with the PermaFlow®  or
Zee Weed® membrane is well suited to meet these needs.
                                                   57

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                                         Section 6
                                        References
U.S. Environmental Protection Agency (EPA). 1994.
   "ZenoGem®  Process   SITE  Program  Final
   Demonstration Test Plan." Submitted to EPA ORD,
   Cincinnati, Ohio. November.

EPA.  1988a.  Protocol for a Chemical  Treatment
   Demonstration Plan. Hazardous Waste Engineering
   Research Laboratory. Cincinnati, Ohio. April.

EPA.   1988b.  CERCLA  Compliance  with Other
   Environmental Laws: Interim Final. OSWER. EPA/
   540/G-89/006. August.

Evans, G.  1990.  "Estimating Innovative Treatment
   Technology Costs for the SITE Program." Journal of
   Air and Waste Management Association. Volume 40,
   Number?. July.

U.S. Department of Energy. 1988. Radioactive Waste
   Management Order. Department of Energy Order
   5820.2A. September.
                                                58

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                                            Appendix A
                                          Vendor Claims
(Note: All information in this appendix was provided by
the vendor, Zenon Environmental Inc.  Inclusion of any
information is at the discretion of Zenon, and does not
necessarily constitute U.S.  Environmental Protection
Agency concurrence or endorsement.)

A.1  Introduction

Zenon Environmental  Inc.  (Zenon)  developed the
ZenoGem® process to remove organic compounds from
wastewater.   The ZenoGem®  system consists  of a
suspended growth, activated sludge system (bioreactor)
integrated with an ultrafiltration (UF) membrane system.
The UF filters the treated water prior to discharge and the
system recycles the biological solids back to the bioreactor
and recovers higher- molecular-weight soluble materials
that would otherwise pass through conventional clarifiers
and filters.  These higher-molecular-weight materials are
returned to the bioreactor for further biodegradation prior
to ultimate discharge.

Ultrafiltration  is a pressure-driven, cross-flow filtration
process in which water to be processed flows tangentially
over the surface of amembrane filter capable of separating
both insoluble materials (bacteria, colloids, emulsions,
suspended solids)  and higher-molecular-weight soluble
materials from the treated water. The filtrate and retentate
are commonly referred to  a permeate and  concentrate,
respectively.    In  addition to  cross-flow  filtration,
alternative vacuum based membrane separation systems
using Zenon's patented Zee Weed® membranes are also
integrated with the bioreactor in the ZenoGem® process
configuration.   These  Zee Weed®   membranes  offer
significant  economic advantages over  the cross-flow
filtration  configuration particularly at higher wastewater
flow rates.  In addition, since the membrane is installed
directly into the bioreactor, operating facilities may be
expanded by  three to six times their original design
 loading without significant alterations to the existing civil
 works.

 The threshold size above which organics are retained by
 the membrane and below which they pass through the
 membrane is called the molecular weight cut-off. This
 value ranges between 0.003 microns to 0.1 microns for
 ultrafiltration membranes and depends on the  specific
 membrane chemistry and pore size. Integrated membrane
 bioreactor technology has advanced quickly in recent
 years  as   improved  membrane  chemistries  and
 configurations have produced modules with higher fluxes
 and lower fouling potential.

 A.2   Advantages of the ZenoGem®
       Process

 The ZenoGem® process  has the following specific and
 significant technical advantages over alternative oxidation
 processes such as activated sludge with clarifiers, fixed
 film bioreactors, fluidized bed bioreactors or physical-
 chemical treatment.

A.2.1 Process Less Vulnerable to Upsets

 The most common problem encountered in conventional
biological systems is the loss of biological solids because
 of process upsets or changes in the hydraulic or organic
 loading.  In a  conventional activated sludge  system,
 clarifier performance depends on the settleability of the
floe. If an upset occurs and a difficult-to-settle "pin floe"
or "filamentous floe" forms, the biological solids can
easily be lost.  In the short term, an  effluent  high in
suspended solids and BOD5 will be produced. The effluent
BOD5 will remain high until the biological population has
been restored.  If an upset occurs in a fixed film-type
biological system (rotating biological contractor, fluidized
bed) and sloughing occurs, these solids  can be lost from
                                                   59

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the system resulting in poor quality effluent.

In the ZenoGem® process, the effluent quality does not
depend on the settleability of the biological floe.  The
biological solids will be retained even if an upset occurs in
the bioreactor. The UF membranes are very robust and
experience has proven that the risk of failure resulting in
the loss of biological solids is very remote.

A.2.2 Improved Effluent Quality

The ultrafiltratic-n membrane provides virtually absolute
suspended solid-liquid separation, thus preventing the loss
of biological solids in the effluent. Furthermore, certain
organics, including free and emulsified oil and grease, are
retained thereby further improving the effluent quality.

A.2.3 Reduced Sludge Production

In contrast  with  other  biological  waste treatment
processes, the volume of sludge produced is significantly
reduced and operation at high solids retention times (up to
 100 days) is possible.

A.2.4 Improved Biological Degradation
        of Retained Organics

Soluble organics in the wastewater of a size greater than
the membrane molecular weight cut-off are retained in the
bioreactor for a period of 15 to 50 times longer than the
hydraulic retention time of the bioreactor (based on
wastewater  flow rate).   As a result, the biological
 population has a longer time to mineralize the organics and
 better degrade them.

 A.2.5 Accurate Control  of Sludge Age

 Because virtually no solids  are  lost from the permeate
 (discharge) stream and the wasting of biological solids is
 strictly restricted, the sludge age can be very accurately
 controlled, and bioreactor performance can be optimized
 to the specific wastewater characteristics.  Ammonia also
 may be removed through nitrification.

 A.2.6 Improved Oxygen Transfer
        Efficiency

 Oxygen transfer in ZenoGem® systems is improved over
 competitive systems because the biological cells  in the
bioreactor are more dispersed and oxygen diffuses more
rapidly to all the cells. In competitive systems, oxygen
transfer to the cells at or near the center of a floe or near the
surface of a fixed film system is restricted by the cells in
the immediate vicinity.  With improved oxygen transfer
efficiency, less aeration is required and operating costs are
reduced.

A.2.7 Smaller Bioreactor Size

Since settleability  of sludge is  not a concern in the
ZenoGem®  process,  high   biomass  levels  can  be
maintained within the bioreactor. Whereas conventional
bioreactors  cannot maintain higher than 5,000 - 10,000
milligrams per liter (mg/L) of bacteria, measured as mixed
liquor volatile suspended solids (MLVSS), the ZenoGem®
process is operated at 20,000 - 30,000 mg/L MLVSS. This
difference means that the ZenoGem® bioreactor can be
three to six times smaller than a conventional bioreactor,
or the same size bioreactor can handle three to six times
more wastewater provided adequate aeration in supplied.

A.3  Application of ZenoGem7 Process

The ZenoGem® technology has developed quickly in
recent years  as improved  membrane chemistries and
configurations have produced modules with higher fluxes
and lower fouling potentials. The ZenoGem® process is
ideally suited for anyone or more of the following:

   •   Wastewater containing significant quantities of
   emulsified oil and grease

   •   Wastewater containing suspended solids that do
   not settle easily

   •   Conventional treatment processes cannot
   produce an effluent that consistently meets the
   discharge requirements

        Sludge disposal costs contribute significantly to
   the treatment cost

   •    Treated water may be reused within the plant as
   make-up water

   •    A long solids retention time is desirable

   •    Physical retention of certain soluble components
    is critical to achieving the treatment objectives
                                                   60

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   •    Wastewater contains potentially inhibitory or
   complex organic compounds

   •    The current biological treatment process re-
   quires upgrading or expansion
 A.4 Case Studies

 A.4.1 Landfill Leachate Treatment -
        Dectra-Lairnont, France

 Dectra-Laimont is a 9-hectare Class I landfill in France
 that began operations in 1983.  Since 1987, the landfill
 received wastes only from  local chemical and metal
 processing industries. Leachate is pumped from ten shafts
 at various locations throughout the site to a 1500 cubic
 meters (m3)-capacity aerated holding pond. Each  day,
 approximately 10 m3 of leachate is produced.  Effluent
 discharge from the site is direct to surface water and
 consequent discharge criteria are strict. In addition, the
 leachate composition is variable with frequent fluctuations
 in organic strength and other compounds.

 A.4.2 GM Mansfield

 Zenon installed a ZenoGem® system followed by double-
 pass reverse osmosis to treat the leachate and discharge
 direct to  the  environment.   The  ZenoGem®  system
 operated  at GM's  Cadillac Luxury Car  Division in
 Mansfield, Ohio to treat 40,000  gallons per day of oily
 wastewater from tooling, cooling tower blowdown, steam
 cleaning booths, baler house, floor washing, and boiler
 blowdown.    The wastewater  contained  primarily
 emulsified oil and  grease, suspended solids, and heavy
 metals.

 The wastewater is directed through grit screens for gross
 solids removal followed by free oil removal by corrugated
 plated interceptors.  The wastewater then flows to an
 equalization tank and finally to the ZenoGem® bioreactor.
Urea  and  phosphoric acid  are  added  as  nutrient
supplements and sodium hydroxide is used to adjust the
PH.

The  system was  commissioned  in  1992  and  has
consistently met  or exceeded  discharge criteria as
illustrated  in Table A-l.  The ZenoGem® system is
 particularly amenable to the treatment of oily wastewater
 because the ultrafiltration membrane rejects the high-
 molecular-weight oil and grease and keeps the material in
 the bioreactor for the entire sludge retention time, not just
 the hydraulic retention time like conventional clarifier
 based activated sludge systems. This advantage allows
 microorganisms more time to mineralize the oil and grease
 and leads to an extremely high-quality effluent.

 A.4.3 Closed-Loop, Zero-Discharge
        ZenoGem7/RO System, Saltillo,
        Mexico

 Zenon designed, manufactured and  installed a closed-
 loop, zero-discharge system for Chrysler Mexico's engine
 manufacturing plant in Saltillo, Mexico.  The plant treats
 as much as 40,000 gallons per day of oily wastewater of
 sufficient quality that it can be recycled directly within the
 plant. The ability to recycle wastewater is extremely
 important in Saltillo as the fresh water is limited tp
 groundwater.   Continued  discharge of even  mildly
 contaminated effluent would eventually seriously impact
 the aquifer.

 In the process, free oil is removed and the wastewater is
 directed to the ZenoGem® system, where the oil and grease
 and  other  organic  fractions  are  removed.     The
 ultrafiltration permeate is then directed  to a reverse
 osmosis  unit for  polishing and removal of dissolved
 inorganics and metals. The unit has  been operating for
 over 1 year, producing high-quality water for reuse in the
 engine manufacturing plant.

 Based on the performance data presented in Table A-2 the
 ZenoGem® unit is extremely effective at the removal of
 COD while the RO simply provides final polishing.

A.5  ZenoGem® Installations

The following table presents a summary of some  of the
full-scale ZenoGem®  installation that  are operating on a
variety of different wastewaters worldwide.
                                                  61

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Table A-1. GM Mansfield ZenoGem® Performance
         Parameters
Feed (mg/L)
ZenoGem®
Permeate (mg/L)
Discharge
Criteria (mg/L)
COD
BOD
TO&G
TPH
5539
-
1330
1220
631
91
15
9

200
50
35
Table A-2. Chrysler Mexico ZenoGem8/ RO Performance
            Parameter
    Feed
 ZenoGem®
 Permeate
 RO
 Permeate
            COD
    3100 mg/L
 390 mg/L
 7 mg/L
 Table A-3. Summary of ZenoGem® Installations
Plant
GM Windsor, Ontario, Canada
GM Mansfield, Ohio, USA
Chrysler Mexico, Saltillo, Mexico
GM Ramos Arizipe, Mexico
Secifarma, Milan, Italy
Ferrero, Milan, Italy
Driesen Tannery, Netherlands
Recept Composting, Netherlands
Dectra Landfill, France
Oriick Industries, Ontario, Canada
IBM, Toronto, Ontario
Wastewater
Oily
Oily
Oily
Oily
Pharmaceutical
Food
Tannery
Leachate
Leachate
Oily
Spent Cleaner
Capacity
fapd)
260,000
40,000
40,000
40,000
32,000
27,000
26,000
7,000
3,000
2,000
1,000
                                               62

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     Appendix B
Summary of Field Data
         63

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Table B-1. September Reid Measurements
TEMPERATURE (Degrees Celsius}
02-Sep-94
03-Sep-94
04-Sep-94
05-Sep-94
06-Sep-94
07-Sep-94
08-Sep-94
09-Sep-94
10-Sep-94
11-Sep-94
12-Sep-94
13-Sep-94
14-Sep-94
15-Sep-94
16-Sep-94
17-Sep-94
18-Sep-94
19-Sep-94
20-Sep-94.
21-Sep-94
22-Sep-94
23-Sep-94
24-Sep-94
25-Sep-94
26-Sep-94
27-Sep-94
28-Sep-94
29-Sep-94
26
24
25
26
28
28
27
28
29
27
26
26
28
27
26
26
25
27
24
NA
25
27
25
29
24
25
24
23
31
31
31
31
32
33
32
32
32
31
32
33
35
32
32
32
32
33
33
NA
32
33
31
31
29
30
32
31
30
31
31
31
32
33
32
32
33
32
32
34
35
32
32
32
32
33
33
NA
32
33
31
31
32
32
32
33
34
S4
31
30
31
31
32
33
32
32
33
32
31
33
35
32
33
32
33
33
32
NA
33
34
32
31
31
31
32
33
S1
6.39
6.34
6.41
6.23
6.28
6.27
6.22
6.14
5.92
6.13
6.21
6.28
6.17
6.30
5.86
6.01
5.94
6.17
6.32
NA
6.10
6.09
6.40
6.47
6.45
6.75
6.27
6.34
pH
S2
7.73
7.71
7.70
7.64
7.50
7.26
7.31
7.32
6.80
6.70
6.82
7.07
7.16
7.32
7.00
6.94
6.93
7.21
7.42
NA
7.18
7.14
7.30
7.32
7.22
7.34
7.06
6.94
6.79
S3
7.75
7.80
7.75
7.66
7.51
7.24
7.40
7.31
6.83
6.73
6.72
7.05
7.31
7.42
7.16
7.16
7.44
7.19
7.22
NA
7.33
7.29
7.34
7.45
7.26
7.59
7.16
7.20
6.93
S4
7.98
8.01
7.94
7.85
7.65
7.38
7.72
7.45
6.95
6.88
7.03
7.27
7.91
7.56
7.09
7.32
7.13
7.70
7.40
NA
7.50
7.51
7.44
7.58
7.56
7.84
7.31
7.29
7.04
DISSOLVED OXYGEN (mg/L)
S1 S2 S3
8.10
4.70
2.30
2.80
1.90
1.90
1.90
2.00
2.00
1.40
1.70
2.30
1.60
3.60
3.40
3.80
3.00
3.00
4.50
NA
2.00
3.50
2.40
5.30
2.30
2.70
3.10
5.50
5.80
0.10
0.00
0.00
0.00
0.00
0.10
1.00
0.50
1.00
1.10
0.00
0.10
0.40
1.00
0.70
0.80
1.20
0.10
0.30
NA
0.30
0.90
1.00
0.70
0.80
0.80
0.80
0.60
0.70
0.30
0.00
0.00
0.00
0.00
0.10
2.00
0.50
1.40
0.80
0.00
0.00
0.00
1.00
0.80
0.80
1.00
0.00
0.50
NA
0.80
1.40
1.20
1.40
1.40
0.60
0.60
0.40
0.80
S4
8.20
5.20
5.60
5.70
5.00
4.00
4.50
4.50
2.50
2.50
3.90
2.30
2.50
6.00
4.60
2.90
4.00
3.20
3.70
NA
3.30
2.80
3.70
7.70
2.90
2.30
3.10
3.90
2.80
  S = Sampling Port

-------
Table B-2. October Field Measurements
DATE
01-Oct-94
02-Oct-94
03-Oct-94
04-Oct-94
05-Oct-94
06-Oct-94
07-Oct-94
08-Oct-94
09-Oct-94
10-Oct-94
11-Oct-94
12-Oct-94
13-Oct-94
14-Oct-94
15-Oct-94
16-Oct-94
17-Oct-94
18-Oct-94
19-Oct-94
20-Oct-94
21-Oct-94
22-Oct-94
23-Oct-94
24-Oct-94
25-Oct-94
26-Oct-94
27-Oct-94
28-Oct-94
29-Oct-94
30-Oct-94
TEMPERATURE (degrees Celsius)
S1 S2 S3
24
25
23
23
22
26
28
23
23
23
25
20
22
23
23
21
22
22
23
22
24
24
26
25
24
24
22
22
25
25
32
34
32
31
29
28
31
30
31
31
28
29
31
30
31
34
34
33
33
34
33
32
34
33
31
31
26
27
34
31
33
34
32
32
30
30
31
31
33
32
29
30
32
30
33
35
35
34
35
34
34
32
35
34
35
32
33
34
33
34
S4
33
34
31
32
30
30
32
31
33
32
29
30
31
30
34
34
34
34
35
34
34
32
34
34
34
32
33
33
34
33
S1
6.36
6.48
6.92
6.34
5.76
6.08
6.21
6.08
6.05
6.04
6.28
6.67
6.74
6.62
6.72
6.18
6.42
6.44
6.34
6.44
6.40
-6.42
6.22
6.36
6.44
6.28
6.14
6.08
6.23
6.34
pH
S2
7.10
7.08
7.66
6.99
6.46
6.53
6.47
6.40
6.07
6.09
6.84
6.83
6.98
6.84
6.93
6.94
7.05
7.01
6.93
6.87
6.93
6.89
7.04
7.06
7.14
6.54
6.74
6.82
7.39
7.55
S3
7.10
7.20
7.73
7.32
6.73
6.82
6.93
6.70
6.80
6.92
6.97
6.71
7.08
6.96
7.10
7.00
7.00
7.07
6.99
7.03
7.04
7.01
7.10
7.15
7.26
6.94
7.15
7.12
7.47
7.52
S4
7.25
7.29
7.91
7.24
6.96
7.14
7.21
6.56
6.90
7.03
7.35
7.05
7.42
7.23
7.38
7.06
7.04
7.09
7.14
7.13
7.10
7.14
7.15
7.20
7.22
7.14
7.17
7.20
7.57
7.79
DISSOLVED OXYGEN (mg/L)
3.60
3.10
5.00
4.70
3.90
3.60
3.80
3.50
4.20
3.40
3.20
4.60
3.60
3.60
4.20
5.50
2.70
3.60
3.20
3.60
3.80
2.80
3.70
2.80
5.60
3.30
3.07
3.02
3.30
3.60
0.80
0.40
0.00
0.00
0.70
0.80
0.70
0,60
0.70
0.00
0.10
0.60
0.80
0.90
0.80
0.00
0.70
0.70
0.40
0.70
0.90
0.70
0.60
0.70
0.80
0.90
0.00
0.00
0.60
0.00
0.50
0.70
0.10
0.00
0.80
0.60
0.80
0.80
0.90
0.00
0.00
0.90
0.90
1.00
0.60
0.00
0.90
0.80
0.90
1.00
0.60
0.40
0.80
1.00
1.00
0.60
0.00
0.00
0.40
0.00

1.40
2.00
2.50
2.40
4.10
2.90
2.70
2.00
3.20
2.20
1.20
2.50
2.40
4.20
3.20
3.80
0.70
1 10
1 * I v
2.40
4.10
4.10
3.10
2.00
3.20
7.70
3.90
1.22
1.62
5.30
3.50
    S = Sampling Port

-------
Table B-3. November Reid Measurements
                        TEMPERATURE (Degrees Celsius)
                                                                           PH
                                                                                                          DISSOLVED OXYGEN (mg/L)
                                                                             S3
                                                                                     S4
                                                                                            S10
                                                                                                    S1
                                                                                                            S2
                                                                                                                    S3
                                                                                                                            S4
                                                                                                                                   S10
DATE
OI-Nov-94
02-Nov-94
OS-Nov-94
04-Nov-94
05-Nov-94
OS-Nov-94
07-Nov-94
OS-Nov-94
09-Nov-94
IO-Nov-94
11-Nov-94
12-Nov-94
13-Nov-94
14-NOV-94
15-Nov-94
16-Nov-94
17-Nov-94
18-Nov-94
19-Nov-94
20-Nov-94
21-NOV-94
22-NOV-94
23-NOV-94
S1
23
22
22
28
24
24
21
22
25
23
22
21
24
23
24
23
23
22
24
36
21
22
24
sz
34
31
34
34
33
34
35
36
37
36
38
33
37
39
37
35
33
39
32
32
34
32
33
aj
35
32
34
34
34
35
36
37
37
37
38
36
39
39
40
33
37
39
39
37
38
36
36
39
33
34
34
33
34
36
38
39
37
37
37
39
39
39
38
36
39
39
36
38
36
35
22
• 40
20
32
24
33
10
13
12
5
6.40
6.35
6.45
6.31
6.47
6.50
6.16
6.17
6.15
6.38
6.03
6.14
6.22
6.53
6.61
6.33
6.44
6.36
6.36
6.50
6.46
6.30
6.36
7.37
7.21
7.29
7.58
7.23
7.32
7.29
7.46
7.47
7.76
7.51
7.57
7.67
7.85
7.96
7.92
7.94
7.81
7.41
7.52
7.83
7.28
7.75
7.41
7.21
7.32
7.52
7.25
7.35
7.31
7.50
7.52
7.82
7.54
7.65
7.69
7.79
8.02
8.00
7.98
7.84
7.79
7.72
7.98
7.33
7.80
7.42
7.26
7.44
7.65
7.30
7.35
7.34
7.60
7.59
7.83
7.63
7.66
7.84
7.94
8.03
8.07
8.05
7.98
7.81
7.74
8.05
7.38
7.96
MA
7.74
NA
7.75
NA
NA
7.72
NA
7.61
NA
7.81
NA
NA
7.91
NA
8.09
NA
8.21
NA
NA
8.18
NA
8.00
2.85
2.47
3.67
0.65
4.07
3.83
4.38
4.89
6.14
5.74
10.27
6.48
6.99
3.80
6.15
7.59
6.23
4.50
5.73
4.30
6.47
6.69
NA
0.00
0.00
0.00
0.00
0.01
0.01
0.00
0.01
0.00
0.00
0.00
0.01
0.01
0.00
0.02
0.01
0.03
0.00
0.06
0.07
0.09
0.00
0.01
0.00
0.00
0.02
0.00
0.02
0.01
0.04
0.01
0.43
0.56
0.02
0.03
0.02
0.01
0.16
0.11
0.02
0.01
0.04
0.50
0.00
0.00
0.01
1.05
1.16
2:25
3.75
2.05
2.83
2.04
2.24
4.95
2.83
3.76
2.76
2.75
2.84
2.59
2.63
1.67
0.74
1.55
2.24
2.53
1.18
0.77
NA
1.93
NA
0.66
NA
NA
4.20
NA
6.10
NA
6.74
NA
NA
2.15
NA
5.08
NA
3.24
NA
NA
6.07
NA
3.09
     S = Sampling Port

-------
Table B-4. Total Liquid Flow of Influent Stream (M1)
Date
02-Sep-94
03-Sep-94
04-Sep-94
05-Sep-94
06-Sep-94
07-Sep-94
08-Sep-94
09-Sep-94
10-Sep-94
l.l-Sep-94
12-Sep-94
13-Sep-94
14-Sep-94
15-Sep-94
16-Sep-94
17-Sep-94
18-Sep-94
19-Sep-94
20-Sep-94
21-Sep-94
22-Sep-94
23-Sep-94
24-Sep-94
25-Sep-94
26-Sep-94
27-Sep-94
28-Sep-94
29-Sep-94
30-Sep-94
Ol-Oct-94
02-Oct-94
03-Oct-94
04-Oct-94
05-Oct-94
06-Oct-94
07-Oct-94
08-Oct-94
09-Oct-94
10-Oct-94
ll-,Oct-94
12-Oct-94
13-Oct-94
14-Oct-94
15-Oct-94
16-Oct-94
17-Oct-94
Pump Reading (percent gpm)
07:00 am 11:00 am 3:00 am
1
1
1
1
1
1
0.25
0.25
0.25
0.25
0.25
0.25
0.25
0.26
0.26
0.25
0.26
0.26
0.26
0
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
1
1
1
1
1
1
0.25
0.25
0.25
0.25
0.25
0.25
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
1
1
1
1
1
1
0.25
0.25
0.25
0.26
0.25
0.25
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
, 0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
Average
1
1
1
1
1
1
0.250
0.250
0.250
0.253
0.250
0.250
0.257
0.260
0.260
0.257
0.260
0.260
0.260
0
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
Calculated Flow Daily Flow
(anm)* (Liters)
0.692
0.692
0.692
0.692
0.692
0.692
0.360
• 0.360
0.360
0.361
0.360
0.360
0.363
0.364
0.364
0.363
0.364
0.364
0.364
0
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
3,772
3,772
3,772
3,772
3,772
3,772
1,961
1,961
1,961
1,969
1,961
1,961
1,977
1,985
1,985
1,977
1,985
1,985
1,985
0
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
1,985
Daily Flow
996
996
996
996
996
996
518
518
518
520
518
518
522
524
524
522
524
524
524
0
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
                                                         67

-------
Table B-4. Total Liquid Flow of Influent Stream (M1) (continued)
Pump Reading (percent gpm)
Date 07:00 am 11:00 am 3:00 am
18-Oct-94
19-Oct-94
20-Oct-94
21-Oct-94
22-Oct-94
23-Oct-94
24-Oct-94
25-Oct-94
26-Oct-94
27-Oct-94
28-Oct-94
29-Oct-94
30-Oct-94
31-Oct-94
Ol-Nov-94
02-Nov-94
03-Nov-94
04-Nov-94
05-Nov-94
06-Nov-94
07-Nov-94
08-Nov-94
09-Nov-94
10-Nov-94
ll-Nov-94
12-Nov-94
13-Nov-94
14-Nov-94
15-Nov-94
16-Nov-94
17-Nov-94
18-Nov-94
19-Nov-94
20-Nov-94
21-Nov-94
22-Nov-94
23-Nov-94

0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.18
0.18
0.41
0.41
0
16

0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.2
0.26
0.18
0.18
0.41
0.41
0
0

0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.26
0.2
0.18
0.18
0.41
0.41
0
0

Calculated Flow Daily Flow Daily Flow
Average (gpm)* (Liters) (gallons)
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.260
0.240
0.240
0.1 8Q
0.180
0.410
0.410
0.000
5.333

0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.364
0.355
0.355
0.329
0.329
0.431
0.431
0.000
2.612

1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1985
1937
1937
1792
1792
2347
2347
0
6228
175,831
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
524
512
512
473
473
620
620
0
1645
46,455
                                                           68

-------
Table B-5.  Total Liquid Flow of Effluent Stream (M4)
Date
02-Sep-94
03-Sep-94
04-Sep-94
05-Sep-94
06-Sep-94
07-Sep-94
08-Sep-94
09-Sep-94
10-Sep-94
ll-Sep-94
12-Sep-94
13-Sep-94
14-Sep-94
15-Sep-94
16-Sep-94
17-Sep-94
18-Sep-94
19-Sep-94
20-Sep-94
21-Sep-94
22-Sep-94
23-Sep-94
24-Sep-94
25-Sep-94
26-Sep-94
27-Sep-94
28-Sep-94
29-Sep-94
30-Sep-94
Ol-Oct-94
02-Oct-94
03-Oct-94
04-Oct-94
05-Oct-94
06-Oct-94
07-Oet-94
08-Oct-94
09-Oct-94
10-Oct-94
ll-Oct-94
12-Oct-94
13-Oct-94
14-Oct-94
15-Oct-94
16-Oct-94
17-Oct-94
Pump
7:00 am
0.5
0.53
0.54
0.53
0.33
0.1
0.1
1.04
1.06
0.88
0.78
0.67
0.69
0.64
0.5
0.58
0.6
0.58
0.52
0
0.5
0.58
0.55
0.53
0.55
0.52
0.43
0.36
0.47
0.47
0.48
0.47
0.52
0.52
0.41
0.42
0.39
0.36
0.39
0.31
0.45
0.45
0.48
0.53
0.57
0.53
Reading
11:00 am
0.51
0.555
0.53
0.5
0.28
0.1
0.1
1.12
0.97
0.89
0.77
0.69
0.64
0.6
0.58
0.6
0.6
0.54
0.5
0
0.49
0.49
0.58
0.56
0.47
0.53
0.4
0.32
0.41
0.47
0.47
0.46
0.46
0.48
0.42
0.42
0.38
0.36
0.42
0
0.45
0.46
0.46
0.55
0.53
0.53
(gpm)
3:00 am
0.47
0.52
0.53
0.52
0.26
0.1
0.1
1.06
0.98
0.89
0.69
0.67
0.65
0.65
0.6
0.58
0.6
0.52
0.48
0
0.48
0.48
0.58
0.55
0.54
0.58
0.39
0
0.43
0.47
0.46
0.5
0.42
0.46
0.44
0.46
0.4
0.46
0.43
0.76
0.45
0.58
0.51
0.5
0.54
0.53
Average Flow
(gpm)
0.49
0.54
0.53
0.52
0.29
0.10
0.10
1.07
1.00
0.89
0.75
0.68
0.66
0.63
0.56
0.59
0.60
0.55
0.50
0.00
0.49
0.52
0.57
0.55
0.52
0.54
0.41
0.34
0.44
0.47
0.47
0.48
0.47
0.49
0.42
0.43
0.39
0.39
0.41
0.54
0.45
0.50
0.48
0.53
0.55
0.53
Calculated
Flow (gpm)*
0.485
0.526
0.524
0.508
0.285
0.098
0.098
1.055
0.986
0.872
0.734
0.665
0.649
0.619
0.550
0.577
0.590
0.537
0.491
0.000
0.482
0.508
0.560
0.537
0.511
0.534
0.400
0.334
0.429
0.462
0.462
0.469
0.459
0.478
0.416
0.426
0.383
0.387
0.406
0.526
0.442
0.488
0.475
0.518
0.537
0.521
Daily Flow
(Liters)
2643
2866
2857
2768
1554
536
536
5750
5375
4750
4000
3625
3536
3375
3000
3143
3214
2929
2679
0
2625
2768
3054
2929
2786
2911
2179
1821
2339
2518
2518
2554
2500
2607
2268
2322
2089
2107
2214
2866
2411
2661
2589
2822
2929
2839
Daily Flow
(Gallons)
698
757
755
731
410
142
142
1519
1420
1255
1057
958
934
892
793
830
849
774
708
0
694
731
807
774
736
769
576
481
618
665
665
675
661
689
599
613
552
557
585
757
637
703
684
745
774
750
                                                        69

-------
Table B-5. Total Liquid Flow of Effluent Stream (M4) (continued)
Pump Reading (gpm) Average Flow
Date 7:00 am 11:00 am 3:00 am (gpm)
18-Oct-94
19-Oct-94
20-Oct-94
21-Oct-94
22-Oct-94
23-Oct-94
24-Oct-94
25-Oct-94
26-Oct-94
27-Oct-94
28-Oct-94
29-Oct-94
30-Oct-94
31-Oct-94
Ol-Nov-94
02-Nov-94
03-Nov-94
04-Nov-94
05-Nov-94
06-Nov-94
07-Nov-94
08-Nov-94
09-Nov-94
lO-Nov-94
ll-Nov-94
12-Nov-94
13-Nov-94
14-Nov-94
15-Nov-94
16-Nov-94
17-Nov-94
18-Nov-94
19-Nov-94
20-Nov-94
21-Nov-94
22-Nov-94
23-Nov-94

0.45
0.49
0.46
0.49
0.5
0.53
0.5
0.51
0.51
0.5
0.52
0.54
0.54
0.66
0.79
0.8
0.81
0.73
0.78
0.69
0.88
0.95
1
0.97
1.02
1.01
1.02
0.99
0.7
0.95
0.96
1.06
1.02
0.94
0.75
0.7
0.42

0.48
0.47
0.46
0.47
0.48
0.52
0.51
0.49
0.5
0.5
0.56
0.55
0.59
0.68
0.77
0.8
0.79
0.79
0.77
0.76
0.87
0.97
0.98
0.99
1.01
1.01
1.04
1.03
0.85
0.98
0.92
1.09
0.91
0.9
0.69
0.52
0.41

0.47
0.45
0.44
0.48
0.52
0.51
0.5
0.49
0.5
0.51
0.51
0.54
0.61
0.71
0.8
0.81
0.76
0.73
0.8
0.82
0.91
0.99
1
0
1.03
0.94
1.03
0.92
0.83
1
0.95
1.04
1.01
0.77
0.69
0.4
0

0.47
0.47
0.45
0.48
0.50
0.52
0.50
0.50
0.50
0.50
0.53
0.54
0.58
0.68
0.79
0.80
0.79
0.75
0.78
0.76
0.89
0.97
0.99
0.98
1.02
0.99
1.03
0.98
0.79
0.98
0.94
1.06
0.98
0.87
0.71
0.54
0.42

Calculated
Flow (gpm)*
0.459
0.462
0.446
0.472
0.491
0.511
0.495
0.488
0.495
0.495
0.521
0.534
0.570
0.672
0.773
0.790
0.773
0.737
0.770
0.744
0.872
0.953
0.976
0.963
1.003
0.970
1.012
0.963
0.780
0.960
0.927
1.045
0.963
0.855
0.698
0.531
0.408

Daily Flow
(Liters)
2500
2518
2429
2572
2679
2786
2697
2661
2697
2697
2839
2911
3107
3661
4215
4304
4215
4018
4197
4054
4750
5197
5322
5250
5465
5286
5518
5250
4250
5233
5054
5697
5250
4661
3804
2893
2223
270,221
Daily Flow
(Gallons)
661
665
642
679
708
736
712
703
712
712
750
769
821
967
1113
1137
1113
1062
1109
1071
1255
1373
1406
1387
1444
1397
1458
1387
1123
1382
1335
1505
1387
1231
1005
764
587
71,392
70

-------
Table B-6. Oxidation Reduction Potential (mV)
                                    Oxidation Reduction Potential (mV)
DATE
07-Sep-94
14-Sep-94
05-Oct-94
19-Oct-94
02-Nov-94
09-Nov-94
16-Nov-94
23-NOV-94
S1
530
170
319
335
257
258
NA
330
S2
2
-510
-62.5
NA
-94
NA
NA
195
S3
-37
-470
NA
NA
-101
-108
NA
120
S4
170
230
282
266
252
242
NA
227
S10
NA
NA
NA
NA
246
224
NA
360
                   S = Sampling Port
                                                   71

-------
       Appendix C
Summary of Analytical Data
            72

-------
Table C-1. MMA Analytical Results - September
                  DATE
S1
S2
                                                            S3
                                        S4
02-Sep-94
03-Sep-94
04-Sep-94
05-Sep-94
06-Sep-94
07-Sep-94
08-Sep-94
09-Sep-94
10-Sep-94
ll-Sep-94
12-Sep-94
13-Sep-94
14-Sep-94
15-Sep-94
16-Sep-94
17-Sep-94
18-Sep-94
19-Sep-94
20-Sep-94
21-Sep-94
22-Sep-94
23-Sep-94
24-Sep-94
25-Sep-94
26-Sep-94
27-Sep-94
28-Sep-94
29-Sep-94
30-Sep-94
1430
NA
1470
1300
1630
1810
1950
1660
NA
1370
1600
1550
1860
2160
567
NA
2250
2580
NA
2340
2740
2300
NA
2450
2080
2460
2290
2890
3630
O.020
NA
NA
O.100
NA
0.009
NA
0.017
NA
NA
15.600
NA
<0.020
NA
<0.100
NA
NA
0.020
NA
NA
NA
<0.020
NA
NA
<0.020
NA
O.020
NA
<0.040
<0.020
NA
NA
O.I 00
NA
0.251
NA
0.325
NA
NA
18.800
NA
<0.020
NA
0.200
NA
NA
O.020
NA
NA
NA
0.020
NA
NA
O.020
NA
0.020
NA
O.040
0.324
NA
0.029
0.062
0.073
0.287
0.086
0.477
NA
11.600
16.800
7.270
0.007
0.015
O.010
NA
0.010
0.010
NA
O.010
O.010
O.010
NA
0.018
0.010
O.010
O.020
0.065
O.010
NA
NA
.NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA •
NA
NA
NA
NA
              < = Less than the reported value.
                   Reported value is the Detection Limit.
                     S = Sampling Port
                                                  73

-------
Table C-2. MMA Analytical Results - October
                                  S1
S2
S3
                                                                         S4
                                       S10
02-Oct-94
03-Oct-94
04-Oct-94
05-Oct-94
06-Oct-94
07-Oct-94
08-Oct-94
09-Oct-94
10-Oct-94
ll-Oct-94
12-Oct-94
13-Oct-94
14-Oct-94
15-Oct-94
16-Oct-94
17-Oct-94
18-Oct-94
19-Oct-94
20-Oct-94
21-Oct-94
22-Oct-94
23-Oct-94
24-Oct-94
25-Oct-94
26-Oct-94
27-Oct-94
28-Oct-94
29-Oct-94
30-Oct-94

1760
1690
1960
1890
1440
1600
NA
1600
1840
1680
1650
1820
1740
NA
1790
1910
1760
1560
1980
1780
NA
1900
2410
2620
2120
2340
2220
NA
2150
2210
NA
<0.040
NA
<0.040
NA
O.020
NA
NA
<0.020
NA
<0.020
NA
<0.020
NA
NA
O.020
NA
O.020
NA
O.020
NA
NA
<0.020
NA
O.100
NA
<0.020
NA
NA
<0.020
NA
<0.040
NA
<0.040
NA
<0.020
NA
NA
<0.020
NA
O.020
NA-
<0.040
NA
NA
O.020
NA
<0.020
NA
O.020
NA
NA
<0.020
NA
O.100
NA
<0.020
NA
NA
O.040
0.050
<0.010
<0.010
O.010
O.010
<0.010
NA
<0.015
<0.010
O.010
<0.010
<0.007
<0.010
NA
O.010
<0.010
<0.010
<0.010
<0.010
<0.010
NA
<0.010
<0.010
<0.010
<0.020
<0.020
<0.020
NA
<0.020
<0.020
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.288
NA
NA
NA
NA
NA
NA
<0.020
<0.020
NA
NA
<0.020
                 < = Less than the reported value.
                    Reported value is the Detection Limit.
         S = Sampling Port
                                                     74

-------
Table C-3. MMA Analytical Results - November
          DATE
TIME*
S1
S2
                                                              S3
                                                   S4
                                                  S10
Ol-Nov-94
02-Nov-94
03-Nov-94
04-Nov-94
05-Nov-94
06-Nov-94
07-Nov-94
08-Nov-94 800
08-Nov-94 1000
08-Nov-94 1200
08-Nov-94 1400
09-Nov-94
10-Noy-94
ll-Nov-94
12-Nov-94
13-Nov-94
14-Nov-94
15-Nov-94
16-Nov-94
17-Nov-94
18-Nov-94
19-Nov-94
20-Nov-94
21-Nov-94
22-Nov-94
23-Nov-94
1890
2060
2120
2220
NA
2050
2360
2020
7480
6500
7140
6220
9240
6480
NA
7110
7420
7830
8640
7470
7690
NA
9450
8420
9500
9090
NA
O.020
NA
<0.100
NA
NA
<0.050
<0.020
<0.020
0.011
<0.050
<0.100
NA
<0.040
NA
NA
<0.200
NA
<0.050
NA
O.020
NA
NA
<0.010
NA
0.011 J
NA
O.020
NA
<0.100
NA
NA
<0.100
<0.020
<0.040
<0.040
<0.400
<0.100
NA
<0.100
NA
NA
0.013 J
NA
0.002 J
NA
O.050
NA
NA
<0.025
NA
<0.006 J
<0.010
<0.010
<0.010
<0.010
NA
<0.010
O.100
<0.020
<0.020
<0.020
<0.020
<0.010
<0.010
<0.010
NA
0.005
<0.010
0.004
<0.010
0.005
<0.010
NA
0.004
0.005
0.123
0.021
NA
O.010
NA
<0.010
NA
NA
<0.010
<0.020
<0.020
<0.020
<0.020
<0.010
NA
<0.010
NA
NA
0.005
NA
<0.010
NA
<0.010
NA
NA
0.005
NA
O.010
      < = Less than the reported value.
           Reported value is the Detection Limit.
      * = Shock Loading
                                S = Sampling Port
                                                 75

-------
Table C-4. TCL VOC Concentrations - September
DETECTED TCLVOC
COMPOUNDS (uolL)
SAMPLING LOCATION SI
Methytone chloride
Trichkxoethylene
Benzen*
Toluene
SAMPLING LOCATION S2
Mettyteoe chloride
Acetone
Trichtoroethylene
MethyHs^butyl ketone
Mettiyl ethyl ketone
Benzene
Toluene
SAMPLING LOCATION S3
Methytone chloride
Acetone
Tnchtoroethytene
MelhyHso-outyl ketone
Methyl ethyl ketone
Benzene
Toluene
SAHPUNQ LOCATION S4
Melhylene chloride
Trichtoroethylene
MethyHso-butyl ketone
Mettiyl ethyl ketone
Benzene
Toluene


2.500U
2.500U
2.500U
2.500U

4.71J
218
5.0U
SOU
26.1J
S.OU
S.OU

5.40
270
5.0U
SOU
39.4J
S.OU
5.0U

5.50
S.OU
SOU
100U
5.0U
S.OU

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
SET

10.000U
S.OOOU
S.OOOU
S.OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

6.86
S.OU
SOU
100U
5.0U
5.0U

636
852
282J
500U

25U
591
25U
250U
500U
25U
25U

15.5J
1,070
25U
250U
500U
25U
25U

8.85
1.75J
SOU
1GOU
5.0U
S.OU

618
905
279J
105J

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

11.6
5.0U
SOU
100U
5.0U
S.OU
TOWER

SO.OOOU
SO.OOOU
SO.OOOU
SO.OOOU

14.1
26.3J
3.48J
9.15J
41 .4J
1.85J
1.23J

14.2
28.8J
3.37J
9.88J
38.6J
1.73J
5.0U

16.6
10U
100U
28.2J
10U
10U
OS-Seo.94

100.000U
SO.OOOU
SO.OOOU
SO.OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

7.31
5.0U
SOU
100U
S.OU
5.0U
09-S«p-94 10-Sep-M

100.000U
100.000U
100.000U
100.000U

8.87
100U
2.20J
6.S2J
100U
S.OU
0.922J

9.39
21.5J
2.32J
9.30J
100U
S.OU
5.0U

9.61
S.OU
3.4SJ
100U
S.OU
1.41J

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
11-S«p-94

SO.OOOU
SO.OOOU
SO.OOOU
SO.OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

25.4,1
SOU
500U
1.000U
SOU
SOU
12.Sep.94

SO.OOOU
SO.OOOU
SO.OOOU
SO.OOOU

32.0J
1,OOOJ
50J
soou
67.2J
SOU
SOU

23.6J
1.000U
sou
20.5J
1.000U
SOU
SOU

500U
SOOU
S.OOOU
10.000U
soou
soou
1M»M

SO.OOOU
SO.OOOU
SO.OOOU
SO.OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

250U
2SOU
2.500U
S.OOOU
250U
250U
1+Sec-94

10.000U
10.000U
10.000U
10.000U

S.OU
100U
S.OU
10.2J
100U
S.OU
S.OU

6.28
100U
S.OU
4.58J
100U
S.OU
S.OU

9.73
Z07J
SOU
100U
S.OU
•5.0U
IS^ep-94

10.000U
10.000U
10.000U
10.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

7.22
2.02J
SOU
100U
S.OU
S.OU
       J * Estimated Concentration (also used when compound is detected beta* quantitatkm limit)
       U « Not Detected (detection «raH reported)
       S > Sampling port

-------
Table C-4. TCL VOC Concentrations - September (continued)
                                                                                SEPTEMBER
DATE
SAMPLING LOCATION S1
Methylene chloride
Trichloroethylene
Benzene
ToHiene
SAMPLING LOCATION S2
Mefliylene chloride
Acetone
Trichloroethylene
MethyMso-butyl ketone
Methyl ethyl ketone
Benzene
Toluene
SAMPLING LOCATION S3
Methylene chloride
Acetone
Trichloroethylene
Methyl-lso-butyl ketone
Methyl ethyl ketone
Benzene
Toluene
SAMPLING LOCATION S4
Methylene chloride
Trichloroethylene
MethyHso-butylketona
Methyl ethyl kelone
Benzene
Toluene
SAMPLING LOCATION S10 - Not Analyzed
16-SCP-94

SOOJ
500U
SOOU
SOOU

23.8
SOU
S.OU
4S.OJ
SOU
22U
30U

SOU
1.000U
SOU
SOOU
1.000U
sou
sou

11.2
s.ou
sou
100U
S.OU
S.OU

17-Sep-94

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA

1£Sep-94

100.000U
100.000U
100.000U
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

141
SOU
63.5J
1,00011
SOU
SOU

19-Sep-94

100,0001)
100.000U
100.000U
100.000U

8.40
28.9J
S.OU
SOU
toou
5.0U
5.0U

9.14
76.3J
S.OU
SOU
100U
S.OU
S.OU

16.0
3.66J
SOU
100U
0.96 8J
S.OU

20-Ser>-94

100.000U
100.000U
too.ooou
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

7.59
S.OU
SOU
100U
S.OU
5.0U

21-SC0-94

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA

22-Sep-94

S.OOOU
S.OOOU
S.OOOU
S.OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

•s.ou
5.DU
SOU
100U
S.OU
S.OU

23-SCP-94

100.000U
100.000U
100.000U
100.000U

3.88J
100U
S.OU
10.3J
100UJ
S.OU
S.OU

5.47
100U
S.OU
12.5J
100UJ
5.0U
S.OU

5.0U
5.0U
SOU
100UJ
5.0U
S.OU

24-Sep-9*

NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA

25-S«p.94

100.000U
100.000U
10D.OOOU
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

12.4
5.0U
SOU
100U
S.OU
S.OU



100.000U
100,00011
100.000U
loo.ooou

7.81
10U
1.0U
26.3
10U
4.4U
6.0U

7.36
100U
S.OU
13.1J
100U
S.OU
S.OU

7.60
S.OU
SOU
100U
S.OU
S.OU



100.000U
100.000U
100.000U
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

8.66
5.0U
SOU
100U
5.0U
S.OU



too.ooou
100.000U
100,OOOU
100.000U

3.33J
100U
S.OU
23.3J
100U
S.OU
S.OU

5.41
100U
S.OU
8.79J
100U
S.OU
S.OU

9.90
S.OU
SOU
100U
S.OU
5.0U



SO.OOOU
SO.OOOU
so.ooou
so.ooou

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

9.12
S.OU
4.57J
100U
S.OU
5.0U








11.0
74.0J
10U
34.SJ
5.34J
10U
10U

13.1
117J
10U
42.2J
200U
10U
1.54J

11.8
2.65J
SOU
100U
5.0U
1.3BU

   J * Estimated Conccntralion (also used whan compound Is delected below quanttafion limn)
   U = Not Delected (delection limil reported)
   s * Sampling Port

-------
Table C-5.  TCL VOC Concentrations - October
DETECTED VOC
COMPOUNDS IJJg/L)
SAMPLING LOCATION SI
Mffthyl cbtoricto
Methytofwchlorfdt
o+p-Xyfenei
SAMPLING LOCATION S2
Melilytow chloride
Acetone
Trichtofoethylene
MethyHso-butyl ketone
Methyl ethyl ketone
Toluene
Methyl cWoridfl
SAMPLING LOCATION S3
Methylene chloride
Acetone
Trichkxoettiylene
MethyHso-butylkelone
Methyl ethyl ketone
Toluene
Mettiyl chloride
SAMPLING LOCATION S4
Methylene chloride
Acetone
Trichloroethylene
MethyHso-butylketona
Methyl ethyl ketone
Benzene
Toluene
Chloroform
Elhylbenzene
Styrene
SAMPLING LOCATION S10
Methylene Chloride
1.1,2,2-Telrachloroethane



NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA



15,300
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

2.93J
100U
S.OU
SOU
1COU
S.OU
0.604J
S.OU
S.OU
S.OU
NA
NA



SO.OOOU
2S.OOOU
25.000U

5.34J
200U
10U
24.1J
200U
10U
20U

6.6J
52.6J
10U
17.9J
200U
10U
20U

6.49
101
5.0U
14.7J
29.8J
S.OU
S.OU
5.0U
S.OU
S.OU
NA
NA



SO.OOOU
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

9.08
100U
3.41J
SOU
100U
S.OU
S.OU
S.OU
S.OU
S.OU
NA
NA

OC1
******

50,00011
25,00011
25.000U

"10U
137J
3.13J
17.4J
200U
10U
20U

8.30J
200U
10U
22.3J
200U
10U
2.69J

8.56
100U
2.95J
SOU
1DOU
S.OU
5.0U
S.OU
5.0U
S.OU
NA
NA

[OmSK
c*oct-94

SO.OOOU
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

11.6
100U
3.98J
SOU
100U
S.OU
0.744J
S.OU
S.OU
5.0U
NA
NA

07-Oet-M Dt-Oct'S4

SO.OOOU
25.000U
25.000U

3.07J
29.SJ
5.0U
8.36J
100U
5.0U
3.27J

2.21J
61.2J
S.OU
11.7J
2.20J
S.OU
2.21J

3.35J
100U
S.OU
SOU
100U
5.0U
5.0U
S.OU
S.OU
S.OU
NA
NA


NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

W-Oct-M

SO.OOOU
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

10.5
100U
3.14J
SOU
100U
S.OU
S.OU
S.OU
S.OU
S.OU
NA
NA

lrj-Od-J4

SO.OOOU
25.000U
25.000U

7.35
83.40
1.91J
SOU
100U
S.OU
10U

6.44
99.3J
2.1 9 J
SOU
100U
5.0U
10U

6.85
100U
233J
SOU
100U
S.OU
S.OU
5.0U
S.OU
S.OU
NA
NA
NA
11-Oet-M

SO.OOOU
25.000U
14,400J

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

S.OU
100U
5.0U
SOU
100U
5.0U
1.57J
14.0
5.0U
S.OU
NA
NA
NA
12-Oct-M

SO.OOOU
25.000U
2S.OOOU

7.23
223
4.19J .
6.13J
56.6J
1.44J
10U

7.17
382
4.33J
6.90J
60.SJ
1.47J
10U

7.33
100U
3.95J
SOU
100U
S.OU
1.37J
S.OU
S.OU
S.OU
NA
NA
NA
IMJct-W

SO.OOOU
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

5.14
100U
2.97J
SOU
100U
S.OU
1.01J
S.OU
S.OU
S.OU
NA
NA
NA
140CH4

SO.OOOU
25,0000
25.0000

5.0U
482
Z70J
13.SJ
82.5J
1.93J
10U

5.03
365
3.13J
9.64J
78.8J
2.05J
20U

4.45J
100U
3.47J
SOU .
100U
S.OU
2.74J
S.OU
2.12J
S.OU
NA
NA
NA
      J = Estimated Concentration (also used when compound is detected below quantitatton limit)
      U = Not Detected (detection limit reported)
      S = Sampling Port

-------
Table C-5.  TCL VOC Concentrations - October (continued)
DETECTED VOC
COMPOUNDS (ugll)
DATE

Methyl chloride
Methylene chloride
o»pXylenes
SAMPLING LOCATION S2
Methylene chkxide
Acetone
Trichloroelfiylene
Methyl bo butyl kelone
Methyl ethyl ketone
Toluene
Methyl chloride
SAMPLING LOCATION 33
Methylene chloride
Acetone
Trichloroethylene
MethyHsWxityl fcetone
Methyl ethyl ketone
Toluene
Methyl chloride
SAMPLING LOCATION 34
Methyfcne chloride
Acetone
Trichloroethylene
MethyHso-butyl kelone
Methyl ethyl ketone
Benzene
Toluene
Chloroform
Bhylbenzene
Slyrene
SAMPLING LOCATION 510
Methylene Chloride
1,1^-TttmcMomthiine
Toluene
1SJM-I4

NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
1«*t-M

50.000U
25.000U
25.0000

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

6.03
100U
5.00
SOU
1000
S.OU
5.0U
S.OU
5.00
S.OU

NA
NA
NA
17.0CM4

SO.OOOU
25.000U
25.000U

6.11
2,660
4.20J
8.32J
349
5.0U
10U

(.45
1,300
4.66J
10.1J
159
Lew
10U

6.01
100U
4.52J
sou
100U
S.OU
2.03J
5.0U
S.OU
S.OU

NA
NA
NA


SO.OOOU
25.000U
25.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

8.02
100U
4.41J
SOU
100U
S.OU
2.05J
S.OU
S.OU
S.OU

NA
NA
NA
1l-Oct-l4

100,0000
50,0000
so,ooou

7.40
71.1J
3.61J
4S.7J
1000
2.12J
100

7.03
161
2.96J
30.2J
21.0J
1.85J
100

757
100U
3.51J
SOU
100U
S.OU
3.11J
S.OU
S.OU
S.OU

NA
NA
— a*_
JB-OCW4

100.000U
50.0000
50.000O

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

9.06
100U
4.21J
SOU
1000
5.00
2.17J
S.OU
S.OU
S.OU

7.53
S.OU
S.OU
OCTOBER

100.000U
SO.OOOU
SO.OOOU

6.49
45.2J
2.81J
45.5J
100U
5.0U
10U

5.77
140
2.60J
53.9
100U
2.05J
10U

5.72
100U
2.75J
SOU
1000
S.OU
1.76J
5.00
S.OU
5.00

NA
NA
	 "*

NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
HA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA


100,OQOU
50,0000
SO.OOOU
S2
NA
NA
NA
HA
NA
NA
HA

NA
NA
NA
NA
NA
HA
NA

4.99J
100U
2.02J
SOU
100U
S.OU
0.770J
5.00
S.OU
5.00

NA
NA


200.000U
100.0000
100,0000

5.10
S5.7J
2.SOJ
27.0J
1000
S.OU
100

5.23
7S.5J
2.73J
31.8J
100U
O.B16J
too

4.62J
1000
2.SSJ
SOU
1000
S.OO
5.00
S.OU
5.00
5.00

NA
NA



200.0000
100,0000
100,OOOU

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

11.4
100U
6.15
SOU
100U
1.30J
2.31J
S.OO
S.OU
2.36J

NA
NA



100.000U
SO.OOOU
50,0000

25U
3,050
250
250U
1,000
250
SOU

250
769
250
250U
500U
25U
SOU

6.68
100U
3.30J
SOU
1000
5.0U
5.00
S.OU
S.OU
5.00

NA
NA



200.000U
100.000U
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

6.9t
100U
3.67J
SOU
100U
S.OU
1.0SJ
5.0U
S.OU
S.OU

S.OU
1.14J



200.000U
100,0000
100.0000

6.18
304
2.SSJ
14.4J
4>.5J
S.OO
10U

6.14
256
2.43J
10.5J
37.4J -
5.00
100

6.16
1000
2.62J
SOU
1000
5.0U
5.00
S.OU
5.00
5.00

S.OU
5.00



NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA



200,0000
100,0000
100.000U

NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA

1.97J
1000
5.0U
SOU
100U
S.OU
S.OU
S.OU
S.OO
S.OU

NA
NA







S.OU
314
5.00
SOU
62.4J
5.0U
10U

10U
864
10U
100U
200U
2.03J
20U

S.OU
100U
S.OO
SOU
1.33J
SOU
1.58J
S.OU
S.OO
S.OU

5.00
S.OU

    J • EsUnuMd Concentntton (also usad whwi
    U « Not Detected (dotedton fci* reported)
    S « StrnpfcTflPort
                             compound b dctectod below quinUtUon Hm«)

-------
Table C-6.  TCL VOC Concentrations - November
                                                                                                    NOVEMBER
DETECTED VOC
COMPOUNDS (M9/L)
SAMPLING LOCATION SI - Not delected
SAMPLING LOCATION S2
MithyHnecHoflde
Acetone
Trichtoreethylene
MilhyHio-butyl ketone
U.Jiyf ethyl ketone
BMIZMM

Ethybenzene
Styrene
Chlorobenzene
Carton d&uWe
SAMPLING LOCATION S3
Methylene chloride
Acetone
Trichkmethylene
MethyHsc-butyl ketone
Methyl ethyl ketone
Toluene
Benzene
Stvrene
Carbon dteutfide
SAMPLING LOCATION S4
Methylene chloride
Acetone
Trichtooetfiytena
Methyl ethyl ketone
Toluene
Benzene
Ethylbenzene
Styrene
m+p-Xylenes
SAMPLING LOCATION S10
Acetone
Methyl ethyl ketorw


NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

4.39J
100U
UOJ
100U
S.OU
S.OU
5.0U
S.OU
S.OU
NA
NA
02.HOT.M

8.48
130
1.40J
7.S7J
22.5J
S.OU
S.OU
S.OU
S.OU
S.OU
100U
4.25J
171
S.OU
11.4J
100U
SOU
S.OU
S.OU
100U

2.68J
100U
1.45J
100U
S.OU
S.OU
S.OU
5.0U
S.OU
100U
100U


NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

6.27
100U
1.76U
100U
S.OU
S.OU
S.OU
S.OU
S.OU
NA
NA


2SU
1,000
25U
250U
98.9J
25U
25U
25U
ZSU
25U
SOOU
2SU
1,070
ZSU
250U
SOOU
25U
2SU
25U
SOOU

3.16J
100U
S.OU
100U
S.OU
S.OU
S.OU
s.ou
100U
100U
100U


NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
<*#»** 	

NA
NA.
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

4.83J
100U
5.0U
100U
1.01J
S.OU
S.OU
S.OU
S.OU
NA
NA


12.3J
873
13U
130U
2SOU
13U
3.I3J
13U
13U
13U
250U
2SU
587
2SU
250U
SOOU
4.S3J
ZSU
25U
SOOU

12.2
100U
5.24
100U
2.93J
S.OU
S.OU
S.OU
S.OU
100U
100U
MO

12.0
946
4.15J
SOU
43.8J
S.OU
S.OU
S.OU
S.OU
S.OU
100U
11.3
489
3.83J
8.18J
151
S.OU
S.OU
S.OU
100U

11.3
100U
3.89J
100U
2.96J
S.OU
S.OU
S.OU
S.OU
100U
100U
OtNov-M TIME4
1000

22.8
115
9.73
SOU
100U
S.OU
ZiSJ
S.OU
S.OU
S.OU
100U
25.9
269
11.0
100U
200U
1.89J
10U
10U
200U

22.6
100U
103
100U
2.23J
5.0U
S.OU
5.0U
5.0U
100U
100U
1200

229
10.5J
S7.3J
4.52J
8.09
S.OU
3.68J
S.OU
100U
48.9
207
20.1
100U
200U
6.24J
S.04J
2.08J
200U

46.9
33.2J
19.7
48.8J
6.61
4.61J
S.OU
9.33
5.0U
100U
100U
100U
1400

13.6
878
13U
130U
71.5J
13U
NO
NO
ND
NO
100U
100U
2,100
100U
1.000U
2.000U
100U
100U
100U
2.00U

14.9
100U
3.48J
100U
2.13J
S.OU
S.OU
S.OU
S.OU
100U
100U
100U
OWtov-M

ZSU
(48
ZSU
250U
ZSU
ZSU
ZSU
ZSU
ZSU
SOOU
sou
1,450
SOU
SOOU
1.000U
sou
sou
sou
1.000U

4.51J
100U
S.OU
100U
S.OU
S.OU
5.0U
5.0U
S.OU
100U
100U
100U
10-Nov-M

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

13.4
100U
5.02
100U
5.0U
S.OU
S.OU
s.ou
S.OU
NA
NA
NA
   J x Estimated Concentration (also used when compound Is detected betow quantftttion lit*)
   U - Not Detected (detection Imtt reported)
   • = Shock Load
   S * Sampling Port

-------
Table C-6. TCL VOC Concentrations - November (continued)
                                                                                                 NOVEMBER
DETECTED VOC
COMPOUNDS (mg/L)
DATE
11-Nov.94
12-NOV-94
13JJOV-94










SAMPLING LOCATION S2
Methytene chloride
Acetone
Trichtoraethylent
MethyHso-butyl ketone
Methyl ethyl ketone
Benzene
Toluene
Ethylbenzene
Styrene
Chtorobenzene
Caibon disulfide
SAMPLING LOCATION S3
Methytene chloride
Acetone
Tnchtoroethytene
MettijHso-butyl kclone
Methyl ethyl katona
Tolueno
Benzene
Styrene
Caibon disulflde
SAMPLING LOCATION 54
Methytone chloride
Acetone
Trichtoroethylene
Methyl ethyl ketone
Toluene
Benzene
Ethyibenzene
Styrene
m+p-Xytenes
SAMPLING LOCATION S10
Acetone
Methyl ethyl ketone
Caibon disulfide
10.9
410
10U
100U
200U
10U
10U
10U
lou
10U
2QOU

25U
771
2SU
•250U
500U
25U
2SU
25U
500U

11.6
100U
3.84J
100U
5.0U
5.0U
5.0U
5.0U
5.0U

100U
100U
100U
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

10.3
100U
3.26J
100U
S.OU
S.OU
S.OU
5.0U
S.OU

NA
NA

SOU
2,010
SOU
500U
280J
SOU
SOU
SOU
SOU
SOU
1.000U

8.47
1,160
S.OU
SOU
123
5.0U
S.OU
S.OU
1.53J

7.63
100U
S.OU
100U
S.OU
S.OU
5.0U
5.0U
S.OU

100U
100U

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

12.7
100U
4.11J
100U
S.OU
S.OU
S.OU
S.OU
1.58J

NA
NA

9.61J
541
13U
130U
303
13U
13U
13U
13U
13U
2.19J

11.1
150
3.18J
20.3J
8.91J
S.OU
S.OU
S.OU
1.9SJ

12.2
100U
3.43J
100U
S.OU
S.OU
5.0U
S.OU
S.OU

NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

11.1
ioou
3.S1J
100U
5.0U
5.0U
S.OU
S.OU
S.OU

NA
NA

12.6
762
4.11J
SOU
269
1.0(1
2.01
S.OU
5.0U
S.OU
3.06J

13.0
794
S.93J
100U
312
1.99J
10U
10U
3.35J

13.6
100U
4.79J
100U
1.S4J
5.0U
5.0U
5.0U
5.0U

100U
100U

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

12.1
100U
4.49J ,
9.58J
1.44J
S.OU
S.OU
5.0U
S.OU

NA
NA

10U
444
10U
100U
200U
10U
2.11J
10U
10U
10U
2.64J

11.4J
690
25U
250U
160J
2SU
2SU
25U
SOOU

8.33
100U
2.57J
4.14J
1.74J
S.OU
S.OU
S.OU
S.OU

100U
100U

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

60.9
100U
22.9
ioou
7.67
7.54
2.19J
16.4
S.OU

ND
ND

25U
576
2SU
250U
107J
25U
25U
25U
2SU
2SU
2.91J

10U
322
10U
100U
50.7J
10U
10U
10U
3.16J

S.OU
100U
S.OU
29.1J
S.OU
S.OU
S.OU
S.OU
S.OU

29.1J
8.46J

 J » Estimated Concentration (also used when compound Is detected below quanetafon limit)
 U = Not Detected (detection limit reported)
 S = SampBnjPort

-------
Table C-7. COD Analytical Results - September (mg/kg)
                                             S2
S3
S4
                                                                                    S10
02-Sep-94
03-Sep-94
04-Sep-94
05-Sep-94
06-Sep-94
07-Sep-94
08-Sep-94
09-Sep-94
10-Sep-94
ll-Sep-94
12-Sep-94
13-Sep-94
14-Sep-94
15-Sep-94
16-Sep-94
17-Sep-94
18-Sep-94
19-Sep-94
20-Sep-94
21-Sep-94
22-Sep-94
23-Sep-94
24-Sep-94
25-Sep-94
26-Sep-94
27-Sep-94
28-Sep-94
29-Sep-94

4,280
NA
NA
2,750
3,820
2,990
3,970
4,310
NA
3,740
4,140
4,140
3,680
5,380
1,490
NA
6,510
6,890
NA
NA
6,680
7,380
NA
6,920
6,760
6,990
13,600
4,150
7,450
453
NA
NA
95
75
974
NA
812
NA
NA
2,360
NA
2,130
NA
4,010
NA
NA
9,243
NA
NA
NA
6,310
NA
NA
14,100
NA
14,200
NA
8,892
257
NA
NA
367
3,500
1,040
NA
852
NA
NA
2,360
NA
1,810
NA
10,000
NA
NA
746
NA
NA
NA
5,620
NA
NA
13,400
NA
14,000
NA
14,388
84
NA
NA
153
142
550
111
852
NA
809
863
600
501
256
321
NA
120
390
NA
NA
909
1,160
NA
437
444
922
460
470
888
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
                S = Sampling Port
                                                    82

-------
Table C-8. COD Analytical Results - October (mg/kg)
                 DATE
S1
S2
                                                         S3
                                       S4
                                      S10
02-Oct-94
03-Oct-94
04-Oct-94
05-Oct-94
06-Oct-94
07-Oct-94
08-Oct-94
09-Oct-94
10-Oct-94
ll-Oct-94
12-Oct-94
13-Oct-94
14-Oct-94
15-Oct-94
16-Oct-94
17-Oct-94
18-Oct-94
19-Oct-94
20-Oct-94
21-Oct-94
22-Oct-94
23-Oct-94
24-Oct-94
25-Oct-94
26-Oct-94
27-Oct-94
28-Oct-94
29-Oct-94
30-Oct-94
31-Oct-94
5,183
4,880
4,518
4,497
4,040
2,932
NA
5,380
4,700
4,910
5,170
4,960
5,450
NA
4,500
5,410
4,600
4,830
NA
4,450
NA
2,430
6,060
6,340
6,140
5,820
5,910
NA
5,060
5,200
NA
9,752
NA
11,140
NA
13,740
NA
NA
7,250
NA
15,100
NA
18,800
NA
NA
2,910
NA
19,200
NA
11,300
NA
NA
19,700
NA
20,400
NA
19,400
NA
NA
9,530
NA
11,910
NA
11,850
NA
14,930
NA
NA
8,970
NA
12,400
NA
19,400
NA
NA
2,990
NA
16,500
NA
20,700
NA
NA
20,900
NA
19,200
NA
18,100
NA
NA
18,800
528
14
843
431
771
562
NA
10
362
532
545
447
418
NA
483
469
662
782
NA
566
NA
1,190
1,880
1,620
1,550
1,250
481
NA
351
516
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,090
NA
NA
NA
64
             S = Sampling Port
                                                 83

-------
Table C-9. COD Analytical Results - November (mg/kg)
                        TIME*
         * = Shock Load
         S = Sampling Port
S1
S2
S3
                                                                           S4
                                                 S10
Ol-Nov-94
02-Nov-94
03-Nov-94
04-Nov-94
05-Nov-94
06-Nov-94
07-Nov-94
08-Nov-94 800
08-Nov-94 1000
08-Nov-94 1200
08-Nov-94 1400
09-Nov-94
lO-Nov-94
ll-Nov-94
12-Nov-94
13-Nov-94
14-Nov-94
15-Nov-94
16-Nov-94
17-Nov-94
18-Nov-94
19-Nov-94
20-Nov-94
21-Nov-94

5,230
5,980
5,300
6,140
NA
5,770
6,400
5,910
16,300
19,600
18,500
20,600
20,200
18,100
NA
17,100
19,900
19,200
18,400
16,200
20,700
NA
21,900
21,400
21,400
NA
19,400
NA
18,200
NA
NA
21,500
25,700
17,900
20,000
13,300
22,400
NA
2,590
NA
NA
2,030
NA
18,200
NA
2,380
NA
NA
3,740
3,740
NA
19,800
NA
24,100
NA
NA
11,800
2,770
27,200
21,400
21,100
12,500
NA
13,000
NA
NA
3,690
NA
6,540
NA
2,170
NA
NA
4,170
4,170
513
408
405
405
NA
1,290
1,320
1,170
1,080
1,180
1,260
1,520
1,450
.60
NA
627
1,020
2,140
823
355
860
NA
1,220
1,010
1,010
NA
441
NA
78
NA
NA
75
100
138
121
1,040
93
NA
56
NA
NA
177
NA
218
NA
283
NA
NA
436
436
                                                   84

-------
Table C-10. Air Analytical Results
SAMPLING LOCATIONS
VOCsfoBbv)

Acetone
Benzene
2-Butamme(MEK)
Chloiofoim
1,4-Dichlorobenzene
Dichloromethane
Ethylbenzene
1,1,2,2-Tettachloroethane
Tetrachloroethene (PCE)
Toluene
Trichloroethene(TCE)
Trichlorofluoromelhane (F-ll)
Trichlorotrifluoroetliane (F-I13)
Xylenes
FIXED GASES/METHANE
Caibon Dioxide
Oxygen
Nitrogen
Methane
Caibon Monoxide
SS
(Inlet Air Strum]
9/28

460
2.0U
5.0
5.0U
ZOU
10U
ZOU
l.OU
l.OU
2.0U
l.OU
3.0
ZOU
2.0U
9/28
0.1U
22.0
78.0
0.005U
0.1U
1
9/14

50.0
120
5.0U
10U
2.0U
320
13.0
31.0
2.0U
66.0
2SO
23.0
16.0
5.0U
9/14
1.6
21.0
77.0
0.005U
0.1U
S6
(Air Recirculnlion Stream)
9/28 10/12 10/25 Ills'

46.0
,1.8
0.2U
0.5U
0.4
4.0
0.2U
O.IU
O.IU
2.3
9.1
0.2U
0.4
0.3
9/28
0.2
22.0
78.0
0.005U
OIU

22.0
9.4
0.5U
3.0
0.2U
52.0
0.5U
0.2U
0.2U
12.0
48.0
0.5U
0.5U
0.5U
10/12
0.5
21.0
78.0
0.005U
O.IU

1600
28.0
2.0U
5.0U
2.0U
140
2.0U
l.OU
l.OU
34.0
160
2.0U
2.0U
2.0U
10/25
1.3
20.0
79.0
0.005U
O.IU

80.0
81.0
10U
20U
5.0U
520
10U
5.0U
140
130
520
5.0U
10U
300
11/8
1.2
21.0
78.0
0.005U
0.005U
11/21

20U
ZOU
5.0U
10U
ZOU
20U
5.0U
ZOU
2.0U
5.0U
ZOU
5.0U
5.0U
5.0U
11/21
0.1U
22.0
78.0
0.005U
O.IU
9/14
49.0
63.0
0.2U
0.5U
l.OU
0.2U
ZOU
O.SU
0.2U
0.2U
0.5U
0.2U
5.0
1.3
O.SU
9/14
O.IU
22.0
78.0
0.005U
O.IU
9/28

51.0
0.2U
0.5U
l.OU
0.2U
2.0U
0.5U
0.2U
0.2U
0.5
0.2U
O.SU
0.5U
0.5U
9/58
O.IU
22.0
78.0
0.005U
O.IU
S7
(Emissions Stream)
10/12 10/25

10U
8.0
ZOU
5.0U
2.00
60.0
2.0U
l.OU
l.OU
14.0
86.0
ZOU
ZOU
ZOU
10/12
0.8
21.0
78.0
0.005U
O.IU

120
2.0U
2.0U
5.0U
ZOU
120
2.0U
l.OU
l.OU
25.0
ISO
ZOU
ZOU
ZOU
10/25
1.3
20.0
79.0
0.005U
O.IU
11/8*

SOU
380
10U
20U
5.0U
1300
10U
5.0U
5.0U
480
1700
5.0U
10U
IOU
11/8
1.0
21.0
78.0
0.005U
O.IU
11/21

20U
ZOU
5.0U
IOU
ZOU
100
5.0U
ZOU
ZOU
5.0U
ZOU
5.0U
S.OU
5.0U
11/21
O.IU
22.0
78.0
0.005U
O.IU
9/14
1.1
13.0
0.2U
O.SU
l.OU
0.2U
ZOU
0.5U
0.2U
0.2U
,0.5U
0.2U
20
0.5U
O.SU
9/14
O.IU
2ZO
78.0
0.005U
O.IU
S9
(Emission Stream After Carbo
9/28 10/12 10/25
ZO
3.0
0.2U
0.5U
l.OU
0.2U
110
OJU
0.2U
0.2U
1.4
3.0
0.5U
0.5U
0.5U
9/28
1.3
21.0
78.0
0.005U
O.IU
15.0
IOU
ZOU
ZOU
S.OU
2.0U
60.0
ZOU
l.OU
l.OU
ZOU
l.OU
2.0U
2.0U
2.0U
10/1J
0.5
21
78
O.OOSU
O.IU
23.0
80.0
2.0U
2.0U
S.OU
ZOU
IOU
ZOU
1.0U
l.OU
zou
28.0
2.0U
ZOU
ZOU
1005
1.3
20.0
79.0
O.OOSU
O.IU
n Filter)
11/8*
ND
50
S.OU
IOU
20U
S.OU
50U
IOU
S.OU
S.OU
IOU
S.OU
S.OU
IOU
IOU
11/8
12
21.0
78.0
O.OOSU
O.IU

7.8
l.OU
0.2U
0.2U
O.SU
0.2U
140
OJU
0.1U
0.1U
0.2U
0.1U
0.2U
0.2U
0.2U
11/21
O.IU
22.0
78.0
O.OOSU

     Notes:

     '-Shock Load
     U - Not detected (value reported is detection limit)

-------
       Table C-11.  Nutrients
00
                    Ammonia as Nitrogen (mg/L)                   Nitrate/Nitrite (mg/L)                        Phosphate (mg/L)
   DATE      SI     S2     S3     S4     S5    S10    SI     S2     S3     S4     SS     S10     SI     S2    S3     S4     S5    S10

   14-Sep-94   NA    NA    NA    NA     NA   NA    NA    NA    NA    NA    NA    NA    NA    NA    NA   NA    NA    NA
   05-Oct-94    0.11     14     14    0.11     49  NA     0.75     0.4     1.1    0.1     3.9   NA    <0.04      83     96    0.14   1300  NA
   19-Oct-94    0.14     0.9    3.7    0.28      11  NA     0.41     0.4    0.14  <0.05     12   NA      0.05    120     150  <0.04    1200  NA
   02-Nov-94     0.1     29     30    0.78     65   0.59   0.45    0.06    0.64  <0.05     1.5  <0.05     0.19     26     210     1.1   1100   0.94

   09-Nov-94   NA     NA     NA    NA     NA   NA    NA    NA     NA     NA    NA    NA    NA    NA    NA   NA    NA    NA
   16-Nov-94    0.18     84     93     0.2    0.06    710   0.29    0.47     3.6  <0.05  <0.05     1.6    0.07    170     170     1.3      2    540
   23-Nov-94   NA     NA     NA    NA     NA   NA    NA    NA     NA     NA.   NA    NA    NA    NA    NA   NA    NA    NA

Notes:
NA-Not Analyzed
< - Corresponding value represents method detection limit; indicates that sample was below detection limit

-------
          Table C-12.  Metals Concentrations
00
ANALYTE
(uq/U
SAMPLING LOCATION S1
Aluminum
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Zinc
SAMPLING LOCATION S2
Aluminum
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Sodium
Nickel
Zinc
SAMPLING LOCATION S3
Aluminum
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Nickel
Zinc
02-Sep-94

220
100U
40
7.8J
10U
9,800
140
84
0.20U
10J
2,780

13,300
100U
100
44
920
23,400
520
350
0.14J

89
8,410

14,500
100U
110
47
990.00
27,200
580
380
0.20U
93
8,920
16-Sep-94

260
100U
74
6.6J
14
17,100
260
150
0.1 3J
19J
4,060

16,400
100U
410
250
1,130
160,000
1,800
988
3.7

230
26,600

16,800
100U
423
250
1,150
160,000
1,900
1,020
3.6
230
27,400
30-S6D-94

290
100U
67
5.7J
8.5J
15,400
220
130
0.11J
22
3,070

20,100
100U
1,130
420
1,370
363,000
4,300
2,100
1.1

390
55,800

18,900
100U
991
380
1,300
296,000
4,100
2,050
1.6
380
49,000
14-Oct-9*

33QJ
100UJ
66.00
3.5J
8.5J
21,500
200
140
0.13J
19J
2,680

15,600
100U
1,400
260
1,090
420,000
3,900
2,570
0.47

410
71,300

46J
100U
1.5J
5.5J
10U
170
45U
43
0.1 5 J
12J
270
20-Oct-94

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
27-Oct-94

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
28-Oct-94

270
100U
64
4.1J
10U
18,600
180
140
0.055J
14J
1,400

17,800
100U
2,070
150
1,050
406,000
7,300
3,430
1.3J
NA
398,000
86.70

16,500
100U
1,910
130
1,000
357,000
6,640
3,240
2.4
460
84,500
07-NOV-94

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

19.80
0.14
2.00
0:40
1.10
586
6.88
3.23
NA

0.53
79.60

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
800
08-NOV-94

340
100U
44
3.7J
4.3J
11,600
110
98
. 0.40U
10J
810

15,300
100U
1,820
130
790
358,000
4,530
3,030
1.7J

430
77,900

15,300
100U
2,000
120
800
296,000
4,790
3,430
0.93J
490
78,000
1000
08-NOV-94

920
100U
110
11
4.6J
29,700
260
230
2.0U
22
1,300

2,400
100U
1,930
89
630
225,000
3,000
31,200
2.2

440
83,700

19,100
100U
2,140
280
990
499,000
5,740
3,630
0.75J
550
93.400
TIME*
1200

1,100
100U
130
16
5.0J
36,500
300
270
2.0U
27
1,400

15,800
100U
1,880
170
850
342,000
4,730
3,210
1.3J

470
76,900

10,000
100U
1,790
50
390
142,000
2,000
3,160
1.6J
450
76,500
1400
Oa-Nov-94

900
100U
150
16
3.1J
32,700
330
290
2.0U
31
1,600

11,500
100U
1,640
100 '
630
244,000
3,400
2,830
0.93J

410
74,200

12,100
100U
1,660
81
630
213,000
3,600
2,890
2.2
420
66,100


740
100U
160
13
2.8J
34,000
330
290
0.14J
29
2,020

22,300
24J
2,260
400
1,150
623,000
7,690
3,650
0.047J

610
95,800

24,400
100U
2,410
470
1,280
717,000
8,400
3,860
0.86
660
101,000
                Notes:
                *-Shock Load                          ND - Not Detected
                J - Not Detected; Corresponding Value Estimated.
                U - Not Detected; Corresponding Value Represents the Detection Limit.

-------
Table C-12. Metals Concentrations (continued)
ANALYTE
SAMPLING LOCATION S4
Aluminurn
Arsenic
Cadmium
Chromium
Copper
Irnn
iron
Lead
Manganese
Mercury
NHrkpl
INIUvtfl
Zinc
SAMPLING LOCATION S10
Aluminum
Arsenic
Cadmium
Chromium
Copper
Irnn
iron
Lead
Manganese
Mercury
Nickel

160
100U
1.7J
2.4J
4.5J
40J
45U
7.9
0.075J
20U
71
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

16-SBP-94
120
100U
2.9J
5.6J
9.8J
64J
9.4J
21
0.16J
36
150
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
30-SCP-94
86
100U
1.3J
10U
10U
200
45U
21
0.20U
8.8J
240
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
14-Oet-94
12.80
100U
1.51
0.08
0.90
218
3.60
2.60
3.3
0.04
70
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
20-Oct-84
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.07
ND
ND
ND
0.01
0.20
ND
0.01
ND
0.01
0.12
27-Oct-94
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.14
ND
ND
ND
ND
0.04
ND
0.01
ND
ND
0.01
28-Oct-S4
130
100U
4.0U
3.4B
10U
130
16B
59
0.20U
5.7B
140
88B
22B
4.0U
10U
10U
59B
45U
6.2
0.042B
20U
51
OT-Nov-94
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
800
OS-Nov-94
84
100U
4.0U
2.1J
10U
140
13J
35
0.20U
4.3J
100
74
100U
4.0U
10U
9.7J
35J
45U
6.1
0.40U
20U
50
1000
08-NOV-94
76J
100U
1.2J
10U
4.0J
220
45U
43
0.20U
4.6J
140
80J
100U
0.80J
10U
2.0J
30J
13J
14
0.20U
20U
32
Time
1200
OS-Nov-94
S4J
100U
1.1J
3.9J
10U
160
45U
60
0.20U
6.0J
160
120
100U
4.0U
5.3J
10U
46J
9.1J
18
0.40U
S.1J
38
1400
OB-Nov-94
140
100U
1.6J
2.9J
10U
170
45U
40
0.20U
4.3J
110
98J
24J
4.0U
10U
10U
30J
45U
27
0.20U
20U
37
09-NOV-94
160
100U
4.0U
10U
10U
63J
45U
50
0.045J
20U
86
71J
100U
4.0U
10U
10U
120
45U
9.1
0.052J
20U
37
      Notes:
      •-Shock Load                          ND - Not Detected
      J - Not Detected; Corresponding Value Estimated.
      U - Not Detected; Corresponding Value Represents the Detection Limit

-------
Table C-13. TSSandVSS
DATE

02-Sep-94
05-Sep-94
07-Sep-94
09-Sep-94
12-Sep-94
14-Sep-94
16-Sep-94
18-Sep-94
23-Sep-94
23-Sep-94
26-Sep-94
28-Sep-94
30-Sep-94
Ol-Oct-94
05-Oct-94
07-Oct-94
10-Oct-94
12-Oct-94
14-Oct-94
16-Oct-94
19-Oct-94
21-Oct-94
24-Oct-94
26-Oct-94
28-Oct-94
31-Oct-94
02-Nov-94
04-Nov-94
07-Nov-94
08-Nov-94
08-Nov-94
08-Nov-94
08-Nov-94
09-Nov-94
ll-Nov-94
12-Nov-94
16-Nov-94
18-Nov-94
20-Nov-94
23-Nov-94
28-Nov-94
28-Nov-94
Total Suspended Solids (mg/L)
SI S4 S10

14
9
7
7
19
6
10
9
7
NA
10
5
3
3
3
5
4
16
36
17
10
8
15
14
14
11
10
13
48
18
100
66
71
46
43
19000
39
33
30
NA
NA
NA


1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
0.5
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
NA
NA
NA

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
9100
49000
Volatile Suspended Solids (mg/L)
SI S4 S10
~n 	
14
9
7
6
16
5
9
7
7
NA
9
4
3
3
3
5
4
10
22
9
6
5
10
12
12
9.6
8
9
40
15
72
51
52
38
34
17000
28
30
27
NA
NA
NA
	 1 	

1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
0.5
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NA
NA
im~m —

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
6300
39000
      Notes:
           NA - Not Analyzed
                                                  89

-------
Table C-14. TOG (mg/L)
                             DATE
 SI
STREAM
         S4
S10
                            02-Sep-94
                            16-Sep-94
                            30-Sep-94
                            14-Oct-94
                            28-Oct-94
                            09-Nov-94
500
900
800
900
800
3100
        120
        800
        120
        140
        170
        340
JNA
NA
NA
NA
26
140
                                                  90

-------

-------
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-------