EPA/540/R-95/536
                                     July 1996
 GRACE Bioremediation  Technologies
Daramend™ Bioremediation 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 information in this document has been funded wholly or in part by the U.S.  Environ-
mental Protection Agency (EPA) in partial fulfillment of Contract No. 68-CO-0048 and  Contract
No. 68-C5-0036 to Science Applications International  Corporation. It has been subject to the
Agency's peer and administrative review, and it has been  approved for publication  as  an  EPA
document. Mention of trade  names of commercial products  does not constitute an endorse-
ment or recommendation for use.

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

    The  National Risk Management Research  Laboratory (NRMRL)  is the Agency's center for
investigation of technological and management approaches for  reducing  risks from threats to
human health and the environment. The focus of the Laboratory's research program is on
methods  for the  prevention and control of pollution  to air, land, water  and subsurface resources;
protection of water quality in public water systems;  remediation of contaminated sites and ground
water; and  prevention and control of indoor air pollution. The goal of this  research effort is to
catalyze  development and implementation of innovative, cost-effective  environmental technolo-
gies;  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
    This report summarizes the results and activities of the demonstration of GRACE
Bioremediation Technologies  DARAMEND™ Bioremediation Technology  for the  treatment of
soils contaminated  with polynuclear aromatic hydrocarbons (PAHs) and  chlorinated phenols,
including pentachlorophenol  (PCP). The primary market for the DARAMEND™  Bioremediation
Technology consists of industrial wood preserving facilities that have used chlorinated phenols
and creosote derived PAHs as wood preservatives. This technology is patent pending and was
developed by  GRACE  Bioremediation  Technologies in Mississauga,  Ontario, Canada. The
demonstration was conducted at the Domtar Wood Preserving  Facility in Trenton,  Ontario, un-
der the USEPA's Superfund  Innovative Technology Evaluation  (SITE) Program.

    This demonstration  was  conducted for the Risk Reduction Engineering Laboratory (now the
National Risk Management Research Laboratory) in October 1993 to September 1994, and the
final report was completed as of November 1995.

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                                              Contents
Foreword	  ,	m
Abstract	iv
Tables	     yii
Figures  	    	v!»
Acronyms, Abbreviations and Symbols	    ix
Acknowledgments	     xi
Executive Summary 	      1

Section 1   Introduction
           1.1    Background	 	   7
           1.2    Brief  Description of Program and  Reports	   7
           1.3   The SITE Demonstration Program	   9
           1.4    Purpose  of the Innovative Technology Evaluation Report (ITER)	  9
           1.5   Technology  Description	    9
           1.6    Key Contacts	     10

Section  2   Technical Applications Analysis	     12
           2.1    Key Features	  12
           2.2    Operability of the Technology	     12
           2.3    Applicable Wastes	     14
           2.4   Availability  and Transportability of the Equipment 	    14
           2.5   Materials Handling Requirements 	    15
           2.6    SITE  Support Requirements 	     15
           2.7    Ranges of Suitable SITE Characteristics 	    15
           2.8   Limitation of the Technology 	     16
           2.9   ARARS for the DARAMEND™ Bioremediation Technology	   17
                 2.9.1    Comprehensive  Environmental Response, Compensation,  and Liability  Act
                        (CERCLA) 	     17
                 2.9.2   Resource  Conservation and Recovery  Act (RCRA)	   17
                 2.9.3   Clean Air Act (CAA)	     20
                 2.9.4   Clean Water Act (CWA) 	    20
                 2.9.5   Safe Drinking Water Act (SDWA)  	    20
                 2.9.6   Toxic Substances Control Act (TSCA) 	    20
                 2.9.7   Occupational Safety and Health Administration (OSHA) Requirements	  21
                 2.9.8   State Requirements 	     21

 Section  3   Economic Analysis	     22
           3.1  Introduction	     22
           3.2   Conclusions 	     22
           3.3   Issues and Assumptions 	     23
                 3.3.1    Waste Volumes and Site Size	    23
                 3.3.2    Process Optimization  and Performance 	.•	23
                 3.3.3    Process Operating Requirements  	    23
                 3.3.4    Financial Assumptions	24
           3.4   Basis for Economic Analysis	    24

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                                      Contents  (Continued)
                3.4.1  Site Preparation 	    24
                3.4.2   Permitting and Regulatory  Requirements	   26
                3.4.3 Capital Equipment	    26
                3.4.4  Startup  	    27
                3.4.5   Consumables and Supplies 	  :	27
                3.4.6  Labor	    27
                3.4.7   Utilities  	    27
                3.4.8   Effluent Treatment and  Disposal	   28
                3.4.9   Residuals and  Waste Shipping, Handling, and Storage  	  28
                3.4.10 Analytical Services	    28
                3.4.11  Facility Modification, Repair, and Replacement	28
                3.4.12 Demobilization 	    28
           3.5 Results 28

Section 4 Treatment Effectiveness	    32
           4.1 Background	    32
           4.2 Detailed Process Description	    34
           4.3 Methodology 	    35
                4.3.1  Sampling 	    35
                4.3.2 Data Analysis	    36
                4.3.3 Statistical Analysis 	    36
           4.4 Performance Data	    39
                4.4.1   SITE  Contractor Results from Pre-Demonstration	  39
                4.4.2  Summary of Results - Primary Objectives 	  39
                4.4.3  Summary of Results - Secondary Objectives 	  40
                       4.4.3.1    The Magnitude of Reduction in the Sums of the Concentration of Select
                                 PAHs and Chlorinated Phenols in the No-Treatment Plots Soils..	 40
                       4.4.3.2    The Magnitude of Reduction for Specific PAHs and Chlorinated Phenolic
                                 Compounds Within  Each Demonstration Plot	  40
                       4.4.3.3    Comparison of Performance of Treatment Plot vs. No-Treatment Plot	44
                       4.4.3.4    The Toxicity of the Soil to Earthworms and Seed Germination in Each of the
                                 SITE Demonstration Plots Before and After Treatment                     44
                       4.4.3.5    The Fate of Total Recoverable Petroleum Hydrocarbons in Each of
                                 the Demonstration Plots 	  46
                       4.4.3.6    General  Soil Conditions - Inhibitors/Promoters to Technology's  Effectiveness. 46
                       4.4.3.7    The Possible  Generation of Leachate 	  48
                       4.4.3.8    Treatment Effects on the Microbial Biomass  	  48
                       4.4.3.9    Tendency for the Downward Migration of Contaminants	 51
                       4.4.4     Process Operability and Performance	  51
           4.5 Process Residuals	    54

 Section 5  Other Technology Requirements	   56
           5.1   Environmental  Regulation  Requirements	  56
           5.2 Personnel Issues 	    56
           5.3 Community Acceptance	   56

 Section 6  Technology  Status	    58
           6.1   Previous Experience	58
           6.2 Scaling Capabilities	   58

 Appendix A Developer's Claims..	    59
                                                     VI

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                                                 Tables
ES-I    Feasibility Study Criteria Evaluation for the DARAMEND™ Bioremediation Technology	  2
2-1      Federal and State ARARs for the DARAMEND™ Technology	   18
3-1      Full-Scale Estimated Remediation Costs	    25
3-2     Site Preparation Costs	     26
4-I      Primary and Secondary Objective Results  for Total PAHs and Total  Chlorinated Phenols	  41
4-2     Specific Results for Each PAH and Chlorinated Phenol Compound Detected in the Treatment Plot	42
4-3     Specific Results for Each PAH and Chlorinated Phenol Compound Detected in the No-Treatment Plot  	 45
4-4     Summary of Statistical  Analysis of Contaminant Reductions in the Treatment and No-Treatment Plots..	 46
4-5     Mortality of the Earthworm 	     46
4-6     Inhibition of Germination 	     47
4-7     Results of Total Recoverable  Petroleum Hydrocarbon Analysis	   47
4-8     Summary Report for GRACE Bioremediation Technologies DARAMEND™ SITE Project: Total
        Dioxins/Furans	     48
4-9     DARAMEND™  Particle  Size Distribution Data	    55
                                                      VII

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                                              Figures
I-1     Site Location Map	     8
1-2     SITE Demonstration  Plots in Relation to GRACE Bioremediation  Technologies Plot	  8
3-1     Estimated Full-Scale Remediation  Costs	    30
3-2     Estimated Full-Scale Remediation  Costs (Without Disposal Costs) 	   31
4-I     Maintenance Record	    33
4-2     Soil Sample Aliquots for Sampling  Events 0 and 3	   37
4-3     Soil Sample Aliquots for Sampling  Events 1  and 2	   38
4-4     Primary and Secondary Objective  Results	    41
4-5     PAH Percent Removal by Number of Rings	    43
4-6     PAH Removal by Number of Rings	    43
4-7     Results of Total Recoverable Petroleum Hydrocarbon Analysis (TRPH)	  48
4-8     CFU/Gram Soil Using 100% PCA Agar	    49
4-9     CFU/Gram Soil Using  10% PCAAgar	    49
4-10   CFU/Gram Soil Using 25 mg/L PCP in Agar	   50
4-11    CFU/Gram Soil Using  12 mg/L PCP in Agar	   50
4-12   CFU/Gram Soil vs. TPAHs - 100% PCA 	   52
4-13   CFU/Gram Soil vs. TPAHs - 25 mg/L PCP	   52
4-14   CFU/Gram Soil vs. TCPs - 100% PCA  	   53
4-15   CFU/Gram Soil vs. TCPs - 25 mg/L PCP	   53
                                                   VIII

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                    Acronyms, Abbreviations and  Symbols
nq
AO
AQCR
AQMD
ARAR
ATTIC
BTEX
CAA
CCME
CERCLA
CERI
CFR
CFU
Cl
cm
CO
CO2
CP
CWA
DQO
EIT
EPA
ESD
FS
hf
kWh
MCL
CLG
MDL
mg/kg
mg/l
NAAQS
NCP
ND
NPDES
NRMRL
NTIS
ORD
OSHA
OSWER
PAH
Micro gram
Micrograms per kilogram
Micrograms per liter
Administrative Order
Air Quality Control Regions
Air Quality Management District
Applicable or relevant and appropriate requirements
Alternative Treatment Technology Information Center
Benzene, toluene,  ethylbenzene, and xylene
Clean  Air Act
Canadian Council of Ministers for the Environment
Comprehensive Environmental Response, Compensation,  and Liability Act
Center for Environmental Research Information
Code  of Federal Regulations
Colony Forming  Units
Confidence intervals
Centimeters
Carbon  Monoxide
Carbon  Dioxide
Chlorinated Phenol
Clean  Water Act
Data Quality Objective
Environmental Improvement  Technologies
U.S. Environmental Protection Agency
Explanation of Significant Difference
Feasibility Study
Horsepower
Innovative Technology  Evaluation Report
Kilogram
Kilowatt
Kilowatt-hour
Maximum contaminant levels
Maximum contaminant level  goals
Minimum Detection Limit
Milligrams per kilogram
Milligrams per liter
National Ambient Air Quality Standards
National Oil  and Hazardous  Substances Pollution Contingency Plan
Non-Detect
National  Pollutant  Discharge Elimination System
National  Risk Management Research  Laboratory
National Technical Information Service
EPA Office of Research and Development
Occupational Safety and Health  Act
Office of Solid Waste and Emergency Response
Polynuclear Aromatic Hydrocarbon
                                               IX

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            Acronyms, Abbreviations and  Symbols  (Continued)

PCA                 Plate Count Agar
PCB                 Polychlorinated  biphenyl
PCE                 Tetrachloroethane
PCP                 Pentachlorophenol
POTW               Publicly Owned  Treatment Works
PPE                 Personal protective equipment
PSD                 Particle  size distribution
RCRA                Resource Conservation and Recovery Act
S.U.                  Standard Units
SAIC                 Science Applications International  Corporation
SARA                Super-fund Amendments and Reauthorization  Act
SDWA                Safe Drinking Water Act
SITE                 Super-fund  Innovative  Technology  Evaluation
SWDA               Solid Waste Disposal Act
TC                   Total Carbon
TCP                 Total Chlorinated Phenols
TER                 Technology Evaluation  Report
THC                 Total Hydrocarbon Compounds
TIC                  Total Inorganic Carbon
TKN                 Total Kjeldahl  Nitrogen
TPAH                Total Polycyclic  Aromatic Hydrocarbons
TPH                 Total Petroleum Hydrocarbons
TRPH                Total Recoverable Petroleum Hydrocarbons
TSCA                Toxic Substances Control Act
TSD                 Treatment, Storage, and  Disposal
LIST                 Underground  Storage Tank
VISITT               Vendor  Information System for  Innovative Treatment Technologies
voc                 Volatile  Organic Compound
WHC                Water Holding Capacity
yd3                  Cubic yards

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                                  Acknowledgments
    This report was developed under the direction of Teri Richardson, the EPATechnical Project
Manager for this SITE demonstration at NRMRL in Cincinnati, Ohio.

    This  report  was prepared by the Environmental Technology Division of Science Applica-
tions International  Corporation (SAIC),  Hackensack,  NJ under the direction of Michael  M.  Bolen,
the SAIC  Work Assignment Manager, for the EPA under Contract No. 68-CO-0048. This report
was written in large part by Mr. Bolen, John King, Omer Kitaplioglu, and  Dr. Robert Hoke. Sta-
tistical analyses and the experimental  design were developed by Kirk Cameron and Dan  Patel.
Project Quality Assurance was provided  by Rita Schmon-Stasik and Joseph Evans. Field man-
agement responsibilities were performed by Steve Stavrou, with the exception  of the baseline
event, which was  overseen by William Dorsch.  Technical support  was provided by  Dr. Scott
Beckman, Dr.  Herbert Skovroneck, Joseph Zollo, Andrew Matuson, Antonia Laros, Brandon
Phillips, Paul Feinberg, Kate Mikulka, and  Nicole Hart.

    The cooperation and participation of Alan  Seech,  Paul Bucens, Dean Fisher, Brian O'Neill,
and supporting staff of GRACE Bioremediation Technologies throughout the course of the  project
and in  review of this report are gratefully acknowledged.

    Special thanks are offered to the employees at the Domtar Wood  Preserving Facility for
their hospitality  and assistance throughout this  SITE demonstration.
                                            XI

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                                         Executive  Summary
  This report summarizes the results and activities of the
demonstration  of GRACE Bioremediation  Technologies'
DARAMEND™ Bioremediation Technology for the treatment
of soils contaminated with polynuclear  aromatic hydrocar-
bons (PAHs)  and  Chlorinated Phenols (CPs), including pen-
tachlorophenol  (PCP).  The primary market for the
DARAMEND™ technology consists of industrial wood pre-
serving facilities that have used CPs and creosote derived
PAHs as wood preservatives. This technology is patent
pending and was developed  by  GRACE Bioremediation
Technologies in Mississauga,  Ontario, Canada. The dem-
onstration was  conducted  at the Domtar Wood Preserving
Facility in Trenton, Ontario, under the U.S.  Environmental
Protection Agency's  (USEPA's)  Superfund Innovative  Tech-
nology Evaluation (SITE)  Program.

  The DARAMEND™  Bioremediation Technology is a
bioremediation  process that treats soils contaminated with
PAHs and CPs by adding and distributing solid-phase or-
ganic amendments according to a strict application,  moni-
toring, and maintenance program. According to the devel-
oper, the DARAMEND  Bioremediation Technology re-
duces the acute toxicity of the soils aqueous phase by tran-
siently  binding  soil  contaminants and  allowing
bioremediation to proceed in highly toxic  soils. Further-
more,  the  developer  claims  the DARAMEND™
Bioremediation Technology is an effective  bioremediation
alternative for the treatment of soils containing high  levels
of CPs and PAHs,  which are typically considered too toxic
for bioremediation. The traditional treatments for these soils
include soil washing, incineration, or landfilling. There are
approximately  400 industrial  wood treatment facilities in
the United States and an  additional 200 sites in Canada
that exhibit  soils  contaminated with CPs  and creosote. The
Appendix contains additional  information presented  by the
developer, GRACE  Bioremediation Technologies.

   Under  the SITE Program, the technology was evaluated
to determine its  effectiveness in reducing  PAHs and CPs
in excavated soil at the Domtar site, after a proposed 240
days  of treatment (actual 254 days). The technology was
evaluated against the nine criteria for  decision-making in
the Superfund  Feasibility Study Process. Table ES-I sum-
marizes the specific federal environmental regulations
pertinent  to the  operation  of  the  DARAMEND™
Bioremediation Technology, including the transport, treat-
ment, storage, and disposal of wastes and treatment re-
siduals.

  The  DARAMEND™ Bioremediation Technology  is appli-
cable to the in situ and ex situ  remediation of soils con-
taminated  with PAHs and CPs. According to the developer,
the technology has been proven on soils with  PAH con-
centrations up to 18,500 mg/kg,  total petroleum hydrocar-
bon  concentrations up to 8,700  mg/kg, and PCP  concen-
trations up to 660 mg/kg. However, soils with extremely
high concentrations of  target compounds (i.e., 1800  mg/
kg of PCP) have proven resistant to the  DARAMEND™
Bioremediation Technology. The technology is a simple  soil
remediation system, both in design and implementation.
The  process involves a certain amount of materials han-
dling: the ex situ application more so than the in situ appli-
cation. The ex situ application  is similar to landfarming tech-
nologies in that a large amount of space is required to treat
the soils. In an ex situ  application, the process is designed
to generate no leachate. The process does  not require  any
major  utilities to  operate. Inhibitors to the technology  are
inordinate amounts of  debris in the soil,  acidic soils  (pH
<2),  and elevated heavy metal  concentrations in the  soil
(not yet determined by the  developer). According to  the
developer, the DARAMEND™ Bioremediation Technology
appears  to be  limited to soils contaminated with
nonhalogenated and slightly halogenated  organic com-
pounds and is not suited for soils contaminated with PCBs
and  other  highly halogenated organics.

  A  full-scale clean up of this demonstration  site using  this
technology was  estimated to cost  between $619,000 for
an in situ plot case with an attendant unit cost of $92/m3
($70/yd3), and $959,000 for an ex situ  plot case with an
attendant  unit cost of $140/m3 ($1 08/yd3). These costs were
calculated  based on the following assumptions: an equal
soil volume (6,800 m3);  a treatment depth of 0.6 m;  a treat-
ment period of 11 months  to meet regulatory standards;
one treatment cycle for the in  situ plot; and five treatment
cycles for the ex situ  plot, since the ex situ plot can only
accommodate 2,300 m2 of soil per cycle. For both cases
above, residuals  and waste  shipping and  handling charges
were the predominant cost.  Without residuals disposal, the
unit costs  decrease to $46/m3 ($35/yd3) for the in situ  plot,
representing a 50% reduction,  and $96/m3 ($73/yd3) for
the ex situ  plot, representing a 31% reduction.  No costs

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Table ES-I.  Feasibility Study Criteria Evaluation for the DARAMEND™ Bioremediation  Technology
Overall Protection of
Human Health and the
Environment
Provides both short-
and long-term protect-
ion by reducing or
eliminating organic
(PAHs and TCPs)
contaminants in soil.









Reduction of Toxicity,
Compliance with Long-Term Effectiveness Mobility, or Volume Short-Term
Federal ARARS and Permanence Through Treatment Effectiveness Imolementabilitv
Requires compliance Provides for
with RCRA treatment, irreversible treat-
storage, and land ment of PAHs and
disposal regulations TCPs.
(of a hazardous
waste).









Significantly reduces The DARAMEND™ Involves few
toxicity, mobility, and Bioremediation administrative
volume of soil contami- Technology requires difficulties.
nants through treatment, a period of approxi-
mately 240 days for
the degradation of
contaminants to reach
regulatory standards.
Length of time is based
on contaminant type,
concentration levels,
and the characteristics
of the media.


Community
Cost Acceptance
A first estimate Minimal short-term
cost is $50 to risks to the commu-
$80 USD/ton. nity make this tech-
The cost is nology appealing to
affected by pro- the public.
ject parameters
such as contami-
nant type and
initial concentra-
tion; soil volume
requiring remedi-
ation; climate;
remediation time
frame; and project
scope of work.
State
Acceptance
State ARARs
may be more
stringent than
federal regula-
tions.










Removes existing       Excavation,  construc-
contamination  source,   tion, and operation of
thereby preventing      onsite treatment unit
continual  contamination may require compli-
to  other  environmental   ance with location-
media,                 specific ARARs.
                       Prevents further
                       ground water
                       contamination  and
                       pollutant  migration.
Eliminates contamina-
tion source, thus re-
ducing the mobility of
contaminants to other
environmental  media.
System is easy
to install and
operate. Uses
conventional
excavation  and
tilling  equipment.
Technology is
generally  accepted
by the public  be-
cause it provides a
permanent solution.
State accept-
tance of the
technology
varies de-
pending upon
ARARs.
Requires measures
to protect workers and
community  during
excavation,   handling,
and treatment.
Process does not
generate significant
air emissions or
wastewater during
implementation  of
treatment.
Volume of soil after
treatment is slightly
increased due to the
addition of  treatment
amendments.
May require a
greenhouse type
enclosure to ensure
proper soil tempera-
ture and humidity.
Noise generated
during system in-
stallation could  be
troublesome,  but
once the process is
operational it does
not generate  much
appreciable  noise.

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were  assigned  for effluent treatment and disposal since
no leachate was generated for the  ex situ case. This was
also assumed for the in situ case at the demonstration
site,  although the developer indicated that pilot-scale test-
ing at other sites would be  required. For both cases, labor
and site preparation were among the top four cost catego-
ries,  after residual and waste shipping and handling costs,
costs attributed to analytical  services, capital equipment,
demobilization, permitting, and regulatory requirements are
about the same for both cases. The evaluation of the ex
situ application of the technology was the primary focus of
this SITE demonstration.

  The EPA SITE demonstration area consisted of two plots,
a Treatment Plot and a  No-Treatment Plot, containing ex-
cavated contaminated soil  from the same source on-site
(former  processing area). The plots were constructed iden-
tically, with the exception that the No-Treatment Plot was
only 2 m x 6 m, and the  Treatment  Plot was a 6  m x 36 m
area.  The No-Treatment Plot was left idle over the course
of the demonstration and was isolated from the treatment
process. The Treatment Plot consisted  of a 12-inch thick
layer of excavated soil targeted  for the DARAMEND™
Bioremediation  Technology  and evaluation by  the  SITE
Program.  Once the organic amendments were mixed into
the Treatment  Plot soil, monitoring  and maintenance  of
the Treatment Plot occurred over a  period of 11  months.  A
total of  254 treatment days occurred, excluding  days dur-
ing which  the soil temperature fell below 15°C. GRACE
Bioremediation Technologies,  the developer, monitored the
plot at least biweekly, by measuring the soil temperature,
soil water holding capacity,  soil moisture, and air tempera-
tures, and by conducting Microtox™ soil toxicity assays.
Maintenance  of the Treatment Plot consisted of biweekly
tillage and irrigation of the soil.

  The demonstration of the DARAMEND™ Bioremediation
Technology was conducted  from October 1993 to Septem-
ber 1994 at the Domtar site. The Domtar site is  located 90
miles east of Toronto, Ontario, along the northern coast  of
Lake Ontario.  The site was a wood-preserving  facility for
several  decades;  otherwise, very little is known  about the
history of the site. The facility is currently used to store  treated
lumber,  railroad ties,  and telephone poles.  Past  wood pre-
serving  operations used PCP (a chlorinated phenol com-
pound),  petroleum hydrocarbons, and creosote-derived PAHs
in their  processes. As a result the surrounding soil was con-
taminated by accidental  spills and by drippings during the
drying process. Recently, some of this contaminated soil was
excavated and  stockpiled for treatment by GRACE
Bioremediation  Technologies.  This  excavated soil was  uti-
lized  during the SITE demonstration.

  The primary objective  of the SITE demonstration was  to
evaluate the technology's  ability to reduce total PAHs and
total CPs (TCPs) in the Treatment Plot, which was expected
to be on the order of 95%, over a period of 240 days (eight
months) of treatment. To  accomplish this objective the
Treatment Plot was sampled at the  start (day 0) and at the
end of the demonstration (day 254), as well as during two
intermediate periods.  Soil samples were analyzed for semi-
volatile  organic compounds  (SVOCs,  by SW846 EPA
Method 3540/8270),  which  included  PCP and selected
PAHs.

  Process  performance was evaluated by comparing the
concentrations of the following analytes before and after
treatment:
                               Total Chlorophenols

                               . 2-chlorophenol
                               . 2,4-dichlorophenol
                               . 2,4,5-trichlorophenol
                               . 2,4,6-trichlorophenol
                               . Pentachlorophenol
Total  PAHs

• Naphthalene
• Acenaphthalene
• Acenaphthene
• Fluorene
• Phenanthrene
• Anthracene
• Benzo(g,h,i)Perylene
• Fluoranthene
• Pyrene
• Chrysene
• Benzo(a)pyrene
• Benzo(b)fluoranthene
• Benzo(k)fluoranthene
• Benzo(a)anthracene
• lndeno(l,2,3-c,d)pyrene
• Dibenzo  (a.h)anthracene
• Benzo (g,h,i) perylene
  The total  list of chlorophenols presented by the devel-
oper has been abbreviated to the above list to include those
analytes routinely analyzed under SW846 354018270.

  As  the process is temperature-dependent, the treatment
period only  incorporates days when the average daily soil
temperature within the plot was above 15°C. Originally,
the demonstration was scheduled  to run  until the begin-
ning of June 1994, but was extended to  the  end  of Sep-
tember due  to the number of days the soil  temperature fell
below 15°C during the winter months.

  As  part of the secondary objectives a variety of param-
eters  were evaluated  as  listed below:

   . Determine the magnitude of reduction in the sums
    of the concentrations of select PAHs and CPs in the
    No-Treatment Plot soils.

   . Determine the magnitude of reduction  for specific
    and  chlorinated  phenolic  compounds within each  of
    the SITE  demonstration plots.

   . Determine the toxicity of the soil to  earthworms  and
    seed germination in each of the  SITE  demonstra-
    tion plots  before and after treatment.

   . Monitor the fate of total recoverable petroleum hydro-
    carbons (TRPH)  in each  of the SITE demonstration
    plots.

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   . Monitor general soil  conditions (i.e., nutrients, toxins)
    that  might inhibit  or promote  process  effectiveness,
    such as total carbon (TC), total inorganic carbon (TIC),
    nitrate-nitrite, phosphate, total kjeldahl nitrogen (TKN),
    pH,  particle size distribution  (PSD), chlorides and to-
    tal metals within each of the SITE demonstration plots.

   . Monitor for the presence of  leachate  within  the SITE
    demonstration Test Plot.

   . Monitor each of the SITE demonstration plots for ac-
    tive microbial populations, specifically focusing on to-
    tal heterotrophs and PCP degraders, as a way to quali-
    tatively assess the magnitude  of biodegradation over
    the course of the eight-month test.

   . Monitor the upper sand layer in  contact with the treated
    soil to qualitatively  assess any tendency for downward
    migration  of contaminants.

  These  primary and  secondary project  objectives were
achieved through a carefully planned and executed sam-
pling  and analysis plan. For this demonstration SVOCs
were  considered  critical during "Baseline" and "Post-Treat-
ment" sampling (Event  #0 and Event #3) of the SITE dem-
onstration Treatment Plot. This parameter  was considered
noncritical during sampling  of the No-Treatment Plot and
during the two intermediate  rounds of Treatment Plot sam-
pling  (Event #1 and Event #2). The period of performance
evaluation was estimated by the developer to be approxi-
mately 240 days  (actual 254 days) starting on October 14,
1993. A week in September marked the final Event #3 (254
days) or  "Post Treatment Sampling" of the plots. The two
intermediate rounds (Event #l and Event #2) occurred on
the 88th  day and on the 144th day of treatment in April
1994  and June  1994.  No sampling was conducted during
the months of November, December, January, February,
and March since little biodegradation was  expected to oc-
cur at low winter temperatures.

  An  additional objective of this demonstration was to de-
velop data on  operating  costs for the DARAMEND™
Bioremediation Technology so that the applicability and cost
effectiveness of this process at other sites can be evalu-
ated.  Capital costs were obtained from  the developer.
Operating and maintenance costs  were either estimated
or obtained from the developer. Estimates for labor require-
ments were developed  using observations  made  and  data
gathered  during the demonstration. The companion docu-
ment  to this report is  the Technology  Evaluation  Report
(TER), which  contains  such information as  quality assur-
ance/quality control protocols, raw  and  summarized data,
and project chronology.

Conclusions  Based on Primary Objectives
  The DARAMEND™ Bioremediation Technology achieved
an overall 94% removal of  PAHs (with a 90% confidence
interval (Cl) of 93.4%  to 95.2%) and an overall 88% re-
duction of TCPs  (with a 90% confidence interval  of 82.9%
to 90.5%) after  254 days of treatment of the Treatment
Plot ex situ soils. Total PAHs were reduced from an aver-
age of 1710 mg/kg to 98 mg/kg and TCPs were reduced
from an average of 352 mg/kg to 43 mg/kg. Statistical com-
parison with 10%  level of significance indicate that reduc-
tions of PAHs and  chlorophenols realized in the Treatment
Plot were significantly higher that those realized in the  No-
Treatment Plot (presented later in this section).

Conclusions Based on  Secondary
Objectives
  The results of the demonstration suggest the following
conclusions regarding the technology's performance at  the
Domtar site. These conclusions were based on secondary
objectives:

No-Treatment  Plot Total PAH and TCP
Reduction Rates
  . Results  from the  No-Treatment Plot indicate total PAHs
   were reduced by 41% (with  a 90% Cl of 34.6% to
   48.7%) and CPs were reduced 0%. Total  PAHs were
   reduced from  an average of 1312 mg/kg to 776 mg/kg
   and TCPs remained at an approximate average of 217
   mglkg.

Treatment Plot - Specific PA H Compounds
and  Chlorinated Phenols
  . The reduction  of individual  PAHs and CPs in the Treat-
   ment Plot ranged from approximately 98% to 41%.
   Statistical analysis indicated that the reductions  ob-
   served  were significant with a 90% confidence level.
   The 3-ring and 4-ring PAH compounds were reduced
   more significantly than the  5-ring and 6-ring PAH com-
   pounds. The approximate average reduction rate of 3-
   ring and 4-ring PAH compounds was  97%; 5-ring and
   6-ring PAH compounds averaged approximately 77%
   and 40% removal, respectively.

No-Treatment  Plot  Specific PAH
Compounds and  Chlorinated Phenols
  . The reduction of individual PAHs and CPs in the No-
   Treatment Plot ranged from approximately 76% to 0%.
   The 3-ring and 4-ring PAH compounds were reduced
   more  significantly than the  5-ring and 6-ring PAH com-
   pounds. The approximate  average reduction rates of
   3-ring and 4-ring  PAH compounds were 64% and 34%,
   respectively. In comparison, the 5-ring  and  6-ring PAH
   compounds  averaged approximately  16%  and 20%
   removal, respectively.

Toxicity
  . Toxicity  analysis results indicate that  the treatment pro-
   cess appeared to reduce the toxicity of the Treatment
   Plot soil to both the earthworms and  plant seeds. At
   the end of the treatment process, the Treatment Plot
   soil sample was  considered nontoxic. The earthworms
   in the Treatment Plot soil exhibited a  100% mean
   mortality rate during the baseline. After 254  days of
   treatment  by the DARAMEND™  Bioremediation

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   Technology, earthworms exhibited a 0% mean  mortal-
   ity rate. Plant seeds in the Treatment Plot soil exhib-
   ited  a 100 to 52% mean inhibition  of germination rate
   (lettuce and radish, respectively) during the  baseline.
   After 254 days of treatment, lettuce and radish seeds
   exhibited  a 33%  and  0%  mean inhibition of germina-
   tion  rate,  respectively. The No-Treatment Plot exhib-
   ited  only  a slight reduction in toxicity and the soil re-
   mained toxic.  Only radish seed  germination changed
   from 82% mean  inhibition to 28% mean inhibition in
   the  No-Treatment Plot (others exhibited practically  no
   change). This slight reduction in toxicity of the  No-Treat-
   ment Plot soils is consistent  with the slight  reduction
   in PAHs  observed.

Total Recoverable Petroleum  Hydrocarbons
  . The results of the TRPH data for each plot  indicated
   significant reductions  occurred in the Treatment Plot
   (87%) and no reduction in the No-Treatment Plot mo/-
So/7  Chemistry
  . A significant reduction of PAHs and CPs in the Treat-
   ment Plot soil was  exhibited  despite the concentra-
   tions of metals and conventional soil chemistry present.
   The soil was primarily free of any inhibitors that may
   have impeded the biodegradation of the PAHs and
   CPs. The metals concentrations ranged  from 6690  mg/
   kg of iron to 1 mg/kg  of cadmium.  Levels of pH ranged
   from 8.16 to 9.38 in the Treatment Plot.  In addition,
   other soil chemistry analyses (e.g., nitrate-nitrite,  total
   organic  carbon, etc.) gave  no evidence  that nutrient
   levels in the soil were increased as a result  of the treat-
   ment process.  The No-Treatment  Plot exhibited  rela-
   tively the same soil  chemistry  as the Treatment Plot
   over the duration of the demonstration. Only TIC was
   elevated in the Treatment Plot (26,300  mg/kg to
   216,000 mg/kg) in comparison to the No-Treatment
   Plot (13,800 mg/kg to 96,200 mglkg).

  . Analysis of chlorinated  dioxins  and  furans  in the Treat-
   ment Plot at the beginning and  end of the  project indi-
   cated the presence of low concentration of various
   penta-,  hexa-, and hepta- congeners in both soils. The
   major  constituents were the fully chlorinated conge-
   ners. The toxic congener 2,3,7,8-TCDD was absent.
   Decreases, if any, in  totals for tetra-, hexa-,  hepta- octa-
   congeners would  lead one to suspect that  a  decrease
   has occurred over the course of the demonstration.

Leachate  Monitoring
  . No leachate was generated as a result of the  treat-
   ment process.

Microbial Biomass  Populations
  . The magnitude of biodegradation was enhanced  by
   the  treatment process and  inhibited by the PCP,  as
   measured by colony forming units (CPU) of total het-
   erotrophic microbial  biomass.  In  addition, the micro-
   bial  data suggests that high total  PAH concentrations
    in the soil had an inhibiting effect on the microbial bio-
    mass of the demonstration soil, including organisms
    that may be capable of metabolizing PCP. A large de-
    gree of variability (i.e., standard deviation) was asso-
    ciated with these conclusions,  and they may  not  be
    statistically significant. However,  all  observed trends
    were consistent and  biologically plausible.

Pollutant Migration Monitoring
  . Evaluation of the possible downward migration  of con-
    taminants was compromised prior to  the demonstra-
    tion and during the demonstration by the developer.
    No  conclusions can be substantiated.

Operability and Overall Performance
  . The  operability  and overall performance of the  tech-
    nology was very satisfactory. The treatment process
    was  installed, monitored, and maintained by the de-
    veloper as designed. Only one incident occurred: the
    underlying clean sand layer was accidentally mixed
    with the overlying demonstration soils  during the  dem-
    onstration (prior to the 88th day of treatment). Pos-
    sible dilution  calculations  indicate that  this incident had
    an insignificant effect (i.e.,  PCP approximately  2%) on
    the overall  performance of the technology. Section
    4.4.4 discusses this in more  detail.

  The findings of this  SITE  demonstration  are supported
by several complementary observations, all of which  dem-
onstrate that the  contaminants were removed  by the
DARAMEND™ Bioremediation  Technology. These include
(1)  a  statistical analysis of the first and last sampling epi-
sodes that indicate significant decreases in total  PAHs and
PCP;  (2) intermediate  measurements that show  steadily
declining values for these contaminants; (3) a marked de-
crease in TRPH over the  duration of the test; (4) decrease
in toxicity as measured by earthworm and seedling bioas-
says;  and (5)  bacterial plate counts that illustrate  enhanced
activity in the Treatment Plot. Taken together these obser-
vations  are more convincing than any single set  of data
considered separately.

  Other technology requirements for the implementation
of the DARAMEND™  Bioremediation Technology  may in-
clude  permits for the treatment, storage, construction,  pos-
sible air emissions,  etc. Personnel issues  are a factor de-
pending on the scale of the remediation. Otherwise, health
and safety issues for personnel are generally the same as
those that  apply at all hazardous  waste treatment  facili-
ties. Community issues may occur  depending  on the
community's exposure  to noise  and airborne particulate
generated during site preparation and  pretreatment activi-
ties.

  The following  sections of this report contain the  detailed
information that supports the  items summarized in this Ex-
ecutive  Summary.

  This section provides background information  about the
SITE- Program, discusses the purpose of this Innovative
Technology Evaluation  Report (ITER), and describes the

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DARAMEND™  Bioremediation  Technology. For additional
information about the SITE Program, this technology, and
the demonstration site, key contacts are listed at the end
of Section 1.

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                                               Section i
                                             Introduction
1.1  Background
  The GRACE  Bioremediation  Technologies  SITE dem-
onstration was conducted to evaluate the performance of
the developer's  DARAMEND™ Bioremediation  Technology
in  remediating PAH and  chlorinated phenol  contamination
in  wood-treatment soils from the Domtar Wood Preserv-
ing Facility in Trenton, Ontario. According to the developer,
the DARAMEND™ Bioremediation Technology is an effec-
tive bioremediation alternative to soil washing, incinera-
tion,  or  landfilling for soils containing  high levels  of CPs
and PAHs, which are typically considered too toxic for
bioremediation.

  The primary markets for the DARAMEND™ Bioremediation
Technology are industrial wood treatment facilities that have
used CPs  and creosote-derived  PAHs as wood preserva-
tives. There are  approximately 400 such sites in the United
States and an additional 200 in Canada. The DARAMEND™
Bioremediation Technology has  been applied to five other
PAH- and PCP-contaminated sites in Canada. According to
the developer, the success of the technology with wood pre-
serving  chemicals, such as PAHs, has allowed the contami-
nant range to be extended to phthalates in soils. In addition,
the developer states that a new  bioremediation technology
based on the DARAMEND™ Bioremediation Technology is
being developed that  rapidly reduces the concentrations of
organochlorine pesticides and organic explosives in soil.

   Prior to the developers participation in the EPA SITE Pro-
gram, the technology  underwent successful bench and pilot
scale testing by the developer on soils from the demonstra-
tion site. During the developer's  pilot-scale program, the re-
duction  of in situ chlorinated phenol concentrations to be-
low the  Canadian Council of Ministers for the  Environment
(CCME) guideline of 5 mg/kg,  and the  99%  reduction of
PCP (is a chlorinated  phenol) concentration  from 680 to 6
mg/kg, were  reported.  Total PAH concentrations were  also
reduced from 1485  mg/kg to 35 mg/kg during  this time. In
 1993, to assess the  reliability and cost effectiveness of the
technology,  GRACE  Bioremediation  Technologies con-
ducted  a full-scale demonstration at the Domtar facility to
treat 3000 tons of soil in situ and  1500 tons ex situ. Based
on the  results  of the site characterization in September
1993 and some further soil screening, targeted test soils
at the Domtar site were found to be acceptable for the
demonstration  of the DARAMEND™  Bioremediation Tech-
nology. The EPA SITE demonstration of the ex  situ
DARAMEND™ Bioremediation Technology was conducted
over the  next 11 months, from October 1993 to Septem-
ber 1994, at the Domtar site.

  The Domtar Wood Preserving Facility is located in Tren-
ton,  Ontario, Canada, approximately 90 miles east of
Toronto,  along the northern coast of Lake  Ontario (see
Figure l-l). Very little  is known about the history of the
site, other than its long history (several  decades)  as a
wood preserving facility. The wood treatment process re-
sulted in  the deposition of      creosote, and  petroleum
hydrocarbons in the soil. The facility currently operates
as a large storage yard for treated  lumber, railroad  ties,
and telephone poles; however, all wood preserving op-
erations  have  ended.  SITE demonstration activities  were
conducted at the northern end of the Domtar property and
utilized the  excavated soils from the former wood treat-
ment area (see  Figure 1-2).

1.2 Brief  Description  of Program and
Reports
  The  SITE Program  is a formal program established by
EPA's Office of Solid Waste and Emergency  Response
(OSWER) and  Office of  Research and Development
(ORD) in response to the  Superfund Amendments and
Reauthorization Act of 1986 (SARA). The SITE Program
promotes the development, demonstration,  and use of new
or innovative technologies to clean up Superfund sites
across the country.

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

   . the Emerging Technology Program

   . the Demonstration Program,

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                 Detroit
                                                  CANADA
Trenton
                                 *
                               Cleveland
Figure l-l. Site Location Map Trenton,  Ontario and Vicinity.
                                                     Toronto
                                                         *
                                                            '• Buffalo
                                                                 U.SA
                                                                                   *
                                                                                 Rochester
                                                                                         N
                                                SITE Demo No-Treatment Plot
               GRACE Bioremediation Technologies'
                        Main Treatment Area
                                                           2
                                                         Meters
  36 Meters
                               S2
                               03
                               Q)


                               CD
                                         Approximately 200 Meters
Figure 1-2. SITE Demonstration Plots in Relation to GRACE Bioremediation Technologies Plot.

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  . the  Monitoring  and  Measuring Technologies Program,
    and

  . the  Technology Transfer Program.

  The Emerging  Technology  Program focuses on  concep-
tually proven bench-scale technologies that are  in an early
stage of development involving pilot or laboratory testing.
Successful technologies are encouraged to advance to the
Demonstration  Program.

  The  Demonstration Program  develops reliable  perfor-
mance  and  cost data on innovative technologies so that
potential users may assess  the  technology's site-specific
applicability.  Technologies evaluated are either currently
available or close to being  available for remediation of
Superfund sites. SITE  demonstrations are conducted on
hazardous waste sites  under conditions  that closely simu-
late full-scale  remediation conditions, thus assuring  the
usefulness and reliability of information collected. Data
collected are used  to assess (1) the performance of the
technology, (2) the  potential  need for pre-  and post-treat-
ment processing of wastes, (3)  potential operating prob-
lems, and (4)  the approximate costs. The demonstrations
also allow for evaluation of long-term risks and operating
and maintenance costs.

  Existing technologies that  improve field monitoring and
site characterizations are identified in the Monitoring and
Measurement Technologies  Program. New technologies
that provide  faster,  more  cost-effective contamination and
site assessment data are supported by this program. The
Monitoring and Measurement Technologies Program also
formulates the protocols  and standard  operating proce-
dures for demonstrating methods and equipment.

  The  Technology  Transfer Program disseminates techni-
cal information on innovative technologies in the Emerg-
ing Technology Program,  Demonstration  Program, and
Monitoring and Measurement Technologies  Programs
through various activities. These  activities increase  the
awareness and  promote  the use of innovative technolo-
gies for assessment and remediation at Superfund sites.
The goal of technology transfer activities is to develop in-
teractive communication  among  individuals requiring up-
to-date  technical information.

 1.3 The SITE Demonstration Program
  Technologies are selected for the SITE Demonstration
 Program through annual requests for proposals. ORD staff
 review the proposals to determine which technologies show
the most promise for use  at  Superfund sites. Technologies
chosen must  be at the pilot- or  full-scale stage, must  be
 innovative, and must have some advantage over existing
technologies.  Mobile and  in situ  technologies  are  of par-
ticular  interest.

  Once EPA has accepted a proposal, cooperative agree-
 ments between  EPA and the developer  establish respon-
sibilities for conducting the  demonstrations and  evaluat-
ing the technology. The developer is responsible for dem-
onstrating  the technology at the  selected site and  is ex-
pected to  pay any costs  for transport, operation, and re-
moval of the equipment. EPA is responsible for project plan-
ning, sampling and  analysis, quality assurance and qual-
ity control,  report  preparation,  information  distribution, and
transport and disposal of treated waste materials.

  The results of this evaluation of the DARAMEND™
Bioremediation Technology are published in two  docu-
ments: the SITE Technology Capsule and the ITER. The
SITE  Technology Capsule  provides  relevant information
on the technology,  emphasizing  key results of  the SITE
demonstration. TER  is available as a supporting document
to the  ITER. Both the SITE Technology Capsule and the
ITER are  intended for use  by remedial managers  when
making a  detailed evaluation of the technology for a spe-
cific site and waste.

1.4  Purpose of the Innovative Technology
Evaluation  Report
  This ITER provides information on the DARAMEND™
Bioremediation Technology  and  includes a comprehensive
description of the demonstration and its results.  The ITER
is intended for use by EPA remedial project managers, EPA
on-scene coordinators, contractors, and other decision
makers in implementing specific remedial actions. The
ITER is designed to aid decision makers  in further  evalu-
ating specific technologies for consideration as applicable
options in a particular cleanup operation. This report rep-
resents a critical step in the development and commer-
cialization of a treatment technology.

  To encourage the general use of demonstrated technolo-
gies,  EPA provides information regarding  the applicability
of each technology to specific sites and wastes.  The ITER
includes information on cost and performance, particularly
as evaluated during the  demonstration. It also  discusses
advantages, disadvantages, and  limitations  of  the tech-
nology.

   Each SITE demonstration evaluates the performance of
a technology in  treating  a  specific waste. Waste charac-
teristics at other sites may differ from those at the demon-
stration site. Therefore, successful field demonstration  of
a technology at one site does not necessarily ensure its
applicability to other sites. Data from the field demonstra-
tion  may  require extrapolation to estimate the  operating
ranges in which the technology will perform satisfactorily.
Only limited conclusions can be drawn  from  a single field
demonstration.

 1.5 Technology  Description
   GRACE  Bioremediation Technologies' DARAMEND™
 Bioremediation Technology treats soils  contaminated  with
 PAHs and CPs  by adding and distributing solid-phase or-
ganic  amendments according  to a  strict application/moni-
toring/maintenance  program. The   DARAMEND™

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Bioremediation Technology is  patent pending and consists
of three components:

   . Addition of solid-phase organic soil  amendments of
    specific PSD  and nutrient content,

   . Distribution  of the soil amendments through the target
    matrix and the homogenization and aeration of the
    target matrix  using specialized tilling  equipment, and

   . A specialized soil moisture control system  designed
    to maintain moisture  content within a  specified range,
    to facilitate  rapid growth of an active microbial popula-
    tion and prevent the generation of leachate.

  According to the developer,  the  organic  amendments
enable the soil matrix to supply biologically available wa-
ter and  nutrients to  contaminant-degrading  microorgan-
isms, and transiently bind pollutants to reduce the  acute
toxicity of the soils aqueous phase, allowing the microor-
ganisms  to  survive  in soils containing very high concen-
trations  of toxicants. After homogenization  GRACE
Bioremediation  Technologies  amendments  are  added to
the soil in a volume of approximately 1 to 5% of the total
volume of the soil.  Addition of the amendments may in-
crease the soil volume up to 15% depending  on the amount
of pore space present. Typically, amendments are added
solely at  the beginning of the  treatment process,  however,
it is possible that approximately 10% of the original amount
may need to be added midway or near the end of the  treat-
ment period, based on the soil sample analytical results.
Once incorporated into the soil matrix, DARAMEND™ or-
ganic amendment particles are hydrated, begin  releasing
nutrients,  and are rapidly colonized by  microorganisms.
The  particles also have surface charges  that electrostati-
cally draw organic contaminants toward them. In  this way
the DARAMEND™  Bioremediation Technology creates
many microsites where soil  contaminants such  as  PCP
are first  drawn and then biodegraded.  The enzymatic
mechanism by which soil  bacteria destroy  PCP is  well rec-
ognized and results in complete  conversion  of  the con-
taminant  to carbon dioxide, water, and chloride ions.

  Tilling of the soil serves three  functions:  to reduce varia-
tions in soil  physical  and chemical properties; to  increase
the diffusion of oxygen to microsites; and to facilitate the
uniform distribution of soil amendments. The soil  matrix is
homogenized by tilling with a power take-off driven  rotary
tiller.  GRACE Bioremediation Technologies  utilizes two
tillers each of which  is pulled by a 75 hp tractor. The  tillers
are 2.1 and 1.7 m wide and can reach an effective depth
'of 60 cm.

  In addition, the developer determines the water-holding
capacity (WHC) of the targeted soils and  employs a spe-
cialized soil moisture  control system within  a  specific range
to encourage the proliferation  of large active microbial
populations, yet limit the  generation of leachate.  The fre-
quency of irrigation is determined by weekly monitoring of
soil moisture conditions. The  growth rate  of microbial bio-
mass is characterized via regular monitoring of soil tem-
perature using a commercial version of a hand-held ther-
mocouple.

  Biweekly maintenance of the plots consists  of the fol-
lowing tasks: plot tillage  using a specialized tractor and
tiller, soil  monitoring for moisture and temperature, and plot
irrigation. These are considered proprietary components
of the  developer's  process.

  The only form  of  pre-treatment  required by the
DARAMEND™ Bioremediation  Technology is the mechani-
cal screening of the soil (10 cm screen)  in  order to remove
debris  (rocks, wood, metal) that may interfere with  distri-
bution  of the organic amendment. Screened soil is trans-
ported to the treatment  area and spread  uniformly  in the
constructed treatment plots to  a  maximum depth of 0.6 m.
The constructed treatment plots consist of an area under-
lain with a  high-density polyethylene liner  (impermeable to
the target compounds). This liner will be underlain with 10
cm of screened  sand to prevent structural damage. An-
other 15-cm-thick sand layer and a 4-mm-thick fiberpad
are spread  on top of the liner to minimize the potential for
direct contact between the liner  material and tillage  equip-
ment. The  demonstration ex situ treatment area covered
an area of 2300 m2 and allowed treatment  of approximately
1500 tons of soil.

  The treatment plots may also be contained within a tem-
porary waterproof structure to produce  a warmer environ-
ment  in northern  latitudes, and  to aid  in  the retention of
soil moisture. The waterproof structure  consists of an alu-
minum frame covered by a shell of polyethylene sheeting
and is left  open at each end to allow  for equipment ac-
cess.

1.6  Key  Contacts
  Additional information on the DARAMEND™ Bioremediation
Treatment Process and the SITE Program can be obtained from
the following sources:

The DARAMEND™ Technology

Alan G. Seech
Director of  Operations
GRACE Bioremediation Technologies
3451 Erindale Station  Road
P.O.  Box 3060, Station A
Mississauga,  Ontario,  Canada L5A  3T5
Phone: (905)  272-7427
Fax:      (905) 272-7472
Email:  aseech@fox.nstn.ca

The SITE Program

Robert A. Olexsey,  Director
Superfund  Technology Demonstration  Division
U.S.  Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati,  Ohio  45268
Phone:  (513)  569-7861
Fax:     (513) 569-7620
                                                       10

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Teri L. Richardson
EPA SITE Technical  Project  Manager
U.S. Environmental Protection  Agency
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
Phone: (513) 569-7949
Fax:    (513) 569-7105

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

  . The Alternative Treatment Technology Information
    Center (ATTIC) System (operator:  513-569-7272; dial-
    in: 513-569-7610; telnet access: cinbbs.cin.epa.gov)
    is  a comprehensive, automated information  retrieval
    system that integrates data on hazardous waste treat-
    ment  technologies into  a centralized, searchable
    source. This database provides summarized informa-
    tion on innovative treatment  technologies.

  .The Vendor Information System for Innovative Treat-
    ment Technologies (VISITT)  (Hotline:  800-245-4505;
    Fax:  513-891-6685) database contains  information on
    231 technologies offered by 141 developers.

  .The OSWER CLU-ln electronic bulletin  board contains
    information  on the  status of  SITE  technology demon-
    strations (Operator: 301-589-8368; Access: 301-589-
    8366).

  Technical reports may be obtained by contacting the
Center for  Environmental  Research Information  (CERI),
26 West Martin Luther King  Drive,  Cincinnati, OH 45268
at 513-569-7562.
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                                                Section  2
                                Technical  Applications Analysis
  An  important  aspect  of  the  DARAMEND™
Bioremediation Technology is an understanding of the spe-
cific  physical and chemical  properties of the contaminated
soil that could limit the effectiveness of bioremediation. The
analysis is based on the SITE demonstration  results,  and
conclusions are based exclusively on these data since only
limited  information is available on other applications of the
technology. The EPA SITE Demonstration evaluated the
ex situ version of the DARAMEND™  Bioremediation Tech-
nology, which involved the treatment of approximately
11 Om3 of soil contaminated with PAHs and CPs,  including
PCP. Aseparate //isitudemonstration of the DARAMEND™
Bioremediation Technology was also conducted during the
same time frame  but was not  evaluated  under  the EPA
SITE Program. The DARAMEND™  Bioremediation Tech-
nology has been successfully applied to soils with widely
different physical and chemical properties.

2.1  Key Features
  The  DARAMEND™  Bioremediation  Technology  has
been successfully applied to soils with widely  different
physical  and chemical  properties.  DARAMEND™
Bioremediation Technology  is  generally an  inexpensive
remedial alternative and its remedial mechanism involves
the complete destruction of contaminants, to C02  and H20.
The  technology is  based upon the addition of specially for-
mulated solid phase organic amendments of a specific
PSD. In addition, these amendments  are supplemented
with  controlled-release  macronutrients and  trace  elements.
According to the  developer, the amendments increase the
ability of the soil matrix to supply biologically available water
and  nutrients to stimulate indigenous populations of con-
taminant-degrading  soil  microorganisms. Furthermore, the
developer claims that the amendments also transiently  bind
the contaminants to reduce the acute toxicity  of  the soil's:
aqueous phase, thus allowing the  microorganisms to sur-
vive  in  soil containing very high concentrations of contami-
nants.  Hence,  according  to  the  developer,  the
DARAMEND™ Bioremediation Technology can effectively
bioremediate soils traditionally considered too toxic for di-
rect  bioremediation.
2.2 Operability of the Technology
  The DARAMEND™ Bioremediation Technology is rela-
tively simple to operate. It consists of three integrated treat-
ment  components:

   . Addition of the appropriate specially formulated  solid-
    phase organic soil amendments to the  target matrix

   . Distribution of the soil amendments through the target
    matrix and the  homogenization and aeration of the
    target matrix  using specialized tilling equipment

   . Soil moisture control using a specialized system  to
    maintain moisture content within  a specified  range,  to
    facilitate rapid growth  of an  active microbial popula-
    tion and control the generation of leachate.

   For insituapplications of the technology,  the soil is ini-
tially broken up with excavation equipment to a depth  of
0.6 m, which is  the limit for the specialized  tilling equip-
ment. The soil is  broken up to  reduce compaction and  re-
move debris from the treatment zone. Following these ini-
tial soil preparation measures and the addition of amend-
ments, the soil is tilled with a power takeoff driven rotary
tiller. Tilling homogenizes the soil by effectively reducing
the physical and chemical variations and  evenly distrib-
utes soil amendments through  the treatment  zone.

   For ex  situ  applications of the technology, contaminated
soil is excavated and screened  to  10 cm to  remove debris
(rocks, wood, metal) that might interfere with the incorpo-
ration of the organic amendments. Screened soil is then
transferred to a  contained treatment area consisting of a
 bermed concrete pad or a plastic  lined treatment plot.
These contained  treatment areas are  sized  according  to
the volume of soil to be treated and the minimum space
requirements for  effective operation of the tilling equipment
within the treatment  plots. If a lined treatment  plot is  used,
the HOPE plastic  liner is  underlain  with  10 cm of  screened
sand to prevent structural damage to the liner. The liner is
overlain by a 4mm thick  fiberpad, and another sand  layer,
15 cm thick, is spread on top of the fiberpad, to  minimize
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the potential  for direct contact between the liner and the
tillage equipment. Once the upper  bedding material is  in
place, the screened soil is deposited on top of the sand to
a uniform depth of 0.5 m. Using a power take-off driven
rotary tiller, the soil  is homogenized  to reduce the physical
and  chemical variations of the soil. As with the in situ ap-
plication of the technology, the tilling equipment is also used
to facilitate the  uniform distribution of soil  amendments.
The  contained treatment areas are  typically covered by a
waterproof, temporary structure  to prevent excessive soil
wetting due  to rainfall and snow melt that would hinder
biodegradation  and lead to the generation of leachate.

  An  important  aspect  of  the  DARAMEND™
Bioremediation Technology is an  understanding of the spe-
cific  physical  and chemical properties  of the contaminated
soil that could limit the effectiveness  of bioremediation. This
information is acquired during an initial site  characteriza-
tion  and subsequent treatability  studies.  Once an under-
standing of various soil properties is  obtained, the  devel-
oper determines what alterations  would make the soil ideal
from a microbiological perspective, and selects  an organic
amendment  formulation with the specific PSD and  nutri-
ent profile to effect these  alterations. According to the de-
veloper,  the  DARAMEND™ Bioremediation  Technology
has  been successfully applied  to soils with widely different
physical  and chemical properties. For soils with high  clay
content DARAMEND™ organic soil amendments designed
to prevent agglomeration (i.e.,  formation  of large  clods)
are  employed.

  Since the  partitioning  of many soluble organic com-
pounds between leached,  adsorbed, and  biodegraded frac-
tions is influenced to some degree by textural variations,
percent organic matter and moisture content of the soil,
these physical  parameters need to  be defined during the
initial site characterization. Soil moisture is particularly
important, since excess moisture could limit the diffusion
of oxygen through the soil matrix to microbially active
microsites. Understanding the soil's WHC is also  impor-
tant  in gaining insight on the irrigation requirements of the
subject soil.

  Chemical properties of the soil that are explored  during
site  characterization/treatability  studies  include soil pH,
macro- and  micronutrient availability, the  presence  and
concentration of inhibiting compounds  (i.e., heavy metals,
cyanide)  and contaminant types and concentrations. Soil
pH affects solubility, toxicity,  adsorption,  and volatilization
of organic contaminants and ultimately the  biotransformational
capacity of the soil. A determination is  made  during this
initial characterization  as  to whether soil pH has to  be ad-
justed. The  nutrient requirements necessary to sustain
bacterial viability and growth are determined  based  on  the
mass of contaminants in the soil. These requirements  are
compared to the actual mass of nutrients available in the
matrix.  If the soil is lacking  in  the nutrients available  for
complete bioassimilation  of the contaminant mass, more
nutrients are  added to the soil. The soil is sampled for toxic
metals and any other compound that might be detrimental to
the indigenous  microbes. At elevated concentrations these
compounds could negate the viability of bioremediation as
a  remedial alternative  for these soils.  The initial concen-
trations of PAHs and chlorophenols in the soils are also
determined to assess if these concentrations have the
potential to limit the rate at which biodegradation  proceeds.
Soils with extremely  high concentrations of target contami-
nants  might need to  be mixed with soils having lesser
amounts of contamination  in order to  optimize the condi-
tions for biodegradation.

   The  presence of prolific indigenous microbial populations
that utilize the  organic contaminants as a food  source  is
another potential  operating parameter.  Microbial  activity  is
assessed prior to treatment and periodically during treat-
ment as part of assessing the biotransformational capaci-
ties of the soil. Soil samples are collected over the course
of the remediation  to  evaluate changes  in the microbial
populations resulting from system operation. Standard plate
count  methodologies are employed in the enumerations.
In situations where the microbial populations  are inad-
equate, the indigenous  communities may be augmented
with strains  of  hydrocarbon and PCP degrading microbes
previously cultivated from the contaminated soil. The soil
in the  treatment plots did not  require augmentation during
the Demonstration.

   Periodic soil tilling is  an important  operating aspect of
the DARAMEND™  Bioremediation  Technology.  Following
soil characterization and any treatability  studies,  the ap-
propriate  organic amendment formulation is tilled  into the
soil marking  the  start  of treatment. The amendments se-
lected are matched  to the specific physical and chemical
limitations of the soil to  optimize biodegradation.  The
amendments are thoroughly mixed into the contaminated
soil  using specialized  tilling equipment.  The  soil  is tilled
every  two weeks and  after each irrigation to increase dif-
fusion of  oxygen to the  microsites and to ensure  uniform
distribution of irrigation water in the soil profile.

   Maintaining the treated soil's moisture  content  after or-
ganic  amendment addition is  critical. After addition of the
organic amendments, the WHC  of the soil-amendment
mixture is determined, and the irrigation requirements of
the treated soil are established.  WHC is an expression used
to describe the mass of water that a soil can hold against
the force of gravity. As  long as a soil continues to retain
water  being added it is  below 100% WHC. Saturation,  or
 100%  of WHC, has been reached at this point where added
water  begins to be released from the soil. During  remedia-
tion, the soil  moisture content  is maintained within  a speci-
fied range (below the soil's WHC)  to facilitate  rapid growth
of a  large and viable  microbial population.  According  to
the developer, maintenance of soil moisture within a nar-
row range is critical for effective biodegradation  of the tar-
get compounds.  Excess soil moisture  can impede the dif-
fusion of  oxygen through the soil  matrix to microbially ac-
tive microsites, due to  a low ratio of air-filled to water-filled
pores. If soil moisture  falls below the optimum range, bio-
degradation can be inhibited  due to  inadequate biologi-
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cally available water.  Soil moisture is controlled by cover-
ing the treatment plots to eliminate wetting from precipita-
tion. The frequency of irrigation is determined  by  weekly
monitoring of soil moisture conditions at two depths: 0-20
and 40-60 cm. The upper horizon is the zone where most
of the water is consumed by microbial utilization, evapora-
tion, and downward migration. The lower horizon is moni-
tored for any excess soil moisture to appear.  Taken to-
gether the  two values  allow effective  characterization of
the moisture status of the soil profile and thus indicate when
irrigation is needed.

  Soil temperature is monitored regularly because it  can
greatly influence the  rate of bioremediation. Metabolic re-
actions tend to occur rapidly under warmer conditions  and
proceed more slowly  under  cooler  conditions. In  colder cli-
mates, the remediation season would be shorter, thereby
extending the time it takes to remediate a site  using the
DARAMEND™ Bioremediation Technology. For an ex situ
application, an enclosure that functions as a greenhouse
can  be  constructed over the treatment plots to extend vi-
able biodegradation into  the winter months.  Enclosures are
typically  not installed, since their  construction  adds sub-
stantially to the technology's capital cost, and the trade-off
of reduced remediation  time typically does  not justify the
construction expense.

  To chart the  progress of bioremediation  using  the
DARAMEND™ Bioremediation  Technology the  developer
periodically samples the treated soil. Sampling is performed
by dividing the treatment area up into sample zones mea-
suring 10 m on a side. Each sample zone is further subdi-
vided into 1 nf sub-units. Soil homogenization due to fre-
quent tilling negates  the need  to collect soils from every
sub-unit. Typically,  5  sub-units from each sample zone are
selected for sampling using a random number generator.
Cores collected from  each sub-unit within a  single  sample
zone are homogenized together  to form a single repre-
sentative sample of that sample zone.  Periodic sampling
also allows the  developer  to determine if further  adjust-
ments to the physical and  chemical properties of  the soil
are warranted.

2.3 Applicable Wastes
  As of this writing, the DARAMEND™  Bioremediation
Technology has been applied to six PAH- and PCP-con-
taminated  soil  sites in Canada. The DARAMEND™
Bioremediation Technology is considered suitable for the
in situ and ex situ remediation  of soil contaminated with
PAHs and CPs,  including PCP. These  compounds (e.g.,
PCP and creosote)  have  been used in the treatment of
wood because of their ability to inhibit  or slow down the
destruction of wood by microbes and  other wood-infesting
organisms.  It is  these same anti-microbial/bacterial char-
acteristics that make bioremediation  of soils contaminated
with wood  treatment chemicals difficult. The ability of the
technology to reduce the acute toxicity of the soil's aque-
ous phase by transiently binding soil contaminants allows
the process to treat soils typically  considered too toxic for
biodegradation.  According to the  developer, the technol-
ogy has been  proven on soils with PAH concentrations up
to 18,500 mg/kg, total petroleum hydrocarbon  concentra-
tions up  to 8,700 mg/kg,  and PCP concentrations up to
660 mg/kg.

  Soils with extremely high concentrations of target com-
pounds  have proved resistant to the DARAMEND™
Bioremediation Technology.  Bench-scale testing  conducted
on soil with a PCP concentration  of  18,000 mg/kg indi-
cated that treatment was  ineffective due to high acute soil
toxicity. In these situations,  the developer has diluted the
highly contaminated soil with less contaminated soil to di-
lute the  contaminants to a range  more suitable for the
DARAMEND™ Bioremediation Technology. The presence
of certain inorganic compounds (heavy  metals) at  elevated
concentrations may make a soil unsuitable for treatment
using the DARAMEND™  Bioremediation Technology.

2.4 Availability and Transportability  of the
Equipment
  The DARAMEND™ in  situ and ex situ  Bioremediation
Technology  is simple in  design  and implementation. The
DARAMEND™ Bioremediation Technology is generally not
considered  to be a mobile technology because the pro-
cess components are not trailer-mounted and are not ca-
pable of being transported from site  to site. Most hard-
ware  components and materials needed to construct treat-
ment plots are common and readily obtainable from local
hardware/plumbing stores and  lumber  yards.  Other equip-
ment, including  machinery, trailers, and storage  sheds can
often be  rented  locally. Utilizing rental equipment also tends
to eliminate transportation  needs and costs. Among the
pieces of equipment that  might be  required  are dump
trucks, rotary tillers, front-end loaders, mechanical shaker
screens,  backhoes, excavators,  skid-steer loaders, grad-
ers,  fork lifts, electrical generators, and steam cleaners.
The DARAMEND™ Bioremediation  Technology is as-
sembled  onsite  with basic  hardware  and  plumbing com-
ponents  that can be  transported  to the site in vehicles no
larger than  a pick-up truck. The only  supplies  that  might
have to  be brought in are the soil amendments and some
laboratory and sampling  items. Given  these  features, the
DARAMEND™ Bioremediation Technology is  always avail-
able.

   System installation  can take from a week to a  month.
The time it takes to set up  an ex situ  system depends on
the volume  of soil to  be  processed, the distance that the
soil has  to  be transported,  and the size of the treatment
plots. An in  situ  system takes  considerably  less  time to get
started since no construction is involved and the soil does
not have to be excavated  and screened. The initial soil
characterization  and any treatability   studies would likely
be conducted concurrently  or prior to  system installation.

   System demobilization  activities would consist of discon-
necting utilities,  disassembling the  treatment plots, return-
ing treated  soil  to its original  location, regrading,  decon-
taminating equipment, and arranging for disposal of all
residuals. Large debris that is initially screened from the
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soil will need to be handled, stored, and disposed of as
hazardous  waste.

2.5  Materials Handling Requirements
  The DARAMEND™ Bioremediation  Technology involves
a certain amount of materials handling; the ex situ appli-
cation more so than the in situ application. For ex situ treat-
ment,  contaminated soil must  be excavated,  screened,
homogenized, and  if the initial concentrations are too high,
diluted with less contaminated soil. In situ treatment re-
quires  only that the soil be  homogenized. Both applica-
tions require the incorporation of organic amendments into
the soil using tilling equipment.  Depending on  terrain fea-
tures and the volume of soil to be treated, site and soil
preparation can involve any combination of dump trucks,
front-end loaders,  backhoes,  excavators, conveyors,  skid-
steer loaders, graders, and fork lifts, in addition to a power
take-off rotary tiller. Screening equipment (Le., subsurface
combs, portable vibrating  screen,  etc.) is often required
for both in situ and ex situ treatment  to remove coarse
material in the soil (e.g., cobbles, large pieces of wood
and  metal, other debris) that would  interfere  with the in-
corporation of the  amendments.  In addition, ex situ treat-
ment also  involves the  construction  of a contained treat-
ment cell consisting of a bermed concrete pad  or a plastic
liner/fibrepad/sand  layer configuration  prior to delivery of
the contaminated soil. Once the soil is  properly  prepared
and  delivered to the treatment cell, the physical and chemi-
cal properties of the soil will be defined during the initial
waste  characterization.  Regular tilling   initially  distributes
the organic amendments through the soil.  Afterwards, the
soil is tilled every two weeks or  immediately after irrigation
to increase oxygen to microsites and ensure  uniform dis-
tribution of irrigation water in  the soil profile.

  The  DARAMEND™ Bioremediation Technology is de-
signed to limit  the production of leachate. Although  con-
trols are in  place to limit excessive soil wetting  due to rain-
fall/snow melt, extreme  weather conditions can cause prob-
lems. The ex situ treatment plots are  lined with HOPE and
are contoured in a manner that would  direct any leachate
along the central axis of the plot for collection. Any leachate
that  is  collected must be disposed  of according to regula-
tory  criteria or slowly recycled back into the plot as irriga-
tion  make-up water.

  After treatment,  the  ex  situ treatment plots  are disas-
sembled  and consumable items,  such as the  polyethylene
sheeting, fiberpad, and  plot covers must be disposed of.
Large  debris that  was initially screened from the soil will
need to be handled, stored, and disposed of as hazardous
waste. Treated soils can remain onsite,  if they satisfy site-
specific ARARs.

2.6 Site  Support Requirements
  Technology support  requirements  include utilities,  sup-
port  facilities, and  support equipment. These requirements
are discussed below.
  The DARAMENDTM  Bioremediation Technology does not
require any major utilities to operate. Minor utilities needs
include electricity, a potable water supply, telephone, and
sewer service. Electricity with  110 volt service is  needed
to supply power to a laboratory/field trailer. If power is un-
available  and a connection to the power grid  is considered
unfeasible, electric generators would  likely satisfy any
power requirements. Water is  necessary for  soil irrigation,
equipment decontamination, laboratory uses, and  person-
nel consumption. If potable water is unavailable, it can be
trucked in and stored  onsite.  Phone service to the site would
allow the field trailer to operate as a satellite office and
would promote more efficient  project  administration func-
tions. Phone service is  also important in  summoning emer-
gency assistance.  If  a  sewer  connection is  not available,
portable toilets can be  used for sanitary purposes.

  Support facilities required by the DARAMEND™
Bioremediation Technology  include a laboratory/field  trailer
and  a storage shed for storing  amendments,  supplies, and
tools. A roll-off or drum storage area is required for the
temporary storage of  screened debris  generated during
soil  preparation. An assortment of heavy equipment, dis-
cussed in Section  2.5,  is required during treatment  setup
and  decommissioning.

  Access to the site must be provided over roads suitable
for travel by heavy equipment. Personnel must  also be
able to reach the site without  difficulty. Depending on site
location,  security measures might be necessary to protect
the public from accidental injury and to prevent accidental
or intentional damage to the developer's equipment. A chain
link fence with a locking gate large enough to allow trucks
to enter and  leave should provide adequate security.

2.7 Ranges of Suitable  Site Characteristics
  To date, the DARAMEND™  Bioremediation  Technology
has  been applied to total petroleum hydrocarbons (TPH),
PAH, and chlorinated  phenol  contaminated  soils  at wood
treating facilities. This  report represents a critical step in
the development and  commercialization of a treatment
technology.

  The  site should be  well graded  and accessible to an
assortment of heavy equipment such as  dump trucks,  front-
end  loaders,  backhoes,  excavators,  skid-steer  loaders,
graders,  fork lifts and a rotary tiller. Areas that are desig-
nated for excavated or in situ treatment must be free of
utilities lines or other underground features (i.e., fuel tanks,
piping). The subsurface should  be free  of large debris,  such
as might be found in a landfill.

  Areas  designated for the staging of ex situ treatment
plots must satisfy the space requirements of the treatment
plots. Since the depth  of the soil deposited in  a treatment
plot  is  dictated by the  limitations of the tilling equipment,
approximately  20 m2 of surface area are necessary to treat
10 m3 of  contaminated  soil. Tilling equipment can only mix
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soils to a depth of 0.5 m. The maximum tilling depth also
imposes  limitations on  the  in situ application of the tech-
nology. If contamination  extends to greater depths,  a  pos-
sible option is to treat the soil 0.5 m at a time, whereby the
treated soil  is temporarily removed to expose the next layer
of contaminated soil. However,  remediating  the  site a layer
at a time will increase the throughput time.  For in situ treat-
ment, any dimension plot can be treated; however, in ad-
dition to the depth  limitation previously discussed,  any  in
situ plot should be free of obstruction that could  interfere
with  tilling  equipment. Other space requirements include
an area large enough to set up a laboratory/field trailer
and a drum staging  or roll-off storage area.  Sufficient space
should be available to  maneuver the trailer and  roll-off in
and out of the  site, and there should be room for a  waste-
water storage tank and  a tank truck if potable water needs
to be trucked in. Enough space for a small shed used  to
store  organic amendments and tools should also  be avail-
able. A small area,  measuring 4 m2, is needed  to facilitate
the decontamination of equipment and personnel through-
out the  remediation.

   Since the DARAMEND™ Bioremediation Technology
physically and chemically  alters  the  contaminated  soil  to
enhance the rate of bioremediation, soil characteristics  at
a  particular site are not as critical  in determining a site's
suitability for the DARAMEND™  Bioremediation  Technol-
ogy  as they might be  for  other bioremediation technolo-
gies. A number of factors that could interfere with the pro-
cess would be an inordinate amount of debris in the soil,
that  would  interfere with  the  incorporation  of organic
amendments and reduce the effectiveness of tilling, and
the presence of toxic compounds (i.e., heavy metals) that
may be detrimental  to soil microbes. In addition, soils with
a high humic content could interfere with the application  of
the DARAMEND™ Bioremediation Technology by slow-
ing down the cleanup through increased  organic adsorp-
tion and oxygen demand.

   Sites  that  are suitable  for the  DARAMEND™
Bioremediation Technology should not be prone to sea-
sonal flooding nor have a water table that fluctuates  to
within 1 m of the site's surface. A high water table and
flooding will interfere with attempts to maintain soil mois-
ture  within  the narrow  range necessary for effective bio-
degradation and could potentially redistribute  contamina-
tion  across the site. Flooding could also  destroy  the  ex
situ treatment plots, equipment, and  supplies.

  The DARAMEND™ Bioremediation Technology is  suit-
able for organic contaminants found in  wood  preserving
soils, such  as  PAHs and CPs.  The developer has also re-
ported encouraging results with soils contaminated  with
light oils, heavy oils, and phthalates. The developer has
indicated that the technology would experience problems
with  soils contaminated with PCBs.  In addition, soils with
extremely  high contaminant levels may limit  the rate  at
which biodegradation proceeds,  and would need to be
mixed with  less contaminated soil to  allow biodegradation
to proceed.
  The technology can be operated in nearly every climate,
although  remediation  times are extended in colder climates
due to a significant reduction in the rates of remediation
during the winter months. A canopy placed over the treat-
ment plot to prevent  excessive soil wetting by precipitation
also insulates the soil to some degree.

  The DARAMEND™ Bioremediation Technology can be
used in fairly close proximity to inhabited areas,  providing
that appropriate measures are implemented to prevent off-
site emissions,  odors, and  noise. The DARAMEND™
Bioremediation  Technology  generates very little noise,
since the plots are left idle for the majority of the treatment
period.  Some noise will be generated during the initial
phases  of remediation  that will involve excavation and till-
ing of the soil. Additional noise would  be generated when
the soil is refilled  every other week. Precautions might need
to be taken at some  sites to limit the production of volatile
emissions and dust during  excavation and tilling.

2.8 Limitations of the Technology
  The ex situ DARAMEND™  Bioremediation Technology
is similar to landfarming technologies in that a large amount
of space is required to treat the soils.  Fortunately, most
work to date has been done on former wood preserving
sites,  which by nature have plenty  of land available. The
land  requirements of the technology are  exacerbated  by
the limitations  of the tilling  equipment, which can only till
soil down to a depth  of 0.6 m. As a result, the surface di-
mensions of a treatment plot  are enlarged to compensate
for the depth limitations. The  tillage  equipment also limits
the depth to which soil can be  remediated in the in situ
application of the technology.  The in situ treatment plot
must also be free of any surface and subsurface obstruc-
tions that would  interfere with soil tilling.

  The  ex situ  application  of   the   DARAMEND™
Bioremediation Technology requires soil  to  be excavated
from one area and treated in another area. Communities
generally prefer  technologies  that do  not  require excava-
tion due to the noise and potential emissions that are pro-
duced. Communities also object to the inherent hazards
associated with increased heavy equipment and truck traffic
in their neighborhoods.

  At some sites  the reduction of contaminant concentra-
tions may be caused more by volatilization than biodegra-
dation. This problem  has not  been  encountered yet, since
the technology has only been applied to soil contaminants
characterized by  low volatility. If the technology is applied
to a site where the contaminants  consist primarily of lighter,
more  volatile compounds a significant percentage of the
contaminant mass will be volatilized as a result of soil  han-
dling.  It is likely that certain controls would have to  be imple-
mented  at sites where soils are contaminated primarily with
volatile organic contaminants, in order to  meet air quality
standards.
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  The DARAMEND™ Bioremediation Technology appears
to be limited to soils contaminated with  non-halogenated
and  slightly halogenated organic compounds.  The devel-
oper claims that the technology would probably not work
on soils contaminated with PCBs or highly halogenated
organics.  In addition, the DARAMEND™ Bioremediation
Technology is a soil remediation  system and does not treat
ground water, surface water, or sludge.

2.9  ARARS for the DARAMEND™
Bioremediation  Technology
  This subsection discusses specific  federal environmen-
tal  regulations  pertinent to the  operation  of the
DARAMEND™  Bioremediation  Technology  including the
transport, treatment,  storage, and disposal  of wastes and
treatment  residuals.  Federal and state  applicable  or rel-
evant  and appropriate requirements (ARARs)  are pre-
sented in  Table 2-1.  These regulations are reviewed with
respect to the demonstration results. State and local regu-
latory requirements,  which may be more stringent, must
also  be addressed by remedial  managers. ARARs include
the following: (1) the Comprehensive Environmental Re-
sponse, Compensation,  and  Liability Act;  (2) the Resource
Conservation and Recovery Act; (3) the  Clean Air Act; (4)
the Safe Drinking Water Act;  (5) the Toxic Substances
Control Act;  and  (6) the Occupational Safety  and  Health
Administration  regulations. These six general ARARs are
discussed  below.

2.9.1  Comprehensive  Environmental
Response,  Compensation,  and  Liability Act
(CERCLA)
  The  CERCLA of 1980 as amended by the Superfund
Amendments and Reauthorization Act  (SARA) of 1986
provides for federal funding to  respond to releases or po-
tential releases of any hazardous substance into the envi-
ronment, as  well as to  releases of pollutants  or contami-
nants that may present  an imminent  or  significant danger
to public health and  welfare or to the environment.

  As part of the  requirements of CERCLA, the EPA has
prepared  the National Oil and Hazardous Substances Pol-
lution Contingency  Plan (NCP) for hazardous substance
response.  The  NCP is codified  in Title 40 Code of Federal
Regulations (CFR) Part 300, and delineates the  methods
and  criteria used to determine the appropriate extent of
removal and cleanup for hazardous waste contamination.

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

   . Use remedial  alternatives that permanently  and sig-
    nificantly reduce the volume,  toxicity, or mobility of
    hazardous  substances, pollutants, or contaminants.

   .Select  remedial  actions that protect human health and
    the environment, are  cost effective,  and involve per-
    manent solutions and alternative treatment or resource
    recovery technologies to the maximum extent possible.

  .Avoid offsite transport and  disposal  of untreated haz-
    ardous substances  or contaminated materials when
    practicable treatment  technologies exist  [Section
    121 (b)].

  The DARAMEND™ Bioremediation Technology  meets
each of these requirements. Volume, toxicity, and mobility
of contaminants in the waste  matrix are all  reduced as a
result of treatment. Organic compounds are biodegraded
by indigenous soil microbes either insituor ex situ in a
series of specially designed treatment plots. In both cases,
contaminants are subject to biochemical reactions that
convert them to cell material and energy for metabolic pro-
cesses.  Even  though  microbial, biochemical  byproducts
of these reactions were not monitored during the demon-
stration, they were assumed to consist of carbon dioxide
and water. Except for the debris that is screened from the
soil prior to treatment, the need for offsite   transportation
and  disposal of solid waste  is eliminated  by ms/futreat-
ment. Soils, once treated, can be left in place. Volatile
emissions  generated during construction and tilling opera-
tions might require control and treatment prior to release
to the atmosphere.

  In general, two types of responses  are possible  under
CERCLA: removal and  remedial action. Superfund removal
actions are conducted in response  to an immediate threat
caused by a release of hazardous substances.  Removal
action decisions are documented in an  action  memoran-
dum. Many removals involve  small quantities of waste  or
immediate threats requiring quick  action to alleviate the
hazard. Remedial actions are governed by the  SARA
amendments to CERCLA. As stated above,  these amend-
ments promote remedies that  permanently reduce the vol-
ume, toxicity, and mobility of hazardous  substances, pollut-
ants, or contaminants. The DARAMEND™ Bioremediation
Technology is likely to be part of a CERCLA remedial action.

  Onsite remedial actions must comply with federal and
more stringent state ARARs. ARARs are determined on a
site-by-site basis and may  be  waived under  six conditions:
(1) the action is an interim measure, and the ARAR will be
met  at completion;  (2) compliance with the  ARAR would
pose a greater risk to health and  the environment than
noncompliance; (3) it is technically impracticable to meet
the ARAR;  (4)  the standard of performance of an ARAR
can be met  by an equivalent method:  (5) a state ARAR
has not been consistently applied elsewhere;  and (6) ARAR
compliance would not provide a balance between the pro-
tection achieved at a particular site and demands  on the
Superfund  for other sites. These waiver options  apply only
to Superfund actions taken onsite,  and justification for the
waiver must be clearly demonstrated.

2.9.2 Resource  Conservation  and
Recovery Act (RCRA)
  RCRA, an amendment to the Solid Waste Disposal Act
(SWDA), is the primary federal legislation governing haz-
                                                      17

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Table 2-1.   Federal and State Applicable and Relevant and Appropriate Requirements (ARARs) for the DARAMEND™ Bioremediation Technology
Process Activity
                                  ARAR
                              Description of
                               Regulation
                                 General
                               Applicability
                                    Specific
                                 Applicability to
                                 DARAMEND™
Waste Characterization of
untreated wastes
Soil  excavation
Storage prior to
processing
RCRA: 40 CFR  Part 261
or state equivalent
                              CAA: 40 CFR Part 50
                              (or state equivalent)
                              RCRA: 40 CFR Part 262
                              or state equivalent
RCRA: 40 CFR Part 264
or state equivalent
Waste processing
Waste processing
RCRA: 40 CFR Part 264
(or state  equivalent)
CAA: 40 CFR Part 50
(or state equivalent)
Storage of auxiliary
wastes
 RCRA: 40 CFR Part 264
 Subpart J (or state
 equivalent)
                              RCRA: 40 CFR Part 264
                              Subpart I (or state
                              equivalent)
Standards that apply to
identification and
characterization of wastes
                          Regulations govern toxic
                          pollutants, visible emissions
                          and particulates
                          Standards that apply to
                          generators of hazardous
                          waste
Standards applicable to
the storage of hazardous
waste
Chemical and physical
analyses must be performed
to determine if waste is a
hazardous waste.
                           If excavation  is performed,
                           emission of volatile com-
                           pounds or dusts may
                           occur.

                           Excavated  soils may be
                           considered hazardous
                           waste.
Excavation and pretreat-
ment screening may
generate hazardous over-
sized wastes that must be
stored  in waste piles.
Standards that apply to
treatment of wastes in a
treatment facility
 Regulation governs toxic
 pollutants, visible emissions.
 and particulates
When hazardous wastes
are treated, there are
requirements for operations,
recordkeeping, and contin-
gency planning.

Stack gases may contain
volatile organic compounds,
or other regulated  gases
 Regulation governs stan-
 dards for tanks at treatment
 facilities
                           Regulation covers storage
                           of waste materials gener-
                           ated
 If storing non-RCRA wastes,
 RCRA requirements may
 still be relevant and appro-
 priate
                            Applicable for RCRA
                            wastes; relevant and appro-
                            priate for  non-RCRA wastes
Chemical and physical
properties of waste
determine its suitability
for treatment by
DARAMEND™

Applied to construction
activities  (i.e., excavation
and screening) during
system installation

Staged soil for ex situ
treatment should be
placed in treatment plots
immediately

If stored in a waste pile,
the materials should be
placed on and covered
with plastic, and tied
down to minimize fugi-
tive emissions. The time
between  excavation and
treatment (or disposal if
material is unsuitable for
treatment) should be
minimized

Applicable  or appropriate
for DARAMEND™ oper-
ations
 During the SITE Demon-
 stration, no stack gases
 were  emitted, however,
 stack gases may be of
 concern and must not
 exceed limits set for the
 air district of operation.
 Standards for monitoring
 and recordkeeping apply

 Storage tanks for liquid
 wastes (e.g., decontami-
 nation waters and con-
 densate) must be
 placarded appropriately,
 have  secondary contain-
 ment, and be inspected
 daily

 Roll-offs or drums con-
 taining drill cuttings need
 to be labeled as hazard-
 ous waste. The storage
 area needs to be in good
 condition,  weekly inspec-
 tions are required, and
 storage should  not
 exceed 90 days unless a
 storage permit is
 obtained
             (continued)
                                                                    18

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Table 2-1    Continued
Process Activity

Waste characterization
(treated waste)
Storage after treatment
    ARAR

RCRA: 40 CFR Part 261
(or state equivalent)
RCRA: 40 CFR Part 264
Subpart I (or state
equivalent)
Waste disposal
                           RCRA: 40 CFR Part 262
                           CWA: 40 CFR Parts 403
                           and/or 122 and 125
   Description of
     Regulation

Standards that apply to
identification and character-
ization of wastes
Standards that apply to
the storage of hazardous
waste
                       Standards that pertain to
                       generators of hazardous
                       waste
                       Standards for discharge of
                       wastewater to a POTW or
                       to a navigable waterway
      General
    Applicability

Chemical and physical
analyses must be performed
to determine if treated
waste is a hazardous waste.

The treated material will be
stored in the plot until it has
been characterized and a
decision on final disposition
has been made.
                         Generators must dispose
                         of wastes at facilities that
                         are permitted to handle the
                         waste. Generators must
                         obtain an EPA ID number
                         prior to waste disposal.
                         Discharge of wastewaters
                         to a POTW must meet pre-
                         treatment standards; dis-
                         charges must be permitted
                         under NPDES.
                           RCRA: 40 CFR Part 268    Standards regarding land    Hazardous wastes must
                                                  disposal of hazardous
                                                  wastes
                                                meet specific treatment
                                                standards prior to land dis-
                                                posal, or must be treated
                                                using specific technologies.
       Specific
    Applicability to
    DARAMEND™

Chemical and physical
properties of treatment
residuals must be per-
formed prior to disposal.

The treatment plots must
be maintained. If stored
in a waste pile, oversize
material should be
placed on and covered
with plastic, and tied
down to minimize fugitive
emissions. The material
should be disposed of or
otherwise treated  as
soon as possible.

Waste generated by the
DARAMEND™ is limited
to contaminated drill cut-
tings. Spent activated
carbon could  be another
waste if carbon is used in
the treatment of system
off gases.

Applicable and appropri-
ate  for decontamination
wastewaters and  con-
densate.
                                                  The treated material will
                                                  be stored in the treat-
                                                  ment plot until it has
                                                  been characterized and
                                                  a decision on final dis-
                                                  position has been made.
 ardous waste activities and was passed in 1976 to ad-
 dress the problem of how to safely dispose of municipal
 and  industrial solid waste. Subtitle  C of RCRA  contains
 requirements for generation, transport, treatment,  storage,
 and disposal of hazardous waste, most  of which  are also
 applicable to CERCLA activities. The Hazardous and Solid
 Waste Amendments (HSWA)  of  1984  greatly expanded
 the scope and requirements of RCRA.

   RCRA regulations define hazardous wastes and regu-
 late their transport, treatment, storage, and disposal. If soils
 are determined  to be hazardous  according to RCRA (ei-
 ther  because of a characteristic or a listing carried by the
 waste), all RCRA  requirements  regarding the management
 and  disposal of hazardous waste must be  addressed by
 the remedial managers.  Criteria for identifying character-
 istic  hazardous  wastes are included in 40 CFR Part 261
 Subpart  C.  Listed wastes from specific and nonspecific
 industrial  sources,  off-specification  products, spill clean-
                                    ups, and other industrial sources are itemized in  40 CFR
                                    Part 261  Subpart D. If the Domtar demonstration  site was
                                    located within the United States, the technology would likely
                                    be subject to RCRA regulations because the former wood
                                    treatment facility would  be contaminated with  RCRA-listed
                                    wastes included under the F034 code (e.g., wastewaters,
                                    process residuals,  preservative  drippage,  and  spent for-
                                    mulations from wood  preserving processes  generated  at
                                    plants that use creosote formulations).  RCRA regulations
                                    do  not apply to sites where RCRA-defined hazardous
                                    wastes are not present.

                                      Unless they are specifically delisted through delisting
                                    procedures, hazardous wastes listed  in 40 CFR Part 261
                                    Subpart D remain listed  wastes regardless  of the treat-
                                    ment they  may undergo  and  regardless of the final  con-
                                    tamination level in the streams and residues.  This implies
                                    that even after remediation, "clean" wastes are still classi-
                                                             19

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tied as hazardous because the pretreatment material was
a listed waste.

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

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

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

  The CAA requires that  treatment, storage, and disposal
facilities comply with primary and secondary ambient  air
quality  standards. Fugitive  emissions from  the
DARAMEND™ Bioremediation Technology may come from
(1)  excavation and construction of ex situ treatment plots,
(2) periodic tilling of soil in ex situ and /fls/totreatment
plots, and (3) the staging and storing of screened debris.
Soil moisture should be managed during system installa-
tion to prevent  or minimize the impact from fugitive emis-
sions. State  air quality standards may require additional
measures to  prevent fugitive emissions.

2.9.4 Clean  Water Act  (CWA)
  The objective of the CWA is to restore and maintain the
chemical, physical, and biological  integrity  of the nation's
waters. To achieve  this  objective, effluent  limitations  on
toxic pollutants  from  point sources were established. Pub-
licly-owned treatment works (POTWs) can  accept waste-
waters with toxic pollutants; however the facility discharg-
ing the wastewater must  meet pretreatment standards and
may need a discharge permit. A facility desiring to discharge
water to a navigable waterway must apply for a permit
under the National  Pollutant  Discharge  Elimination Sys-
tem (NPDES). When an NPDES permit is issued, it in-
cludes waste  discharge requirements according to volume
and  contaminant  concentration.

  The only wastewater produced by the DARAMEND™
Bioremediation Technology that might need to be managed
is wastewater generated during equipment  decontamina-
tion.  Soil moisture in the treatment plots is controlled within
strict limits to optimize biodegradation and prevent the
generation of leachate. Leachate could also  be generated
as a consequence of rainwater or snow melt seeping
through a treatment plot cover.  Decontamination water
could amount to several thousand  gallons  depending on
the scale of a remediation effort at a given site. Depending
on the levels of contaminants and the volume of this waste-
water,  pretreatment might be required prior to  discharge
to a  POTW.  This water could possibly be used as makeup
water for spray irrigation of the treatment plots thereby elimi-
nating the need for disposal at a POTW.

2.9.5  Safe Drinking Water Act (SDWA)
  The SDWA of 1974, as most recently amended by the
Safe Drinking Water Amendments of 1986,  requires EPA
to establish regulations to protect human health  from con-
taminants in drinking water. The legislation  authorized na-
tional drinking water standards and  a  joint federal-state
system  for ensuring  compliance with  these  standards.

  The  National  Primary Drinking  Water Standards are
found in 40 CFR Parts 141 through  149. These drinking
water standards  are  expressed as  maximum contaminant
levels (MCLs)  for some constituents,  and maximum  con-
taminant level goals  (MCLGs)  for others. Under CERCLA
(Section 121  (d)(2)(A)(ii)), remedial actions are required to
meet the standards of the MCLGs when relevant.  The
DARAMEND™ Bioremediation  Technology is not aground-
water remediation technology, but it could improve the
quality of the ground water by reducing contaminant load-
ing by bioremediating the source of contamination in the
vadose zone.

2.9.6   Toxic  Substances Control Act (TSCA)
  The  TSCA of 1976 grants EPA the authority to prohibit
or control the manufacturing,  importing,  processing,  use,
and disposal of any  chemical substance that presents  an
unreasonable risk of injury to  human  health or  the envi-
ronment. These regulations may be found in 40 CFR Part
761; Section 6(e) deals specifically with PCBs.  Materials
with less than 50 ppm PCB are classified  as non PCB;
those containing between 50  and  500 ppm are classified
as PCB-contaminated; and those with  500 ppm PCB or
greater are classified as PCB. PCB-contaminated materi-
als may be disposed of in TSCA-permitted landfills or de-
stroyed by incineration at  a  TSCA-approved  incinerator;
PCBs must be incinerated.  Sites where spills of  PCB-con-
taminated material or PCBs have  occurred after May 4,
 1987,  must be addressed  under the PCB  Spill  Cleanup
Policy  in 40  CFR Part 761, Subpart G. The policy estab-
                                                       20

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lishes cleanup  protocols for addressing such releases
based upon the volume and concentration  of  the spilled
material. To date, it has not been documented that the
DARAMEND™ Bioremediation Technology is useful for
PCB-contaminated  wastes.

2.9.7  Occupational  Safety and Health
Administration  (OSHA)   Requirements
  CERCLA remedial actions and RCRA corrective  actions
must be performed in accordance with the OSHA require-
ments detailed in 20 CFR Parts 1900 through 1926, espe-
cially §1910.120, which  provides for the health  and safety
of workers at hazardous waste sites. Onsite construction
activities at Superfund or RCRA corrective action sites must
be performed in  accordance with Part 1926 of OSHA, which
describes  safety and health regulations for construction
sites. State OSHA requirements, which may be significantly
stricter than federal standards, must also be met.

  All technicians and subcontractors involved with the con-
struction and  operation  of the DARAMEND™
Bioremediation Technology will  be required  to  have com-
pleted  an OSHA training  course  and be familiar  with all
OSHA requirements  relevant to  hazardous waste sites.
Workers on hazardous  waste sites must also be enrolled
in a medical monitoring program. The elements of any
acceptable program must include (1) a health  history, (2)
an initial exam before hazardous waste work starts to es-
tablish  fitness for duty and a medical  baseline, (3)  periodic
examinations  (usually annual) to determine whether
changes due to exposure may have occurred  and to en-
sure continued fitness for the job, (4) appropriate medical
examinations after a suspected or known  overexposure,
and  (5) an examination at termination.

  For most sites,  minimum  personal  protective equipment
(PPE) for workers will  include gloves, hard hats, safety
glasses, steel-toe boots, and Tyvek®. Depending on con-
taminant  types  and concentrations,  additional PPE may
be required, including  the use  of air purifying respirators
or supplied air.  Noise  levels during the construction and
operation of the  DARAMEND™  Bioremediation Technol-
ogy are not expected  to be  high, except during the con-
struction, which  will involve the operation of heavy equip-
ment. During these activities,  noise levels should be moni-
tored to ensure that workers are not exposed to noise lev-
els above a time-weighted average of 85 decibels over an
eight-hour day.  If noise levels  increase above this limit,
workers will be required to wear ear protection. The levels
of noise  anticipated are not  expected to adversely affect
the community, depending on its proximity to the treatment
site.

  Workers will be required to comply  with the recently pro-
mulgated OSHA requirements for confined spaces (29 CFR
§1910.146),  including  requirements  for stand-by  person-
nel,  monitoring, placarding, and protective equipment.
Since the construction  phase  of DARAMEND™
Bioremediation Technology will  require  some  excavation,
trenches could be considered confined spaces (based on
type  and depth).  Other construction- or plant-related OSHA
standards may  also apply while installing and managing
the DARAMEND™ Bioremediation Technology, including
shoring of  trenches, and lock-out/tag out procedures on
powered equipment.

2.9.8 Sfafe Requirements
   In  many  cases, state requirements supersede the  cor-
responding federal program, such as OSHA or  RCRA,
when the state  program is federally approved and the re-
quirements are  more strict.
                                                      21

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                                                 Section 3
                                          Economic  Analysis
3.1  Introduction
  This economic analysis is based primarily on results and
experiences gained  from the SITE demonstration that was
conducted  over an  11-month period at the Domtar Wood
Preserving Facility  located in Trenton, Ontario, Canada.
The costs associated with treatment by the GRACE
Bioremediation Technologies DARAMEND™ Bioremediation
Treatment Technology, as presented in this economic analy-
sis, are defined by  12  cost  categories that reflect typical
cleanup activities performed at Superfund sites. Each of
these cleanup activities is defined  and discussed. Many of
the cost assumptions are derived from information sup-
plied  by GRACE  Bioremediation Technologies,  based on
a full-scale remediation  project at the Domtar facility and
other field projects conducted in Canada. Certain assump-
tions  and  costs  are also  based on  previous experience
with  similar bioremediation processes evaluated  under the
SITE Program. Collectively, they form the basis  for a cost
analysis of a full-scale remediation  using this technology
at the  Domtar facility.

  The  GRACE Bioremediation  Technologies DARAMEND™
Bioremediation Treatment Technology is  principally  appli-
cable to wood preserving soils and sediments contami-
nated with organic wood preserving compounds, such as
PCP and PAH constituents of creosote. A number of fac-
tors  could affect the cost of treatment. Among  them are
soil type,  contaminant type  and concentration, soil mois-
ture, geographic location, site size  and accessibility,  re-
quired support facilities and  utilities, and treatment goals.
It is  important to thoroughly  and properly characterize the
site before  implementing this technology, to determine the
amount and  type of amendment to add,  and to  decide
whether a leachate  collection, storage, and treatment sys-
tem is needed. Although this characterization  cost may be
substantial, it is not included here. It is also highly recom-
mended that  a treatability study be performed so that the
amendment that would  be most effective at a  particular
site can be identified and its respective dosage level de-
termined. The cost for this is also  not included here.

  An economic analysis  for a full-scale remediation at this
site was done for an in situ and an ex situ case,  assuming
the process was implemented in a similar manner with simi-
lar performance to that demonstrated  under the SITE Pro-
gram. Cost figures  provided here are "order-of-magnitude"
estimates  and are  generally +50/-30%.

3.2  Conclusions
  . A full-scale cleanup of this site using this technology
   was estimated to cost between $619,000 for an in situ plot
   with an attendant unit cost of $92/m3($70/yd3), and
   $959,000 for an ex situ plot with an  attendant  unit cost
   of $140/m3($108/yd3), including the cost of  residual
   disposal.  The  residual consisted  of  oversized  particles
   screened out of the soil during pretreatment and
   deemed to be hazardous. Landfilling was assumed to
   be the preferred disposal option, although this may
   not be permissible for these types of wastes  in some
   jurisdictions.

  . Without residual  disposal, the unit  costs decrease to
   $46/nf ($35/yd3) for the in situ plot, representing a 50%
   reduction, and  $96/m3 ($73/yd3)  for the  ex situ plot,
   representing a 31% reduction.

  . In either case, the in situ plot was far more economi-
   cal to  set up and operate than the  ex situ plot.  How-
   ever,  there are  instances where ex situ treatment
   may be more advantageous than  in situ treatment,
   particularly for  highly toxic or recalcitrant soils. Better
   control over moisture content and temperature can  be
   achieved,  resulting in more uniform  treatment without
   isolated pockets  of high concentration soils.

  . For both cases, residuals and waste shipping and han-
   dling was the predominant cost category  (51% for the
   in situ case and 35% for the ex situ case).

  . No costs  were assigned for effluent  treatment  and dis-
   posal  because the SITE demonstration results  showed
   that no leachate  was generated for the ex situ case.
   This was also assumed to be the case for the in situ
   plot, although the developer has indicated that pilot-
   scale testing would be required at other sites  because
   it is a highly site-specific phenomenon.

  . For the in situ plot, startup (22%),  site preparation
   (ll%),  and labor (8%) were the  next largest  catego-
                                                       22

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    ries;  together with  residuals  and waste shipping  and
    handling, they account for over 90% of the total cost.

  . For the ex situ  plot, residual  and waste shipping  and
    handling costs were followed by labor (29%),  site
    preparation  (18%),  and consumables and supplies
    (1 0%), again accounting for over 90% of the total.

  . For both plots,  labor and site preparation were among
    the top four cost categories. In the case of the ex situ
    plot,  this is related to the construction of the treatment
    pad,  the purchase and installation of the  greenhouse,
    the additional labor  connected with multiple treatment
    cycles, and the longer treatment times associated  with
    a smaller plot.  For the in situ plot, these  costs are a
    reflection of the larger plot size assumed.

  . Costs attributed to  analytical services, capital equip-
    ment, demobilization,  and permitting and regulatory
    requirements are about  the same  forboth  plots.  This
    indicates that these categories do not appear to de-
    pend on whether an in situ or ex situ process is se-
    lected.

3.3 Issues  and Assumptions
  This section summarizes the major issues and assump-
tions used. In general,  assumptions are  based on infor-
mation provided  by the developer and observations made
during this and other SITE demonstration projects.

3.3.1 Waste Volumes and Site Size
  This economic  analysis assumes that the site and wastes
have already been thoroughly and  properly characterized,
and that these results were  used to optimize  the
DARAMEND™ Bioremediation  Technology,  i.e., the type
and amount of contaminants present, the heterogeneity of
the soil, the type and  amount of amendment  to add,  etc.
Therefore, it does not include the  costs for treatability stud-
ies, waste characterization tests, pilot studies, or process
optimization. All of these activities could add substantially
to costs  and time required for remediation.

  The volume of soil to be treated was estimated to be
6,800 m3 (8,900 yd3). Two scenarios were considered.  The
first was  in situ treatment of the contaminated soil without
excavation; the  second  was  above ground treatment  in a
fabricated plot contained in  a greenhouse, hereafter re-
ferred to as the ex situ case. For both cases, treatment
down to  a depth of 0.6  m (2 ft) was assumed. For the ex
situ case, a half-acre plot (2,300 nf, 25,000 ft2) was as-
sumed, containing two parallel plots  each covered by a
greenhouse. This scenario would  require five treatment
cycles to treat the entire volume  of waste. For the in situ
plot, the entire volume  of waste was assumed  to be treated
in a single 1 l-month period. This would require an area of
11,400 nf (123,000 ft2) or 2.8 acres. Smaller or larger  in
situ batches could be treated depending on the site physi-
cal constraints and the client requirements. Use of a green-
house cover depends as much on the physical shape  of
the treatment area  as the size of the area.
3.3.2 Process Optimization and
Performance
  The performance of a full-scale system for both scenarios
considered here was assumed to be similar to the ex situ
case demonstrated under the  SITE  Program.  Results from
the SITE demonstration  indicated that PCP concentrations
were  reduced 88%,  PAH concentrations were reduced
94%,  and TRPH concentrations were reduced 87% over
an 11 -month period that included a full winter season. Al-
though the developer fell slightly shy of its claims, it was
assumed that treatment goals would have been  attained
had the demonstration gone on for a full 12 months.

  Since better control over the bioremediation process can
be maintained in a greenhouse, the ex situ plot could treat
the same soil in less time than the in situ plot. Further-
more, the ex situ  plot could  treat  more  recalcitrant soils
with  higher initial contaminant  concentrations in the same
period of time. For this  analysis, the  latter was assumed.
For the in situ plot, GRACE Bioremediation Technologies
measured the average initial  PAH  concentration to be 77
mg/kg and the average initial PCP concentration  to  be 6
mg/kg. The ex situ  plot, on the other hand, had an  average
initial PAH concentration of  500  mg/kg and an average
initial PCP concentration of 125 mg/kg. For purposes  of
this analysis, it was assumed that the in situ plot would
achieve similar performance  levels due to lower  starting
contaminant concentrations. The tacit assumption is that
this level of removal would be  sufficient to meet regulatory
standards.

3.3.3 Process  Operating Requirements
  For this bioremediation technology,  the  majority of activ-
ity occurred either during site preparation and startup  or
during demobilization.  For the  ex situ case, involving mul-
tiple treatment  cycles,  there  is additional labor  between
cycles to remove the treated  soil and replace it with con-
taminated soil for the next treatment cycle. As will be dis-
cussed in more detail later, this effort involves manpower
as well as the necessary equipment and materials. These
have  all  been lumped into a single hourly rate that will  be
referred to in the text as the  labor, equipment, and mate-
rial (LE&M) rate. This rate was used in the startup and
demobilization  cost categories.

  For the ex situ case, this LE&M rate was also used as a
separate line item under the  labor cost category entitled
'Changeover.'This  represents the work effort involved be-
tween treatment cycles to  excavate  cleaned  soil  and re-
place it with contaminated soil. For both in situ and ex situ
cases, another  line item entitled "Maintaining  Treatment"
was used to reflect the manpower requirements  for plot
maintenance. These tasks would  include monitoring soil
physical  and chemical  properties (i.e.,  moisture,  pH, tem-
perature), irrigating to  maintain target  soil  moisture con-
tent, tilling to ensure a homogeneous and aerated soil
mass, and inspecting the site regularly.  Routine equipment
maintenance could also be done by the plot maintenance
people already  onsite.
                                                       23

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  SITE demonstration results from the ex situ plot indi-
cated that no leachate was generated. This was also as-
sumed to be the case with the ms/fuplot. To  determine
whether this would be true for other insitu applications,
GRACE Bioremediation Technologies  would probably con-
duct ex situ pilot tests before designing a full-scale reme-
diation system.  Consequently, the cost of leachate collec-
tion and treatment was not included for  either  the insituor
ex situ case.

3.3.4 Financial Assumptions
  All  costs are given in  U.S. dollars, without  accounting
for interest rates,  inflation, or the time value of money. In-
surance and taxes are assumed to be  fixed costs  listed
under "Startup"  and are calculated as 10% of annual capi-
tal equipment costs.

3.4  Basis for  Economic Analysis
  In order to compare the cost effectiveness of technolo-
gies  in the SITE Program,  EPA breaks down costs into the
12 categories  shown in Table 3-1, using the general as-
sumptions already discussed. The assumptions used for
each cost factor are discussed in more detail below.

3.4.1 S/te Preparation
  The amount of preliminary preparation necessary for
bioremediation technologies is highly  site-specific. For this
analysis, generic  site preparation responsibilities such as
site  design and layout, surveys and site logistics, legal
searches,  access  rights and roads were all assumed to be
performed by the responsible party (or site owner) in con-
junction with the developer. None of these costs have been
included  here.

  The focus instead was  on technology-specific activities.
These included treatment plot  fabrication, utility connec-
tions, trailer rentals, fence installation, and where  appro-
priate, greenhouse construction (Table  3-2).  These are
generally  one-time charges and are  necessarily site-spe-
cific. In the case of the ex situ plot, there may be recurring
charges associated with  replacing the sand  layer and re-
pairing the  polyethylene  liner and/or  the fiberpad. When
treated soil is  removed from the plot some of the sand
may be removed, and damage to the  liner and/or fiberpad
may occur. Hence, replacements may be necessary. This
cost  is included  under Maintenance and Modifications.
Since the treatment depth was assumed to  be the same
as that in  the SITE demonstration, 0.6 m (2 ft),  costs were
based on area rather than volume.

  Treatment plot  fabrication costs were  assumed to con-
sist  of two components,  earth work and treatment plot
preparation (Table 3-2). Earth work involved the cleaning
of debris  and brush, and the grading of soil. Both plots
would require this step and costs were estimated  using
the following formula from the developer:

  $5,000  + $5,000 (A/1,500m2)
where A is the area of the plot in m2. This is justified by the
fact that the contractor used to do these tasks and usually
required a  minimum  charge of $5,000 just to mobilize his
equipment  and bring it onsite,  regardless of the site size.
The second term represents the cost to perform these tasks
based on $5,000/1 ,500m2. The result of this calculation
was  rounded up to nearest $5,000 to  get a conservative
estimate.

  For the ex situ  plot, an additional component is required
to account for preparation and installation of a 1 Ocm (4  in.)
thick sand  buffer zone, a 4mm thick fiberpad, a polyethyl-
ene  liner, and another 15cm (6 in.) thick sand layer. The
developer estimated  these costs to be about $40,000 in-
cluding labor, equipment, materials,  and miscellaneous ex-
penses, such as per  diem rates, travel costs, and personal
protective equipment. As discussed earlier, no provision
for a leachate collection, storage,  and treatment system
was included for either plot.

  Utility connection  costs for electricity and water have
been included even though some sites may not require
these. A minimum of 110 V electric service was assumed
to be required for the office trailer  (lights, air conditioning,
heater, outlets,  etc.).  For the ex situ case, additional power
will be required to run small blowers that separate the  two
sheets of polyethylene  in the  greenhouse  canopy.  Water
is necessary for  irrigation, decontamination, and  hygiene
purposes. An additional $7,500 has been included for an
irrigation system in  the ex situ plot greenhouses. The in
s/fuplot relied on  natural  precipitation for  irrigation due, in
part, to lower contaminant  concentrations.  Irrigation equip-
ment may also be installed for the ms/fuplot but this  cost
has  been included here.

  Trailer rentals  have been included even  though  some
sites may not require them. Costs  were linearly scaled up
according to treatment time, and rates were  obtained from
this and  other SITE  projects.  For the ex situ case, it may
be cheaper to purchase the trailers  and amortize their costs
over the 5-year life of the project rather than rent them.
Also, additional portable toijets and perhaps a septic  tank
hookup would be required in those instances where addi-
tional  people would  be onsite,  i.e.,  between  treatment
cycles.

  Although security fencing may  already exist on  some
sites, the cost for additional fencing to separate the treat-
ment area from other operations at the site was included.
The cost ($4/linear ft) was obtained from previous SITE
demonstrations. The  length of fencing required for each
plot was obtained by assuming a square geometry  and
finding the length  of a side by taking the square  root of the
plot  area. This was multiplied by 4 to get the perimeter and
multiplied again by 3 to account for additional space  that
may be required for  support structures or for maneuvering
equipment around the site.

  The cost to buy and install two 9  m (30 ft) wide and  230
m (760 ft) long greenhouses was  obtained from  GRACE
                                                        24

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Table 3-1.   Estimated Full-Scale Remediation Costs using the GRACE Bioremediation Technologies DARAMEND™ Treatment Technology for
           Two Cases
Cost Category
1 . Site preparation
Treatment Plot Fabrication
Utility Connections
Trailer Rentals
Fence Installation
Greenhouse Construction
Total Costs
2. Permitting and Regulatory Requirements
3. Capital Equipment
4. Startup
Soil Preparation
Amendment Incorporation
Fixed Costs
Total Costs
5. Consumables and Supplies
Amendment Incorporation for Successive
Treatment Cycles
Gasoline
Health and Safety Gear
Total Costs
6. Labor
Maintaining Treatment
Changeover (soil preparation)
Total Costs
7. Utilities
8. Effluent Treatment & Disposal
9. Residuals and Waste Shipping & Handling
10. Analytical Services
11. Maintenance and Modifications
12. Demobilization
Total
In situ Plot
6,800 m3
(1 1 ,400 m2)
$ %

45,000
2,250
6,550
16,800

70,600 11.4
$3,000 0.5
9,600 1.5

23,500
116,000
960
140,000 22.6



250
2,000
S250 0.4

52,000
52,000 8.4
_ —
—
316,000 51
20,000 3.2
— —
5,700 0.9
619,150 99.9
$

55,000
9,750
30,400
7,500
70,000'
172,650
$3,000
8,500

4,700
23,100
850
28,700


92,400
250
2,000
94,700

18,800
260,000
279,000
2,100

340,000
20,000
6,000
4,600
959,250
Ex situ Plot
1 ,360 m3
(2,300 m2)
%






18.0
0.3
0.9




3.0




9.9


29.1
0.2
_
35.4
2.1
0.6
0.5
100
                                                               25

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Table 3-2.   Site Preparation Costs
Cost Item
                         In situ Plot
                         6,800 m3
                         (11,400 m2)
Ex Situ Plot
 1,360 m3
(2,300 m2)
1. Treatment Plot Fabrication
    a. Earth work (cleaning debris and brush, and soil grading)
    b. Preparation of sand buffer zones, fiberpad, and polyethylene
      liner to house contaminated soil in treatment plot
                       Total

2. Utility Connections
  a. Electricity (110V service)
  b. Water
                       Total
                         $45,000
                         $45,000
                          $1,250
                          $1,000
                          $2,250
$15,000

$40,000
$55.000
 $1,250
 $8,500
 $9,750
3.





4.


5.

Trailer Rentals
a. Office trailer (12' x 60' w/ 4 office rooms and toilet) - $400/mo
b. Portable toilet and septic tank - $300/mo.

c. Garbage dumpster (6 cu. yd.) - $70.50/mo.
Total
Installation of Fence ($4/linear ft)

Total
Purchase and Installation of Two Greenhouses (30'W x 7601 each)
Total SITE Preparation Costs

$4,800
3 mo.
$900
$850
$6,550
4,200 linear
ft.
$16,800

$70,600

$24,000
7 mo.
$2,100
$4,250
$30,400
1,900 linear
ft.
$7,500
$70,000
$172,650
 Bioremediation Technologies.  This  included the purchase
 price as well as the cost to securely anchor the structure
 to the ground to prevent damage from  high winds and the
 installation of large access doors for heavy earth  moving
 equipment.

 3.4.2  Permitting and Regulatory
 Requirements
  This  category includes costs associated with  system
 health/safety  monitoring and  analytical protocol develop-
 ment, as well as permitting costs.  Permitting  and regula-
 tory costs can vary  greatly because  they are very site- and
 waste-specific. For the Domtar Wood Preserving Facility
 the  only environmental permit required was an alteration
 to the Ontario Ministry of Environment and Energy Certifi-
 cate of Approval for liquid,  solid, and gaseous waste han-
 dling.

   For the greenhouse,  a building permit may be required
 from the local governing body before construction  com-
 mences. Additional requirements  to  be considered are
 flame spread index of the greenhouse material, appropri-
 ate  number  and location of emergency exits, installation
 of CO  monitors and/or smoke detectors,  and adoption  of
 proper  health and safety procedures while working in the
 greenhouse,  such as the "buddy system."

  An estimated $3,000 has been assigned to this cost cat-
 egory to allow for technical support services that GRACE
 Bioremediation Technologies  would provide to the client.
 The reader should  be aware that obtaining and complying
with  permits and any  other applicable regulatory standards
could potentially be a very expensive and time-consuming
activity.

3.4.3  Capital Equipment
  Bioremediation technologies  are inherently  not  capital
equipment intensive. Since the  heavy earth moving equip-
ment is necessary for a relatively short period of time, it is
far more economical to contract out those services than it
is to tie up capital in purchases.

  Therefore, for purposes of this analysis, it has been as-
sumed  that OSHA-trained personnel and  any necessary
equipment would be contracted during startup and demo-
bilization,  to set up the treatment plot and  subsequently
decommission  it. For the ex situ plot, the intermediate pro-
cess  of replacing treated  soils  with contaminated soils for
each treatment cycle was also assumed  to be done by
contracted personnel  and has  been  included  in the Labor
cost  category.

  The only piece of hardware required to  successfully
implement this technology is a tractor to run the rototiller.
The  cost of purchasing vs. renting  would be dependent on
the size of the plot and the treatment time. The cost to rent
was assumed to be $800/mo while the purchase price was
estimated to be $17,000. For a 12 month  period, it is ad-
vantageous to rent at  a yearly  cost of $800/mo x 12 mo =
$9,600  rather than buy. Conversely,  for the ex situ plot,
buying the tractor and amortizing the cost over a useful
life of 10 years yields an annual expense of $1,700, or
$8,500 for the 5-year duration  of the remediation.
                                                         26

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  GRACE  Bioremediation Technologies  considers  the
rototiller to be a commercially proprietary item and an inte-
gral part of its treatment process. Its cost has been in-
cluded as part of amendment  addition under the startup
category on a $/m3 basis.

3.4.4  Startup
  Startup activities  for this technology  include excavating,
screening,  handling  the oversized material,  adding  the
amendment,  and homogenizing the  soil. As discussed
under Capital  Equipment costs,  it was assumed that some
of these  activities would be contracted out  for both of the
cases  considered.

  The work was  divided into two segments. In preparation
for amendment addition, the first segment  involved exca-
vating,  screening, and handling  the oversized  material.  For
the in situ case, this was primarily accomplished by a sub-
surface ripper and rock picker. For the  ex situ plot, the  soil
was excavated, screened through a 10 cm (4 in.) grizzly
screen and deposited onto the  treatment plot. All of these
tasks were  assumed to be  contracted out. Based on expe-
rience,  GRACE  Bioremediation Technologies estimated
that soil  could be processed at a rate of  approximately
14.5 m3/hr (19 yd3/hr). The LE&M rate was inferred from
the  SITE demonstration to  be  $50/hr,  including all neces-
sary equipment and materials. The reader is cautioned  that
this hourly  rate can vary  greatly according to geographic
location  and should  be conservatively estimated for  the
site under  consideration.

  The  second segment involved adding the  amendment
and homogenizing the soil using the  rototiller to ensure
uniform  treatment. These tasks were  assumed to be
handled  by GRACE Bioremediation Technologies person-
nel. Amendment type and  dosage are very  site-specific.
Key factors that  affect these parameters are  contaminant
type  and concentration, and physical  characteristics  and
nutrient content of the soil.  The  amendment may  be added
all at  once or periodically  throughout  treatment, depend-
ing  on soil properties and the  extent  of remediation.  For
the sake of simplicity, it was assumed that the necessary
amendment was added during  Startup and that no further
amendment additions were required. The cost of amend-
ment addition would typically include the cost of the amend-
ment;  shipping,  handling, and storage;  and  the associated
labor, equipment, and consumables  necessary to incor-
porate the amendment into the  soil matrix.  Based on these
factors, a reasonable  estimate for amendment  addition was
given  by GRACE Bioremediation technologies as $1  7/m3
of soil.

  For the ex situ plot, the  cost of soil  preparation for suc-
cessive treatment cycles was considered under the Labor
cost category.  Similarly,  the  cost of incorporating  the
amendment into the  soil  matrix for successive  treatment
cycles was  included in the Consumables and Supplies cost
category.
  Fixed costs such as insurance and taxes were assumed
to be 10% of annual capital equipment costs  or $960 for
the in situ plot and $850 for the ex situ plot.

3.4.5 Consumables  and Supplies
  The main item that could be considered "consumable"
for  this process  would  be  the amendment. This may not
necessarily be a one-time charge. As discussed under
Startup, depending upon how well the remediation is pro-
gressing, new amendment  may need to be added periodi-
cally. For simplicity,  it was  assumed that amendment was
added only at  the beginning with no  further additions for
the remainder of treatment.  For the ex situ  case, this would
have to be repeated for every treatment cycle, and this
cost is accounted for as shown in Table 3-I.

  Other items that should  be included here are the gaso-
line required by the tractor, and health  and safety gear.
Gasoline for the tractor was assumed to cost  about $5/wk
for the insitup\oi and $1  /wk for the ex s/fuplot.  Either way,
the total cost of gasoline for the tractor to treat 6,800 m3 of
contaminated soil is about $250. Health and  safety  gear
was estimated to cost about $2,000 a year.

3.4.6 Labor
  Once the treatment  plot is established  and amended,
the amount of labor involved is minimal. Rototilling to aer-
ate the soil once every two weeks, irrigating as necessary,
taking moisture and temperature readings every two weeks,
sampling  to determine the extent  of  bioremediation that
has occurred,  and maintaining the  facility  and equipment
is  about  all   the   work  that  is required.  GRACE
Bioremediation Technologies has indicated that labor costs
are dependent  on plot size  and intensity of sampling. Based
on  experience from the SITE demonstration,  it was esti-
mated that this  would require no more than two people
working a standard  40-hour week. An  hourly labor rate of
$13/hr was assumed; this includes a base salary,  benefits,
overhead, general and administrative  (G  & A) expenses,
travel, per diem, and rental car costs. This would yield a
labor cost of $52,000 annually.

  The largest contributor, however,  is the  work associated
with multiple treatment cycles. As discussed under Startup
costs, the total  LE&M for additional treatment cycles for
the ex situ plot is $260,000, while plot maintenance is es-
timated to cost only $18,800.

3.4.7  Utilities
  The major utility demand for this project was electricity.
In addition to the power required for the office trailer, elec-
tricity was used  to power the blowers separating the two
layers of polyethylene  sheeting on  each greenhouse for
the ex situ plot.  The blowers were required every 45 m
(150 ft) and were rated at 1.15 amps at 115 V (133 watts).
Therefore, six  blowers  for  the two greenhouses were re-
quired for a total of 800 watts. At $0.06/kWh, the electricity
usage for the  ex situ plot would be $420/yr (0.8 kW x 24
                                                       27

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hr/day x 365 days/yr x $0.06kWh) or about $2,100 for the
5 year period.

  The primary use of water for the ex situ plot was irriga-
tion. The irrigation demand is dependent on season, soil
character, treatment  protocol,  temperature,  and climate.
The in situ plot relied solely on natural precipitation. The
cost of water usage for the ex situ plot was estimated to be
so low that no value was assigned.

3.4.8 Effluent  Treatment and Disposal
  Since there was no leachate  produced during the  SITE
demonstration of the ex situ plot, it was assumed that no
leachate would be produced during the course of the full-
scale remediation. Pilot-scale testing showed that this
would also.be true  for the in situ plot.  Therefore, there  were
no costs assigned to this category for either case.

3.4.9 Residuals  and Waste  Shipping,
Handling,  and Storage
  During the  SITE demonstration, oversized material  sepa-
rated out during the Startup phase was analyzed and found
to be hazardous. Because this may not necessarily be the
case at every site, residual disposal costs  were estimated
two ways. First, it was assumed that the  residual was a
hazardous waste  and needed to be  handled appropriately
offsite.  Secondly,  it was assumed that it was not hazard-
ous and could be landfilled at the same site with no addi-
tional costs incurred.

  The oversize material was 7% by volume of the total soil
treated. The average bulk density was assumed to be 1.3
tons/m3or about 620 tons for the 6,800 m3 of soil. The cost
of landfilling hazardous  material was  assumed to be $5001
ton.  It should be pointed  out that landfilling PCP contami-
nated waste may  not be  permissible  in some jurisdictions.
In that  case, the  only  disposal option would  be incinera-
tion at 2 to 3 times the cost of landfilling. Therefore,  if this
material is hazardous, disposal costs may be as low as
$300,000 or as high as $1 ,000,000.

  The  only other  residual generated during the course of
the SITE demonstration that required disposal was  PPE.
This cost would probably  be greatest during site prepara-
tion, startup,  and  demobilization  activities, and  between
treatment cycles for the ex situ plot.  PPE usage should be
minimal during treatment. It was assumed that an average
of one drum of PPE per month of treatment would  be gen-
erated.  At a disposal cost of $500/drum, this would trans-
late to $6,000 for 12 months of treatment.

3.4.70 Analytical Services
  The  project analytical costs will  necessarily be depen-
dent on site-specific factors,  such as  regulatory  require-
ments  regarding  sampling intensity,  frequency, and analy-
ses. For this  estimate,  a  sampling program that generates
one sample per 100  m3 was assumed. Thus, 68 samples
per sampling event would be generated  for 6,800 m3 of
soil. Soil  moisture, temperature, and pH would be  mea-
sured  every two  weeks  at an internal cost of $10. This
would then total $16,320  (68 samples/event x 2  events/
month x 12 months x $IO/sample). To determine the
progress of treatment, PCP and PAHs would be measured
less frequently, perhaps once every quarter.  To account
for  the  costs of PAH/PCP analyses, duplicate  samples,
additional  samples/analyses required by regulatory agen-
cies, and  shipping and handling, this category  was  esti-
mated  at $20,000.

3.4.11 Facility  Modification,  Repair,  and
Replacement
  Replacement, repair,  and/or modification of the sand lay-
ers, polyethylene liner, and/or the fiberpad in between treat-
ment cycles may be necessary. This has been estimated
at $1,500  per treatment cycle or $6,000 for four treatment
cycles.  Seasonal modifications to the greenhouse, such
as opening the side vents at the  beginning of the summer
season and closing them at the beginning of the winter
season, are considered negligible costs and therefore have
not been  included.

3.4.72  Demobilization
  Demobilization of the in situ plot would require  minimal
effort. The key tasks  would  be levelling, seeding,  and com-
pacting  the treated  area. The cost is estimated to be about
$5,700.

  For the ex  situ  area, the demobilization  would involve
dismantling the greenhouse, removing the synthetic treat-
ment pad material, returning treatment pad soil and  clay
to the site as clean fill, levelling, seeding, and compacting
the treatment  area. It is estimated that the cost of these
activities would be about $4,600.

3.5 Results
  The  results indicate that  a full-scale cleanup of this site
using this technology would  cost between $619,000 and
$959,000, including the cost of residual disposal. The cor-
responding unit costs  would range from $92/m3 ($70/yd3)
for the in s/toplot to $1  40/nf ($1 08/yd3) for the ex situ  plot.
Without residual disposal, the unit costs decrease substan-
tially; $46/m3 ($35/yd3)  for the in  situ  plot, representing a
50% reduction, and $96/m3 ($73/yd3) for the ex situ plot,
representing a more modest but still significant 31% re-
duction. In either case, the in situ plot was far more  eco-
nomical to setup and operate than the ex situ plot (it would
cost 34% less with residual disposal, and 52%  less with-
out residual disposal).

  Although this is  a considerable difference,  there could
be  circumstances where ex situ treatment would be more
advantageous  than  in  situ  treatment. For instance, recal-
citrant soils with  high contaminant  concentrations could
be  treated in an ex situ greenhouse, which allows better
control  over moisture content and temperature and, there-
fore, more uniform treatment without isolated pockets of
high concentration soils.  For the same initial  contaminant
concentration,  treatment in the controlled  environment of
a greenhouse  would be faster than  relying solely on  natu-
                                                       28

-------
ral irrigation and temperatures. Finally, ex situ treatment in
a greenhouse may be more easily accepted by the com-
munity than uncovered in situ treatment, even though there
might not be a technical advantage.

  The 12 cost categories for the two cases considered here
are shown in Figure 3-I. Figure 3-2 displays the same cost
categories minus the cost category Residuals + Waste
Shipping  + Handling.  For both the in situ  and ex situ plots,
the predominant cost category was Residuals & Waste
Shipping  & Handling  (51% for the in situ case  vs. 35% for
the ex situ case).

  For the in situ plot,  the next highest cost categories were
Startup (22%),  Site Preparation (11%)  and Labor (8%).
These four highest cost categories  accounted for over 90%
of total costs. Analytical Services (3%), Capital Equipment
(2%) and Demobilization (1%) were the  next largest con-
tributing factors. Permitting and  Regulatory  Requirements
and  Consumables & Supplies each  contributed 0.5%  or
less to total costs.

  For the ex situ plot, the Residuals  & Waste  Shipping &
Handling cost category was followed  by  Labor (29%),  Site
Preparation (18%), and Consumables & Supplies (10%).
These four items again accounted for over  90% of costs.
Startup (3%), Analytical Services (2%), and  Capital Equip-
ment (1%) were the  next  largest categories. Maintenance
and  Modifications  and  Demobilization  each   contributed
about 0.5%,  while Permitting  and Regulatory Requirements
and  Utilities were insignificant cost contributors.
  No costs were attributed to Effluent Treatment and Dis-
posal for either plot  because  it was assumed that no
leachate  would be generated. This observation was  con-
firmed during  the SITE demonstration project on the ex
situ plot.

  For both plots, Labor and  Site Preparation were among
the  top four cost categories. In the case of the ex situ plot,
this is related to the construction of the treatment pad, the
purchase and  installation of the  greenhouse, the additional
labor connected with  multiple treatment  cycles, and the
accompanying  longer treatment times associated with  a
smaller plot. For the in situ plot, these costs are a reflec-
tion of the larger plot size assumed. Cost contributions from
Analytical  Services, Capital  Equipment,  Demobilization,
and Permitting and Regulatory  Requirements  are  about
the same for both  plots. This indicates that these catego-
ries are not dependent on the size of the site.  Maintenance
and Modification and Utility costs were insignificant for the
in situ plot because of the relatively short cleanup time
involved.

  This section presents the results of the EPA SITE dem-
onstration conducted at the  Domtar Wood Preserving Fa-
cility in  Trenton, Ontario, Canada. This section discusses
the effectiveness  of the DARAMEND™ Bioremediation
Technology in remediating  PAHs and CPs in wood  treat-
ment soils.
                                                       29

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                                             In Situ Plot (6800 m3)
                                                Capital Equipment 1.5%
                          Site Preparation 11.4%


            Demobilization 0.9%

               Analytical 3.2%
      Startup 22.6%
                                                                                       Consumables/
                                                                                            Supplies 0.4%
                                                                                          Labor 8.4%
                                                                                      Permitting 0.5%
                     Residuals/Waste  51.1%
                                              Ex Situ Plot (1360m3)
                      Analytical 2.1%
Residual/Waste 35.4%
                                    \
                Demobilization 0.5%\
          Site Preparation
          18.0%
             Capital
             Equipment 0.9%
                 Startup 3.0%
           Permitting 0.3%
                                                                                       Utilities 0.2%
                                                                               Labor 29.1%
                     Consumables/
                         Supplies 9.9%
                                       Maintenance 0.6%
Figure 3-1.  Estimated  full-scale remediation costs.
                                                         30

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                                                     In  Situ Plot  (6800  m3)


                                                                Startup 46.2%
                Capital
                Equipment 3.1%
                                                                                                  Consumables/
                                                                                                  Supplies 0.8%
                                                                                                   Labor 17.2%
                  Site Preparation 23.3%
                                                                                   Permitting 1.0%
                                                Demobilization 1.8%        Analytical 6.5%





                                                     Ex  Situ Plot  (1360  m3)


                                                                Labor 45.0%
                   Utilities 0.3%

          Analytical 3.3%

          Demobilization 0.8%
                        Site Preparation 27.9%
Figure 3-2. Estimated full-scale remediation costs.
            Permitting 0.5%


                 Maintenance 0.9%
                                                                                                  Consumables/
                                                                                                  Supplies 15.3%
Startup 4.6%
                                                                     Capital Equipment 1.4%
                                                                31

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                                                Section  4
                                     Treatment Effectiveness
4.1  Background
  The DARAMEND™ Bioremediation Technology SITE
demonstration utilized a portion  of a much  larger full-scale
demonstration area being treated simultaneously by
GRACE Bioremediation  Technologies,  the developer, at
the Domtar site. The full-scale technology demonstration
was co-funded by Domtar, Environmental Canada, and the
Ontario Ministry of the Environment. GRACE Bioremediation
Technologies, was contracted to treat 3,000 tons of soil in
situ and 1,500 tons of excavated soil (ex situ) at the Domtar
site, for a period of approximately one year.  The SITE dem-
onstration involved the treatment of approximately 300 tons
of excavated soil. GRACE Bioremediation Technologies
installed, maintained  (i.e., tilling and irrigation), and moni-
tored the ex situ treatment system, which covered an area
of approximately 2,300 m3. The EPA SITE demonstration
involved the  construction  of a separate Treatment Plot and
No-Treatment  Plot that  were  monitored  and maintained
by the  developer.

  The Domtar Wood Preserving Facility operated for sev-
eral decades at the site and was responsible for the depo-
sition of CPs, creosote,  and petroleum hydrocarbons to
the native soil.  The wood preserving process has been
discontinued at the facility and the property is currently
used for the storage of treated lumber,  railroad ties,  and
telephone poles.  In the past decade, soils  surrounding the
former  process  area  have been excavated and stockpiled
for treatment. The SITE  demonstration focused on these
soils which, according to the developer, have the highest
concentrations of PAHs and CPs.  Historical data collected
by the developer indicated that the excavated soil con-
tains total chlorophenol concentrations from 276  mg/kg to
1228 mg/kg (PCPI  from 249  mg/kg to 1176 mg/kg)  and
total PAHs from 577 mg/kg to 2068 mg/kg.

   Prior to the SITE demonstration,  EPA collected composite
samples of the  soil  to be used in the Treatment and No-
Treatment Plots. The Treatment Plot exhibited total PAH
concentrations ranging  from 2274 mg/kg to 3453 mg/kg
and total chlorinated phenol concentrations  ranging from
540 mg/kg to 740 mg/kg (only  PCP was  detected).  The
No-Treatment Plot exhibited a total PAH concentration of
1718 mg/kg  and a total  chlorinated phenol concentration
of 360 mg/kg  (only pentachlorophenol  was detected).
  This SITE  demonstration  was conducted  to evaluate the
performance of GRACE  Bioremediation Technologies'
DARAMEND™ Bioremediation Technology to remediate
PAH and  chlorinated phenol contamination in soils from
the Domtar Wood Preserving  Facility in Trenton, Ontario.
According to the developer, the DARAMEND™ Technol-
ogy is an effective bioremediation alternative for the treat-
ment of soils containing levels of CPs  and PAHs typically
considered too toxic for bioremediation.

  The  developer claimed  that  the DARAMEND™
Bioremediation Technology can achieve a 95% reduction
in total PAHs and a 95% reduction in TCP over an eight-
month period of treatment. The performance was evalu-
ated using the  pre- and post-treatment concentrations  of
the analytes listed below:
                              Total Chlorinated  phenols

                              . 2-chlorophenol
                              . 2,4-dichlorophenol
                              .  2,4,5-trichlorophenol
                              .  2,4,6-trichlorophenol
                              . Pentachlorophenol
Total PAHs

 Naphthalene
 Acenaphthalene
 Acenaphthene
 Fluorene
 Phenanthrene
 Anthracene
 Benzo(g,h,i)Perylene
 Fluoranthene
 Pyrene
 Chrysene
 Benzo(a)pyrene
 Benzo(b)fluoranthene
 Benzo(k)fluoranthene
 Benzo(a)anthracene
 lndeno(l,2,3-c,d)pyrene
 Dibenzo (a.h)anthracene
 Benzo (g,h,i) perylene
  The total list of CPs presented by the developer has been
abbreviated to the above list, which includes  only those
analytes routinely analyzed under SW846 3540/8270. Data
collected during  the developer's pilot testing  program have
shown that  PCP  comprises 96% of the  total contamination
contributed  by      This being the case, the elimination of
chlorinated  phenolic compounds not  routinely analyzed in
                                                      32

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SW3540/8270 had a negligible effect on the measured per-
formance of this technology.

  As the process is temperature-dependent, the treatment
period only includes days when the average daily soil tem-
perature within the greenhouse was above 15°C. The dem-
onstration  was originallv scheduled to run until the begin-
ning of June 1994: but was extended by the 93 days that
the greenhouse average soil temperature fell below 15°C.
The actual number of treatment days between the initial
baseline sampling and the final sampling event totaled 254.
A  summary of sampling and  data monitoring  activities is
presented in  Figure  4-I.

Primary  (Critical)  Project Objectives
  The SITE demonstration was designed to determine
whether the developer's claim could  be achieved during a
full-scale application  of the technology.  The primary  ob-
jective was evaluated by comparing  the sums of the con-
centrations of select PAHs and CPs in soils within the dem-
onstration Test Plot, after 254 days of treatment  by the
DARAMEND™ Bioremediation Technology. The Test Plot
was physically separated from the  GRACE Bioremediation
Technologies plot and was evenly divided into 54 2 x 2
meter subplots. Soil samples for critical analyses were
collected from designated  subplots using a random num-
ber generator as discussed in the TER. Homogenized soil
cores  from each  of the designated subplots were analyzed
for SVOCs  using analytical  SW846 Method 3540/8270.

Secondary  (Non-Critical) Project Objectives
  Other objectives  of the demonstration included:

  • Determine the  magnitude of  reduction  in the sums of
    the concentrations of select  PAHs and CPs in the No-
    Treatment Plot soils.

  • Determine the magnitude of reduction for specific PAHs
    and chlorinated phenolic compounds within each  of
    the SITE demonstration  plots.

  • Determine the  toxicity of the soil to  earthworms and
    seed germination in each of the SITE demonstration
    plots before and after treatment.

  • Monitor the fate of TRPH in each of the SITE demon-
    stration  plots.

  • Monitor general soil conditions (i.e.,  nutrients,  toxins)
    that might  inhibit  or  promote process  effectiveness,
    such as TC, TIC, Nitrate-Nitrite,  Phosphate, TKN, pH,
    PSD,  Chlorides and  Total Metals within each of the
    SITE demonstration plots.
                                                                                        AA
                         +  +
                          No  treatment  occurred  12/13/93
    •!  3/1   6/94
      -50-30  -10   10   30   50   70  90  110  130 150  170  190 210 230  250  270 290 310 330350

                                            One interval = 20 calendar days
                              •   Tillage              •   Demonstration sampling
                              A  Irrigation            ^  Pre-demonstration activities
                              +   Amendment added   • Soil temperature  below
Figure 4-1.  Maintenance  Record.
                                                       33

-------
  . Monitor for the presence of leachate within the SITE
    demonstration Test Plot.

  . Monitor each of the SITE demonstration plots  for ac-
    tive microbial populations, specifically focusing on to-
    tal heterotrophs and PCP degraders, as a way to quali-
    tatively assess the magnitude of biodegradation over
    the course of the eight-month test.

  . Monitor the upper sand layer in contact with the  treated
    soil to qualitatively assess any tendency for downward
    migration of contaminants.

  These  primary  and secondary project  objectives were
evaluated through a carefully planned and executed sam-
pling and analysis plan (see TER). For this demonstration
SVOCs were considered critical during  "Baseline" and
"Post-Treatment" sampling (Event #0 and Event #3) of
the SITE demonstration  Treatment  Plot.  This  parameter
was considered noncritical during sampling  of the  No-Treat-
ment Plot and during the two intermediate  rounds of Treat-
ment  Plot sampling (Event #1 and Event #2).  The period
of performance evaluation was estimated by the devel-
oper to be approximately 240 days (actual 254 days) start-
ing on October 14,  1993  (Event #0) and  ending on Sep-
tember 26, 1994 (Event #3). The two intermediate  rounds
were performed on the 88th day and on the 144th day of
treatment which occurred on April 21,  1994 and on June
14,1994  (Events #l  and #2). No sampling was  conducted
during  the  winter months of December,  January,  Febru-
ary, and  March since little biodegradation was expected to
occur at  low winter  temperatures.

  An additional objective  of this demonstration was to de-
velop  data on operating costs for the  DARAMEND™
Bioremediation Technology so that the applicability and cost
effectiveness of this  process at other sites could  be evalu-
ated. The results of  the economic analysis were presented
in Section 3.

4.2 Detailed Process Description
  GRACE Bioremediation  Technologies  demonstrated their
patented  DARAMEND™ Bioremediation Technology on  a
portion of an  ex  situ plot  located in a 10  x 200  m green-
house-enclosed treatment plots installed  along the north-
west corner of the Domtar Wood Preserving Facility. The
SITE plots consisted of a 2 x 6 m No-Treatment Plot and  a
6 x 36 m Treatment Plot.  Both plots were  constructed and
bermed off from  the larger  GRACE Bioremediation Tech-
nologies  plot to facilitate testing under the SITE Program.
The Treatment Plot  underwent  treatment by  the
DARAMEND™ Bioremediation Technology and was main-
tained in the same manner as the larger  GRACE
Bioremediation Technologiesplot. The  No-Treatment  Plot
received no treatment and was left idle and covered
throughout the demonstration period.

  The  excavated soil provided for the SITE demonstration
plots,  according to the developer, had a total chlorophenol
concentration in the range of 276 mg/kg to 1228 mg/kg
(PCP from 249 mg/kg to 1  ,176 mg/kg); total PAHs  ranged
from 557 mg/kg  to 2068 mg/kg. Actual Test and No-Treat-
ment  Plot concentrations were verified during the pre-dem-
onstration sampling effort  conducted a  month before the
start of the demonstration (September 7, 1993). Prior to
placing  the test soil in  the SITE demonstration plots, the
test soil was screened by the developer to remove debris
that might interfere with the homogenization or incorpora-
tion of organic amendments (see Sections 4.4.1 and 4.4.4
regarding the soil screening process). The screened soil
was transported to  the treatment  area and stockpiled  on a
polyethylene liner until  construction  of  the SITE demon-
stration plots was complete.

  The No-Treatment Plot was physically isolated from the
adjacent treatment areas by wooden walls that rose 1.5 m
above the surface of the soil, extended  downward through
the soil and the underlying sand layer,  and rested on the
fiberpad  that protected the underlying  plastic liner. This was
done  to  protect the No-Treatment Plot  soil from inadvert-
ent inoculation by nearby tillage or by the migration of sub-
surface  water.

  GRACE Bioremediation  Technologies treated the soil in
the SITE demonstration Treatment Plot through the  addi-
tion and  even distribution of its solid-phase organic amend-
ments using a  specially designed rotary  tiller. Tilling serves
the dual  purpose of  reducing  variations  in soil  physical and
chemical properties and aerating the soils. The developer
determined the WHC of the Treatment  Plot soils and em-
ployed a specialized soil  moisture control system to en-
courage  the proliferation of large active microbial popula-
tions and limit  the generation of leachate. These are con-
sidered  proprietary components of the developer's process.
Figure 4-I illustrates the overall  schedule of the demon-
stration,  depicting the number of calendar days on which
sampling, tillage, irrigation,  and the addition of amendments
occurred. In  addition, Figure 4-1  depicts a total of 93 "no
treatment days," from December 13, 1993 to  March 16,
1994, when the soil temperature in the Treatment Plot was
below 15°C.

Plot  Construction
  The Treatment and No-Treatment Plots were contained
at the northern  end of a temporary "greenhouse" that also
housed GRACE Bioremediation   Technologies'  demonstra-
tion plot (See  Figure I-2). The  waterproof structure con-
sisted of an aluminum frame  covered by a shell of polyeth-
ylene sheeting  and could be opened at each  end to allow
for equipment access.

   Both  the Treatment  and No-Treatment Plots were un-
derlain  with  a  high-density  polyethylene  liner (imperme-
able to the target compounds).  This liner was underlain
with 10 cm of screened sand to prevent structural damage
to the liner. Another 15-cm-thick sand layer and a 4-mm-
thick fiberpad  were spread on top of the liner  to minimize
the potential for direct  contact between the liner material
and tillage equipment.
                                                       34

-------
  Once the upper bedding material had been spread across
the plot, the targeted test soil was screened and then de-
posited within the lined  plots to a depth of 0.6 m. Each
demonstration plot was isolated  from the adjacent plots by
earthen berms with wooden boards protruding  1.5 m above
the top of the soil.  One side of the Treatment Plot remained
open for tilling equipment access.

Decontamination  Pad
  GRACE  Bioremediation Technologies constructed a de-
contamination  pad  adjacent to  the demonstration area to
facilitate cleaning of the tilling equipment and prevent cross-
plot  contamination.

Site Preparation  for  Treatment
  Soil targeted for treatment by  the DARAMEND™
Bioremediation Technology was prepared  by GRACE
Bioremediation Technologies prior to  being placed in the
control and treatment plots. Soil  stored near the wood treat-
ment site  was collected  with a backhoe and introduced
into a screening device in order to remove debris (rocks,
wood, metal) that could  interfere with incorporation of the
organic amendment. Oversized  debris was  stockpiled  in  a
secure area near the runoff collection  and treatment area,
to prevent the generation of leachate  containing the target
compounds. Screened soil was  then transported  to the
treatment  area and spread onto the prepared No-Treat-
ment and  Treatment Plots to a  depth of 0.5 m.

  The soil matrix was initially  homogenized in both the
Treatment and No-Treatment Plots by tilling with a power
take-off driven rotary tiller to ensure  uniform physical and
chemical soil properties,  and to facilitate distribution of soil
amendments.  GRACE Bioremediation  Technologies  uti-
lized two tillers, each of which was pulled by a 75 hp trac-
tor. The tillers are 2.1 and 1.7  m wide and can reach an
effective depth of 60 cm.

  After homogenization GRACE Bioremediation Technolo-
gies' patented amendment was added to  the  Treatment
Plot soil in a volume of approximately  1% of the total vol-
ume of the soil. The organic amendments increase the
supply of  biologically available water and nutrients to  con-
taminant-degrading microorganisms. Addition of the
amendments may increase the soil volume up to 15% de-
pending on the amount of pore space present. Typically
amendments are added solely at the beginning of the treat-
ment process, however,  an additional 2% was added in
December 1993, and an  additional  1% was added in March
1994, based on soil sample analytical results.

Plot Maintenance
   Figure 4-1 illustrates the frequency of Treatment Plot
maintenance, which consisted  of the  following tasks:

   • tilling the plot using  a tractor and tiller

   . monitoring for  moisture and temperature
  . irrigating the plot

  Soil in the Treatment Plot was tilled immediately after
the commencement of irrigation, and at weekly intervals
thereafter, to increase diffusion of oxygen to microsites and
to ensure the uniform  distribution of irrigation water in the
soil profile.

  All plot monitoring was performed by the developer, and
a daily  log of measurements was maintained. The fre-
quency  of irrigation was determined by weekly  monitoring
of soil moisture conditions;  successful bioremediation de-
pends on maintenance of the soil's  water holding capacity.
The growth  rate of microbial  biomass was characterized
via regular monitoring of soil temperature using a com-
mercial  version of a hand-held thermocouple.

4.3 Methodology

4.3.1 Sampling

Pre-Demonstration
  During the week of September 7, 1993, representative
soil samples were collected by the SITE contractor from
both demonstration  plots to satisfy the following pre-dem-
onstration objectives:

   . Characterize the target media  for treatment

   . Ensure the presence and concentration of  target
    compounds present in the target  media

   . Identify any conditions present in the soil  that could
    inhibit the treatment process or its validation.

  The pre-demonstration sampling plan called for five com-
posite samples to  be collected using  hand augers;  how-
ever, the soil contained large stones  and concrete debris
that necessitated the use of a pick-axe and shovel. All
samples were analyzed for SVOCs (which included PAHs
and CPs) and one composite was analyzed for metals,
VOCs, pesticides/PCB's,  PSD,  and dioxins/furans.  One
composite sample from the No-Treatment  Plot was  col-
lected and  analyzed for SVOCs, metals, VOCs, and PSD.
Due to  the amount of oversized material (greater than 1/2-
inch), three  composite samples were screened  in the field
using a 1/2-inch  screen to determine the ratio of rocks to
soil in the plots. In  addition, a  representative sample  of the
undersized and oversized soil was collected  from each of
these three composites and  sent to  the laboratory for  semi-
volatile  organic analysis (SW 846-8270).

Demonstration
  The primary objective of the SITE demonstration was to
evaluate the effectiveness  of the  DARAMEND™
Bioremediation Technology in  degrading PAH and CPs
contamination in wood-treatment soil at  the Domtar site.
The collection of soil samples from the Treatment Plot be-
gan following pretreatment  of the soil, which entailed:
                                                       35

-------
  . Screening of the soil to a diameter of 10 cm

  . Addition of proprietary  organic amendments to the soil
    (1% of volume of soil)

  . Homogenization of the soil  and amendments

  The 2 m x 6 m No-Treatment Plot received the same
screened and  homogenized soil  as the Treatment Plot  but
no organic amendments or moisture were added, and  no
tillage  occurred.

  The  SITE demonstration  called for four  sampling events
These four sampling events were as follows:
  Event #0

  Event #l

  Event #2

  Event #3
Baseline
October 14, 1993*
Intermediate -April 21, 1994

Intermediate - June 14,  1994

Final             September 26, 1994
  Note: * - The day after the amendments were tilled into
the soil.

  These sampling  events in relation to the treatment pro-
cess are depicted in Figure 4-I. Figures 4-2 and 4-3 show
the locations sampled and parameters analyzed within
each grid  during the four sampling events.

  During all four sampling events, grab soil samples were
collected from the  selected subplots using a hand  auger,
and were  analyzed for SVOCs (SW 846 3540/8270)  (which
includes the analysis for CPs and PAHs). Portions of soil
from each of the subplots were retained and mixed together
to form a single composite sample, which  was analyzed
for the parameters indicated in Figure 4 2 and Figure 4-3.

4.3.2  Data Analysis
  The  analytical results, once validated, were  reduced  to
develop the average  sums of the concentrations  of total
PAHs,  individual PAHs, TCP, and individual CPs. To evalu-
ate the primary objectives,  only the initial and  final levels
of the  specified 16 PAHs and the specified 5 CPs (CP)
were utilized to calculate the magnitude of reduction  of
PAHs and CPs in  the SITE demonstration  Plots.

  The  total PAH and total CP percent reductions in the
SITE demonstration plots were calculated using Equations
1 and  2, respectively:
      % RedPAH = Cip™ " C|PAH x (100) =
                                                   (1)
         CiP
               x (100)
                                               Redcp  =

                                            !.£!2Lx(100)
                                               CiOP
                                       where,


                                         piPAH
                                         "fPAH
                                         C«P
       .average initial PAH concentration in  the  plot
       a average final PAH concentration in the plot
       =  average initial chlorinated phenol concentration
          in the plot
       =  average final  chlorinated phehol concentration
          in the plot

  The percent reduction of  specific compounds in  each
plot is given by equation 3.
                                           fCP
                            o/0 Red =    »  "   » x (100) =
                                              -^x(100)
                                                                          (3)
                                          where,

                                          C".  = average initial concentration of compound y in the
                                               plot
                                          C"  = average final concentration of compound y in the
                                               plot

                                          In  addition, the composite soil data from each plot was
                                        evaluated to  measure changes in soil toxicity, reduction of
                                        TRPHs, concentrations of metals,  conventional soil chem-
                                        istry,  and  PSD. Separate individual  grab samples were also
                                        collected  and evaluated to track changes in the microbial
                                        populations of each plot. Furthermore,  the  area underly-
                                        ing the demonstration soil was sampled and monitored
                                        during each  sampling event, for the possible migration of
                                        contaminants downward  into the underlying  sand layer or
                                        the presence of leachate collecting on the liner.

                                        4.3.3 Statistical Analysis
                                          The pre-and post-treatment concentration data for total
                                        and individual PAHs,  and total  and  individual  chlorophenols
                                        were used to further compute the point estimates and their
                                        respective confidence intervals for removal  efficiencies of
                                        these contaminants. The  basic statistical  methodology  used
                                        toanalyze the data collected during  sampling events 0  and
                                        3 is described below. CIs were constructed at two levels of
                                        confidence, 80% and 90%.

                                          First the separate pretreatment  and post-treatment data
                                        were analyzed by constituent in tests of normality on the
                                        raw data  and tests  of log normality on the log-transformed
                                        data. These tests indicated that the separate data sets,  as
                                        wells as the paired  ratios of effluent to influent  data, gen-
                                                        36

-------
                 No-Treatment

                    Plot
                                       Test  Plot
                62





                63



                64
                 *




                65



                66
55



56





57



58




59
 *


60
           3456789     10



           E         E                      E
                                                                                         12     13    14    15    16    17    18
19    20   21   22   23  24   25  26  27   28    29   30    31    32    33    34    35   36




      E                  E   .                   E   .                  E           '


37    38   39   40   41   42   43  44  45   46    47   48    49    50    51     52    53   54




           EE          .               Ed>   •    •           E


    .  = sampling points (random selection for treatment plot)
Parameter
2 7
Semivolatiles X X
Semivolatiles
(Triplicate) MS/MSD X
Semivolatiles - sand
Total heterotrophs/
POP degraders X
Chloride
TKN,NO,/NO,,PQ,,
TC.TIC.'pH "
TRPH
Metals
PSD
Dioxirts/Furans
Toxicity
Test Plot
8 11 13 18 18 22 25 28 30 35 36 38 42 46 47 51
XXXXXXXXXX XX XX
X
XX X
XXX X XXX X
1 composite
1 composite
1 composite
1 composite
1 composite
1 composite
1 composite
No-Treatment Plot
55 56 57 58 59 60 61 62 83 64 85 66
X X X X X
X

XXX
1
1
1
1
1

1
X X X X X X X


X X X
composite
composite
composite
composite
composite

composite
           E - Contingency samples.

           E(1)  Sampled in triplicate and extracted in the lab as contingency samples (one sample was analyzed for MS/MSD)
Figure 4-2.  Soil Sample Aliquots for Sampling Events 0 and 3.

-------
No-Treatment
Plot
61
62
63
64
65
66
55
56
57
56
59
60
Test Plot
1 2 3456769 1O 11 12 13 14 15 16 17 16
* • * •
19 20 21 22 23 24 25 26 27 26 29 30 31 32 33 34 35 36
* * * * * •
37 36 39 40 41 42 43 44 45 46 47 46 49 50 51. 52 53 54
.
. = sampling points (random selection for treatment plot)
Parameter
2 7
Semivolafites X X
Semivolatiles
(Triplicate) MS/MSD
Semivolatiies - sand
Total heterotrophs/
POP degraders X
Chloride
TKN,NO,/NQ,,,PQ4,
TC, TIC.'pH "
Test Plot
8 11 13 16 18 22 25 28 30 35 36 38 42 46 47 51
XXXXXXXXXX XX XX
X X
XX X
X X X X X X X X
1 composite
1 composite
No-Treatment Plot
55 56 5? 58 59 60 61 62 83 64 85 68
XXX XXX
XXX XXX
1 composite
1 composite
Figure 4-3.  Soil Sample Aliquots for Sampling Events 1 and 2.
erally  satisfied the assumption of log normality at the a =
0.01 level of significance. Letting z. = (y/x) represent the
ith paired ratio of effluent concentratfbn  to'rnfluent concen-
tration, the assumption that the z.'s follow an approximate
log normal distribution implies that the  quantities log (z) =
(log y-logx^ follow an approximate normal distribution.
Furthermore, the normal distribution also  then describes
the behavior of the average  of these log ratios:
         1
 log z =  -I, log z,  = (log  y-logx)
         n
and a t-statistic with (n-l) degrees of freedom (where n
represents the number of data pairs) can be formed using
the  expression:
 tn-1
[togz-log(1-R0)lWn
         S,,
(5)
                'log z
where R0 is the developer's claimed or expected removal
efficiency and S ,  2 is the standard deviation of the logged
ratios.
                                                     This formula was used to develop a confidence interval
                                                   for  the true expected  removal efficiency. By  rearranging
                                                   the terms and solving for log (1 -R0), we have the approxi-
                                                   mate equation :

                                                   log(1 -R0)6 fog z ± tMJ,-  %^                     <6>
                                                                              Vn
                                                   Further exponentiation and rearrangement leads to the fi-
                                                   nal Cl expression for R0:
                                             (4)    R0e1-exp  I logz ±
                                                                              Vn
                                                          (7)
  This was then the expression used to compute the  re-
moval a was chosen to be .10, since a "cuts off" one tail of
the t-distribution, so that a total of 20% is cut off when the
upper and lower confidence limits are computed. Likewise,
for 90% confidence, a was chosen to be

  One other point should be noted concerning the  point
estimates of removal efficiency. Rather than simply taking
one minus the mean effluent divided by the mean  influent,
the point estimates were based  on the  paired samples.
                                                        38

-------
The method used in this case is equivalent to computing
one minus the geometric mean of the paired effluent to
influent  ratios. Explicitly, the following equation  was em-
ployed:
R =  1  - exi
pjlog  z]
(8)
  This  point estimate will generally be slightly different from
the typical one minus the mean effluent divided by the mean
influent, but it explicitly accounts for the pairing in the data
and  has much  better understood statistical  properties.

Process Monitoring
   Field and process monitoring data were taken by the
developer at a  predetermined frequency. These measure-
ments  included:

   . Microtox™ Soil Toxicity Assays

   . Pore Water Monitoring

   . Air Sampling

   • Soil  Temperature  Monitoring

   • Soil Water  Holding Capacity

   • Soil Moisture Monitoring

   • Greenhouse Ambient Air Temperature

   • Greenhouse Air Temperature During Sampling

   • Outside Air Temperature

4.4 Performance Data

4.4.1   SITE  Contractor Results from Pre-
Demonstration
   Pre-demonstration  soil samples were collected by the
SITE contractor to characterize the target media for treat-
ment and non-treatment;  to ensure the  presence, concen-
tration, and variability of target compounds (PAHs and PCP)
present in the  target media; and to identify any possible
conditions  present in the soil that would inhibit the treat-
ment process or its validation  (i.e., oversized particles, di-
oxins/furans, metals,  volatile  organics,  pesticides, and
PCBs). Analysis of the pre-demonstration data from each
plot indicated concentrations of target  contaminants ac-
ceptable to the developer, and a possible inhibitor to the
evaluation  process.

   The  Treatment Plot exhibited  total PAH concentrations
ranging from 2274 mg/kg to 3453 mg/kg  and TCP concen-
trations ranging from 540 mg/kg to 740 mg/kg.  The No-
Treatment  Plot  exhibited total PAH  concentrations of 1772
mg/kg  and TCP concentrations of 360  mg/kg. PCPI was
the only chlorinated phenol detected in both plots. The only
VOC detected was acetone, which may have been a labo-
ratory  artifact. Pm-demonstration soil data for organic com-
pounds only  utilized soil samples sieved to  less  than 0.5
inches  in diameter.
  According to the  developer, no inhibitors were evident in
the demonstration soils. The test soil had been previously
screened by the developer to a diameter of 2 inches. No
abundant concentrations of toxic heavy  metals were evi-
dent in either plot. Pesticides,  PCBs, and carcinogenic di-
oxins were not detected  in the Treatment Plot. The No-
Treatment Plot soil was not analyzed for pesticides, PCBs,
or dioxin/furans.

  An important physical observation made during the pre-
demonstration was the abundance  of oversized  material
(greater than 1 inch in diameter) as supported by the re-
sults of the particle size distribution  analysis of the soil in
each plot. The developer  had screened the ex situ soil pre-
vious to  sampling to a particle size of approximately 4
inches. The  particle size distribution  analysis indicated that
the Treatment Plot soils exhibited  13%  fines, 26% sand,
and 61% gravel or larger.  Particles larger then gravel size
comprised 51% of the total soil sample. The abundance of
this oversized material would  potentially  bias the  evalua-
tion and would require additional analyses to correct. Dis-
cussions with  the developer resulted in  the soil from the
two plots being  removed  and re-screened to less than  1
inch in diameter and replaced into the  plots prior to the
start of the demonstration.

   In addition, to enhance  the evaluation of the technology,
the laboratory screened  the composite samples to a 1-
inch particle size and analyzed representative subsamples
for SVOCs.  The concentrations and variations observed
during pre-demonstration  activities were  used  to support
assumptions made in developing  the demonstration's ex-
perimental  design.

4.4.2  Summary of Results • Primary
 Objectives
   Results from  the SITE  demonstration  indicate that the
DARAMEND™ Bioremediation Technology significantly
reduced total PAHs and  TCP during the period of treat-
ment (254 days) in  the Treatment  Plot. The  primary objec-
tive was established by comparing  the sums of the con-
centrations of select PAHs and of CPs from the excavated
wood-treatment soils within the Treatment Plot prior to the
application  of the DARAMEND™ Technology and at the
end of approximately 8 months (254 days) of treatment.

   Total PAHs were reduced from an average of 1710 mg/
kg to 98 mg/kg, a 94% reduction with a 90% Cl of 93.4 to
95.2%; TCP were reduced from an average of 352  mg/kg
to 43 mg/kg, an 88% reduction with a 90%  Cl of 82.9 to
90.5%. Table  4-I summarizes the performance of the
DARAMEND™ Bioremediation Technology over the course
of the SITE demonstration. Figure 4-4 graphically depicts
the performance of the primary objectives.

   It should be noted that during the statistical treatment of
the Treatment Plot data no outliers were  detected and thus
excluded from the analyses. Six constituents were consis-
tently non-detected during  both sampling events and  could
not be statistically  analyzed for this reason. These include:
                                                       39

-------
2-Chlorophenol,  2,4-Dichlorophenol, 2,4,6-Trichlorophenol,
2,4,5 Trichlorophenol, Naphthalene, and Acenaphthylene.
To calculate removal efficiencies of TCP and total PAHs in
light of these non-detected compounds, three different
cases were constructed: 1) putting all  NDs at the MDL, 2)
putting all  NDs at half the MDL, and 3)  putting  all  NDs at 0.
All three cases  gave very similar results, concluding that
the treatment of non-detects  in this particular dataset is
not a significant issue.  Using  the statistical methodology
described  in Section 4.3.3,  point estimates,  R,  for % re-
ductions in the geometric mean concentrations of total
PAHs and total  chlorophenols, and their respective CIs
were computed  and are presented below.

  These results indicate  that with a 90% level of confidence
(i.e., 10%  chance of error) total PAHs and total chlorinated
were reduced by 93.7% or more and 84% or more, re-
spectively, in the Treatment  Plot over a  period of 254
days.

  Supporting documentation is presented in  Appendix B
of the TER, which includes descriptive  analyses of the set
of ratios for each compound examined on a  log scale as
well as histograms and  probability plots, descriptive  statis-
tics, and the results of a Shapiro-Wilk test of normality
(which on the log scale tests the original ratios for log-
normality).

4.4.3  Summary of Results - Secondary
Objectives
4.4.3.1  The Magnitude of Reduction in  the Sums
of the Concentration of Select PAHs  and
Chlorinated Phenols in the No-Treatment Plots
Soils
  Results  from  the  SITE demonstration indicate that no
significant  reduction  in  TCP occurred  during  the demon-
stration in  the No-Treatment Plot.  This secondary objec-
tive  was evaluated by comparing  the sums of the concen-
trations of the CPs from the excavated wood-treatment
soils within the No-Treatment Plot over the approximately
8 months (254 days) of no-treatment.
Parameter
R
80% Cl      90% Cl
Total PAHs( 1)           .946  (.939,  .952)  (.936,  .954)
Total PAHs(2)           .945  (.938,  .951)  (.935,  .953)
Total PAHs(3)           .944  (.937,  .951)  (.934,  .952)
Total  Chlorophenols(l)  .906 (.885, .922) (.878,  .927)
Total   Chlorophenols(2)  .893 (.869, .913) (.861,  .918)
Total   Chlorophenols(S)  .872 (.840, .898) (.829,  .905)
  TCP remained at an approximate average of 217 mg/
kg. However, total PAHs were reduced from an  aver-
age of 1,312 mg/kg to 776 mg/kg, a 41% reduction with
a 90% Cl of 34.6 to 48.7%. Table 4-I summarizes the
performance of the DARAMEND™ Bioremediation  Tech-
nology over the course of the SITE demonstration. Fig-
 ure 4-4 graphically presents the performance of this
 secondary objective. It should be noted that during the
 statistical treatment of the No-Treatment Plot data no
 outliers were detected and thus excluded from the analy-
 ses.

 4.4.3.2 The  Magnitude of Reduction for Specific
 PAHs  and Chlorinated Phenolic Compounds
 Within Each Demonstration Plot
  Results from the  SITE demonstration indicate that the
 DARAMEND™ Bioremediation  Technology  reduced (mod-
 erately to significantly) all the targeted PAHs and CPs dur-
 ing the  period of treatment (254 days)  in the Treatment
 Plot. The secondary objective  was accomplished by com-
 paring the sums of the concentrations of  each PAH and of
 each  chlorinated phenol from the excavated wood-treat-
 ment soils within the Treatment Plot, prior to the applica-
 tion of the DARAMEND™ Technology and at the end of
 approximately eight  months (254 days)  of treatment.

 Treatment  Plot
  The reduction of specific PAHs ranged from approxi-
 mately 98% for acenaphthene to approximately 41% for
 benzo(g,h,i)perylene.  The only targeted chlorinated phe-
 nol detectable in the Treatment Plot was PCP. The reduc-
 tion of PCP was approximately 88% which was reduced
 from an average of 352 mg/kg  to 43 mg/kg. Table 4-2 sum-
 marizes the performance of  each individual target  com-
 pound treated by the DARAMEND™ Bioremediation Tech-
 nology over the course of the SITE demonstration.

  The analysis of the Treatment Plot's PAH  data indicates
 that the DARAMEND™ Bioremediation  Technology pro-
 duced significant reductions of 3-ringed and 4-ringed PAH
 compounds (both averaged approximately 97%), with  lower
 reductions for 5-ringed and 6-ringed PAH compounds (av-
 erage approximately 77% and 40%,  respectively).  Figures
 4-5 and 4-6 demonstrate the  reduction per each of the 3-
 ringed, 4-ringed, 5-ringed, and g-ringed PAH compound
 groups. No statistical analysis was required to support
 these  conclusions on the Treatment Plot results for spe-
 cific PAHs and CPs,  however,  a statistical  analysis was
 performed  as a byproduct of the analysis of total  PAHs
 and TCP in Section 4.4.2.  This analysis is presented be-
 low.

  A statistical analysis of the demonstration's specific PAHs
 and CPs from the baseline soil sampling event  (Event #0,
 0 days of treatment) and the final soil sampling event (Event
#3,  254 days of treatment) was utilized to calculate the
 point estimates for average removal and associated lev-
 els  of significance and confidence intervals. The statistical
 approach was the same utilized for the  evaluation of the
 primary objective (see Section 4.4.2).

  Six constituents were consistently non-detect during both
 sampling events and could  not be statistically analyzed for
this  reason. These  include 2-Chlorophenol,  2,4-
 Dichlorophenol, 2,4,6-Trichlorophenol, 2,4,5-Trichlorophenol,
                                                     40

-------
Table  4-1    Primary and Secondary Objective Results for Total PAHs and TCP
                                                 GRACE Bioremediation Technologies
                                            Daramend™ Bioremediation Treatment Process
                                                      Trenton, Ontario, Canada

                                                      (Concentrations in mg/kg)
Treatment Plot
Analyte
Total PAHs
TcPAHs
TB(a)PEQ
TCPs
Days of Treatment
0 88 144 254
1710
390
55
352
619
250
59
158
221
123
31
90
98
54(43)'
15(11)'
43
Percent
Removal
94.3
86. 1(89.0)'
72.4(80.3)'
87.8
0
1312
377
62
217
No-Treatment Plot
Days of No-Treatment
88 144
1155
338
56
288
982
309
62
356
254
776
274
45
218
Percent
Removal
40.9
27.1
26.7
0
All data is mg/kg on a dry weight basis
TPAHs     -  Total Polynuclear aromatic Hydrocarbons
TcPAHs  -  Total Carcinogenic Polynuclear Aromatic Hydrocarbons
TB(a)PEQ  - Total  Benzo(a)Pyrene  Equivalents
TCPs      - Total  Chlorinated  Phenols
l-Data  provided by  Grace Bioremediation Technologies based on analyses of split samples by an independent laboratory.

Note:  Percent removals presented in this table have been calculated using the arithmetic average (mean) concentrations from Events 0 (day 0)
       and 3 (day 254).
               2000
            0)
                                                                                                   144
                                                                                                                254
                                                                    Days
 Figure 4-4. Primary and Secondary Objective  Results Total      and TCP.
                                                                  41

-------
Table 4-2.  Specific Results for Each PAH and Chlorinated Phenol Compound Detected in the Treatment Plot

                                           GRACE Bioremediation Technologies
                                      DARAMEND™ Bioremediation Treatment Process
                                               Trenton, Ontario, Canada

                                                    Treatment Plot
                                               (Concentrations in mg/kg)
Compound Compound Type
Pentachlorophenol Chlorinated Phenol
Fluorene
Acenaphthene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
lndeno(l,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
3-Ring PAH
3-Ring PAH
3-Ring PAH
3-Ring PAH
4-Ring PAH
4-Ring PAH
4-Ring PAH
4-Ring PAH
5-Ring PAH
5-Ring PAH
5-Ring PAH
5-Ring PAH
5-Ring PAH
6-Ring PAH
Event 0
Average
Concentration
350.00
43.0
62.0
190.0
70.0
550.0
390.0
80.0
120.0
61.0
66.0
39.0
17.0
6.5
16.0
Event 1
Average
Concentration
160.0
36.2
34.4
20.0
14.0
120.0
120.0
25.0
50.0
59.0
50.0
38.0
16.0
12.3
15.0
Event 2
Average
Concentration
90.0
4.1
3.9
4.7
5.4
34.0
34.0
8.2
17.0
41 .0
19.0
21.0
12.0
4.6
11.0
Event 3
Average
Concentration
43.00
1.16
0.99
3.60
4.70
13.00
11.00
3.80
6.80
15.00
6.70
10.00
9.10
2.60
9.50
Percent
Removals
. 87-7
97.3
98.4
98.1
93.3
97.6
97.2
95.3
94.3
75.4
89.8
74.4
46.5
70.5
40.8
Average
Percent
Removals
87.7
97.1



97



77.1




40.6
Note: Percent removals presented in this table have been calculated using the arithmetic average (mean) concentrations from Events 0 (day 0) and
     3 (day 254).
Naphthalene,  and  Acenaphthylene.  To calculate total
chlorophenols and total PAHs in light of these nondetected
compounds, three different cases  were  constructed:  1)
putting all NDs at the MDL, 2) putting all NDs at half the
MDL, and 3) putting  all NDs at  0. All three cases  gave very
similar  results, concluding  that the treatment of non-de-
tects in this  particular dataset  is  not a  significant issue.

  One other non-detect sample occurred during Event #0
for  constituent  Dibenzo(a,h)anthracene.  The  MDLof 47,300
mg/kg for this sample  is very high relative to the other de-
tected concentrations  for this  compound  in the pretreat-
ment (all of which were no greater  than  11,000). Further-
more, all the post-treatment samples contained this com-
pound at similar levels. Avalue equal to the average  of the
other pre-treatment sample  values for this constituent was
utilized,  a method often used  for missing  data values. Al-
though the data value was not missing, it does appear
somewhat anomalous.
  Given all these considerations, point  estimates for aver-
age removal  (R) and the associated Cl are presented be-
low:
Parameter
80% Cl
90% Cl
Pentachlorophenol
Acenaphthene
Fluorene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
lndeno(l,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo(g,h,i)perylene
.872 (.
.986 (,
.979 (.
.981 (.
.942 (.
.977 (,
.974 (,
.954 (,
.946 (,
.773 (,
.902 (.
.749 (,
.470 (,
.618
.454 (,
840, .
898) (
.983, .989) (
,973, .
978, .
983) (
984) (
,929, .952) (
.974, .980) (
.970, .977) (
.949, .959) (
.940, .952) (
.740, .802) (
,888, .914) (
.717, .777) (
.391, .539) (
(.565
, .664)
.339, .550) (
.829,
'.982,
'.971,
.977,
.924,
:.973,
:.969,
:.947,
.938,
:.729,
:.884,
;.707,
'.364,
'(.548,
'.299,
.905)
.989)
.985)
.985)
.955)
.981)
.978)
.960)
.954)
.810)
.918)
.785)
.559)
.677)
.575)
                                                          42

-------
Figure 4-5. PAH Percent Removal By Number of Flings.
i nnn
S
"ro
c
o
o
° K nn
o>
2
9 200 -










•i
•I



c^^a 3-ring PAHs
^ra 4-ring PAHs
cssi 5-ring PAHs
E2Z3 6-ring PAHs





Treatment Plot






	 I
X
X
•><
0


i
vSj


I

	 sK 	
•.'• OcffV . vX^SSc, .
88 144 254

1
No-Treatment Plot







s
fl
0

^J
^Jfi

	 JH 	



1
i
?
B
88
	 ifc 	
.... Ja., «








X
X 	
X
j
144 254
                                                               Days
Figure 4-6. PAH Concentration By Number of Rings.
                                                              43

-------
  As discussed above, based on the estimated Cl, the
developer's claim can be said  to be supported by statisti-
cal hypothesis testing at the .10 significance level for
acenaphthene,  fluorene,  phenanthrene,  anthracene,
fluoranthene,  pyrene,  benzo(a)anthracene, and chrysene.
None of the other tested compounds meet the  claim at
this level of significance.

  Supporting documentation is presented in the TER, which
includes a descriptive analyses  of the set of ratios  for each
compound examined on a log scale as well as histograms
and probability plots, descriptive statistics, and the results
of a Shapiro-Wilk test of normality (which  on the log scale
tests the original ratios for log  normality).

No-Treatment  Plot
  The  reduction  of specific PAHs ranged from  approxi-
mately 76% for fluorene to approximately -14% for
benzo(b)fluoranthene.  The only targeted  chlorinated phe-
nol detectable in the No-Treatment Plot was PCP. No sig-
nificant reduction of PCP was  encountered (average
baseline  concentration of 216.7 mg/kg  in comparison with
an average final concentration  of 217.5 mg/kg). Table 4-3
summarizes the performance of each individual target com-
pound  left untreated by the DARAMEND™ Bioremediation
Technology over the course of the SITE demonstration.

4.4.3.3 Comparison of Performance  of Treat-
ment  Plot vs.  No-Treatment  Plot
  Statistical comparisons with respect to individual  and total
PAHs,  and individual  and total chlorophenols were per-
formed to establish if the point estimates  of contaminant
removal efficiencies computed for the Treatment Plot were
significantly different from  those computed for the No-Treat-
ment Plot. These comparisons were made with  a 10% level
of significance and the results are presented in Table 4-4.
Results of this analysis indicate that by day 254 (i.e., sam-
pling Event 3) of the  demonstration study the percent re-
ductions in the  geometric mean concentrations of all detected
target  contaminants  in the Treatment Plot  (except for
Dibenz(a.h)anthracene) were significantly higher than  those re-
alized in the NoTreatment   Plot. For Dibenz(a,h)anthracene,
the reductions in  the  two plots by day 254 were statisti-
cally indifferent. This may have been  due to the inherent
limitations associated with low initial concentrations (around
10 mg/kg) in both soils.  With respect to the two critical
parameters, total  PAHs and TCP,  through all three subse-
quent sampling events (1,2, and 3) of the study the reduc-
tions realized in the Treatment Plot were significantly higher
than those in the No-Treatment plot.

4.4.3.4 The Toxicity of the Soil to Earthworms
and Seed Germination in Each of the SITE
Demonstration  Plots Before and After  Treat-
ment
  Toxicity tests were  performed on the pre- and post-re-
mediation soil  samples to determine if the toxicity of the
soil had decreased due to the degradation of the com-
pounds of interest. Two toxicity tests, germination of let-
tuce  and radish seeds and earthworm  survival,  were  used
to evaluate the efficacy of the DARAMEND™ Bioremediation
Technology in soils contaminated with  CPs and PAHs. This
battery of tests was  conducted on untreated  and
DARAMEND™ treated, pre-and post-remediation samples
of contaminated soil. In addition, negative and positive
controls were  utilized as part of the testing regime.  Both
controls were used to assess the health of the test organ-
isms; the  positive  control would produce  an observable
effect.  The positive control response  should also be within
two standard deviations  of the running mean of the  posi-
tive control response as determined from  a control  chart
tracking recent positive control tests.  If either the negative
or positive control  response was  outside acceptable lev-
els as indicated in the DQOs (i.e., negative control sur-
vival is 80%  or positive  control response is two standard
deviations  away from running mean), the health of the test
organisms must be  examined and the tests may need to
be conducted  again. The seed germination toxicity testing
utilized lettuce  (Lactuca sativa) and radish (Raphanus
sativus). The earthworm toxicity tests utilized the red worm
(Eisenia foetida).  Each of the test species was routinely
used in the  evaluation of contaminated soils.

  In  all tests  of 100%  pre-treatment  soil  (i.e., untreated
and DARAMEND™ treated soil from Event #0), the end-
points of  interest for a  particular test species were de-
pressed relative to negative controls. The endpoints of in-
terest were plant germination and  earthworm survival. For
example, 50% inhibition  of lettuce and radish seed germi-
nation  prior to remediation was calculated to occur in soil
mixtures containing approximately 4% and 60%  of the con-
taminated  soil, respectively, while the concentration of con-
taminated  soil required to kill 50% of the earthworms was
calculated to be  approximately 25%.

  The  DARAMEND™ Bioremediation Technology ap-
peared to reduce the toxicity of the contaminated soil to
both  the plant seeds and the earthworms in the Treatment
Plot. Post-remediation toxicity  of the  untreated, contami-
nated soil  in the No-Treatment Plot to the earthworms was
only slightly decreased  while the DARAMEND™-treated,
contaminated soil was essentially non-toxic. The slight re-
duction in  toxicity of the  No-Treatment  Plot  soils is consis-
tent with the slight reductions in PAHs observed. Similarly,
the  inhibition of seed germination post-remediation was
only  slightly  reduced in  the  untreated, contaminated  soil
while the  100% DARAMEND™-treated, contaminated  soil
treatments caused  0% and 33%  inhibition  of germination
for radish  and lettuce seeds, respectively.  Negative  and
positive control samples included within the  testing scheme
were within acceptable limits  and the toxicity testing analy-
ses conformed to all appropriate QA/QC  requirements.
Table 4-5  and 4-6 present the results of the toxicity tests.
                                                       44

-------
Table 4-3.    Specific Results for Each PAH and Chlorinated Phenol Compound Detected in the No-Treatment Plot

                                                GRACE Bioremediation Technologies
                                           DARAMEND™ Bioremediation Treatment Process
                                                     Trenton,  Ontario, Canada

                                                         No-Treatment Plot
                                                     (Concentrations in mg/kg)
Compound
Compound
Type
Pentachlorophenol Chlorinated Phenol
Fluorene
Acenaphthene
Phenanthrene
Anthracene
Fluoranthene
Pyrene
3-Ring
3-Ring
3-Ring
3-Ring
4-Ring
4-Ring
Benzo(a)anthracene 4-Ring
Chrysene
4-Ring
Benzo(b)fluoranthene 5-Ring
Benzo(k)fluoranthene 5-Ring
Benzo(a)pyrene
5-Ring
lndeno(l,2,3-cd)pyrene 5-Ring
Dibenz(a,h)anthracene 5-Ring
Benzo(g,h,i)perylene 6-Ring
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
PAH
Event 0
Average
Concentration
216.7
14.4
23.5
37.2
30.8
461.7
355.0
75.2
117.0
58.5
58.4
36.8
14.6
16.1
13.8
Event 1
Average
Concentration
288.3
34.5
15.8
16.2
16.3
416.7
303.3
65.2
99.0
56.5
55.2
35.3
15.0
11.9
13.8
Event 2
Average
Concentration
355.0
23.1
16.8
15.3
12.2
315.0
276.7
52.5
84.0
53.7
49.8
31.2
14.5
23.1
13.8
Event 3
Average
Concentration
217.5
3.5
7.1
15.0
12.3
185.5
270.0
44.3
76.0
66.8
38.8
32.3
12.1
4.1
11.1
Percent
Removals
-0.4
75.7
'69.8
59.7
60.1
59.8
23.9
41.1
35.0
-14.2
38.9
12.2
17.1
74.5
19.6
Average
Percent
Removals
-0.4
64.2



42.9



16.4




19.6
Note: Percent removals presented in this table have been calculated using the arithmetic average (mean) concentrations from Events 0 (day 0) and
      3 (day 254).

-------
Table 4-4.  Summary of Statistical Analysis of Contaminant Reductions in the Treatment and No-Treatment Plots

                                           Percent Reductions in Geometric Mean Concentractions

                           @ Event 1                         @ Event 2
                                    1 Event 3
Contaminant Treatment No-Treatment
of Concern Plot Plot
Acenaphthene
Fluorene
Pentachlorophenoi
Phenanthrene
Anthracene
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
Benzo(a)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
lndeno(1,2,3-cd)pyrene
Dibenz(a,h)anthracene
Benzo{g,h,i)perylene
Total PAHs
Total Chlorophenols
49.3
1 6.4 »
54.5 »
90,9 »
81.4 »
80.2 »
71.8 »
71.6 »
80,7 »
4.2
25.1 »
4.0
3.0
0.0 «
7.5
64,4 »
54.5 »
46.0
0.0
0,0
55.0
50.5
3.4
22,4
15.3
16.8
1.7
8.8
4.7
0.0
29.5
1.4
14,5
0.0
Treatment
Plot
95.8 »
92.7 »
73.3 »
97.4 »
92.3 »
94.7 »
92.8 »
90,4 »
86.7 »
33.6 »
73.1 »
48.0 »
27.1 »
30.0 »
26,8 »
87.6 »
73.3 »
No-Treatment
Plot
31.4
0,0
0.0
56.8
63.3
31.3
29.4
31.7
29.3
6.6
17.7
15.7
1.3
0.0
1.0
27,4
0.0
Treatment No-Treatment
Plot Plot
98,4 »
97.9 »
07.2 , »
98.1 »
94.2 »
97.7 »
97,4 ::»
95.4 »
94,6 »
77.3 »
90.2 »
74.9 »
47.0 »
63.0
45.4 »
94.4 »
87.2 »
84.3
79.1
0.0
68,2
62.7
82.2
30,8
42.3
35,9
0.0
36.4
12.2
18.5
80.0
21.9
42.0
0,0
Note:    Results of Statistical Comparisons between reductions of a given contaminant in the Treatment Plot and that in No-Treatment Plot with a
        90% Level of Confidence! are presented in the Table above using signs described below.
   "»"  Implies that the reduction of the contaminant in the Treatment Plot was Significantly Higher than that in the No-Treatment Plot.
   "=="  Implies that the reductions of the contaminant in the Treatment and No-Treatment Plots were Statistically Indifferent or the Same.
   "«"  Implies that the reduction of the contaminant in the Treatment Plot was Significantly Lower than that in the No-Treatment Plot,
 4.4,3,5 The      of Total Recoverable Petroleum
 Hydrocarbons in        of the Demonstration

  The results of the SITE demonstration concerning total
 recoverable petroleum hydrocarbons (TRPH) indicated a
 significant reduction  occurred in the Treatment Plot  and
 no significant reduction occurred in the No-Treatment Plot.
 In the Treatment Plot, TRPHs were reduced from 7,300
 mg/kg to 932 mg/kg (87% reduction approximately). In the
 No-Treatment Plot, TRPHs remained  at approximately
 5,000 mg/kg. This secondary objective was evaluated by
 comparing  the  results of the TRPH analyses of the tar-
 geted soils in both plots at the beginning and end of the
 approximately 3 months (254 days) of study during the
 SITE demonstration. Table 4-7 and Figure 4-7 exhibit the
 TRPH results for the SITE demonstration.
4.4.3.6 General Soil Conditions • Inhibitors/
Promoters to Technology's Effectiveness
Table 4-5,  Mortality of the earthworm, Eisenia foetida, from 28 day soil
          toxicity tests. Values reported are the mean percent mortal-
          ity in the 100% treated and untreated soil before and after
          remediation. Paired negative control mortality is in paren-
          theses.
                   Mean Percent Mortality

                DARAMEND™Treated Soil
Untreated Soil
Baseline
(October 1993)
Post-Treatment
100%(0%)
0% (3%)
100%(0%)
100% (3%)
                                                         46

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Table 4-6.   Inhibition of germination from 5 day soil toxicity tests con-
          ducted with lettuce (Lactuca sativa) and radish (Raphanus
          sativus). Values reported are the mean inhibition of germi-
          nation in 100% untreated and treated soil before and after
          remediation.  Paired negative control inhibition of germina-
          tion is in parentheses.

            Mean Percent  Inhibition of Germination
Daramend™ Treated Soil
Radish
Baseline
(October 1993)
Lettuce
100% (8%;
Radish
) 52% (4%)
Untreated Soil
Lettuce
97% (5%) 82% (9%)
Post-Treatment  33% (5%)    0%(1%)
(September 1994)
                 92% (5%)  23% (1 %)
  Based on the significant reduction of total PAHs and TCP
in the Treatment Plot soils, no inhibitors to the activity and
longevity of degrading microorganisms in the treatment soil
were  evident. Supportive analytical  results  indicated that
the soil chemistry at the demonstration  site caused no
negative effect to limit the rate at which biodegradation of
PAHs  and CPs  occurred.  Soil chemistry was acceptable
to promote significant biodegradation  in  the Treatment Plot.
PSD results are discussed in  Section 4.4.4.

Presence of Inhibitors to Biodegradation
  The  developer's literature indicates that soil containing
a high concentration of heavy metals  and having a high
acidity,  may  limit the  biodegradation  rate of  the
DARAMEND™ Bioremediation Technology. Soil sample
composites for metals analysis were collected in both plots
initially (day 0) and at the end of the demonstration (day
254).  No significant change occurred in the concentration
of metals in the soil as a result of the treatment process. A
significant reduction  of PAHs and CPs in the Treatment
Plot soils was exhibited  despite the concentrations of met-
als  detected. The various metals present in the soil  exhib-
ited the  following  concentration ranges in mg/kg:  Alumi-
num  3100-3800;  Antimony 11.9-<12; Arsenic 4.8-6.4;
Barium 39.8-<40; Beryllium <1.0-l .0;  Cadmium 0.99-<1.0;
Calcium 140,000-1 67,000; Chromium 8.1  17.7  mg/kg;
            Cobalt 9.9-I 0; Copper 9.8-I 7.2; Iron 4100-6690;  Lead 7.9-
            19.9;  Magnesium 3400-4200; Manganese  150 188;  Nickel
            <0.1 -8.0;  Potassium 995-<1000; Selenium 98.8-99.5; Sil-
            ver Q.0-2.0;  Thallium <2.0; Sodium 995-c1000; Vanadium
            <1 0-1 0; and Zinc 61-1 25. The pH  levels in the Treatment
            Plot ranged from 8.16 to 9.38 during the demonstration.
            The pH levels in the No-Treatment Plot ranged from 8.28
            to 9.5  during the demonstration.

              Single soil  samples were obtained and analyzed for vari-
            ous chlorinated dioxins and furans at the outset  of the
            project and  after 254 days of treatment.  Law concentra-
            tions of various penta-, hexa, and  hepta congeners were
            present in both samples; the major  constituents present
            were  the  fully  chlorinated  congeners, however, the toxic
            congener 2,3,7,8TCDD was absent  in both  events, as seen
            in Table 4-8.

              The small differences in the concentration  of congeners
            between the  two samples are probably more correctly at-
            tributed to sampling variability, rather than to  any changes
            resulting from the DARAMEND™ Bioremediation  Treat-
            ment.  Decreases in totals for tetra-, hexa,  hepta, and octa-
            congeners would, if  anything, lead one to suspect  that a
            decrease  has occurred over the course of the demonstra-
            tion.

            Presence of Promoters of Biodegradation
              According to the  developer, the  DARAMEND™
            Bioremediation Technology  provides nutrients to enhance
            the biodegradation rate of the PAHs and CPs in the dem-
            onstration soil. The analytical  results for the analysis of
            chloride, nitrate-nitrite, phosphate,  TKN, TOC, and TIC in-
            dicates that soil conditions remained somewhat constant
            during the demonstration, with some  trends.  TIC appears
            to be slightly  higher in the Treatment Plot compared  to the
            No-Treatment Plot. Otherwise, no  differences in these pa-
            rameters  were evident between the Treatment and No-
            Treatment Plots.

              Chloride ranged from 83 mg/kg to 283 mg/kg  in the Treat-
            ment Plot compared to 20  mg/kg  to 139  mg/kg  in the No-
            Treatment Plot. TKN ranged from  234 mg/kg  to 450 mg/kg
            in the Treatment Plot compared to 137  mg/kg to 442 mg/
Table 4-7.   Results of Total Recoverable Petroleum Hydrocarbon Analysis
                                           Grace Bioremediation Technologies
                                     DARAMEND™ Bioremediation Treatment  Process
                                              Trenton, Ontario, Canada
Analyte
 Treatment Plot
Days of Treatment
(Concentrations in mglkg)

     Percent
     Removal
 No-Treatment Plot
Days of No-Treatment
                     Percent
                    Removal
TRPH
              7300    NA
                              144

                              NA
                 254

                932
                                                     87.3
                        0

                      5000
    88

    NA
144

NA
254

5200
                   NA - Not Analyzed
                            TRPH - Total Recoverable Petroleum Hydrocarbons
                                                        47

-------
   8000
                                                        Table 4-8.  Summary Report for GRACE Bioremediation Technolo-
                                                                 gies DARAMEND™ SITE Project: Total DioxinslFurans
              0    254
                                    254
Figure 4-7. Results of Total Recoverable Petroleum Hydrocarbon
         Analysis (TRPH).
kg in the No-Treatment Plot. Nitrate and nitrite levels were
from non-detect to 0.8 mg/kg to 0.3 mg/kg, respectively, in
both plots. Phosphates  ranged from  2 mg/kg to 1090 mg/
kg in the Treatment Plot  compared to non-detect to  985
mg/kg in the  No-Treatment Plot. TOC ranged from 58,000
mg/kg to 83,300 mglkg in the Treatment Plot compared to
67,000 mg/kg to 79,400 mg/kg  in the No-Treatment Plot.
TIC ranged  from 26,300 mg/kg to 216,000 mg/kg in the
Treatment Plot  compared to 13,800  mg/kg to 96,200 mg/
kg in the No-Treatment Plot.

4.4.3.7  The Possible Generation of Leachate
  No leachate  was generated as  a byproduct of the
DARAMEND™ Bioremediation Technology. Irrigation  wa-
ter was balanced successfully with  system demands to
avoid the generation of contaminated leachate. Monitored
areas beneath the  Treatment Plot were  free of leachate
over the duration of the demonstration. If generated, this
leachate would  require treatment prior to  discharge.

4.4.3.8 Treatment Effects on the Microbial Biom-
ass
  Total  heterotrophic microbial biomass,  as indicated by
mean colony forming units (CPU) per gram of soil gener-
ally ranged between  1 .0 x  1 O6 and 1 .0 x 1 O10 CFU/g among
all plots and sampling dates. Figures 4-8 through 4-I  1  il-
lustrate  the trends in CPU across sampling dates for two
concentrations  of standard plate count agar (PCA 10%,
100%)  and a basal mineral media (DifCo Bacto Agar) with
PCP supplemented  at two concentrations  (12.5,25 mg/L)
as the  major nutrient source for microbial growth. Micro-
bial biomass as CPU was similar for both concentrations
of PCA media over the course of the study (Figures 4-8
and 4-9). The same observation was also true for both
concentrations  of PCP-supplemented  media (Figures 4-
10 and  4-I 1). For each sampling event the mean CFU in
the DARAMEND™  Bioremediation Technology  treatment
soil were always greater than the mean CFU in the no
treatment soil, with the exception of the CFU for Event  0 in
the 25  mg/L  PCP-supplemented media. The mean  num-
Sample Number
Sampling Event
Analytes
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8_HxCDD
1 ,2,3,6,7,8-HxCDD
1, 2,3,7, 8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3, 7,8, 9-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
OCDF
Total TCDD
Total PeCDD
Total HxCDD
Total HpCDD
Total TCDF
Total PeCDF
Total HxCDF
Total HpCDF
O-TPC-039
00
Cone, (ppb)
ND
ND
10.2 .
11.8
1.75
610
10400
ND
ND
0.142
1.52
ND
ND
1.58
80.4
4.41
733
1.24
ND
81.8
1320
0.0832
2.19
99.1
508
3-TPC-045
03
Cone, (ppb)
ND
0.116
ND
7.73
2.22
406
3830
ND
ND
ND
1.72
0.437
0.716
0.477
23.7
2.15
346
ND
0.264
45.2
890
ND
2.54
42.8
161
ber of CFU in the PCP supplemented media also was al-
ways smaller than the mean CFU in both no treatment
and treatment soils treated with the PCA media. Together,
these observations seem to indicate that PCP inhibits  and
the DARAMEND™  Bioremediation Technology treatment
increases microbial biomass, as measured  by CFU.  These
observations are based on  trends consistently observed
in Figures 4-8 through 4-11,  however, a great deal of vari-
ability is associated with each of the mean values plotted
                                                      48

-------
                                           No Treatment
                     -O- Daramend Treatment
                    8.0E+009
                    1.0E+009 r-
                 o>

                •|  1.0E+008

                 o
                ti.
                 °  1 .OE+007
                 o
                O


                 CO


                2 I.OE+006  -
                    1  .OE+005
                           10193-0
      04/94-1                06/94-2

Sampling Date - Month, Year-Event Number
09/94-3
Figure 4-8. CFU/gram soil using 100% PCA agar.
                                          No Treatment
                   -O- Daramend Treatment
                       6.0E+009
                       1.0E+009
                    c


                    o>
                       1.0E+008
                    o
                    LL.
                    o  I.OE+007
                    o
                    O

                    c
                    (0
                    0)
                       I.OE+006
                        .OE+005
                            10193-0               04194-1             06/94-2

                                           Sampling Date - Month, Year-Event Number
                                             09/94-3
Figure 4-9. CFW/gram soil using 10%  PCA agar.

-------
                                                No Treatment
                           -O- Daramend  Treatment
                     4.0E+008
                     1.0E+008  r
                   c

                   O)
                   c
                      1.0E+007  r
                   >s
                   c

                  "o
                  O

                   CO
                     1.0E+006  -
                      1.0E+005
                             10193-0
Figure 4-10.  CFU/gram soil using 25 mg/L PCP in agar.
          04194-1                   06/94-2
      Sampling Date - Month, Year-Event Number
                                                                                                   09/94-3
                                         No Treatment
                    -O-  Daramend  Treatment
                  5.0E+008
                  10E+008  -
              c

              O)
              c
              "E

              £  1 .OE+007
              ><
              _o
              o
              O

              CO
              •i  1.0E+006  r
                  1 .OE+005

                      10/93-0
    04/94-I                    06/94-2

Sampling Date - Month, Year-Event Number
                                                    09/94-3
Figure 4-11.   CFU/gram soil using 12     PCP in agar.
                                                         50

-------
in these figures.  Statistical analysis of the data could indi-
cate that,  although they are consistently  observed, these
trends  are  not statistically significant.

  Comparisons of mean CPUs and concentrations of TCP
and total polycyclic aromatic hydrocarbons (TPAH) in un-
treated and treated soils over time are presented in  Fig-
ures 4-1 2 through 4-1 5. No discernible trend was obvious
in the mean CPU for the no treatment soil even though
mean TPAH decreased with time (Figures 4-12 and 4-
14). However, mean  CPU for the  DARAMEND™
Bioremediation  Technology treated soil increased over
time with a concurrent decrease in  both  TCP and TPAH
concentrations (Figures  4-12  and 4-14).  This trend was
also supported by an increase in measured soil TIC over
time in the DARAMEND™ Bioremediation Technology
treated soil. Mean CFU also appeared to  increase through
time for no  treatment soil in the 25 mg/L PCP-supplemented
media  while little  trend was obvious for CFU  in
DARAMEND™ Bioremediation Technology treated  soil
(Figures 4-I 3 and 4-I 5). A conservative interpretation  of
these data would suggest that  TPAH concentrations  in
these soils have an inhibiting effect on microbial biomass
in these soils,  including organisms that may be capable of
metabolizing PCP. This interpretation is supported  by the
observation that mean CFU for treatment soil increase over
time in the 100% PCA media as TCP and TPAH concen-
trations decrease over time. A large degree  of variability
(i.e., laboratory's standard  deviation)  is associated with the
mean  CFU values presented  in  Figures  4-12 through 4-
15,  however, and it is likely that although  these trends are
consistent and biologically plausible, they  may not be sta-
tistically  significant.

4.4.3.9 Tendency for the  Downward Migration of
Contaminants
  The  results of monitoring the underlying sand layer be-
neath the target demonstration  soils indicated that the sand
layer was  contaminated prior to  treatment of the demon-
stration soils and further compromised during the  demon-
stration. The initial contamination of the  underlying sand
layer occurred when the demonstration soils were removed
from the plots, after the pre-demonstration  results indicated
the soils needed to be re-screened  (to exclude particles
larger than l-inch). The underlying sand  layer was prob-
ably partially mixed with  the demonstration soils. Secondly,
project logbooks  indicate that the demonstration soils were
further compromised just prior to the demonstration, when
a thunderstorm blew off the protective plastic covering on
each plot.  The greenhouse was  not completed when the
SITE demonstration started. As  a result,  rain water satu-
rated parts of each plot.  Leachate was evident beneath
each plot.  Furthermore, during the demonstration the soils
in  the  Treatment Plot were once accidentally mixed  with
the underlying sand layer prior to April 1994, during a sched-
uled soil tillage. In conclusion, the tendency for pollutants
to  migrate  downward from the treatment soil is inconclu-
sive since this aspect of the evaluation was compromised.
  Baseline total  PAHs and TCP present in the underlying
sand  exhibited  concentrations averaging 430  mg/kg and
115 mg/kg, respectively. Final  total PAHs  and TCP present
in the underlying sand exhibited concentrations averaging
101 mg/kg and 54 mg/kg,  respectively.  Reduction  rates
for total PAHs and TCP were approximately 77% and 53%,
respectively. These results are less  significant than those
of the demonstration soils in  the Treatment Plot and are
reported for the curiosity of the reader.

  In addition, records from the baseline event indicate that
the sand  layer was easily differentiated  from the demon-
stration  soils based on  color. The underlying  sand layer
exhibited  a yellow color, while the demonstration soil ex-
hibited a dark brown color, though one of the three sand
samples collected  during the baseline event exhibited  a
dark stain. After May  1994, differentiation  based  on color
was not possible.  Sampling  was based on targeted depths
and proximity to the fiberpad  beneath the sand layer.

4.4.4   Process  Operability and  Performance
  This section summarizes the operability of the process and
overall performance of the  DARAMEND™  Bioremediation
Technology at the Domtar site. This section  includes discus-
sions about developments and problems encountered, along
with the manner in which these items were resolved.

  The DARAMEND™ Bioremediation Technology  oper-
ated over a period of 254 days with only  a few incidents
that deviated from  the Demonstration Plan.  Otherwise, the
process was installed, monitored, and maintained by the
developer with  regularity as designed  and discussed ear-
lier in this section. These incidents that deviated from the
original  plan are discussed  in detail below.

  During the pm-demonstration, the soil/sand interface was
contrary to the design of the plot: the contaminated soil
layer was  determined to be only 1 -foot thick as opposed to
the 2-foot thickness designed. In addition, a large percent-
age (about 50%) of oversized material  (2 inch to 3/8
inch  in  diameter) was present in the  demonstration soil.
This large percentage of oversized material required the
soil to be  excavated from the plots and re-screened to con-
tain soil particles smaller than  1  inch in diameter to reduce
the amount of oversized material.

  During  the baseline event (Event #0),  pre-sampling ac-
tivities  indicated that the depth of the soil layer was vari-
able (ranging from 0.6 feet to 1.3 feet) throughout the Treat-
ment  Plot. The variability of the  soil's thickness above the
underlying sand layer made  it  impossible to till the soil with-
out mixing the two layers  together. An agreement was
reached to collect the baseline soil samples from the Treat-
ment  Plot after the soil had been tilled to a uniform  depth
of 12 inches, and amendments  had been added. The ini-
tial approved approach was to collect soil samples prior to
treatment. All subsequent  tilling and sampling operations
would be  confined to a depth  of 12 inches.
                                                       51

-------
                                           NT      - * - T
                         8.0E+009
                          l.OE+005
                                 0
                  PAH-NT      -O- PAH-T
                                             2000
                                                                      \  t
                                                                                                 1000
                                                                     I
2        3        0
      Sampling  Event
Figure  4-12.   CFU/gram soil vs. TPAHs - 100% PCA
                                            NT      - • -  T
                          2.0Et008

                          l.OE+008
                       E
                       £  1.0E+007
                          l.OE+006  -
                          1.0E+005
                                  0
                   PAH-NT     -0- PAH-T
                                             2000
                                                                            \    + '
                     \    •
                                                                                                1000
                                                    I	I
                  0
                Event
Figure  4-13.   CFU/gram soil vs. TPAHs - 25 mg/L POP.
                                                                52

-------
                                        NT      -*-T
                 TCP-NT     -0"  TCP-T
                        8.0E+009
                        1.0E+009



                     i

                     o.  1.0E+008
                     <3

                     §
                        1.0E+007
                        i.OEtooe
                        l.OEtOOS
Figure 4-14.   CFU/gram soil vs. TCPs -100% PCA.
                                        NT
                     Z.OEtOOS


                     l.OE+008
                  £  l.OE+007
                     l.OE+006  -
                                                                                          .400

                                                         I
                                           300
                                           200  £_
                                                o
                                                3
                                                                                           100
                                                230

                                                     Sampling Event
.4. T      -o-  TCP-NT     -0-  TCP-T
                                            ,400
                   H
                    t   \

                     \   V*
                      t
                       t
                                                                               • *
                                                                                      - - - -, 300
                                                                                             200
                                  ov -
o>

t

-------
  During subsequent events #1 through #3, sampling of
the sand layer indicated that mixing of the two layers may
have occurred. The sand layer sampled contained a mix-
ture of sand and soil.

   During sampling Event #2, the developer was informed
of the soil and sand mixing issue. The developer suspected
that the two layers were accidentally tilled together during
scheduled plot maintenance. The date of this  incident is
unclear. This dilution of the demonstration soil by  acciden-
tal mixing with the sand layer caused a minor interference
with the  evaluation  of the treatment  process. The magni-
tude of the problem was evaluated  by comparing  the PSD
analyses of composite soil  samples collected  during the
baseline  and final sampling  events. Table 4-9 depicts the
results of this analysis. As a result, a 14% increase in the
sand size fraction of the demonstration soils was observed
by  measuring the increase  in the amount of sand evident
in the Treatment Plot before  and after treatment (Event #CI
vs  Event #3). This increase in sand size particles in the
Treatment Plot is most likely a result of this accidental mix-
ing of these two layers. The overall impact of this incident
had no significant impact (i.e., 2% reduction) on the  over-
all  performance of the treatment process. The supportive
calculations  concerning  the sand dilution issue  are pre-
sented below:

Sand Dilution  Calculations
  To account for the 14%  increase in sand-sized  particles,
the PAH and chlorinated phenol concentrations had  to be
adjusted. PCP was chosen  as an example. The initial (i)
and final (f)  average concentrations  evident in the Treat-
ment Plot were utilized to calculate the percent removals
depicted in Scenarios A and B below:

  Scenario A - Not Accounting for Dilution via Sand Mixing
Incident

  If PCPj = 349 mg/kg and PCP, = 43 mg/kg, as measured
           in the Treatment Plot.
  Then the percent reduction = 1 - Conc./Conc..,
  hence, 1 - 43 mg/kg / 349 mg/kg = 88% reduction,
  approximately.

  But the "final" sample was in fact diluted by 14% due to
the addition of the  sand. Therefore, the PCP, would be
calculated as 43 mg/kg multiplied by 1 .14 (dilution factor)
= 49 mg/kg  if there were no sand present. The 14% "addi-
tional" test mixture due  to the sand has the effect  of lower-
ing the  final analyte concentration as  depicted in  Scenario
B:

Scenario B - Accounting for 14% Dilution via Sand Mixing
             Incident
  PCP = 349 mg/kg
PCPf = 43 mg/kg
  Then the  percent reduction = 1  -Cone., (1.14) /Cone..,
  hence, 1 - 43 mg/kg (1 .14) / 349 mg/kg = 86% reduction'
  approximately.

  Comparison of the 2% reduction  rates indicates an overall
significant difference of approximately 2% on  the overall
performance of the DARAMEND™  Bioremediation  Technol-
ogy on the treatment of PCP.

4.5 Process  Residuals
  The DARAMEND™  Bioremediation Technology demon-
stration generated limited  residuals. The  primary gener-
ated waste during the SITE demonstration was oversized
particles in the form of wood debris, stone, and construc-
tion material that was removed from the targeted test soils
prior  to bioremediation treatment  by a mechanical sieve.
These residual  soils lacked  heavy  metals and carcinogenic
dioxin compounds. No leachate was generated as a  result
of the technology's irrigation  process. However, as a re-
sult  of sampling  and  maintenance/monitoring activities,
used  personal  protection equipment (PPE) and  contami-
nated water from decontamination  activities were gener-
ated.
                                                        54

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Table 4-9.    Soil Particle Size Distribution Data
Non-Treatment Composite (NTC):
Fraction
(Finer)
Fine Sand
Medium Sand
Coarse Sand
Fine Gravel
(Coarser)
9/93
Pre-Demo
-12%
-7%
-10%
-10%
-10%
-50%
10/93
Event 0
-22%
-13%
-15%
-10%
-5%
-32%
Events:
"Pre to 0"
Difference
+IO%
+6%
+5%
—
-5%
-18%
10/94
Event 3
-21%
-13%
-18%
-15%
-8%
-22%
Events:
"0 to 3"
Difference
-1%
—
+3%
+5%
+3%
-10%
The amount of gravel decreased 23% between the pre-demo sampling and Event 0. The NTC sample showed an 11 % increase in the sand
fractions between the pre-demo sampling and Event 0, and an 8% increase over the course of the demonstration.  The amount of finer particles
increased by about 10% before the demonstration, and decreased by about 1% between Event 0 and Event 3.

Treatment Plot Composite (TPC):
Fraction
(Finer)
Fine Sand
Medium Sand
Coarse Sand
Fine Gravel
(Coarser)
9/93
Pre-Demo
-13%
-8%
-10%
-8%
-10%
-51%
10/93
Event 0
-15%
-10%
-15%
-11%
-8%
-40%
Events:
"Pre to 0"
Difference
+2%
+2%
+5%
+3%
-2%
-11%
10/94
Event 3
-25%
-15%
-20%
-15%
-8%
-15%
Events:
"0 to 3"
Difference
+10%
+5%
+5%
+4%
—
-25%
Gravel decreased 13% between the predemo and Event 0, and decreased 25% during the demonstration. The TPC sample showed a 10% total
increase in the sand fractions between the pre-demo sampling and Event 0, and a 14% increase over the course of the demonstration. The amount
of finer particles also increased, by about 2% before the demonstration, and by about 10% during demonstraction activities.
                                                                55

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                                                Section 5
                                Other  Technology  Requirements
  Volatile components generated from the site  may in-
crease with bioremediation as a result of soil  tillage. How-
ever, previous studies by the developer have indicated that
these increased levels are below permissible exposure lim-
its, and organic vapor analyzers used to monitor the breath-
ing zone in the treatment plot never indicated the pres-
ence of airborne VOCs.

5.1  Environmental  Regulation
Requirements
  Federal, state and local regulatory agencies may estab-
lish cleanup standards for the remediation and  may re-
quire permits to be obtained prior to implementing the
GRACE  Bioremediation Technologies DARAMEND™
Bioremediation Technology.  Most federal permits will be
issued by the authorized state agency.  Federal and state
requirements  may  include  obtaining a  hazardous waste
treatment  permit or modifying an  existing  permit regulat-
ing these  activities  on  a given site. A permit would be re-
quired for storage of contaminated soil in a waste pile for
any length of time and for storage in  drums  onsite  for more
than 90 days. Air emission permits will probably not be
required since VOCs are generally not a problem  at these
types of sites. Local agencies may have  permitting require-
ments for construction activities (e.g., excavation and
greenhouse),  land treatment, and  health and safety.

  Section 2 of this report discusses the environmental regu-
lations that apply to this technology. Table 2-I presents  a
summary of the federal and state ARARs for the  GRACE
Bioremediation Technologies DARAMEND™ Bioremediation
Technology.

5.2  Personnel  Issues
  For site preparation  and pretreatment operations (exca-
vation, screening, mixing, amending, and  homogenizing),
the number of workers required is a function of the volume
of soil to be remediated. During the demonstration, these
tasks were contracted  out and generally required 2-4
people using  heavy earth-moving equipment working 12-
hr days.  If multiple treatment cycles are used, additional
labor will be required to replace the treated soil with con-
taminated soil for the next treatment cycle. Since  this was
not done  during the demonstration, the amount  of labor
required is estimated to be  similar to that required for the
pre-treatment activities. Once set up  and "running,"  the
process is not labor-intensive.  Two people working a stan-
dard 40-hr week can till the plot once a week and irrigate it
as necessary, take daily moisture and temperature read-
ings, sample  to determine the progress of bioremediation,
maintain the facility and equipment, and keep the leachate
collection system  and treatment train operational.

  Health and safety issues for personnel are generally the
same as those for all  hazardous waste treatment facilities.
That is, they must have completed  the  OSHA-mandated
40-hr training course for hazardous  waste work, have an
up-to-date refresher certification, and  be enrolled in a medi-
cal surveillance program to ensure that they are fit to  per-
form their duties and to detect any symptoms of exposure
to hazardous materials.

  Emergency response training is the same as the gen-
eral training  required for  operation  of a treatment,  storage,
and disposal (TSD) facility. Training  must address fire-re-
lated  issues such as extinguisher  operation, hoses, sprin-
klers,  hydrants, smoke detectors, and alarm systems. Train-
ing  must also address contaminant-related issues  such as
hazardous material spill control and decontamination  equip-
ment use.  Other issues  include self-contained  breathing
apparatus  use,  evacuation, emergency response planning,
and coordination with  outside emergency personnel (e.g.,
fire/ambulance).

  For most sites, PPE for workers  will include gloves, hard
hats,  steel-toed boots, goggles, and Tyvek®. Depending
on contaminant types and concentrations, additional PPE
may be required.  Noise levels should be monitored during
site preparation and pretreatment  activities to  ensure  that
workers are  not exposed to noise  levels above a time-
weighted average  of 85 decibels, over an  8-hour day. Noise
levels  above this limit will require workers to wear addi-
tional hearing protection.

5.3  Community Acceptance
  Potential hazards to the community include  exposure to
particulate matter released to the  air during site prepara-
tion and pretreatment activities. Air emissions can  be mini-
mized by watering down the soils  prior to excavation  and
handling,  or by conducting  operations  in an enclosure.
                                                       56

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Using multiple treatment cycles  may also mitigate com-
munity exposure  concerns. Depending on the scale of the
project,  the GRACE  Bioremediation Technologies
DARAMEND™ Bioremediation Technology may require
contaminated soils to remain in the treatment plot for ex-
tended periods of time. This is not expected to expose the
community to any airborne particulate  matter,  because  the
process requires  that the soil moisture content  be main-
tained within a specific  range for amendment to be effec-
tive.
  Noise may be a factor to neighborhoods in the immedi-
ate vicinity of treatment. Noise levels may be elevated
during  site preparation and  pretreatment activities since
heavy earth-moving equipment will be  used. Although this
is  a relatively short period of time in relation to the total
treatment time frame, multiple treatment cycles will make
this a recurring  problem. During actual  treatment, however,
there will be no noise  except for that  associated with till-
age.
                                                       57

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                                               Section 6
                                         Technology  Status
  This section discusses the experience of the developer
in applying  the  GRACE Bioremediation Technologies
DARAMEND™ Bioremediation Technology. It also exam-
ines the capability of the developer in using this technol-
ogy at sites with  different volumes of contaminated soil.

6.1  Previous  Experience
  The  effectiveness  of a number of soil amendments for
enhancing bioremediation  of soils contaminated with high
concentrations of CPs and  PAHs (major components of
creosote) was evaluated at  bench- and  pilot-scale.

  Bench-scale research  on eight different soil samples
collected  from wood treatment sites  located  throughout
Canada showed that the  strongest positive effect on
bioremediation was  obtained by  addition of solid-phase,
organic soil  amendments prepared to a specific nutrient
content and PSD. Treatment of  soil with such amendments
facilitated establishment of active populations of PCP-de-
grading bacteria in soils with PCP concentrations as high
as 2170 mg/kg. Residual PCP  concentrations of 0.7 to  8
mg/kg were attained. Other bench-scale work indicated
that the same organic soil  amendments can be used to
enhance microbial decomposition of PAHs and petroleum
hydrocarbons. Significant reductions in soil toxicity was also
observed. Positive results in  the bench-scale investigations
led  to both in situ  and ex situ pilot-scale  demonstrations of
the  technology.

  The pilot-scale demonstration was  performed at the
Domtar Wood Preserving site where several decades of
wood treatment had resulted in deposition of CPs at con-
centrations of 680 mg/kg and total PAH  concentrations of
more than 1400  mg/kg. The soil was a fine sandy loam
(72.3% sand, 23.5% silt, and 4.2% clay) with a pH of 7.4
and an organic carbon content of  1.8%.  Both  /ns/fuand ex
situ treatment plots  showed dramatic reductions in  total
PAHs  using only  the  proprietary organic amendment and
tillage.  The in situ concentations were reduced from 15,670
to 3870 mg/kg (73%) after 149 days while the ex situ con-
centrations were  reduced from 1485 to 35  mg/kg (98%)
after 207 days. The ex situ plot  also showed  reductions in
PCP and TPH concentrations of 99% (from 680 to 6  mg/
kg for PCP and from 6325 to 34 mg/kg for TPH).
  Bench-scale tests of this technology on sediments con-
taminated with PAHs have also been encouraging enough
that ex situ pilot-scale testing has started and the results
are pending.

6.2  Scaling Capabilities
  The  Domtar Wood Preserving  site represents the first
full-scale application of the GRACE Bioremediation Tech-
nologies DARAMEND™ Bioremediation  Technology. The
SITE demonstration was conducted in conjunction with the
full-scale remediation to determine its cost-effectiveness
and applicability to other soils and contaminants.

  The DARAMEND™ technology has  successfully
remediated 1,500 tons of soil ex-s/fuand  3,500 tons  of soil
in-situ (2 ft. of near-surface soil) at the former Domtar Wood
Preserving Facility. The remediated soil  met clean-up cri-
teria set by the Canadian Council of Ministers of the Envi-
ronment, including a  5 mg/kg  criterion for pentachlorophe-
nol. In 1995, full-scale treatment of a second 1,500 ton
batch of soil  was initiated at the site.

  In the United States during 1996, the DARAMEND™
technology was successfully applied at full-scale at a  former
wood perserving  site in Minnesota. Late in 1996 a large-
scale field treatability demonstration was initiated in asso-
ciation with remedial actions  at  the Montana Pole
Superfund site in Butte, Montana.  Commencement of a
full-scale project is planned for the summer of 1997 in
Washington  State.

  Key  developmental work on the technology is focusing
on improving kinetics and expanding applicability with  re-
spect to contaminant type. The range of contaminants ef-
fectively dealt with  by the DARAMEND™ technology  has
now been  expanded to  include phthalates. Concentrations
of phthalates have been rapidly reduced from thousands
toeass then  100 mg/kg during bench-scale studies and
pilot-scale  work at a  site in New Jersey in  1996. For ex-
ample, total  phthalates were reduced from 7,710 mg/kg to
47 mg/kg in soil,  exhibiting a greater then 99% removal
efficiency.

  In addition, a second generation DARAMEND™ tech-
nology has  been developed  by  GRACE  Bioremediation
                                                      58

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  Appendix A
Vendor's Claims
       59

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Technologies.  The new technology rapidly reduces con-
centrations of organochlorine  pesticides  (e.g., DDT  and
Toxaphene™} and organic explosives (e.g., TNT, RDX and
HMX)  in soil.  For example, p,p-DDT,  an organochlorine
pesticide, was reduced from  684 mg/kg to 1.9  mg/kg in
soil and 2,4,6-trinitrotoluene (TNT), an  organic explosive,
was reduced from 7,200  mg/kg to 19 mg/kg in soil, exhib-
iting a  greater then 99% removal efficiency in  both cases.
Extensive laboratory testing has been completed. Pilot-
scale pesticide projects commenced in 1996 in  South Caro-
lina and Ontario, Canada and  will continue in  1997. A pi-
lot-scale project to demonstrate remediation of explosives-
contaminated soil is expected  to commence in 1997.

A.1 Introduction
  Bioremediation  has  many advantages  as  a treatment
technology for soils containing elevated concentrations of
organic contaminants. Among  the  advantages:

  . It can provide a final solution  through complete de-
    struction of the contaminants,  thereby ending  liability
    of  the site owner.

  . It is often the most cost-effective remedial option

  . It is perceived  by the public to be  a  natural, environ-
    mentally  friendly  technology, hence,  generally faces
    fewer  objections from stake holders, and therefore, can
    be more rapidly implemented.

  . It has  lower capital costs than  other remedial options.

  . It is well suited to situations in which the site owner
    prefers to spread site remediation  costs over a num-
    ber of years.

  In contrast to these  advantages traditional bioremediation
has always  had significant  disadvantages in that:

  . It has  acquired a  reputation for being unreliable.

  . It is frequently  unable to reduce concentrations of tar-
    get compounds to the  remediation criteria.

  . It is only effective in  soils  with low to moderate con-
    centrations of acutely toxic  contaminants, such as PCP.

  As a result of these advantages and disadvantages
bioremediation  has been  implemented  frequently, but has
often been unsuccessful  in attaining remediation criteria,
particularly for highly toxic and refractory compounds such
as CPs (CPs) and  high molecular weight PAHs.

A.2 DARAMEND™ Bioremediation
  In 1988,  under sponsorship of the  government of
Canada, GRACE  Bioremediation  Technologies initiated re-
search aimed  at development  of a reliable technology for
bioremediation  of  wood preserving soils  that contain el-
evated levels of CPs and  PAHs. It was determined  that
less than  one-third of the 10 soils  studied could  be effec-
tively  bioremediated by existing protocols based upon  irri-
gation, tillage,  and  addition  of  nutrients.  Additionally,  the
research revealed that the primary factor limiting  biodeg-
radation of PCP and PAHs in the hard-to-remediate soils
was the  number of microsites  with environmental condi-
tions  supportive of vigorous microbiological activity (i.e.,
biologically active microsites with sufficient available wa-
ter, dissolved oxygen, nutrients  and  surfaces for microbial
adhesion). Continued  research, focused on improving  the
number and  quality of microbially active microsites, lead
to development of a bioremediation technology based on
incorporation  of insoluble organic soil'amendments engi-
neered to  provide a  large number of water-filled micropores
with physical  and chemical conditions  conducive to micro-
biological growth.  The organic soil amendments are manu-
factured from naturally occurring materials and are added
to the soil at  rates of 0.25 to 5% by weight. The physical/
chemical properties of the organic soil amendments (e.g.,
particle size and  shape,  nutrient content, nutrient release
kinetics)  and the optimal  application rate are  highly  soil-
specific. The  bioremediation  technology is the  subject of a
patent application filed on behalf of Environment Canada,
and GRACE Bioremediation Technologies has  acquired
the exclusive world-wide  license for its commercial utiliza-
tion. Currently, the technology is available throughout North
America  under the  tradename  DARAMEND™.

   In  1991-1 992,  a  pilot-scale demonstration  of the tech-
nology was conducted at an  industrial wood-preserving site,
owned by Domtar Inc, in Trenton, Ontario, Canada.  The
demonstration included ex situ  treatment of 10 tonnes of
soil in 1991, and 100 tonnes of soil in 1992.  The soils con-
tained PCP and PAHs  at initial  concentrations of  approxi-
mately 700 mg/kg and 1,500 mg/kg, respectively.  In both
demonstrations,  reductions of 98-99% and 9597% in  the
total  concentrations of CPs and PAHs,  respectively, were
attained.

   In 1993 and 1994, a full-scale demonstration  of the tech-
nology was successfully completed at the same site. Dur-
ing the full-scale demonstration more  than 4,000 tonnes
of soil was remediated to below the required criteria (i.e.,
TCPs to less  than 5 mg/kg; carcinogenic PAH compounds
to less than 10 mglkg).

   In 1993, DARAMEND bioremediation was applied to silty-
clay sediment dredged from an industrial harbour  on Lake
Ontario.  During  the 150  tonne pilot-scale  demonstration
the sediment PAH  concentration was  reduced from more
than  1,200 mg/kg to less than 100 mglkg  concentration.

    DARAMEND has  recently  been implemented  using  a
biopile system at sites where available space is limited.

   In  1995, modifications  of the DARAMEND technology
were implemented at industrial sites in the United States
where soils are contaminated  with  phthalates and orga-
nochlorine pesticides (e.g., DDT,  chlordane,  toxaphene,
dieldrin). At other sites, soils containing herbicides includ-
ing 2,4-D and 2,4,5-T are being remediated.
                                                        60

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  A United States patent No.  5,411,664 covering  aspects
of the technology was issued in May of 1995.

  The major components of the technology are:

  . DARAMEND organic soil amendments that are engi-
    neered to have soil-specific properties and are  applied
    at rates determined  during bench-scale op-timization
    studies conducted on the soil to be remediated.

  . A rapid, low-cost process  monitoring  procedure that
    utilizes bench-scale  microcosms and radio-labelled
    analogues of the target compounds to rapidly  provide
    data on biodegradation of the target compound(s).

  . Specialized deep-tillage and soil mixing equipment,

  . Knowledge and experience provided by GRACE
    Bioremediation Technologies' bioremediation  person-
    nel.

  In contrast to traditional  bioremediation the DARAMEND
technology provides the following advantages:

  . Increased  reliability,  which is achieved  by engineer-
    ing the DARAMEND organic soil amendments and
    designing other treatment conditions  on a soil  specific
    basis.

  . Reduced analytical costs since standard analytical
    techniques utilized in process monitoring are replaced
    with radioisotope  microcosm studies  conducted  in par-
    allel with each field  bioremediation project.

  . Lower operation and maintenance costs, because
    application of soil amendment is only performed once
    at the initiation of treatment,  tillage is performed less
    frequently, and remediation criteria are attained more
    rapidly.

  . Ability to bioremediate soils with higher initial con-
    centrations of toxic contaminants and more con-
    sistently attain  low residual  concentrations  of refrac-
    tory contaminants such as carcinogenic PAHs and PCP

  . Reduction or elimination of soil toxicity.

  . Greater treatment depth in landfarming operations (i.e.,
    a full two feet), due to utilization of specialized tillage
    equipment.

  . Capacity to effectively  bioremediate  soils with high clay
    content,  due to the ability of  the soil amendments and
    tillage equipment to favourably alter soil structure.

  . Ability to bioremediate sediments without dewatering,
    due to the  highly adsorptive nature  of the DARAMEND
    soil amendments.

  . Reduced evolution of VOCs and  odours due to the
    adsorptive  properties  of the  organic amendments.

A.3 Summary
  DARAMEND  is  an  innovative,  cost-effective
bioremediation technology.  Its  effectiveness has  been
proven at pilot-scale and full-scale at several sites in  North
America. The advantages of DARAMEND technology are
most apparent, and valuable,  when the  soil or sediment to
be  remediated:

  . contains highly refractory contaminants such as  carci-
    nogenic PAHs;

  . contains high  concentrations of  acutely toxic con-
    taminants such as PCP;

  . has high clay content, or

  . is subject to stringent remediation  criteria.

  GRACE  Bioremediation Technologies' DARAMEND
bioremediation technology is  now available to  site  own-
ers, consulting and  engineering companies throughout
North America and Europe.
                                                      61

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   DARAMEND™ Bioremediation of Soils Containing
Chlorophenols and Polynuclear Aromatic Hydrocarbons
               (Full-Scale  Demonstration)
                       Final  Report
                         Prepared by

                GRACE Bioremediation Technologies
                          formerly
                  Environmental Engineering Group
                      Grace Dearborn, Inc.
                 SSC File No.: 035SS.KA168-2-1222
                     DEEG File No.: UIO-821
                          June 1994
                              62

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Executive  Summary

Dammend™ Bioremediation of Soils Containing
Chlorophenols and Polynuclear Aromatic
Hydrocabons  (Full-Scale Demonstration)
  Remediation of soils containing chlorophenols  and creo-
sote at wood  preserving sites is of particular importance in
Canada due to the large number of such  sites.
Bioremediation can be advantageous to landowners since
it is based upon microbial biodegradation of the target com-
pounds and can  therefore  eliminate future liability. In addi-
tion, it is one of the  most cost-effective remedial options.

  Daramend™ bioremediation was  developed under the
sponsorship  of,  and  is owned by,  the Government of
Canada.  GRACE Dearborn Inc.  has acquired the  licence
for worldwide application of this technology that  has been
successfully applied at bench- and pilot-scale to  remediate
soils containing chlorophenols (CPs) and polynuclear aro-
matic hydrocarbons (PAHs). Daramend  bioremediation
technology involves  the application  of solid-phase,  biode-
gradable, organic soil amendments of specific particle-size
distribution, nutrient  content  and nutrient-release kinetics
to soils at rates determined by bench-scale  optimization
experiments.  The specific  application  rates and composi-
tion of Daramend products are considered to be  propri-
etary information. The application rates typically range from
0.5 to 5% (w/w).

  This  report describes a demonstration  of full-scale,  in
situ and ex situ, Daramend  bioremediation at the  former
Domtar Inc. Wood Preserving site in Trenton, Ontario.

  During the  in situ  demonstration,  approximately   3,500
tonnes of soil in  a 4,800 m2 area were treated. The 4,800
m2 area was divided into 49 separate sampling areas of
approximately 100 m2 each.  In  these sampling areas, ini-
tial total CP concentrations ranged from 0.92  mg/kg  to 27.8
mg/kg  and total PAH concentrations ranged from 8.7 mg/
kg to 662 mg/kg. The results  indicated that, during 305
days of treatment, which  included a period of 136 days
when the soil was frozen or soil temperatures were not
conducive to microbial activity (<5°C), CP concentrations
in all 49  sampling areas were reduced to below the Cana-
dian Council of Ministers of the Environment (CCME, 1991)
remediation  criteria  for industrial soils  (5  mglkg  for each
listed CP). During the same time period the concentra-
tions of all nine CCME listed PAHs were reduced to below
the CCME remediation criteria for industrial soils in  all but
3 of the 49 sampling areas. In  these 3 sampling  areas,
concentrations of two of the more recalcitrant higher mo-
lecular  weight  PAHs,   benzo(b)fluoranthene  and
benzo(a)pyrene  remained  above the CCME remediation
criteria (10 mg/kg) at concentrations ranging from 12 to
17 mglkg.
  During the ex situ demonstration, approximately  1,500
tonnes of soil were treated using Daramend  bioremediation
in two fully  contained treatment cells, designated Treat-
ment Cell 1  and Treatment Cell 2.

  In Treatment Cell 1, the  mean total CP concentration
was reduced by 91% (from 157 to 14 mglkg) after 282
days of Daramend treatment. The CCME  criteria for in-
dustrial soils was reached  for all listed CPs  except pen-
tachlorophenol  (PCP). The  mean concentration of PCP,
the predominant species, remained above the CCME cri-
teria (5 mg/kg) at 12.7 mg/kg. The mean total PAH con-
centration in Treatment Cell 1 was reduced by 67% (from
439 to 44 mg/kg) after 282 days of treatment. The CCME
criteria for industrial soils were reached for 7 of the 9 listed
PAHs. Concentrations of two  of the more recalcitrant higher
molecular weight  PAHs,  benzo(b)fluoranthene  (16.3  mg/
kg) and benzo(a)pyrene (10.6 mg/kg) remained above the
CCME remediation criteria for industrial soil (10 mg/kg).

  In Treatment Cell 2, the  mean total  CP concentration
was reduced by 98% (from 102 to 2 mg/kg)  after 175 days
of Daramend treatment. The CCME criteria  for industrial
soils were reached for all  listed  CPs (5 mg/kg for each
listed CP). The mean total PAH concentration  in Treatment
Cell 2 was reduced by 87% (from 619 to 79  mg/kg) after
251  days of Daramend treatment. The CCME  criteria for
industrial soils were reached for all listed  PAHs.

  The number of treatment days cited for Treatment Cells
1 and 2 include a period of 55 days when the soil was
frozen or soil temperatures  were not conducive to micro-
bial activity (<5°C).

  Microbiological  monitoring indicated that Daramend
bioremediation  did not increase the number or alter the
identity of bacteria being transported offsite  by air, surface
run-off water or soil transport vectors.  Laboratory micro-
cosms containing  soil  collected from ex situ Treatment Cell
1 supported extensive mineralization of added 14C-PCP,
thereby verifying that the observed reductions  in PCP con-
centration were due to biodegradation.

  Scale-up of the technology from pilot- to full-scale
requried a  number of modifications in procedures and
equipment.  For the in situ portion of the demonstration,
the  main  technical issue was development of a  protocol
for efficiently removing large subsurface debris that  hin-
dered incorporation of soil  amendments and subsequent
soil tillage. For the ex situ portion of the demonstration,
the main technical  issue was modification of irrigation pro-
tocols to allow efficient irrigation  of soil during treatment.
Details on these and other technical issues  and their  reso-
lution along  with the estimated cost of applying the tech-
nology at commercial  scale are presented in  this  report.
                                                      63

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In situ/On-Site Bioremediation of Soils Containing
             Chlorinated Phenols  and
       Polynuclear Aromatic Hydrocarbons
                    Final Report
                       Prepared by
              GRACE Bioremediation Technologies
                        formerly
               Environmental/Engineering  Group
                   GRACE Dearborn, Inc.
              SSC File No.: 035SS.KE 144-1-2324
                  DEEG File No.:
                        May 1994
                            64

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Executive  Summary

In  situ/On-Site Bioremediation  of Soils
Containing  Chlorinated Phenols and
Polynuclear Aromatic Hydrocarbons
  Remediation of soils impacted with toxic organic com-
pounds is an issue of increasing concern  to society through-
out North America and the world. Remediation of soils con-
taining CPs  and creosote at wood preserving  sites is of
particular importance in Canada due to the  large number
of such sites.

  Processes that can be used for remediation of soils con-
taminated with organic  wood  preservatives include  soil
washing,  incineration,  landfilling, and bioremediation.
Bioremediation, can  be advantageous  to landowners since
it is based upon microbial biodegradation of the target com-
pounds and  can therefore eliminate future liability. In addi-
tion, it is one of the most cost-effective  remedial options.

  Variables  that can affect the  biodegradation of organic
pollutants, and hence the effectiveness  of bioremediation,
include the structure, reactivity and concentration(s)  of the
target compounds, their interaction with  other compounds
present in the soil, and  the physical, chemical,  and bio-
logical characteristics of the soil.

  Daramend™ bioremediation was developed under the
sponsorship of, and is  owned by, the Government  of
Canada. GRACE Dearborn Inc.  has  acquired  the  licence
for worldwide application of this technology that has been
successfully used at bench-scale to remediate soils con-
taining CPs and pPAHs.  Daramend™ bioremediation in-
volves the addition  of solid-phase, particulate organic soil
amendments to soils at rates determined by bench-scale
optimization experiments. The PSD,  nutrient content and
nutrient-release kinetics of Daramend  soil amendments are
specific to the soil being treated. The  application rates and
composition of Daramend  products are considered to be
proprietary information until patent protection is granted.

   This report describes a pilot-scale  demonstration  of
 Daramend  bioremediation  at the Domtar Inc. wood pre-
serving site  in Trenton,  Ontario.

   Over the course  of two years (1991-1 992),  soil was
treated under  a variety of conditions with Daramend™. Two
 in  situ demonstrations,  and two ex situ (on-site) demon-
strations were conducted. During  the 1991 ex situdemon-
 stration,  the mean total chlorophenol  concentration  in a
treatment area containing 10 tonnes of soil, was reduced
 from 702 mg/kg to less  than the criterion established  by
the Canadian Council of Ministers of the  Environment
 (CCME) for industrial soil (5 mg/kg) in 345 days. In the
 same demonstration, the  mean total  PAH  concentration
was  reduced  from  1442 mg/kg to 35 mg/kg,  and the con-
 centrations  of all PAH isomers  were  reduced to less than
 the CCME  criteria for industrial soil.
  Similar reductions in  CP and  PAH concentrations were
obtained during the  1992 ex situ demonstration,  in which
100 tonnes of soil were treated.

  The first (1991) in situ demonstration was conducted to
enable comparison  between  treatment with a variety of
Daramend  products, and  controls. Reductions  in chlori-
nated phenol  concentrations  were observed  in all treat-
ments; however, of those that  produced statistically  sig-
nificant reductions,  only Daramend bioremediation reduced
total  chlorinated phenol  concentrations to  below the CCME
remediation  criterion for industrial  soils (5  mg/kg).

  A second  in situ demonstration,  conducted in  1992, fo-
cused on  bioremediation  of soil with very  high PAH con-
centrations (ca. 20,000 mg/kg).  Soil undergoing Daramend
treatment  supported greater biodegradation of PAHs than
the tilled control (79% vs. 48%).  Due to high initial concen-
trations, and the short duration of the demonstration  the
PAH concentrations remained above the CCME criteria.

   Radioisotope (14C) microcosm studies were performed
in the laboratory using soil collected  from the  treatment
areas. The  studies  indicated  that  14C-labelled compounds
added to  the  soils  (anthracene, pentachlorophenol) were
extensively  biodegraded as evidenced by substantial  evo-
lution of 14C02, which is the main end product of microbial
metabolism.

   Standard  toxicological  tests,  including earthworm mor-
tality and seed germination, were  performed on soil taken
from the treated area  and the  control area after comple-
tion  of the  1991 ex situ demonstration. The tests indicated
that  Daramend treatment had  reduced  or eliminated the
soil's toxicity.  Earthworms  exposed to soil from the control
area died in four days (100%  mortality),  while all earth-
worms exposed to the Daramend-bioremediated soil  sur-
vived for the full 28 days of the  assay (0%  mortality). Simi-
 lar reductions in toxicity of the  treated soil were revealed
 by seed germination assays. For example oat seeds added
to the untreated control soil failed  to germinate (0% germi-
 nation)  while  in the Daramend-bioremediated soil 93% of
the  oat seeds germinated. In an agricultural soil with no
 history of contamination,  oats germinated at the  same  rate
 (93%) as in the bioremediated  soil.

   A full-scale demonstration  of Daramend bioremediation
was initiated, at the same site, in  1993. The ex situ portion
 of the demonstration is being audited by the EPA's SITE
 Program.

   GRACE  Bioremediation Technologies is in the process
 of commercializing Daramend bioremediation. Commer-
 cialization is proceeding successfully, with the creation of
 four full-time and four part-time positions. We have re-
 sponded to commercial  tenders for work on five sites in
 Canada, and  two in the U.S. We  are presently conducting
 commercial pilot-scale  bioremediation at three sites in
 Canada.
                                                        65
                                                                          ftU.S. GOVETOWEHT PRINTnC OFFICE: 1997-551-420

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