&EPA
          United States
          Environmental Protection
          Agency
            Office of Research and
            Development
            Washington DC 20460
EPA/540/R-96/502
September 1998
General Environmental
Corporation

CURE Electrocoagulation
Technology

Innovative Technology
Evaluation Report

                SUPERFUND INNOVATIVE
                TECHNOLOGY EVALUATION

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                                 EPA/540/R-96/502
                                  September 1998
    General Environmental
           Corporation


   CURE Electrocoagulation
           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 by the U. S. Environmental Protection Agency (EPA) under Contract No.
68-CS-0037 to Tetra Tech EM Inc. (formerly PRC Environmental Management, Inc.).  It has been subjected to the Agency's
peer and administrative reviews and has been approved for publication as an EPA document.  Mention of trade names or
commercial products does not constitute an endorsement or recommendation for use.

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

The National  Risk Management Research Laboratory  is  the Agency's center for investigation of technological and
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 groundwater; and prevention and
control of indoor ah- pollution. The goal of this research effort is to catalyze development and implementation of innovative,
cost-effective environmental technologies; develop scientific and  engineering information  needed by  EPA  to  support
regulatory and policy decisions; and provide technical support and information transfer to ensure effective implementation of
environmental regulations and strategies.

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

                                                       National Risk Management Research Laboratory

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                                                 Abstract
The CURE electrocoagulation system was evaluated for removal of low levels of the radionuclides uranium, plutonium, and
americium  as well as other contaminants in wastewater.   Economic  data from  the Superfund Innovative Technology
Evaluation  (SITE) demonstration are also presented, and the technology is compared to the nine  criteria that the U.  S.
Environmental Protection Agency (EPA) uses to select remedial alternatives for Superfund sites.

The CURE electrocoagulation technology was developed by General Environmental Corporation, Inc. (GEC), of Denver,
Colorado. The technology induces the coagulation and precipitation of contaminants by a direct-current electrolytic process
followed by settling with or without the addition of coagulation-inducing chemicals.  Treated water  is discharged from the
system for reuse, disposal, or reinjection. Concentrated contaminants in the form of sludge are placed in drums for disposal
or reclamation.

The CURE technology was demonstrated under the SITE Program at the U.S. Department of Energy's (DOE) Rocky Hats
Environmental Technology Site (formerly the Rocky Flats Plant) near Golden, Colorado.  Approximately 4,500 gallons  of
wastewater containing low levels  of the radionuclides  uranium, plutonium, and americium were  treated in August and
September 1995. Water from the solar evaporation ponds was used in the demonstration. Six preruns, five optimization runs,
and four demonstration runs were conducted over a 54-day period.

The demonstration runs lasted 5.5 to 6 hours each, operating the CURE system at approximately 3 gallons per minute.  Filling
the clarifier took approximately 2.5 hours of this time. Once the clarifier was filled, untreated influent, and effluent from the
clarifier were collected every 20 minutes for 3 hours. Because of the shortened run times, there is uncertainty whether the data
represent long-term operating conditions.

Results indicated that removal efficiencies for the four runs ranged from 32 to 52 percent for uranium, 63 to 99 percent for
plutonium, and 69 to 99 percent for americium. Colorado Water Quality Control Commission (CWQCC) standards were met
for plutonium and americium in some, but not all cases. However, CWQCC standards for uranium were not met. Arsenic and
calcium concentrations were also decreased by an average of 74 and 50 percent, respectively for the two runs for which metals
were measured.

Evaluation  of the CURE electrocoagulation technology against the nine criteria used by the EPA  in evaluating potential
remediation alternatives indicates that the CURE system provides both long- and short-term protection of the environment,
reduces contaminant mobility and volume, and presents few risks to the community or the environment.

Potential sites for applying this technology include Superfund, DOE, U.S. Department of Defense, and other hazardous waste
sites where water is contaminated with radionuclides or metals.  Economic analysis indicates that remediation cost for a 100-
gallon-per-minute CURE system could range from about $0.003  to $0.009 per gallon, depending  on the duration of the
remedial action.
                                                       iv

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                                        Contents
List of Figures and Tables	viii
Acronyms, Abbreviations, and Symbols	ix
Conversion Factors	xi
Acknowledgments	xii
Executive Summary	1
1   Introduction	3
    1.1  Background	3
    1.2  Brief Description of the SITE Program and Reports	3
    1.3  Purpose of the Innovative Technology Evaluation Report	 4
    1.4  Technology Description	4
        1.4.1    Theory of Coagulation	;	5
        1.4.2    Theory of Electrocoagulation	5
        1.4.3    System Components and Function	6
    1.5  Key Contacts	8
2   Technology Applications Analysis	 9
    2.1  Key Features of the CURE Electrocoagulation Technology	9
    2.2  Technology Performance	9
        2.2.1    Historical Performance	9
        2.2.2    Bench-Scale Study Results	10
        2.2.3    SITE Demonstration Results	10
    2.3  Evaluation of Technology Against RI/FS Criteria	11
    2.4  Factors Influencing Performance	11
        2.4.1    Influent Water Chemistry	11
        2.4.2   Operating Parameters	11
        2.4.3    Maintenance of Equipment	11
    2.5  Applicable Wastes	,	11
    2.6  Site Requirements	11
    2.7  Materials Handling Requirements	14
    2.8  Personnel Requirements	14
    2.9  Potential Community Exposures	14
    2.10 Potential Regulatory Requirements	 15

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                               Contents (continued)

        2.10.1  Comprehensive Environmental Response, Compensation, and Liability Act	15
        2.10.2  Resource Conservation and Recovery Act	;..'.....	17
        2.10.3  Safe Drinking Water Act	.;	17
        2.10.4  Clean Water Act	17
        2.10.5  Occupational Safety and Health Administration	18
        2.10.6  Radioactive Waste Regulations	18
        2.10.7  Mixed Waste Regulations	18
    2.11 Availability, Adaptability, and Mobility of Equipment	18
    2.12 Limitations of the Technology	19
3   Economic Analysis	20
    3.1  Basis of Economic Analysis	20
    3.2  Cost Categories	22
        3.2.1   Site Preparation Costs	22
        3.2.2   Permitting and Regulatory Costs	22
        3.2.3   Capital Equipment	23
        3.2.4   Startup	23
        3.2.5   Demobilization	23
        3.2.6   Labor	,	23
        3.2.7   Consumables and Supplies	24
        3.2.8   Utilities	24
        3.2.9   Effluent Treatment and Disposal	24
        3.2.10  Residual Waste Shipping and Handling	24
        3.2.11  Analytical Services	24
        3.2.12  Maintenance and Modifications	25
4   Treament Effectiveness	26
    4.1  Background	26
    4.2  Review of SITE Demonstration	26
        4.2.1   Site Preparation	26
        4.2.2   Technology Demonstration	26
        4.2.3   Site Demobilization	28
    4.3  Demonstration Methodology	28
        4.3.1   Testing Approach	29
        4.3.2   Sampling and Analysis and Measurement Procedures	31
        4.3.3   Operational and Sampling Problems and Variations from the Work Plan	31
    4.4  Review of Demonstration Results	32
        4.4.1   Summary of Results for Optimization Runs	32
                                              vi

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                             Contents (continued)
       4.4.2    Summary of Results for Critical Parameters	33
       4.4.3    Summary of Results for Noncritical Parameters	35
    4.5 Conclusions	40
5   Technology Status	41
6   References	42
Appendix
    A  Vendor Claims for the Technology
    B  Case Studies
                                           vii

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                                        Figures
1-1    CUKE Schematic Diagram	7
4-1    Site Location Map	27
4-2    CURE Schematic Diagram and Sampling Locations	30

                                        Tables


2-1    Evaluation of Nine Criteria Used in the Feasibility Study	12
2-2    Metals and Water Quality Parameters for RFETS Solar Evaporation Pond Water and
       Corresponding Treaztment Standards	13
2-3    Federal and State ARARs for the CURE System	16
3-1    Costs Associated with the CURE System	21
4-1    Radionuclide Concentrations in Wastewater	34
4-2    Radionuclide Content in Dewatered Sludge	35
4-3    Metal Content in Dewatered Sludge	36
4-4    Metals Concntration in Wastewater	37
4-5    Field Parameter Measurements	38
4-6    Radionuclide Concentration in TCLP Leachate	39
                                             viii

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          Acronyms, Abbreviations, and Symbols
A/B decant water
AEA
ARAR
ATTIC
BOD
C
CDPHE
CERCLA
CERI
CFR
CRE
CWA
CWQCC
DOE
Eh
EPA
GEC
gpm
HSWA
ITER
kWh
LANL
LLRW
Lpm
MCL
mg/kg
mg/L
mS
mS/cm
MS/MSD
Ampere
Water removed from A and B solar pond sludge
Atomic Energy Act
Applicable or relevant and appropriate requirements
Alternative Treatment Technology Information Center
Biological oxygen demand
Degrees Celsius
Colorado Department of Public Health and the Environment
Comprehensive Envkonmental Response, Compensation, and Liability Act
Center for Envkonmental Research Information
Code of Federal Regulations
Contaminant removal efficiency
Clean Water Act
Colorado Water Quality Control Commission
U.S. Department of Energy
Oxidation/reduction potential
U.S. Envkonmental Protection Agency
General Environmental Corporation
Gallons per minute
Hazardous and Solid Waste Amendments
Innovative Technology  Evaluation Report
Kilowatt-hour
Los Alamos National Laboratory
Low level radioactive waste
Liters per minute
Maximum contaminant level
Milligrams per kilogram
Milligrams per liter
MilliSiemens
MilliSiemens per centimeter
Matrix spike and matrix spike duplicate
                                    ix

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   Acronyms, Abbreviations, and Symbols (continued)
 NCP
 NPDES
 NPL
 NRC
 NRMRL
 O&M
 ORD
 OSHA
 OSWER
 PA
 pCi/L
 POTW
 PPE
 ppm
 PRC
 psi
 QA/QC
 QAPP
 RCRA
 RFETS
 SARA
 SDWA
 SEP
 SITE
 SWDA
 TCLP
 TDS
 TER
 TOG
 TRU
 TSS
TTU
lira
pS/cm
V
VISITT
 National Oil and Hazardous Substance Pollution Contingency Plan
 National Pollutant Discharge Elimination System
 National Priorities List
 Nuclear Regulatory Commission
 National Risk Management Research Laboratory
 Operation and maintenance
 Office of Research and Development
 Occupational Safety and Health Administration
 Office of Solid Waste and Emergency Response
 Protected area
 PicoCuries per liter
 Publicly owned treatment works
 Personal protective equipment
 Parts per million
 PRC Environmental  Management, Inc.
 Pounds per square inch
 Quality assurance and quality control
 Quality assurance project plan
 Resource Conservation and Recovery Act
 Rocky Flats Environmental Technology Site
 Superfund Amendments and Reauthorization Act
 Safe Drinking Water Act
 Solar evaporation pond
 Superfund Innovative Technology Evaluation
 Solid Waste Disposal Act
 Toxicity Characteristic Leaching Procedure
 Total dissolved solids
 Technical Evaluation Report
 Total organic carbon
 Transuranic
 Total suspended solids
 Transportable treatment  unit
Micrograms per liter
Micrometer (micron)
MicroSiemens per centimeter
Volts
Vendor Information System for Innovative Treatment Technologies

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

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                                       Acknowledgments
This report was prepared under the direction of Ms. Annette Gatchett, the U.S. Environmental Protection Agency (EPA)
Supcrfund Innovative Technology Evaluation (SITE) project manager at the National Risk Management Research Laboratory
(NRMRL) in Cincinnati, Ohio. This report was prepared by Dr. Theodore Ball, Mr. Jon Bridges, Ms. Barbara DeAngelis, Mr.
David Harr, Ms. Doreen Hoskins, Ms. Jennifer Jones, and Mr. David Walker of PRC Environmental Management,' Inc.
(PRC). Contributors and reviewers for this report were Ms. Gatchett, Mr. Sam Hayes of EPA, and Mr. Carl Dalrymple of
General Environmental Corporation.  The report was formatted by Ms. Melissa Fajt, edited by Mr. Christopher Pytel, and
technically reviewed by Ms. Pauline LeBlanc of PRC.
                                                   XII

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                                       Executive Summary
This executive summary of the CURE electrocoagulation
technology  discusses its  applications, evaluates costs
associated with the system, and describes its effectiveness.

The CURE  electrocoagulation  technology has been
evaluated under the Superfund Innovative Technology
Evaluation (SITE)  program.   The SITE program was
developed by the U.S. Environmental Protection Agency
(EPA) to maximize  the  use of alternative treatment
technologies. To this end, reliable performance and cost
data on innovative technologies are developed during
demonstrations where a technology is used to  treat a
specific waste.

After the demonstration, EPA publishes an Innovative
Technology Evaluation  Report (ITER) designed to aid
decision makers in evaluating the technology for further
consideration as an applicable cleanup option. This report
includes a review  of the technology application,  an
economic  analysis  of  treatment  costs  using  the
technology, and the results of the demonstration.

The CURE electrocoagulation technology induces the
coagulation and precipitation of contaminants by a direct-
current electrolytic process followed by flocculent settling
with or without the  addition of coagulation-inducing
chemicals. The water is pumped through concentric tubes
made of iron or aluminum that act as electrodes. A direct
current electric field is applied to the electrodes to induce
the electrochemical reactions needed to  achieve  the
coagulation. Treated water is discharged from the system
for  reuse,  disposal, or reinjection.    Concentrated
contaminants in the form of sludge are placed in drums for
disposal or reclamation.

The CURE  electrocoagulation  process  involves  the
following basic steps: (1) contaminated water is pumped
through the CURE  electrocoagulation tubes; (2) treated
water is pumped to a clarifier to allow solids to settle out;
(3) clarified water is discharged from the system for reuse,
disposal, or reinjection; (4) solid  waste is stored for
disposal or reclamation.

The technology demonstration had two primary objectives:
(1) document 90 percent contaminant removal efficiencies
(CRE) for uranium, plutonium, and americium to the 95
percent confidence level; and (2) determine if CURE
could treat the waste stream to radionuclide contaminant
levels below Colorado Water Quality Control Commission
(CWQCC) standards at the 90 percent confidence level.

In addition, the technology demonstration had several
secondary objectives.  These were to (1) evaluate anode
deterioration; (2) demonstrate CREs for arsenic, boron,
cadmium, calcium,  lithium, magnesium, total  organic
carbon (TOC), total dissolved solids (TDS), and  total
suspended solids (TSS) of 90 percent or higher at the 90
percent confidence level; (3) document production of
hydrogen  and  chlorine gases; (4) determine  power
consumption by the CURE electrocoagulation system; (5)
determine  optimum system operating  parameters for
treatment  of the demonstration treatment water; (6)
document selected geochemical parameters (pH, oxidation/
reduction  potential  [Eh],   specific  conductivity,  and
temperature) that may affect the effectiveness  of the
CURE electrocoagulation system; (7) determine uranium,
plutonium, americium, andtoxicity characteristic leaching
procedure (TCLP) metals leachability from the flocculent
by TCLP; and (8) estimate capital and operating costs of
building a single treatment unit to operate at the rate of 100
gallons per minute (gpm).

For the demonstration, approximately 4,500 gallons of
water containing up to 2,933 micrograms per liter ( g/L)
uranium, 33.1 picoCuries per liter (pCi/L) plutonium, and
83.5 pCi/L americium were treated in four test runs.  Due

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to operating constraints at the demonstration site, no long-
term evaluation of the treatment system was conducted.
Each run was initiated by running process water through
the CURE system until the clarifier was full (approximately
2.5 hours).  Sampling of clarifier effluent was conducted
for 3  hours  thereafter.   These  tests  may  not be
representative of actual operating conditions.

The CURE technology was evaluated against nine criteria
used for decision making in the Superfund remedy
selection process. This evaluation indicates that the CURE
system can provide short- and long-term protection of
human  health and  the  environment  by  removing
radionuclide contamination from water and concentrating
it in a solid form.

Operation of the CURE  electrocoagulation system must
also  comply  with  several statutory  and regulatory
requirements.   Among  these  are  the  Comprehensive
Environmental Response,  Compensation,  and Liability
Act (CERCLA), Resource Conservation and Recovery
Act (RCRA), Safe Drinking Water Act (SDWA), Clean
Water  Act  (CWA),  Occupational  Safety and Health
Administration (OSHA)  requirements, radioactive waste
regulations, and mixed waste regulations. These statutes
and regulations should be considered before use of any
remedial technology.

Using information obtained from the SITE demonstration,
an economic  analysis was conducted  to examine 12
different cost categories for the CURE system treating
contaminated  groundwater at  a  Superfund site.   The
analysis examined three cases in which the system treated
water for 1,5, and 10 years.  For all treatment durations, a
100 gpm system was used in the cost calculations.  Costs
are summarized below.

Fixed  costs for  all  three scenarios were the same.
Therefore,  for the  1-year treatment  scenario capital
equipment and site preparation dominate costs. Estimated
costs ranged from $0.003 to $0.009 per gallon of water
treated. These costs are estimates, and actual costs will
vary with site  conditions, materials  and  labop costs, and
treatability of the wastestream.

Based  on  the  SITE   demonstration,  the  following
conclusions may be drawn about the effectiveness of the
CURE technology:
Results of chemical analysis of waters collected dur-
ing the four 3-hour demonstration runs showed that
the CURE system removed 32 to 52 percent of ura-
nium, 63 to 99 percent of plutonium, and 69 to 99
percent of americium from solar evaporation pond
water.  However,  CWQCC standards could not be
attained reliably for plutonium and americium, and
were not met for uranium.

Solid waste generated by the CURE treatment sys-
tem during this demonstration is resistant to leaching
of the radionuclides uranium, plutonium, and ameri-
cium.

The volume of waste generated is substantially less
than the volume of water treated.

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                                             Section 1
                                           Introduction
This section provides background information about the
Superfund  Innovative Technology  Evaluation  (SITE)
program,  discusses  the  purpose of  this  innovative
technology evaluation report (ITER), and describes the
CURE electrocoagulation technology.   For additional
information about the demonstration site, this technology,
and the SITE program, key contacts are listed at the end of
this section.

1.1    Background

In  August  and  September  of  1995,  the  General
Environmental   Corporation    (GEC)    CURE
electrocoagulation system was  evaluated at the Rocky
Flats  Environmental Technology Site (RFETS),  near
Golden, Colorado.  The technology demonstration was
conducted  as  a cooperative effort between the  U.S.
Environmental Protection Agency (EPA) and the U.S.
Department of Energy (DOE) which manages the site.

The CURE system was evaluated as a transportable, trailer
mounted unit that  uses  a series of concentric  iron or
aluminum tubes, a power supply to control the electrical
current across the interior and exterior tube, and a clarifier
to  remove  floccules  formed  in  the tubes.    The
demonstration  evaluated the ability  of the system to
remove uranium, plutonium, and americium from solar
evaporation pond (SEP) water at RFETS.

1.2    Brief Description  of the SITE
       Program and Reports

The  Superfund Amendments and Reauthorization  Act
(SARA) of 1986 mandates  that the EPA select, to the
maximum  extent  practicable,  remedial  actions  at
Superfund  sites that  create permanent  solutions  (as
opposed to land-based disposal) for contamination that
affects human health and the  environment.  In response to
this mandate, the SITE program was established by EPA's
Office of  Solid Waste  and  Emergency Response
(OSWER) and Office of Research and Development
(ORD).  The SITE program promotes the development,
demonstration, and use of new or innovative technologies
to clean up Superfund sites across the country.

The SITE program's primary purpose is to maximize the
use of alternatives in cleaning hazardous waste sites by
encouraging the development and demonstration of new,
innovative treatment and monitoring technologies.  It
consists of the Demonstration  Program, the Emerging
Technology Program, the Monitoring and Measurement
Technologies  Program,  and the  Technology  Transfer
Program. These  programs are discussed in more detail
below.

The Demonstration Program develops reliable performance
and cost data on innovative treatment 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
simulate  full-scale  remediation,   thus  assuring  the
usefulness and reliability of information collected. Data
collected are  used to assess  the  performance of the
technology, the potential need for pre- and post-treatment
processing of wastes, potential operating problems,  and
the approximate costs. The demonstrations also allow for
evaluation  of long-term  risks  and  operating  and
maintenance (O&M) costs.

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

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

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

Technologies are selected for the SITE Demonstration
Program through annual requests for proposals. ORD staff
review the proposals, including any unsolicited proposals
that may be submitted throughout the  year, 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
technologies are of particular interest.

Once  EPA  has accepted   a  proposal,   cooperative
agreements between EPA and the developer establish
responsibilities for conducting the demonstrations and
evaluating the technology.  The developer is responsible
for demonstrating the technology at the selected site and is
expected to pay any costs  for transport, operations, and
removal of the equipment.  EPA is responsible for project
planning, sampling and analysis, quality assurance and
quality control (QA/QC), preparing reports, disseminating
information, and transporting and disposing of treated
waste materials.

The results of the CURE electrocoagulation technology
demonstration are published in two documents: the SITE
technology capsule and the ITER.  The SITE technology
capsule provides  relevant information on the  technology,
emphasizing key features of the results of the SITE field
demonstration. In addition to the ITER, EPA prepares an
unbound technical evaluation report (TER)  for  each
demonstration.  The TER contains raw analytical and
quality assurance data and other operating information
collected during the demonstration. The TER is prepared
to document the quality of the demonstration data upon
which the ITER is based.

1.3    Purpose of the Innovative
       Technology Evaluation Report

The  ITER  provides  information  on  the  CURE
electrocoagulation  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 for implementing specific
remedial actions.  The ITER is designed to aid decision
makers in evaluating specific  technologies  for further
consideration as an  applicable option  in a particular
cleanup operation. This report represents a critical step in
the development and commercialization of a treatment
technology.
To   encourage  the  general  use  of  demonstrated
technologies, EPA provides information regarding  the
applicability of each technology to specific sites and
wastes. Therefore, the ITER includes information on cost
and  site-specific  characteristics.    It  also  discusses
advantages,  disadvantages,  and  limitations  of  the
technology.
Each SITE demonstration evaluates the performance of a
technology in treating a specific waste.   The waste
characteristics of  other  sites  may  differ  from  the
characteristics of the treated waste. Therefore, successful
field demonstration of a technology at one site does not
necessarily ensure that it will be applicable at other sites.
Data  from   the  field demonstration  may  require
extrapolation for estimating the operating ranges in which
the technology will perform satisfactorily. Only limited
conclusions   can  be  drawn   from  a  single  field
demonstration.
1.4   Technology Description

The following sections overview coagulation theory, the
electrocoagulation  technology,  and   the  CURE
electrocoagulation system.

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1.4.1  Theory of Coagulation

It has long been known that contaminants are dissolved or
suspended in aqueous solutions due to small, electrostatic
charges at the surface of the molecules or particles. If the
surface charges are similar, the molecules or particles will
repel one another. Competing with this repulsion is van
der Waals' force, a weak intermolecular force that results
in the attraction of molecules to one another. However,
van der Waals' force is very small and decreases rapidly
with  increasing distance between particles.   If the
repulsion  caused  by the stronger  like charges can be
overcome, the van der Waals' force will cause the particles
to coagulate.  The addition of electrolytes which have
bivalent or, more effectively, trivalent cations  is the
conventional means for overcoming the repulsive force of
the charges and causing coagulation into particles large
enough to precipitate out of solution (Sawyer and McCarty
1978).

In conventional coagulation and precipitation, a chemical
amendment is added to the contaminated solution.  The
amendment  is generally alum (aluminum sulfate), lime
(calcium oxide), ferric iron sulfate, or charged synthetic or
natural organic polymers (polyelectrolytes). In each case,
the charged portion of the chemical additive destabilizes
and binds with the oppositely-charged contaminants in
solution, causing them to coagulate and, when of sufficient
mass, to precipitate (Sawyer and McCarty 1978; Barkley
and others 1993). This method of contaminant removal
has the disadvantages of requiring frequent and expensive
chemical  additions  to  the  solution; leaving  high
concentrations of the anionic components of the additive
in solution; and increasing the volume of sludge formed by
subsequent precipitation of the coagulated contaminant.
Some chemical amendments may form stable hydroxide
compounds.  Others may be less resistant to degradation
and may not pass the requirements of the EPA's toxicity
characteristic  leaching  procedure (TCLP)  (SW-846
Method 1311, [EPA 1994]). Failure to pass the TCLP will
result  in the  sludge being characterized as hazardous
waste,  increasing sludge disposal costs, and  reducing
disposal options.

1.4.2 Theory of Electrocoagulation

In  electrocoagulation,  alternating  or  direct  current
electricity is applied to a cathode-anode system in order to
destabilize  any  dissolved  ionic or  electrostatically
suspended contaminants. During the electrolytic process,
cationic species frtirn the anode metal dissolve into the
water  (Equation  1).   These cations  react with the
destabilized contaminants  creating metal  oxides and
hydroxides which precipitate.  If aluminum anodes are
used, aluminum oxides and  hydroxides form; if iron
anodes are used, iron oxides and hydroxides form.  The
formation  of  the  oxides  and hydroxidess and their
subsequent precipitation, are similar to the processes
which occur during coagulation (or flocculation) and
precipitation using alum  or other chemical coagulants.
The differences are the source of the coagulant (in
electrocoagulation   it  is   the  cations  produced  by
electrolytic dissolution of the anode metal [Barkley and
others 1993]), and the activation energy applied promotes
the formation of oxides (Renk 1989). The oxides are more
stable than the hydroxides, and thus, more resistant to
breakdown by acids (Renk 1989).   Oxygen gas is also
produced at  the  anode  by the electrolysis of water
molecules (Equation 2), and chlorine gas can be produced
from chloride ions if they are present in the solution to be
treated (Equation 3).

During the electrolytic production of cations, simultaneous
reactions takes place at the  cathode producing hydrogen
gas from water molecules (Equation 4).  Other important
cathodic reactions include reduction of dissolved metal
cations to the elemental state (Equation 5). These metals
plate on to the cathode.  The chemical reactions taking
place during electrocoagulation  using  iron  anodes are
shown below (Vik and others 1984; Jenke and Diebold
1984; Renk 1989; Barkley and others 1993; Hydrologies,
Inc. 1993).
At the anode:
       Fe(s) - Fe3+(aq)
                                            (1)

                                            (2)
       2Cl-(aq) - C12(g) + 2e-

At the cathode:

       2H2O + 2e- -» H2(g) + 2OH-

                   »M(s)
                                     (3)
                                            (4)

                                            (5)
Where:
Cl'(aq) =      Chloride ion in aqueous solution
Cl2(g)  =      Chlorine gas

-------
Fc{s)  =»     Iron solid
Fe*3(aq)=     Ferric ions in aqueous solution
H'(aq) =     Hydrogen ion in aqueous solution
H2(g)  =     Hydrogen gas
H,O   =     Water
MfN*(aq)=     Metal ion in aqueous solution
M(s)   =     Metal solid
OH'(aq)=     Hydroxide ion in aqueous solution
O2(g)  =     Oxygen gas
e~      =     Electron
N*     =     Charge of metal ion

In solution, the ferric ions supplied by dissolution of the
anode participate in further spontaneous reactions to form
oxides and hydroxides (Drever 1988; Renk 1989; Barkley
and others 1993; Hydrologies, Inc. 1993). Renk (1989)
found  that  oxides  preferentially  formed   in
electrocoagulation  experiments  because  the  energy
supplied by the system exceeded the activation energy for
their formation.  These reactions incorporated dissolved
contaminants into the molecular structure forming acid
resistant  precipitates.  These precipitates are typically
capable of passing  the TCLP.  This can significantly
reduce solid waste disposal costs. Similar reactions occur
when aluminum anodes are used.

1.4.3 System Components and Function

The CURE electrocoagulation technology is  designed to
remove contaminants including dissolved ionic species
such as metals;  suspended colloidal materials such  as
carbon black or  bacteria; and emulsified oily materials
from groundvvater or wastewater.  The CURE  system
induces coagulation of contaminants by means of a direct-
current electrolytic process.  Floccules formed by this
process are allowed to settle in a clarifier. Treated water is
discharged from the clarifier for reuse, disposal,  or
reinjection; contaminants are concentrated in floes that are
dewatered and discharged to drums for ultimate disposal
or reclamation.

A schematic diagram of the  CURE system is shown in
Figure l-l. The major components of the system include
the following:

•    Influent Storage Tank. This tank collects influent
     to be processed by the CURE system in batch mode
     or to provide surge capacity during continuous op-
     eration.
•   Influent pH Adjustment Tank. The influent pH can
    be adjusted in these tanks if required to bring the in-
    fluent pH into the range for optimum operation of the
    electrocoagulation tubes.

•   Electrocoagulation Tubes.  The electrocoagulation
    tubes consist of a tube-shaped anode material that
    concentrically surrounds a tube-shaped cathode ma-
    terial leaving an annular space between the anode and
    cathode. Contaminated water passes through the cen-
    ter of the cathode tube, then through the annular space
    between the cathode and anode tubes. Several elec-
    trocoagulation tubes may be used in series.

•   Clarifier. The clarifier is designed to allow floccules
    (floes) to continue to form in the treated water and to
    settle.  Treated water exits the clarifier as the over-
    flow. The settled floes form a sludge that is removed
    in the underflow.

•   Bag Filter. Heavy duty polypropylene bag filters are
    used to remove sludge from the underflow. Spent
    bag filters and sludge are periodically removed for
    disposal.  Filtrate from the bag filters is recycled
    through the electrocoagulation tubes.

•   Transfer Pumps. Transfer pumps are used to pump
    water from the system influent storage tank through
    the electrocoagulation tubes to the clarifier. Over-
    flow from the clarifier is pumped from a lift station
    to discharge.  Sludge is pumped from the bottom of
    the clarifier through the bag filter.

Several operating parameters can be varied on the CURE
treatment system.  These are:

•   Length of electrocoagulation tubes

•   Spacing between the inner and outer tubes

•   Number of electrocoagulation tubes

    Tube material, either iron or aluminum

•   Treatment sequence

    Number of passes through each
    electrocoagulation tube

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                     Entering
                   1  Influent
                   2  NaOH for pH Adjustment
                   5  Iron from Anodes
   Leaving
3  Dewatered Sludge and bag RIters
4  Treated Water
          Incoming
           Water
                                   Dewatered
                                    Sludge
                                                                                  Legend
                                                                                          »-    Flow Direction

                                                                                                Screen

                                                                                                Pump

                                                                                                Bag Filter
                                                                                                Tank

                                                                                                Cure Tubes
Figure 1-1. CURE schematic diagram.

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•   Flow rate and associated residence time for water in
    the electrocoagulation tubes and clarifier

•   Amperage and accompanying voltage

1.5    Key Contacts

Additional  information  on the  RFETS,  the  CURE
technology, and the SITE program can be obtained from
the following sources:

Rocky Flats Environmental Technology Site
Michael Konczal
Community Relations
U.S. DOE Rocky Flats Field Office
Rocky Flats Environmental Technology Site
P.O. Box 928
Golden, CO 80402-0928
303-966-5993

Jill Paukert
Community Relations
Kaiser-Hill Company, L.L.C.
P.O. Box 464
Golden, CO 80402-0464
303-966-6160
FAX: 303-966-4255

CURE Technology
General Environmental Corporation
c/o Daniel Eide
CURE International, Inc.
 1001 U.S. Highway One, Suite 409
Jupiter, FL 33477
516-575-3500
FAX:  516-575-9510

SITE Program
Robert A. Olexsey
Director, Superfund Technology
Demonstration Division
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7861
FAX: 513-569-7620

Annette Gatchett
EPA SITE Project Manager
U.S. Environmental Protection Agency
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7697
FAX: 513-569-7620

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

     The Alternative Treatment Technology Information
     Center (ATTIC) System is a comprehensive, auto-
     mated information retrieval system that integrates data
     on hazardous waste treatment technologies into a cen-
     tralized, searchable source.  This database provides
     summarized information on innovative treatment
     technologies.  Information is available on-line at
     www. epa.gov/attic/attic. html.

•    The Vendor Information System for Innovative Treat-
     ment Technologies (VISITT) (Hotline: 800-245-4505)
     database contains information on 154 technologies
     offered by 97 developers.

     The OSWER CLU-In electronic bulletin board con-
     tain information on the status of SITE technology
     demonstrations. The system operator can be reached
     at 301-585-8368.

Technical reports may be obtained by contacting the
Center for Environmental Research Information (CERI),
26 W. Martin Luther King Drive in Cincinnati, OH 45268
or by calling 800-490-9198,

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                                             Section 2
                            Technology Application Analysis
This  section  of the  ITER  evaluates the  general
applicability of the CURE system to contaminated waste
sites based on the SITE demonstration results. A detailed
discussion of the  demonstration results is presented in
Section 4 of this report. In addition, the developer's claims
regarding the applicability and performance of the CURE
system appear  in Appendix A and several case studies
provided by the developer appear in Appendix B.

2.1    Key Features of the CURE
       Electrocoagulation Technology

According to the vendor, the CURE system is an ex situ
technology that allows on-site treatment of contaminated
surface or groundwater with limited site preparation.  The
technology is unique in that it can remove radionuclides
and metals from Water without the addition of chemicals.

Operation of the CURE technology utilizes electricity to
liberate ferric iron ions from the electrocoagulation tubes
as the contaminated water passes through the tubes.  The
ferric  ions  combine  with   dissolved or  colloidal
contaminants in the  water forming floes which  are
removed in a clarifier.  Use of the CURE system can
substantially reduce the volume of contaminated media
from the volume of contaminated water to the volume of
the dewatered floes. In addition, the mobility of the waste
is reduced.  The developer claims that the resulting fioc
can pass the EPA's TCLP.

2.2   Technology Performance

According to the technology developer, electrocoagulation
systems have been used to treat wastewaters for over 85
years (Dalrymple 1994).  The CURE electrocoagulation
differs from  those previously used  by  using concentric
pipes as electrodes. This section summarizes the CURE
electrocoagulation technology.
2.2.1 Historical Performance

Electrocoagulation technology using concentric tubes has
been demonstrated as an effective process for the removal
of  metals  from  properly  conditioned electroplating
wastewaters.  Removal levels appear to be better than
those achieved by conventional hydroxide or carbonate
precipitation using caustic soda, soda ash, or lime.  Also,
according to the developer, the metals can be precipitated
at a lower pH as compared to these other commonly used
methods (Dalrymple 1994).

Dalrymple (1994) reports that treatment of electroplating
waste by electrocoagulation  using concentric tubes  in
conjunction with pH adjustment reduced concentrations
of cadmium, chromium, nickel, and zinc by 99.5 percent
or more for all four metals. These results were compared
with treatment of the same waste stream by pH adjustment
only.  Electrocoagulation treatment was 48 percent more
effective than pH adjustment alone for cadmium, and 99.5
percent better  for nickel.  Chromium  removals were
similar for both tests, and zinc removal was 85 percent
higher for pH adjustment alone.

A cadmium plating waste solution was also treated using
the  concentric  tube electrocoagulation.  The cadmium
concentration was decreased by 99.5 percent from 12.0
milligrams per liter (mg/L) to 0.057 mg/L, the copper
concentration was decreased by 96.4 percent from 8,94
mg/L to 0.32 mg/L, the zinc concentration decreased by
86.8 percent from 3.02 mg/L to 0.40 mg/L, and the silicon
concentration decreased by 91.1 percent from 4.49 mg/L
to 0.40 mg/L (Dalrymple  1994).

A truck manufacturing plant installed a concentric tube
electrocoagulation system that reduces the chromium
concentration in their discharge water from 400 mg/L to
0.17 mg/L (99.9  percent removal).  The treated water

-------
complies with their discharge requirement of 1.0 mg/L
(Dalrymple 1994).

Treatment of waste streams from acid mine drainage, can
manufacturing, foundries, city sewage, rendering facilities,
food processing, and synthetic fuel manufacturing has also
been  tested with concentric tube electrocoagulation.
Metals concentration reductions for metals have ranged
from 31 percent for a river water containing 12.0 mg/L
magnesium to 99.9 percent for zinc and chromium in
electroplating wastewater containing 221 mg/L zinc and
169 mg/L  chromium.  Dissolved anion concentration
reductions have ranged from 33 percent for sulfate in an oil
brine  to  99 percent for phosphate in city sewage.  In
addition, biochemical oxygen demand (BOD), oil and
grease concentration, total organic  carbon  (TOC), and
total suspended solids (TSS) were reduced by 32 to 99
percent (Dalrymple 1994).

2.2.2 Bench-Scale Study Results

A trcatability study was  conducted  for  the  CURE
electrocoagulation  technology  prior   to  the   SITE
demonstration (EPA  1995a).   In addition,  RFETS
conducted tests of the CURE system prior to the tests done
by EPA.  Water from the SEPs at RFETS was used for the
tests. The primary objectives of the treatability study were
as follows:

•   Evaluate the effectiveness of the CURE technology
    for removing uranium, plutonium, and americium to
    meet Colorado Water Quality Control Commission
    (CWQCC) standards

•   Determine removal efficiencies for boron, calcium,
    magnesium, the inductively coupled plasma metals
    suite, nitrate, nitrite, total dissolved solids (TDS), TSS,
    and TOC

•   Evaluate the sludge produced by the CURE technol-
    ogy for leachability using the TCLP

Results of the treatability study indicate that the CURE
treatment system is  capable of consistently reducing
radionuclide concentration by more  than 90 percent, and
CWQCC standards were met for radionuclides in all tests
conducted.  Only three other metals (cadmium, chromium,
and boron) exceeded CWQCC standards in the test water.
Cadmium and chromium concentrations were consistently
reduced  to  below the CWQCC standard, but  boron
removal was insignificant. Manganese and molybdenum
concentrations remained the same or increased slightly.
Iron and aluminum concentrations increased during some
of the tests due to dissolution of the anode material.  This
may indicate that the applied potential (voltage) was
higher than necessary for effective coagulation, resulting
in excess dissolution of the anodes.

Results of the TCLP analysis of the dewatered sludge
produced by the CURE technology indicate that the metals
barium,  cadmium,  chromium,  selenium,  and  silver
concentrations in the resultant leachate from the solids
were all below regulatory limits.  Sludge production was
estimated to  be approximately 2.5 cubic centimeters per
liter of influent.

2.2.3 SITE Demonstration  Results

The primary  objectives   of the  CURE  technology
demonstration were to determine contaminant removal
efficiencies  (CREs)  for  the radionuclides  uranium,
plutomum-23 9/240, and americium-241; and determine if
CWQCC standards for these contaminants could be met
with 90 percent confidence.  The mean CREs  were
calculated for each of four runs  which were conducted
after five optimization runs had been completed. The CRE
for uranium  ranged from 32 to 52 percent; the CRE for
plutonium-239/240 was 63 to 99 percent; and the CRE for
americium-241 was 69 to 99 percent.

The CWQCC discharge standards are 15 micrograms per
liter ( g/L) for uranium, 0.05 picoCuries per liter (pCi/L)
for plutonium-23 8/239, and 0.05 pCi/L for americium-
241.  The CWQCC standard for uranium was not met
during the demonstration. Some of the tests achieved the
CWQCC standard for plutonium-239/240, but not all, and
the CWQCC standard was met for americium-241 in one
test only.

The CRE for arsenic was determined to be 78.5 percent,
and at 0.02 mg/L, the effluent arsenic concentration was
below the CWQCC standard of 0.05 mg/L. The results for
aluminum and cadmium were inconclusive because their
concentrations were below the detection limit in both the
influent and the effluent.  Boron, lithium, magnesium,
TOC, and TDS showed little or no removal.  TSS and iron
concentrations increased due to the formation of flocculent
from the dissolving anodes.

The  results of the  optimization  portion  of the
demonstration indicated that three electrocoagulation
                                                   10

-------
tubes with an annular space of 0.1 to 0.5 inches should be
used.  Each tube  was 10-feet long, and the water was
pumped through the system at 3.0 to 3.1 gallons per minute
(gpm).  One pass through the system is all that was
required.  The current was set at 150 amperes,  and the
resulting potential was 20 to 57 volts.

2.3   Evaluation of Technology Against
       RI/FS Criteria

The CURE technology's applicability was also evaluated
based on the nine criteria used for decision making in the
Superfund  feasibility  study process.   Results  of the
evaluation are summarized in Table 2-1.

2.4   Factors Influencing Performance

Three  factors  affect  the  performance of the  CURE
electrocoagulation technology.   These are  (1) influent
water  chemistry,  (2) operating  parameters; and (3)
maintenance of the equipment.  The following sections
discuss these factors.

2.4.1 Influent Water Chemistry

The CURE electrocoagulation technology can treat a wide
variety of wastewaters to remove dissolved and suspended
contaminants. The chemistry of the wastewater, including
the pH, the oxidation/reduction potential (Eh), dissolved
oxygen, TDS, TSS,  and  the  chemical form  of the
contaminants can  affect formation of fioccules,  thereby
affecting the ability of the technology to  remove the
contaminants of interest.  Therefore, pretreatment such as
filtering, aeration, or pH adjustment may be necessary. In
addition, the system should be optimized to the influent
characteristics and the contaminants to be removed.

The SEP   water  used  to  demonstrate  the  CURE
electrocoagulation technology contained high levels of
alkalinity,  bicarbonate,  carbonate, chloride and  total
dissolved solids, as shown in Table 2-2.  CWQCC and
EPA standards  are provided for reference.

2.4.2 Operating Parameters

Use of the  CURE  technology is waste-specific  with
several of the operating parameters requiring optimization
for the specific waste  stream to be treated.  Adjustable
CURE system operating parameters include:
•    Tube length
•    Annular space between the concentric tubes
•    Number of tubes
•    Tube material
•    Sequence of tube materials
     Number of passes through the system
•    Flow rate (residence time)
•    Applied potential that controls the electricalcurrent

2.4.3 Maintenance of Equipment

Routine maintenance of the CURE electrocoagulation
equipment is required for smooth operation. Maintenance
frequency depends on the electrical current applied and the
sizes of the tubes used. The electrocoagulation tubes must
be cleaned periodically to prevent clogging by solids.
Cleaning is  accomplished by  flushing  the system with
clean water.  After flushing is complete, the tubes may be
disassembled and  inspected  for corrosion.   Periodic
replacement of  the  tubes  will be  required  due to
deterioration from the electrocoagulation process. Filter
bags used for dewatering floes also  require  periodic
replacement.

2.5   Applicable Wastes

According to the developer of the CURE electrocoagulation
technology,  the  technology can be applied to many
contaminants dissolved and suspended in water including
metals, uranium,  radium, selenium, phosphates, bacteria,
oils, clays, dyes, carbon black,  silica, as well as  hardness
(calcium carbonate).  Waste streams that the developer
claims can be effectively treated by the technology are:

     Plating plant effluent
•    Landfill leachates
•    Petrochemical waste
•    Bilgewater
     Mine process and wastewater

2.6   Site Requirements

The  main requirement of the trailer-mounted CURE
electrocoagulation  system is electricity to  operate the
electrocoagulation tubes and the pumps that bring water
into and out of the system.  The maximum power required
for the electrocoagulation system as demonstrated is 48
amperes at 480 volts, 3 phase or 96 amperes at 240 volts, 3
phase. . The  system distributes the power to the power
                                                  11

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Table 2-1. Evaluation of CURE Process Based on Nine Criteria of Superfund Feasability Study Process
                   Criteria
                        Evaluation
        1.  Overall protection of
            Human. Health and the
            Environment

        2.  Compliance with Federal
            Applicable or Relevant and
            Appropriate Requirements
            (ARARs)

        3.  Long-Term Effectiveness
            and Permanence
        4.  Reduction of Toxicity,
            Mobility, or Volume
            Through Treatment

        5.  Short-Term Effectiveness
        6.  Implementability
        7.  Cost
        8.  Community Acceptance
        9.  State Acceptance
The CURE technology is capable of removing heavy metal
contaminants from groundwater and therefore prevents further
migration of those contaminants.

Compliance with chemical-, location-, and action-specific ARARs
must be determined on a site-specific basis.
In waste streams with trace levels of contaminants, a high
percentage of the contaminants are permanently removed.
Involves some residuals treatment; (sludge, wastewater) or
disposal.  Treatment is a well documented process.

Significantly reduces toxicity, mobility, and volume of
contaminants through treatment.  Volume of technology residuals
is small compared to the treated water volume.

Presents few short-term risks to workers and community. Some
personal protective equipment is required to be worn by workers.
Technology involves rapid reduction of contaminants hi the waste
stream.

Involves few administrative difficulties.  Utility requirements are
water and electricity.  Access for a 1-ton trailer is required and a
2,000 square feet flat area is required.

Costs range from $0.009 per treated gallon for a one year
operation to $0.003 per treated gallon for a ten year operation.

Minimal short-term risks presented to the community make this
technology favorable to the public.

State regulatory agencies may require permits.
                                                     12

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Table 2-2. Metals and Water Quality Parameters for RFETS Solar Evaporation Pond Water and Corresponding
Treatment Standards
Metal

Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lithium
Magnesium
Manganese
Molybdenum
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Alkalinity
Total
Bicarbonate
Carbonate
Hydroxide
Nitrate
Nitrate plus
Nitrite
Nitrite
TDS
TOC
TSS
PH
Units

mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L (CaCO3)

mg/L (HCCV)
mg/L (C03=)
mg/L (Off)
mg/L
mg/L

mg/L
mg/L
mg/L
mg/L
pH units
Tank 029'

<0.10
<0.05

<0.05
< 0.005
1.9
0.011
7.1
0.014
0.006
0.10
0.09
2.1
130
0.015
0.070
0.04
550
<0.05
0.006
2400
<0.5
0.009
0.073
5900

5700
730
<5
<0.05
<0.05

<0.05
8200
440
130
9.1
Tank 031"

<0.10
<0.05
0.21d
0.08
<0.005
2.0
0.057
35
0.087
0.013
0.23
1.4
2.3
140
0.064
0.10
0.06
560
<0.05
0.012
2600

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Table 2-2. Metals and Water Quality Parameters for RFETS Solar Evaporation Pond Water and Corresponding
         Treatment Standards (continued)
          Notes:

          —     No standard exists
          mg/L  -Milligrams per liter

          *  Concentration, based on data collected during the CURE treatability study, April 1995 (EPA 1995a).
          b  Standards adopted through the Rocky Flats Interagency Agreement - the effluent treatment standard
            governing the demonstration (EPA 1991. Federal Facility Agreement and Consent Order. Denver,
            Colorado. January).

          c  Code of Federal Regulations, Title 40 (40CFR) Part 264.94 Resource Conservation and Recovery
            Act Subpart F Maximum Contaminant Levels (MCL).

          d  Concentration based on data collected from the solar evaporation ponds in 1991 (EG&G Rocky Flats
            1991. Pond Sludge and Clarifier Sludge Waste Characterization Report).

          e  Secondary Maximum Contaminant Levels.
supply for the electrocoagulation tubes and the pump, and
reduces  it  to  supply  the  instrumentation  and air
compressor at 120 volts. The compressor is used to supply
air to a diaphragm pump which is used to move the floes
through the bag filter.

An area of approximately 2,000 square feet is required for
setup of the CURE system, and includes space for influent
and effluent storage tanks. The area should be relatively
flat and should be paved or gravel covered. Site access
requirements for the CURE system are minimal.  The site
must be accessible to a one-half ton pickup truck pulling a
trailer. The roadbed must be able to support such a vehicle
and trailer delivering the system.

2.7   Materials Handling Requirements

The  waste  stream  is   delivered  to  the   CURE
electrocoagulation system using a pump and either piping
or hose. In cases where the distance from the waste source
to the treatment system exceeds  100  feet, additional
pumps may be required to maintain a sufficient delivery
rate. After treatment, effluent water may be recirculated
through the CURE system, stored for further treatment by
another method, discharged directly to another treatment
system,  or  discharged  as treated wastewater  in an
approved manner if treatment is sufficient to meet permit
requirements.
Dewatered sludge and filter bags must be stored until
disposal. Storage in 55-gallon drums is common practice.
These  drums can be easily handled with  a fork  lift
equipped with a drum attachment. In most cases the solid
waste generated by the CURE electrocoagulation system
meets nonhazardous classification. However, confirmation
may be required prior to disposal as such.

2.8    Personnel Requirements

Two persons are required for the CURE electrocoagulation
system operation. The pumps and electrode potentials are
controlled by the system operator while the maintenance
technician monitors  the system for leaks and treatment
effectiveness.  Both personnel  are required for routine
maintenance procedures such as cleaning the tubes and
replacing filter bags.

2.9    Potential Community Exposures

The CURE electrocoagulation may produce chlorine,
oxygen, and hydrogen gases that may be released to the
atmosphere.   However,  operations  during both  the
treatability study and the demonstration did not produce
detectible levels of hydrogen or chlorine emissions. It is
assumed that these gases were primarily dissolved in the
effluent and their release to the atmosphere was slow.
Oxygen emissions were  not measured, but dissolved
oxygen measurements in the effluent indicate that the
                                                    14

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 oxygen produced from hydrolysis is  used up in the
 coagulation reactions.  Hydrogen and chlorine emissions
 from the effluent water are not expected to be hazardous to
 the  general public  or site personnel  under open  air
 conditions.
 Solid wastes  typically  pass  TCLP  requirements for
 disposal as nonhazardous waste.  Therefore, the solid
 waste generated by the CURE electrocoagulation system
 does not generally present an  exposure problem to site
 personnel or the community. Treatment of wastewaters
 containing uranium,  plutonium, and  americium could
 produce low-level radioactive waste sludge. The sludge
 will be  wet and contained,  and will not present a dust
 hazard.  Potential community exposure to radioactive solid
 waste is minimal.

 The most significant exposure would be through a rupture
 in the system. Containment of such a spill is achieved by
 conducting the treatment operations in a lined bermed
 area. Should a rupture occur, the pumps can be turned off,
 and the system can be shut down  immediately.  These
 precautions  will  mitigate  any potential  community
 exposure due to system failure.
2.10  Potential Regulatory Requirements

Under the Comprehensive Environmental  Response,
Compensation, and Liability Act (CERCLA), as amended
by SARA, remedial actions taken at Superfund sites must
comply with federal and state environmental laws that are
determined to be applicable or relevant and appropriate
requirements (ARARs).  This section discusses specific
environmental  regulations that will  most  likely be
pertinent to operation of the CURE system, including the
transport, treatment, storage, and disposal of wastes and
treated residuals, and analyzes these regulations in view of
the demonstration results.  Regulatory requirements must
be addressed by remedial managers on a site specific basis.
Table 2-3 presents ARARs as they relate to the process
activities conducted during the demonstration.

2.10.1  Comprehensive Environmental
        Response, Compensation, and
        Liability Act

CERCLA authorizes the federal government to respond to
releases or potential releases of any hazardous substance
into the environment, as well as to releases of pollutants or
 contaminants that may present an imminent or significant
 danger to public health and welfare or the environment.

 As part of the  requirements of  CERCLA,  EPA has
 prepared the National Oil and Hazardous Substance
 Pollution Contingency  Plan  (NCP) for  hazardous
 substance response. The NCP is codified in Title 40 CFR
 Part 300 and delineates the methods and criteria used to
 determine the appropriate extent of removal and cleanup
 for hazardous waste contamination.
 SARA amended CERCLA,  directing  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 pos-
     sible

     Avoid off-site transport and disposal of untreated haz-
     ardous substances or contaminated materials when
     practicable treatment technologies exist (Section
In general, two types of responses are possible under
CERCLA: removals and remedial actions.  If necessary,
the CURE technology would be part of a CERCLA
remedial action.
Remedial actions are governed by the SARA amendments
to CERCLA. As stated above, these amendments promote
remedies that permanently reduce the volume, toxicity,
and mobility of hazardous substances, pollutants,  or
contaminants.
On-site 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
                                                  15

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Table 2-3. Federal and State ARARs for the CURE System
    Process Activity
ARAR
Description
Basis
Response
Waste
Processing





Storage after
Processing


Waste
Characterization



On-site Disposal





Off-site Disposal



Transportation
for off-site
Disposal




Treated Water
Discharge


RCRA 40 CFR
Part 264. 190 to
Part 264.200 or
state equivalent.



RCRA 40 CFR
Part 264. 190 to
Part 264. 199 or
state equivalent.
RCRA 40 CFR
Part 261
Subparts C & D
or state
equivalent.
RCRA 40 CFR
Part 264.300 to
Part 264.317 or
state equivalent.


RCRA 40 CFR
Part 300.


RCRA 40 CFR
Part 262 or state
equivalent.




SDWA, CWA,
40 CFR Part 440


Standards that apply
to the treatment of
hazardous wastes.




Standards that apply
to the storage of
hazardous wastes hi
drums.
Standards that apply
to waste
characteristics.


Standards that apply
to landfilling
hazardous waste.



Requirements for the
off-site disposal of
wastes from a
Superfund site.
Manifest
requirements and
packaging and
labeling
requirements prior
to transporting.

Standards that apply
to discharge of
treated water

The treatment process
occurs in a series of
pipes.




The treated waste will be
placed hi drums.


Need to determine if
treated material is a
RCRA hazardous waste or
mixed waste.

If left on-site, the treated
waste may still be a
hazardous waste or mixed
waste subject to land
disposal restrictions.

The waste is being
generated from a response
action authorized under
SARA.
The used health and safety
gear must be manifested
and managed as a
hazardous or mixed
waste. An identification
number must be obtained
from EPA.
Wastewater containing
metals and radionuclides
is treated and ultimately
discharged to a stream.
CURE system integrity
must be monitored and
maintained to prevent
leakage or failure; the
system must be
decontaminated when
processing is complete.
The drums will be
maintained in good
condition in a secured
area.
Testing will be
conducted prior to
disposal.


Contact EPA for on-site
hazardous waste
disposal; also, disposal
will be in accordance
with DOE RFETS
requirements.
Wastes must be disposed
of hi an approved
manner consistent with
the waste classification.
Wastes and used PPE
are being stored at
RFETS.




Waters discharged from
the CURE system are
collected for further
treatment at RFETS.
                                                   16

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pose a greater risk to health and the environment than
noncompliance; (3) it is technically impracticable to meet
the ARAR; (4) the standard of performance of an ARAR
can be met by an equivalent method; (5) a state ARAR has
not been consistently applied elsewhere; and (6) ARAR
compliance would not provide a balance between the
protection achieved at a particular site and demands on the
Superfund for other sites. These waiver options apply only
to Superfund actions taken on site, and justification for the
waiver must be clearly demonstrated.

The CURE electrocoagulation technology demonstration
at RFETS met all of the SARA criteria,  the system
significantly  reduced  the  volume  and  mobility of
contaminants.  In addition, it provided a cost effective,
permanent solution to the treatment of contaminated water
at the site.

2.10.2 Resource Conservation and
         Recovery Act

The Resource Conservation and Recovery Act (RCRA),
an amendment to the Solid Waste Disposal Act (SWDA),
was passed in 1976 to address how to safely dispose of the
large  volume  of municipal and  industrial solid waste
generated annually.  RCRA specifically addressed the
identification and management of hazardous wastes. The
Hazardous and  Solid  Waste  Amendments  of  1984
(HSWA) greatly expanded the scope and requirements of
RCRA.

The   presence  of  RCRA  defined   hazardous  waste
determines whether RCRA regulations apply to the CURE
technology. RCRA regulations define hazardous wastes
and  regulate  their transport,  treatment,  storage, and
disposal.  Wastes defined as hazardous under RCRA
include characteristic and listed wastes.   Criteria for
identifying characteristic hazardous wastes are included in
40 CFR  Part 261 Subpart C.   Listed  wastes  from
nonspecific and specific industrial sources, off-specification
products, spill cleanups, and other industrial sources are
itemized in 40 CFR Part 261 Subpart D.

The CURE electrocoagulation system treated SEP water
collected at RFETS. The SEPs have begun RCRA closure
operations. Although wastes have not been disposed in the
ponds since 1986, the ponds are currently regulated under
RCRA.  Water in the SEPs has been declared a RCRA
waste.  Therefore, the sludge collected in the bag filters
during the demonstration were RCRA derived-waste and
were treated as such by RFETS personnel.

Requirements for corrective action at RCRA-regulated
facilities  are provided in 40  CFR Part 264, Subpart F
(promulgated) and Subpart S (proposed).  These subparts
also generally  apply to remediation at Superfund sites.
Subparts  F and S include requirements for initiating and
conducting  RCRA   corrective  actions,  remediating
groundwater, and ensuring that corrective actions comply
with other environmental regulations.  Subpart S  also
details  conditions  under  which particular  RCRA
requirements may be waived for temporary treatment units
operating at corrective action sites.

2.10.3  Safe Drinking Water Act

The  Safe  Drinking  Water  Act (SDWA)  of  1974,
augmented by  the Safe' Drinking Water Amendments of
1986, requires EPA to establish regulations to protect
human health from contaminants in drinking water.  The
legislation authorizes national drinking water standards
and a joint federal-state system for ensuring compliance
with these standards.

The  National  Primary  Drinking Water  Standards,
maximum contaminant levels (MCLs), are found in 40
CFR Parts 141  through 149. In addition, the CWQCC has
set basin specific discharge standards for the streams that
drain the area of RFETS.  Table 2-2 presents MCLs and
CWQCC standards.  Water treated by the CURE system
must meet these standards in order  to  be  discharged
directly to the  drainage.  However, water treated by the
CURE system was returned to a receiving  tank for
subsequent treatment at RFETS.  Wash water from the
decontamination was collected and stored in a tank before
being collected by RFETS for treatment.

2.10.4  Clean Water Act

The CWA is  designed to  restore and maintain the
chemical, physical, and biological integrity of the nation's
waters.  To reach this goal, effluent limitations of toxic
pollutants from point sources were established. Publicly
owned treatment works (POTW) can accept wastewaters
with toxic pollutants from facilities; however, pretreatment
standards must be met and a discharge permit may be
required. A facility wanting to release water to a navigable
waterway must apply for a permit under the National
Pollutant Discharge Elimination System (NPDES). When
                                                   17

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a NPDES permit is issued, it includes waste discharge
requirements.

Three options are available for the water treated by the
CURE system:  off-site disposal at a RCRA treatment
facility; discharge  through a sanitary sewer under an
industrial  pre-treatment permit;  and  discharge to the
waterways of the U.S. under a NPDES permit. During the
demonstration, water treated by the CURE system was
stored and treated at RFETS.

2.10.5  Occupational Safety and Health
        Administration Requirements

CERCLA remedial actions and RCRA corrective actions
must be performed in accordance with OSHA requirements
detailed in 20 CFR Parts 1900 through 1926, especially
Part 1910.120, which provides for the health and safety of
workers at hazardous waste sites! On-site construction
activities at Superfund or RCRA corrective actions sites
must be performed in accordance with Part 1926 of OSHA,
which  provides safety  and  health  regulations  for
constructions sites. State OSHA requirements, which may
be significantly stricter than federal standards, must also
be met.

All technicians operating the CURE system must complete
an OSHA training course and must be familiar with all
OSHA requirements relevant to hazardous waste sites. For
most sites, minimum personal protective equipment (PPE)
for technicians includes gloves, hard hats, steel toe boots,
and coveralls.  Depending on contaminant types and
concentrations, additional PPE may be required.   The
CURE system and support equipment  was mounted and
operated on the bed of a trailer truck. All equipment on the
system meets OSHA requirements for safety of operation.

2.10.6  Radioactive Waste Regulations

The CURE electrocoagulation technology may be used to
treat water contaminated with radioactive elements. The
primary agencies that regulate the cleanup of radioactively
contaminated sites are  EPA,  the Nuclear  Regulatory
Commission (NRC), the DOE, and the  states.

The SDWA  has established MCLs for alpha- and beta-
emitting radionuclides which may be appropriate in setting
cleanup standards for radioactively contaminated water.
Discharge  of  treated  effluent  from  the  CURE
electrocoagulation  system  could also be  subject to
radionuclide concentration limits established in 40 CFR
Part 440  (Effluent Guidelines for Ore  Mining  and
Dressing).  These regulations include effluent limits for
facilities that extract and process uranium, radium, and
vanadium ores.  In addition, several states have set more
stringent standards for surface waters discharged from
nuclear facilities within their jurisdiction.

NRC regulations cover by licenses the possession and use
of source,  by-product,  and special nuclear  materials.
These  regulations apply  to  sites where radioactive
contamination exists and cover protection of workers and
public  from radiation, discharges of radionuclides in air
and water, and waste treatment and disposal requirements
for radioactive  waste.  In evaluating requirements for
treating radiologically contaminated waters, consideration
must be given to the quality of the raw water, the final
effluent,  and any process residuals,  specifically  the
dewatered floes. If the CURE technology is effective for
radionuclides, these radioactive contaminants will be
concentrated in  the dewatered floes. This could affect
disposal  requirements,  as well as health and  safety
considerations.

DOE requirements are included in a series of internal DOE
orders  that have the same force as regulations at DOE
facilities.  DOE orders address exposure limits for the
public, concentration or residual radioactivity in soil and
water, and management of radioactive wastes.
2.10.7  Mixed Waste Regulations

Use of the CURE electrocoagulation technology at sites
with radioactive contamination may involve the treatment
or generation of mixed waste.  As defined by Atomic
Energy Act (AEA) and RCRA, mixed waste contains both
radioactive and hazardous components and is subject to
both acts. When the application of both regulations results
in  a   situation  inconsistent with  the  AEA,  AEA
requirements supersede RCRA requirements.

EPA's Office of Solid Waste and Emergency Response
(OSWER), in conjunction with the  NRC, has  issued
several directives to assist in the identification, treatment,
and disposal of low-level radioactive mixed waste.  If
high-level mixed waste  or transuranic mixed  waste is
treated, DOE internal orders should be considered when
developing a protective remedy.
                                                   18

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2.11  Availability, Adaptability, and
       Mobility of Equipment

The system used for the demonstration is mounted on a 18-
foot long by 6 "-foot wide trailer. This system can easily be
transported to a site for operation. The trailer has a process
pump, four CURE electrocoagulation tubes of different
materials, control panel, power supply, air compressor, a
small clarifier, and a bag filter for dewatering sludge.

The throughput of this system is adjustable as there is a
variable frequency drive on the process pump.  The flow
can be set from 0.5 to 5 gpm.  The clarifier is a simple
design that utilizes the settled floe as a filtering system.
The retention time in the clarifier is 2.3 hours at a flow rate
of 1  gpm.  The retention time required  depends on the
characteristic of the floe.

The  trailer  process  pump can pump  up  to 5  gpm
effectively. The retention time of the clarifier may not be
long enough at this high flow rate. If higher flow rates are
required, the clarifier may be modified or a larger clarifier
may be used.  The trailer unit was built as a test and
demonstration unit and is available for use on short notice.

As an alternate to the demonstration trailer unit, GEC is
manufacturing a larger transportable system. This system
is called a Transportable Treatment Unit (TTU). The TTU
trailer is 42 feet long and 8 ° feet wide and is pulled by a
semitractor.  The TTU is self-contained, requiring only
diesel fuel to operate the generator. The throughput is up
to 50 gpm. The TTU contains a clarifier and filter press for
dewatering the sludge.

2.12  Limitations of the Technology

Electrocoagulation  does not tend to remove inorganic
contaminants that do not form precipitates, such as sodium
and potassium.  If a contaminant does not tend to form a
precipitate or sorb to solids, electrocoagulation will not be
a reliable treatment method.  Although certain large
organic compounds can be removed such as tannins and
dyes, electrocoagulation is not effective in removing light-
weight organic  materials,  such as ethanol, methylene
chloride, benzene, toluene, or gasoline.
                                                   19

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                                              Section 3
                                       Economic Analysis
This section presents cost estimates for using the CURE
technology  to  treat groundwater.   Three  cases  are
presented based on treatment time. These cases are based
on 1-year, 5-year, and 10-year treatment scenarios. The
CURE technology can be operated at several different
flow rates, but 100 gpm was assumed for this economic
analysis because groundwater is typically treated in large
quantities.

Cost estimates presented in this section are based primarily
on data compiled during the SITE bench-scale study and
field-scale demonstration at RFETS.  Costs  have been
assigned to  12  categories applicable to typical cleanup
activities at Superfund and RCRA sites (Evans 1990).

Costs are presented in November 1995  dollars and are
considered estimates. This economic analysis is designed
to conform with the specifications for an order-magnitude
estimate. This level of precision was established by the
American Association  of Cost Engineers for estimates
having an expected accuracy within +50 percent and -30
percent.  In this definition, these estimates are generated
without detailed engineering data.

Table 3-1 breaks down costs for the 12 categories for all
throe cases.  The table also presents total one-time costs
and annual O&M costs; the total costs for a hypothetical,
long-term groundwater remediation project; and the costs
per gallon of water treated.

3.1    Basis of Economic Analysis

A number of factors affect the estimated costs of treating
groundwater with the CURE system. Factors affecting
costs generally include flow rate, type and concentration of
contaminants,   groundwater chemistry, physical  site
conditions,  geographical site location,  availability of
utilities, and treatment goals. Ultimately, the characteristics
of residual wastes produced by the CURE system also
affect disposal costs because they determine whether the
residuals require either  further treatment  or off-site
disposal. GEC claims that the CURE technology can be
used to treat several types of liquid wastes, including
contaminated  groundwater and  industrial wastewater.
Groundwater containing radionuclides was selected for
this economic analysis because radioactive  wastewater
was  used  in this  demonstration,   and groundwater
remediation involves most of the cost categories.  The
following text presents the assumptions and conditions as
they apply to each case.

For each case, this analysis assumes that the CURE system
will treat contaminated groundwater  at  100 gpm on a
continuous flow cycle, 24 hours per day, 365 days per year.
Based on this assumption, the CURE system will treat
about 52.6 million gallons of water a 1-year period. Over
a 5-year period, this  number will  rise to 263 million
gallons, and over 10 years, to 526 million gallons.

This analysis assumes that treated water for each case will
be  discharged to surface water,  and  that  specified
discharge levels will be achieved with one pass through the
electrocoagulation tubes.

The following assumptions were also made for each case
in this analysis:

•   The site is located near an urban area within 500 miles
    of Denver, Colorado, the home office of GEC.

•   Water contamination at the site resulted from mining
    or nuclear operations.

•   Contaminated water  is located in an aquifer within
     150 feet of the surface.
•   Access roads exist at the site.
                                                   20

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Table 3-1 . Costs Associated with the CURE System at a Treatment Rate of 1 00 gpm
Scheduled Treatment Time
Cost Categories
Ivear Svears 10 years
Fixed Costs
Site Preparation
Administrative
Bench-scale study
Mobilization
Permitting and Regulatory Compliance
Capital Equipment
Extraction wells, pumps, and piping
Treatment equipment
, Storage tank purchase (2 tanks)
Portable berm purchase
Startup
Demobilization
Decontamination/reconstruction
Salvage value
Variable Costs
Labor
Consumables and supplies
Replacement components
PPE
Disposable drums for PPE
Miscellaneous
Utilities
Water
Electricity
Effluent treatment and disposal
Residual and waste shipping and handling
Solids disposal
PPE disposal
Analytical services
Maintenance and modifications
Total fixed costs
Total variable costs
Total cost per gallon treated
$18,000
$5,000
$353,700




$5,000
($31,000)



$35,000
$12,400




$26,480


$0
$8,100


$27,000
$40,000
$350,700
$138,980
$0.009
$8,000
$7,000
$3,000

$158,000
$181,200
$4,500
$10,000


$5,000
($36,000)



$10,000
$1,300
$100
$1,000

$200
$26,280


$6,700
$1,400





$18,000
$5,000
$353,700




$5,000
($31,000)



$175,000
$62,000




$132,400


$0
$40,500


$135,000
$200,000
$350,700
$609,900
$0.004
$8,000
$7,000
$3,000

$158,000
$181,200
$4,500
$10,000


$5,000
($36,000)



$50,000
$6,500
$500
$5,000

$1,000
$131,400


$33,500
$7,000





$18,000
$5,000
$353,700




$5,000
($31,000)



$350,000
$124,000




$264,000


$0
$81,000


$270,000
$400,000
$350,700
$1,192,800
$0.003
$8,000
$7,000
$3,000

$158,000
$181,200
$4,500
$10,000


$5,000
($36,000)



$100,000
$13,000
$1,000
$10,000

$2,000
$262,800


$67,000
$14,000





Note:
Costs are based on 1995 dollars and are rounded to the nearest $100.
                                                    21

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     Utility lines, such as electricity and telephone lines,
     exist on site.

     Water will be treated at a rate of 100 gpm and will be
     stored at the site.

     Floe will be treated and then disposed of off site as
     low level mixed waste; wash water will be stored and
     then disposed of off site.

     GEC will sell the CURE system to the site owner.

     One treated water sample and one untreated water
     sample will be collected and analyzed weekly to
     monitor system performance. Analyses will include
     gross alpha, uranium, and metals.

     One full-time equivalent operator will be required to
     operate the equipment, collect all required samples,
     and conduct equipment maintenance and minor re-
     pairs.

     Labor costs associated with major equipment repairs
     or replacement are not included.
3.2    Cost Categories

Cost data associated with the CURE technology have been
assigned to one of the following 12 categories:  (1) site
preparation; (2) permitting and regulatory requirements;
(3) capital equipment; (4) startup; (5) demobilization; (6)
labor;  (7) consumables and  supplies;  (8) utilities;  (9)
effluent treatment and disposal; (10) residual and waste
shipping and handling; (11) analytical services; and (12)
maintenance and modifications.

Costs associated with each category are presented in the
following sections. Each section presents the costs that are
identical for each case. If applicable, differences  among
the costs of the three cases are then discussed.  Some
sections end with a summary of the significant costs within
the category. All direct costs associated with operating the
CURE system are identified as CURE direct costs; all costs
associated with the hypothetical remediation and auxiliary
equipment  are  identified  as groundwater remediation
costs.
 3.2.1  Site Preparation Costs
 Site preparation costs include administration, bench-scale
 testing, and mobilization. This analysis assumes a total of
 about 2,000 square feet will be needed to accommodate the
 skid-mounted  CURE system, support equipment, and
 treated and untreated water storage areas.  A solid gravel
 (or ground) surface is preferred for any remote treatment
 project. Pavement is not necessary, but the surface must be
 able to support a portable unit weight of approximately
 45,000 pounds  during operation.  This analysis assumes
 adequate surface areas exist at the site and will require
 minimal modifications.

 A bench-scale test series will be conducted to determine
 the appropriate specifications of the CURE system for the
 site. Cost of the bench-scale study is estimated at $7,000
 for tests which include analytical work and a site visit.
 Administrative  costs,  such as legal searches and access
 rights, are estimated to be $8,000.

 Mobilization involves transporting  the  entire CURE
 system  from Denver, Colorado, delivering all rental
 equipment to the site, and connecting utilities to the skid.
 For this analysis, the site is assumed to be located within
 500 miles of Denver, Colorado, to minimize transportation
 costs. In addition, equipment vendors are assumed to be
 situated nearby the site. The total estimated mobilization
 cost will be approximately $3,000.

 For each case, total site preparation costs are estimated to
 be $18,000.

 3.2.2 Permitting and Regulatory
       Requirements

 Permitting and  regulatory  costs vary   depending  on
 whether treatment is performed at a Superfund site or a
 RCRA corrective action facility and on the  disposal
 method selected for treated effluent and any solid wastes
 generated.  At Superfund sites, remedial actions must be
 consistent with ARARs of environmental laws, ordinances,
 regulations, and statutes, including federal, state,  and local
 standards  and criteria.  In  general, ARARs  must be
 determined on a site-specific basis.  RCRA corrective
 action facilities require additional monitoring records and
 sampling protocols, which can increase permitting and
regulatory costs.  For this analysis, total permitting and
regulatory costs are estimated to be $5,000.
                                                    22

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3.2.3 Capital Equipment

Capital  equipment  costs include installing  extraction
wells; purchasing and installing  the complete CURE
treatment system including a portable air compressor; and
purchasing two storage tanks, one-for treated water and
one for rinse water. Extraction wells were included in the
scenario because they are usually  required in pump and
treat groundwater remediation systems.

Extraction well installation  costs  associated with  a
groundwater remediation project  include installing the
well and pump connecting the pumps, piping, and valves
from the wells to the CURE system. This analysis assumes
that four 150-foot extraction wells with 4-inch polyvinyl
chloride (PVC) casings will be required to maintain 100
gpm flow rate.  Extraction wells can be installed at about
$150 per foot per well. Total well construction costs for
each case will be about $90,000. Alternatively, secondary
wastewater can be inexpensively  pumped directly from
holding tanks to the system.

Pumps, piping, and valve connections associated with a
groundwater  remediation project will depend on the
following factors: the number and  size of extraction wells
needed, the material selected, the flow rate, the distance of
the extraction wells from the treatment system, and the
climate of the area.  This analysis assumes that four
extraction wells are located within approximately 200 feet
from the CURE system.  Four 25-gpm pumps will be
required to maintain a 100-gpm flow rate, at a total cost of
about $20,000.  Schedule 80  PVC piping and  valve
connection costs are about $60 per foot,  including
underground installation.  Therefore, total piping costs
will be an additional $48,000.

The complete CURE treatment system includes a 16-foot
skid equipped with a power supply, electrocoagulation
tubes, a  clarifier,  a  filter press, transfer pumps, and
electrical control panel. The clarifier and filter press are
each on stand-alone skids. The cost of fabricating  a skid
mounted CURE system capable of treating flow rates of up
to 100 gpm is approximately $181,200.  The system
 includes a redundant set of electrocoagulation tubes to
 allow for cleaning and maintenance.

 A 6,500-gallon high density polyethylene storage tank
 should be used to store the treated water for analytical
 testing prior to off-site discharge or reuse. An additional
 1,000-gallon  polyethylene water storage tank, costing
$1,000, will  be used; for  equipment  washdown and
decontamination rinse waters.  It is assumed that a 6,500-
gallon tank will be purchased  for a cost of $3,500 and a
1,000-gallon tank for $1,000.

One 46- by 64-foot portable containment berm was costed
to provide secondary containment under the CURE system
and storage tanks.  It is assumed that the berm will be
purchased for $ 10,000. For this analysis, total capital costs
are estimated at $353,700.

3.2.4  Startup

GEC  will  provide trained  personnel to  assemble  and
optimize the CURE treatment system. GEC personnel are
assumed to be health and safety trained for the site of
operations. Therefore, training costs are not incurred as a
direct startup cost in this analysis. This analysis assumes
that startup will take two people approximately 40 hours
each to complete and has a total cost of $5,000.

3.2.5  Demobilization

Site demobilization costs  include berm cleaning  and
equipment decontamination,  plus  site restoration  and
confirmation. Site restoration activities include regrading
or  filling  excavation areas,  and demobilization   and
disposal of all fencing. Total demobilization costs  are
estimated to be approximately $5,000.

A lifespan of 15 years is assumed for the CURE system
and a salvage value of approximately 20 percent of the
original cost, or $36,000.

3.2.6 Labor

Labor costs include a full-time equivalent technician to
operate and maintain the CURE system. Once the system
is functioning, it is assumed to operate continuously at the
designed flow rate.  One  technician will monitor the
 system and equipment, make any required operational
adjustments, conduct  routine  sampling, and provide
 administrative services associated with system operations.

 This analysis assumes a 40-hour work week, 52 weeks per
 year, at an hourly rate of $ 16.83. Annual labor cost will be
 approximately $35,000.
                                                    23

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 3.2.7  Consumables and Supplies

 The consumables and supplies associated with CURE
 system operations include replacement components for the
 CURE system, disposable personal protection equipment
 (PPE), drums for disposing used PPE, and miscellaneous
 items.

 Replacement components  include  electrocoagulation
 tubes, fittings, and other miscellaneous parts on the CURE
 system.  This analysis assumes an annual cost of these
 items of $40,000.

 Disposable PPE includes Tyvek coveralls, gloves, and
 booties.  The treatment system operator will wear PPE
 when required by the health and safety plan during system
 operation.   This analysis assumes  the PPE will cost
 approximately S25 per day, be required approximately 1
 day per week, 52 weeks per year for the duration of the
 project. Total annual PPE costs are estimated to be about
 $1,300.

 Three 55-gallon open-headed, plastic-lined drums  are
 estimated to be  needed for disposing of used disposable
 health and safety and sampling gear, as well as for storing
 nonhazardous wastes for disposal. Total disposal drum
 costs are estimated to be about $100 per year.

 Miscellaneous costs of  $1,000 were included for the
 purchase of miscellaneous small parts and supplies.

 3.2.8  Utilities

 Utilities used by the CURE system include electricity and
 water. The CURE treatment system requires about 200
 gallons of potable water per week. This water is used for
 cleaning and decontamination of the CURE system and
 operators. This analysis estimates water to cost $0.02 per
gallon. Total water costs will be about $4 per week, for a
 total of approximately $200 per year. This cost can vary by
 as much as 100 percent depending  on the geographic
 location of the site, availability of water, and distance to
the nearest water main.

Electricity  to  operate  the  process equipment,  field
laboratory equipment, and air compressor is assumed to be
available at the site. Electricity is assumed to cost $3 per
hour,  or about $26,280 per year.  This analysis assumes
that electricity costs about $0.06 per kilowatt-hour (kWh).
Electricity costs can vary by as  much  as  50 percent
depending on the geographical location and local utility
rates.  No estimate of kWh per 1,000 gallons of water
treated has been calculated.

3.2.9  Effluent Treatment and Disposal

The analysis assumes that the effluent stream will have a
pH from 7.0 to 8.3, and  will not contain regulated
pollutants exceeding EPA  and state discharge  limits;
hence, no further treatment should be needed.  Local
regulations may require discharge to a POTW, which may
result in additional charges to the CURE system operator.
For this analysis, effluent treatment and disposal costs are
estimated at $0  per year.

3.2.10 Residual Waste Shipping
         and  Handling

This analysis assumes that approximately 50 cubic feet per
year of dewatered floe.  Disposal of the floe typically
involves mixing the dewatered floe with a powdered
commercial chemical stabilizing material in 55-gallon
drums. During the SITE demonstration, these drums were
stored at  an EPA- and DOE-approved storage facility.
This estimate  assumes the drums will be classified as low-
level mixed waste and disposal costs for 14 drums of
stabilized floe are estimated at  $6,700.

Drummed PPE will be  screened  for radioactivity and
disposed  of  in accordance  with  state  and  federal
requirements. This analysis assumes that approximately
two drums per year must be disposed of and will be
classified as  low  level  mixed waste.   This analysis
estimates a cost of $1,400 for this disposal.

Decontamination and wash water generated during CURE
system operation are returned to the CURE  system  for
treatment.

3.2.11  Analytical Services

Analytical costs associated with a groundwater remediation
project include  laboratory analyses, data  reduction and
tabulation, QA/QC,  and  reporting.  For each case, this
analysis assumes that one sample of untreated water and
one sample of treated water will be analyzed for gross
alpha  radioactivity,  uranium,  and  metal concentrations
each week, along with QA samples. Monthly laboratory
                                                  24

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analyses  are estimated  at  $1,500;  data  reduction,
tabulation, QA/QC, and reporting are estimated to cost
about $750 per month. Total annual analytical services
costs for each case are estimated to be about $27,000 per
year.
3.2.12 Maintenance and Modifications

Annual  repair and  maintenance  costs  apply to  all
equipment involved in every aspect of ground-water
remediation with  the  CURE  treatment  system.   No
modification costs are assumed to be incurred. Based on
information from GEC, total annual maintenance costs are
estimated to be about $40,000 per year.
                                                  25 ,

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                                             Section 4
                                   Treatment Effectiveness
The  following  sections  describe  the   CURE
electrocoagulation demonstration that was conducted at
RFETS during  August and  September 1995.   The
demonstration was  conducted  as  a cooperative effort
between the DOE, EPA, and Colorado Department of
Public Health and the Environment (CDPHE).

4.1    Background

RFETS is located in northern Jefferson County, Colorado,
approximately 16 miles northwest of downtown Denver
(Figure 4-1).  The 400-acre plant site is located within a
restricted area of approximately 6,550 acres, which serves
as  a buffer zone between  the plant and surrounding
communities.  The immediate area around RFETS is
primarily agricultural or undeveloped land.  Population
centers within 12 miles of the facility include the cities of
Boulder, Broomfield, Golden, and Arvada.

RFETS began operations in 1952, and was a key facility in
the federal government's nationwide nuclear weapons
research, development, and production program.  The
mission of the plant has now changed from production to
decontamination and  decommissioning  of facilities,
environmental restoration, and waste management.

The source of water for the demonstration is the RFETS
SEPs. This series of five evaporation ponds is located in
the central portion of the RFETS, inside the protected area
(PA). This series of ponds was initially placed into service
from August 1956 to June 1960. These ponds were used to
store and  treat liquid process wastes having less than
100,000 pCi/L of total long-lived  alpha activity (DOE
1980).   These  process wastes  also  contained high
concentrations of nitrates, and treated  acidic wastes,
including sanitary sewer sludge, lithium chloride, lithium
metal,  sodium  nitrate, ferric chloride, sulfuric acid,
ammonium persulfates, hydrochloric acid, nitric acid,
hexavalent chromium,  tritium, and  cyanide  solutions
(Rockwell 1988).

Placement of process waste material in the SEPs ceased in
1986 due to changes in waste treatment operations.  In
1994, the sludge and liquid remaining in the A and B ponds
were removed and  placed  in storage tanks  inside
temporary structures erected on the 750 Pad.  Water
decanted from this sludge and liquid (A/B decant water)
was used for the demonstration.

4.2   Review of SITE Demonstration

The SITE demonstration was divided into three phases (1)
site preparation; (2) technology demonstration; and (3)
site demobilization.  The following paragraphs discuss
these activities.

4.2.7  Site Preparation

A total of about 5,500 square feet of asphalt paved parking
lot was used to set up the containment berms, portable
generator, waste storage container, and support facilities.
Site preparation required 10 days to complete.  Site
preparation consisted of setting up the containment berm
used to contain the CURE system, unloading two 6,500-
gallon tanks used to store effluent, setting up  a second
berm to contain the tanker truck delivering the water to be
treated by the system, and setting up the hoses required to
bring the water from the tanker truck to the CURE system
and then to the storage tanks.

4.2.2  Technology Demonstration

Prior to conducting the demonstration, GEC conducted six
preruns and five optimization runs over an 11- day period.
The preruns allowed for testing of the system integrity and
confirmation that all equipment was functioning properly.
                                                  26

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                                                                      U.S. DEPARTMENT
                                                                      OF ENERGY
                                                                      ROCKY FLATS
                                                                      ENVIRONMENTAL
                                                                      TECHNOLOGY SITE
                                  INDUSTRIALIZED
                                       AREA
                                                 ENVIRONMENTAL
                                                 TECHNOLOGY
                                                 SITE
Figure 4-1.  Site location map.
                                     NOT TO  SCALE
                                                           27

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 Clean process water was used in all of the preruns.  The
 optimization runs  were used to configure the CURE
 electrocoagulation  system  for  optimal removal  of
 contaminants from the process influent. Parameters that
 were adjusted include the annular space between the tubes,
 the diameter of the tubes, the number of tubes, the tube
 material and the sequence, electrical potential, electrical
 current, and flow rate.

 Approximately 4,500 gallons of contaminated water were
 treated by the CURE system during four  demonstration
 runs conducted over a 2-week period.  The run schedule
 was set up to allow alternating days for demonstration runs
 and system cleanup due to the  operating  schedule at
 RFETS.

 All four runs were conducted using the same operating
 parameters. These parameters were set on the basis of the
 optimization run results.  The demonstration runs were
 conducted to assess the ability of the CURE system to
 consistently  produce  treated  water  meeting  the
 demonstration goals. Sampling activities were performed
 in tvvo phases for each run.  Each run was initiated by
 running    process  water  through  the   CURE
 electrocoagulation  system to the clarifier.  The field
 parameters specific conductance, pH,  dissolved oxygen
 and temperature of the effluent from the CURE tubes were
 measured every 5 minutes for 30 minutes  after pumping
 commenced.  Filling  the  450-gallon  clarifier took
 approximately 2.5  hours. Once the clarifier was full,
 samples of untreated influent, effluent from the clarifier,
 and effluent from the clarifier that was filtered through a
 40-micron filter were collected every  20  minutes for 3
hours. These samples were analyzed for the radionuclides
uranium, plutonium, and americium. The field parameters
were also measured at the two sample locations at the time
of sample collection. Samples were also collected for total
metals analysis at the two sampling locations in runs 1 and
3. The runs were terminated after the last samples were
collected. Dewatered sludge samples were collected after
 each  run and analyzed  for uranium, plutonium,  and
 americium. The TCLP was also performed on the sludge.
 Sludge samples from runs 1 and 3 were also analyzed for
total metals.

4.2.3 Site Demobilization

 Site demobilization activities began after the demonstration
was complete.     Demobilization  activities  included
draining the two  6,500-gallon process  water tanks;
disconnecting the portable generator; and decontaminating
and removing the treatment system, the two 6,500-gallon
storage tanks, and the two temporary berms.

The  CURE system was  decontaminated with high-
pressure  steam at the  RFETS decontamination pad.
RFETS personnel decontaminated the two 6,500-gallon
storage tanks while they were inside the berm by spraying
the tank interiors with  water.  This wastewater was
pumped to a tanker truck and taken to Building 374 for
final treatment.  Rinsate samples were  collected and
analyzed for attainment of the performance standards in
Part  VIII of the Rocky Flats  RCRA  permit.  EPA
decontaminated the larger of the two temporary berms
with non-phosphate detergent and water.

The CURE system, the two 6,500-gallon tanks, and the
berm  were screened for radioactive contamination by
RFETS personnel. The CURE system and the berm were
released by RFETS personnel after the analytical results
indicated that  the decontamination procedures were
successful.

Because  RFETS  personnel  decided  that  additional
analyses of the tank rinsate wastewater was necessary, the
removal schedule for the  tanks and the smaller inflatable
berm was delayed.  Both of the tanks and the inflatable
berm, on which the tanks were setting, remained on-site
for three weeks after the  demonstration. After the tanks
were picked up  by the vendor, the smaller, inflatable berm
was decontaminated with non-phosphate  detergent and
water by EPA.

4.3    Demonstration Methodology

The technology demonstration was designed to address
two primary and eight secondary objectives. The primary
objectives were  to  document 90  percent  CREs  for
uranium, plutonium, and americium to the 95 percent
confidence level; and to determine if CURE could treat the
waste stream to radionuclide contaminant levels below
CWQCC standards atthe 90 percent confidence level. The
data required to achieve  these objectives are called the
critical parameters.  They include  uranium, plutonium,
and americium concentrations in the influent and effluent.

The secondary objectives were as follows:

   •    Evaluate anode deterioration
                                                  28

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    Demonstrate CREs for arsenic, boron, cadmium, cal-
    cium, lithium, magnesium, TOC, TDS, and TSS of
    90 percent or higher at the 90 percent confidence level

*   Document production of hydrogen and chlorine gas-
    ses

•   Determine power consumption by the CURE elec-
    trocoagulation system

•   Determine optimum system operating parameters for
    treatment of A/B decant water

•   Document selected geochemical parameters (pH, Eh,
    specific conductivity, and temperature) that may af-
    fect the effectiveness of the CURE electrocoagula-
    tion system

•   Determine uranium, plutonium, americium, and TCLP
    metals teachability from the flocculent by TCLP

•   Estimate capital and operating costs of building a
     single treatment unit to operate at the rate of 100 gpm

 Secondary objectives provide information that is useful,
but not critical, to the evaluation of the system.  Data
required to achieve the secondary objectives are called
noncritical parameters.  These parameters include:

 •    Periodic visual inspection of the electrodes and docu-
     mentation of their replacement

 •    Influent and effluent concentrations of arsenic, bo-
     ron, cadmium, calcium, lithium, magnesium, TOC,
     and TSS

 •    Air monitoring results for chlorine and hydrogen gas
     at the point where the treated water leaves the elec-
     trocoagulation tubes

     Documentation of the quantity of fuel used by the
     CURE electrocoagulation system and the volume of
     water treated

 •    Documentation of the length of the electrocoagula-
     tion tubes, the annular space between them, the num-
     ber of tubes, the tube material, the number of passes
     through the tubes, the flow rate, the electrical cur-
    rent, and the applied, potential throughout the dem-
    onstration, including the optimization runs

    Periodic measurement of pH, Eh or dissolved oxy-
    gen, specific conductance, and temperature of both
    the influent and effluent

•   Concentrations of TCLP metals and radionuclides in
    the resultant leachate from a TCLP performed on a
    sample of the flocculent

•   Documentation of all costs associated with the dem-
    onstration and an estimation of construction costs

4.3.1  Testing Approach

The CURE electrocoagulation demonstration consisted of
six preruns, five optimization runs, and four demonstration
runs.  The preruns were conducted using clean process
water to test the fittings, piping, and overall integrity.

The optimization runs were used to determine the best
operating conditions for the system.  Parameters such as
the tube material, annular space between the tubes, the
flow rate, and the electrical current were adjusted  during
these runs. These parameters were adjusted in response to
observations of the technology developer and the water
quality   parameters  pH,  dissolved  oxygen,  specific
conductivity,  and  temperature.  Operating  parameters
were also adjusted based on results from quick turn around
 of gross alpha analysis of treated water samples.

 Four  demonstration runs were completed to achieve the
 primary objectives as stated in Section 4.3. Influent and
 effluent water samples were obtained from sampling ports
 LI and L2 (Figure 4-2). Sample results of influent and
 effluent were compared to evaluate the CRE of the CURE
 system. During each 3-hour test run, composite samples of
 influent and effluent were collected each hour from grab
 samples taken at 20-minute intervals. Composite samples
 were collected  to reduce  variability in radionuclide
 concentrations due to inherent system changes.

 QA/QC samples including matrix spikes and matrix spike
 duplicates  (MS/MSD), duplicates, process equipment
 blanks, and sample bottle blanks were collected to evaluate
 the variability associated with the analytical and sampling
 procedures.
                                                    29

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SAMPLE COLLECTION
OR MEASUREMENT LOCATION
Influent from
Solar Pond
Decant Water
Effluent from
CURE Treatment
System
Filter Cake
Power Supply
LOCATION
IDENTIFIER
L1
M1
L2
M2
S1
M3
M4
M5
MATERIAL
Untreated Water
Untreated Water
Treated Effluent
Treated Effluent
Filter Cake
Filter Cake
None
MONITORING
ACTIVITY
Sample Collection
Measurement
Sample Collection
Measurement
Sample Collection
Measurement
Measurement
Measurement
PARAMETERS
Water Chemistry
Flow Rate, Pumping Period, .
Water Characteristics
Water Chemistry
Water Characteristics
Solids Chemistry and
Characteristics
Volume
Voltage, Amperage
Voltage, Amperage
                                                                      x

                                                                     	1

                                                                       M

                                                                       S
                                                                               Valve
Flow Direction

Measurement
Location
Solid Sample
Collection Point

Liquid Sample
Collection Point
                                                                                                                 Screen
                                                                                                                 Sample
                                                                                                                 Port
                                                                                                                 Cure Tubes
Figure 4-2. Sampling and measurement locations.
                                                               30

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The  following approaches were used to achieve the
demonstration's secondary objectives:

     Samples were analyzed to demonstrate the CREs for
     metals, TOC, TDS, and TSS and to evaluate anode
     deterioration

     Field parameter and water quality measurements were
     obtained every 20 minutes throughout each run to
     confirm system stability for the duration of each run.

     Samples of dewatered sludge were obtained to deter-
     mine metals leachability (including radionuclides)
     from the flocculent by TCLP for waste characteriza-
     tion.

     The volume of sludge generated by the treatment pro-
     cess was measured.

     All costs associated with each phase of the demon-
     stration were documented.
 4.3.2  Sampling Analysis and
        Measurement Procedures

 Water  samples  were  submitted  for  total  uranium,
 plutonium-239/240, and americium-241 analysis. Water
 samples from test runs 1 and 3 were also analyzed for total
 metals, TOC, TDS, and TSS.  Samples of influent and
 effluent were obtained at locations LI and L2 shown in
 Figure 4-2. In addition, sludge samples were submitted for
 total uranium, plutonium-239/240, and americium-241
 analysis.  Sludge samples from test runs 1 and 3 were also
 analyzed for total metals, TOC, bulk density, and moisture
 content.  Sludge samples were collected after test runs 1
 and 3 for TCLP analysis.

 In addition to  sampling  and analysis  for chemical
 parameters,  the  operating  conditions of the treatment
 system  were evaluated using  the measurement data
 collected at locations LI and L2 shown in Figure 4-2.  For
 runs 1 through 4, pH,  specific conductivity, dissolved
 oxygen, and temperature were measured at sampling ports
 LI (influent) and L2 (effluent).  Voltage and amperage
 measurements were taken from gauges installed on the
 treatment system (Ml,  M4, and M5).  These sampling
 locations are  shown in Figure 4-2.  Flow rate was
 calculated from time and volume measurements for each
demonstration run. Power consumption was measured by
the amount of diesel'fuel used by the portable generator.

4.3.3 Operational and Sampling
       Problems and Variations from the
       Work Plan

Originally, the CURE SITE demonstration was scheduled
to be completed in 35 days. The SITE team, consisting of
EPA's contractors and DOE's operating contractor at
RFETS, experienced several operational problems during
the demonstration.  Some of these problems resulted in
changes  in  the  demonstration schedule,  while  others
required  making decisions  in the field to solve the
problem.   Some  of these  changes also resulted in
deviations from  the work plan contained in the quality
assurance project plan (QAPP) (EPA 1995b). As a result
of these operational problems, the demonstration was
completed over a period of 5 3 days.  Site preparation was
completed in 10 days; the preruns, optimization runs, and
demonstration runs were completed in 14 days; and
decontamination and demobilization was completed in 29
days. The problems encountered during the demonstration
and their solutions are presented below. Deviations from
the work plan are also presented.

 •   Pressure buildup within the treatment system due to
     an accumulation office in the electrocoagulation tubes
     and  clogging of bag filters resulted in leaks within
     the system.  These problems led to delays in the origi-
     nal demonstration schedule and resulted in several
     additional optimization runs and a retrofit of the treat-
     ment system.  The inner pipes were replaced with
     smaller diameter pipes to allow for more annular space
     between the tubes. In addition, nylon screws were
     placed along the length of each tube to keep the inner
     tube centered within the outer tube. This allowed floc-
     culent to pass more easily through the annular space.
     However, the tubes still required cleaning after each
     run to prevent pressure buildup and to allow data from
     all runs to be comparable.

     As dictated by the CURE demonstration health and
      safety plan (EPA 1995c),  screening of all personnel
     for alpha and beta radiation by RFETS radiation con-
     trol technicians was required upon exiting the bermed
      area. Therefore, the SITE team was constrained by
      the radiation control personnel work schedule which
      also resulted in shorter work days.
                                                    31

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 The bag filters attached to the clarifier filled with floc-
 culent and clogged very easily. The bag filter size
 was changed from 1 micron which was used during
 preruns and optimization runs, to 25 microns for dem-
 onstration runs 1,2, and 4. In addition, a 50- micron
 bag filter was used during run 3 to allow for increased
 flow.

 Samples obtained during demonstration runs were
 alkaline, with a pH range of 7.7 to 9.6. Large quanti-
 ties of acid were required to bring the sample pH to
 2.0 for preservation, as stated in the work plan. The
 addition of large quantities of acid led to generation
 of gases in the samples. Therefore, acid was added
 in small increments to each sample to control effer-
 vescence. This procedure took much more time.

 The work plan  stated that two 6,500-gallon tanks
 would be used during the demonstration.  One tank
 to contain untreated water removed from A and B solar
 pond sludge (A/B decant water) and the other to con-
 tain treated water. However, both tanks were used to
 contain treated water. The untreated A/B decant wa-
 ter remained in the tanker truck used to transport water
 to and from the demonstration site. The tanker truck
 was parked inside an inflatable berm to contain any
 potential spills.

 The work plan stated that the length and diameter of
 the clectrocoagulation tubes and the  type of metal
 tubes used (Al or Fe), were to be determined before
 bringing the treatment system on site. The work plan
 also stated that only flow rate and amperage would
 be changed during the preruns and optimization runs.
 However, because of pressure buildup in the system,
 flow rate, amperage, and tube diameter were changed
 during the preruns and optimization rums.  Iron was
 the only tube material used.

 An effluent process blank was added before com-
 mencement of run 1 to evaluate the flushing efficiency
 of the treatment system. This additional sample was
 not included in the original work plan.

 As stated in the work plan, treated effluent was to be
 routed  to the  clarifier to  allow for the settlement of
 flocculent generated by the treatment system. How-
 ever, the developer was concerned that the small-ca-
pacity clarifier would not be able to handle the flow
     rates used during the treatment process. Therefore,
     samples obtained would not represent the treatment
     capability of a larger capacity clarifier, as originally
     proposed. Because of this issue, two samples of ef-
     fluent water were obtained from sampling port L2.
     One sample remained unfiltered and the other sample
     was filtered after collection into the composite con-
     tainer.  This sample was filtered using a 40-micron
     filter to mimic settling within a larger capacity clari-
     fier as originally proposed in the work plan.  Samples
     were filtered during transfer from the composite
     sample collection container to individual sample
     bottles.

     The work plan stated that a constant flow rate of 5
     gpm would be used throughout runs 1 through 4. As
     a result of the optimization runs, the flow rate used
     for runs 1 through 4 was 3 gpm.

 During the field QA audit of the demonstration, it was
 noted by the EPA auditor that the reality short operating
 runs required by the operating conditions at the site may
 not be  representative of the typical use  of the CURE
 system. Therefore, long-term operating efficiency of the
 CURE system should be extrapolated with caution from
 the limited data collected during the demonstration.
4.4    Review of Demonstration
        Results

This section discusses demonstration results in terms of
the  optimization runs  and  results for  critical and
noncritical parameters.  The  system optimization was
performed to determine the most effective configuration of
the system for treatment of the A/B decant water from the
SEPs at RFETS.
4.4.1 Summary of Results for
       Optimization Runs

Five optimization runs were conducted to determine the
most  effective  configuration  of  the  CURE
electrocoagulation system for treating A/B decant water at
RFETS.  Variable parameters included tube material,
diameter, length,  and number; annular space between
tubes; flow rate; number of passes through the system; and
applied potential (and associated electrical current).
                                               32

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The  configuration  used for the  demonstration  are as
follows:

•    Iron tube material
•    Three pairs of concentric tubes
•    0.1-to 0.5-inch annular space             '
•    One pass through each tube
•    Flow rate of 3.0 to 3.1 gpm
•    Applied potential of 20 to 57 volts and accompany-
     ing current of 135 to 168 amperes

4.4.2 Summary of Results for Critical
       Parameters

A comparison of the first two test runs with the last two
runs indicates that CWQCC standards for plutonium and
americium are most likely to be  met when the influent
concentrations of plutonium and americium are low, while
the  CREs  are  greatest when  concentrations  of these
contaminants are higher. However, higher concentrations
of plutonium and  americium may be  associated with
suspended  solids,  and a  significant  portion may be
removable by prefiltering or settling of the treatment water
prior to treatment.

CREs for Uranium, Plutonium, and Americium

Samples for uranium, plutonium, and americium analysis
were collected from the inflow to the treatment system and
the outflow of the clarifier during  each run.  Both filtered
and unfiltered samples were collected at the outflow of the
clarifier. The filtered samples were passed  through a 40
micrometer  (um) nominal pore size filter.   CREs were
calculated for each test run using composite data from
influent  and both the filtered and unfiltered effluent
concentrations.  The results are presented in Table 4-1.

Analytical results  from the  four runs  indicate that the
source water contained similar concentrations of uranium
throughout the demonstration.  However, the plutonium
and americium  concentrations varied.  Plutonium and
americium tend to sorb to  particulates.  Therefore, the
variation in influent concentrations  for these  metals is
likely  an artifact  of positioning of the  tanker truck
supplying the source water resulting in different amounts
of sediment being pumped into the system.  The first two
runs were conducted with mean influent concentrations of
0.221 and 0.197 pCi/L of plutonium, and 0.202 and 0.172
pCi/L americium. Plutonium and americium concentrations
for runs 3 and 4 were more than 100 times these values.
CREs were calculated for each run based on mean influent
and effluent concentrations (see Table 4-1). The mean
CREs for uranium were 43 percent for unfiltered effluent
and 44 percent for filtered. While these results indicate
that uranium concentrations were reduced considerably,
the objective of 90 percent contaminant removal was not
achieved.  Uranium removal was not as high as expected
based on  results of the bench-scale  treatability study.
Results  from the treatability  study indicated at least 94
percent removal efficiency for uranium, with an influent
uranium concentration that was comparable to the influent
concentration in the demonstration.

It is likely that the  operational parameters used in the
demonstration  were not optimal for  uranium removal.
More  complete  system  optimization  and  treating
wastewater with multiple runs through the CURE system
may improve uranium removal efficiencies.

The  removal efficiencies for plutonium and americium
were much higher than for uranium. Results from run 1 are
comparable to those of run 2, and results from runs 3 and 4
are comparable.  However, results from runs 1  and 2 are
very different than results from runs 3 and 4. Therefore,
the results from the first two runs are presented separately
from the results  of runs 3 and 4.  The reason for such
different results appears to be related to the higher influent
concentrations of plutonium and americium in runs 3 and
4.

The  average CRE for plutonium in the first two runs was
72 percent for the unfiltered effluent and 83 percent for the
filtered effluent.  Average CREs for americium were 74
percent for unfiltered and 70  percent for filtered effluent.
These results are below the 90 percent removal  objective,
although significant removal  was observed.

Higher influent concentrations of plutonium, americium,
and TSS were observed in the influent  for runs 3 and 4. A
change in the orientation of the tanker truck supplying the
system with influent was likely responsible for this.  The
increased concentration of TSS, along with the sorptive
nature of these two radionuclides,  suggests  that the
plutonium and americium were primarily in the solid or
sorbed state, and that prefiltering may  have reduced these
influent  concentrations considerably.  The  CREs for
plutonium and americium in runs 3  and 4 were all 97
percent  or better.     However,  the treated effluent
concentrations of these contaminants for both runs was
higher than the influent concentration for runs 1 and 2.
                                                   33

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Table 4-1. Radionuclide Concentrations in Wastewater
Parameters
Units
Run 1 Influent
Effluent (unfiltered)
CRE
Effluent (filtered)
CRE
Run 2 Influent
Effluent (unfiltered)
CRE
Effluent (filtered)
CRE
Run 3 Influent
Effluent (unfiltered)
CRE
Effluent (filtered)
CRE
Run 4 Influent
Effluent (unfiltered)
CRE
Effluent (filtered)
CRE
Notes:
pCi/L KcoCuries per liter
fig/L Micrograms per liter
CRE Contaminant removal efficiency
Uranium
we/L
2,800
1,900
32%
1,900
32%
2,900
1,600
44%
1,600
44%
2,600
1,400
46%
1,400
47%
2,600
1,300
51%
1,300
52%


Plutonium
nCi/L
0.221
0.082
63%
0.041
82%
0.197
0.039
82%
0.032
84%
33.1
1.03
97%
0.434
99%
26.6
0.706
98%
0.199
99%


Americium
DCi/L
0.202
0.051
75%
0.062
69%
0.172
0.049
72%
0.051
71%
83.5
2.49
97%
0.755
99%
60.5
1.46
98%
0.342
99%


                                                       34

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Confidence limits cannot be calculated for these results
because results for more than two tests are required for the
calculations.

CWQCC Standards for Uranium, Plutonium, and
Americium

CWQCC discharge standards are 15 g/L for uranium, and
0.05 pCi/L for both plutonium-239/240 and americium-
241. CWQCC standards for uranium were not met during
the  CURE demonstration.  The lowest average effluent
concentration of uranium for any run was 1,270  g/L, more
than 250  times the CWQCC standard.  However,  a
minimum  CRE  of 99.8 percent would be required to
achieve the CWQCC standard with the influent water used
in this demonstration.

CWQCC standards for plutonium were met for the filtered
effluent of run  1  and both the unfiltered and filtered
effluent of run 2, and the CWQCC standard for americium
was met in the unfiltered effluent of run 2. The highest
average effluent concentration of both contaminants in
runs 1  and 2 was 0.0817 pCi/L,  which is 63.4 percent
higher than the CWQCC standard. The CWQCC standard
for these contaminants was exceeded by 398 percent or
more in both runs 3 and 4.
4.4.3 Summary of Results for
       Noncritical Parameters

Anode Deterioration

Examination of the electrocoagulation tubes revealed
severe thinning of the tube walls, indicating that extensive
anode deterioration had occurred during the demonstration
runs.  Sludge and effluent iron concentrations from test
runs 1 and 3 suggest that nearly all of the tube material
precipitates.  These results are presented in Tables 4-2 and
4-3.

CREs for Other Contaminants

Table 4-4 lists the influent and effluent metals, TOC, TDS,
and TSS  concentrations  for  runs  1  and 3.   These
constituents were not analyzed in runs 2 and 4. Arsenic
removal was the most significant with an average CRE for
the two  runs of 77  percent.   Calcium removal  was
unexpected,  but  averaged approximately  50 percent.
Magnesium and TOC removals were slight with 15 and 12
percent averages, respectively. No significant removal of
boron, lithium,  or  TDS was  observed,  and  iron
concentrations in the effluent increased by more than an
order of  magnitude in both runs.  CREs could  not be
Table 4-2. Metal Content in Dewatered Sludge
Parameter
Aluminum
Arsenic
Boron
Cadmium
Calcium
Iron
Lithium
Magnesium
Units
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
Runl
<10.0
5.5
<10.0
<0.50
282
19,800
<5.0
1,120
Run 3
33.0
17.8
15.6
0,65
2,400
49,800
<5.0
1780
      Notes:

      mg/kg milligrams per kilogram
       <     less than reported detection limit
                                                  35

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        Table 4-3. Metals Concentrations in Wastev/ater
U)
0\
Parameter
Aluminum
Arsenic
Boron
Cadmium
Calcium
Iron
Lithium
Magnesium
TOC
IDS
TSS
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Avg Influent
<0.20
0.11
2.6
<0.01
16.3
NA
2.3
122
128
8,410
10.5
Raul
Avg Effluent
(Unfiltered)
<0.20
0.026
2.53
<0.01
9.73
12.5
2.27
100
78.7
8,330
32.4
Avg Effluent
(Filtered)
NA
0.0237
2.47
<0.01
10.4
6.4
2.27
99.4
108
8,270
18.4
Avg Influent
0.29
0.1367
2.47
<0.01
42.6
0.257
2.1
126
106
8,510
50.4
Run 3
Avg Effluent
(Unfiltered)
<0.20
0.0343
2.43
<0.01
19.1
12.1
2.07
110
111
8,460
54.23
Avg Effluent
(Filtered)
<0.20
0.0287
2.5
<0.01
19.3
5.27
2.13
112
113
8,360
31.2
CWQCC*
Standards .
0.1
0.05
0.75
0.0015
NS
0.3
NS
NS
NS
NS
NS
        Notes:
        mg/L  milligrams per liter
        <     less than reported detection limit
        NA    not analyzed
        NS     no standard

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Table 4-4. Radionuclide Content in Dewatered Sludge
        Parameter
Units
     Notes:

     mg/kg milligrams per kilogram
     pCi/L picoCuries per liter
Runl
Run 2
Run 3
Run 4
Uranium
Plutonium
Americium
mg/kg
pCi/g
pCi/g
77
0.189
0.182
120
0.178
0.115
120
34.0
95.8
96
23.0
66.4
 determined  for  aluminum or  cadmium because  the
 concentrations were too low in both the influent and the
 effluent.    Changes  between  influent   and  effluent
 concentrations of TSS are inconsistent, suggesting that
 residence time in the clarifier was not sufficient to
 adequately remove the solids from suspension.

 Hydrogen  and Chlorine Gas Production

 Chlorine and hydrogen gases were possible by-products of
 the electrocoagulation process. Results of air monitoring
 over the open clarifier during the test runs did not indicate
 a hazard due to  emission  of these  gases  under the
 conditions of the demonstration.

 Power Consumption

 The CURE  treatment system was operated using a diesel
 powered 50-kilowatt generator. Fuel consumption during
 the demonstration was approximately 8 gallons per hour of
 operation of the CURE treatment system.

 Optimum  Operating Parameters

 The results  of the five optimization runs indicated that the
 following operating parameters would be adequate for
 treating the A/B decant water with the CURE system:

 •    Iron tube material for all tubes

 •    10-foot long electrocoagulation tubes
                                0.1 to 0.5 inch annular spacing between inner and
                                outer tubes

                                Three 10-foot long tube sets (concentric pairs)

                            •   One pass through each tube

                                Flow rate of 3.0 to 3.1 gpm

                                Applied potential of 20 to 57 volts to achieve an elec-
                                trical current of 135 to 168 amperes

                            These are the conditions used for all four demonstration
                            runs.

                            Geochemical Characteristics

                            The four water geochemical characteristics—pH, specific
                            conductivity, dissolved oxygen, and temperature—were
                            measured at 20-minute intervals throughout the four test
                            runs.  Measurements were taken for both the influent and
                            effluent waters.  Table 4-5 summarizes these parameter
                            measurements.

                            Influent  and effluent pH were similar throughout the
                            demonstration.  Generally, pH varied between 8.5 and 9.5,
                             although extremes of 7.77 and  9.66 were recorded.
                            Average specific conductivity at LI was 10.9 millisiemens
                            per centimeter (mS/cm), and that at L2 was 11.4 mS/cm.
                             These results  suggest that some ions in solution were
                             replaced with more conductive ones by the CURE system,
                                                    37

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        Table 4-5.  Geochemical Characteristics Summary
                                                                                      Parameter Range
00
Run Sample Port
1 LI
L2
2 LI
L2
3 LI
L2
4 LI
L2
pH
8.73-8.86
8.55-9.48
8.88-9.21
7.86-9.66
8.70-8.92
8.23-9.60
8.56-8.73
7.77-8.95
Specific
Conductivity
(mS/cm)
10.2-10.6
9.5-11.9
11.2-11.8
10.7-11.4
9.54-11.9
11.0-12.3
10.9-11.5
10.6-11.9
Dissolved
Oxygen
(mg/L)
1.90-3.60
ND*-8.69
1.70-2.54
ND-3.10
1.11-2.44
ND-2.38
1.58-2.81
ND-3.06
Temperature (°C)
28.2-30.2
29.6-36.3
27.2-29.2
27.7-35.4
28.1-30.5
27.1-35.7
26.2-27.0
27.7-33.8
Potential (V)
20-57
20-57
23-57
22-57
25-50
25-50
25-52
25-52
Current
(Amp)
135-160 •
135-160
138-158
138-158
140-168
140-168
150-162
150-162
Flow (gpm)
3.0-3.1
3.0-3.1
2.8-3.1
2.8-3.1
3.0
3.0-3.1
3.0-3.1
2.9-3.1
Pressure
(psO
73-83
74-83
43-59
43-59
29-43
29-43
21-23
21-23
         *ND = Not detectible, detection limit approximately 1 mg/L

         Notes:

         mS/cm  millisiemens per centimeter
         mg/L   milligrams per liter
         °C      degrees Celsius
         V       volts
         A       amperes
         gpm    gallons per minute
         psi      pounds per square inch

-------
although TDS did not change. This may occur by breaking
bonds  in  uncharged complexed  ions  in  the  influent
solution.

The influent typically contained between 2.0 and 3.0 mg/
L  dissolved  oxygen,  indicating  slightly  reducing
conditions.  Dissolved oxygen  content of the effluent
during the first 30 minutes of operation indicate that
oxygen is depleted from  the  process water by the
formation of the  floe in the CURE system.  Effluent
between the CURE system and the clarifier did not contain
measurable concentrations of oxygen during this time.
Later measurements were collected at the outlet from the
clarifier. These measurements indicated similar reducing
conditions to the influent.   These results  suggest that
oxygen is the limiting reagent  in the formation of the
flocculent, and that aerating the influent may increase the
removal efficiency of the system by precipitating more of
the iron in the effluent.

Temperature of the influent during the three hours after the
clarifier had filled was similar to the temperature of the
effluent during the first  30 minutes of operation, but
measurements made after the clarifier had filled were as
much  as  6°C higher than the  influent. These results
suggest that the water in the clarifier had been warmed by
the  warm   days.    Temperature  comparisons  are
inconclusive  since temperature measurements of the
influent were not made during the  first 30 minutes of
operation, and heating of the process water in the tanker
truck may have occurred during  the day.
                                  TCLP Results

                                  Tables 4-2 and 4-4 show the metals and radionuclides
                                  content in the dewatered sludge. Results indicate that the
                                  radionuclides were highly concentrated in the dewatered
                                  sludge, especially plutonium and americium  in sludge
                                  from runs 3 and 4.  Table 4-6 presents TCLP results for
                                  radionuclides. Although no TCLP regulatory limits exist
                                  for uranium, plutonium, and americium, these radionuclides
                                  were analyzed to characterize the leachability of the waste.

                                  Analyses of the  TCLP leachate indicate that uranium
                                  concentrations  in the  leachate exceed  the  CWQCC
                                  standard of 15  g/L by as much as a factor of 30, while
                                  plutonium and americium concentrations are below or
                                  near their standard of 0.05 pCi/L.  For comparison, it
                                  should be noted that the maximum concentration for the
                                  toxicity characteristic for the TCLP metals is typically 100
                                  times that of the EPA MCLs for groundwater (EPA 1995a
                                  and 1995b).

                                  TCLP results indicate that metals were not detected above
                                  TCLP detection limits.  These results suggest  that the
                                  sludge is stable and metals are resistant to leaching.

                                  Operation Costs

                                  A detailed cost analysis is presented in Section 3 of this
                                  report.  The analysis examined  costs for a 100  gpm
                                  treatment system operating for 1, 5, and 10 years. Costs
                                  ranged from $0.009  per treated  gallon for the 1-year
 Table 4-6. Radionuclide Concentration in TCLP Leachate
            Parameter
         Notes:

         mg/L
         pCi/L
          Units
Runl
Run 2
Run 3
Run 4
Uranium
Plutonium
Americium
mg/L
pCi/L
pCi/L
0.44
0.014
0.0049
0.21
0.022
0.022
0.32
0.055
0.160
0.25
0.081
0.270
Milligrams per liter
PicoCuries per liter
                                                    39

-------
operation to $0.003 per treated gallon ,for the  10-year
operation.  Actual costs will vary based on type and
location of installation.

4.5   Conclusions

The primary objectives of the CURE electrocoagulation
demonstration  were not met.   However,  removal of
radionuclides in  the A/B decant water at RFETS was
significant,  and   CWQCC   standards  were  met for
plutonium and americium in some cases, but the target
confidence level of 95 percent was not met.

Significant removal  was also observed for arsenic (74
percent) and calcium (50 percent) indicating that CURE
effectively reduces concentrations of these elements.

TCLP  analyses  of  sludge produced  by  the  CURE
technology during this  demonstration indicate  that the
solid wastes may be classified as nonhazardous.
                                                  40

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                                             Section 5
                                      Technology Status
The  CURE technology has  been installed in many
industrial  locations.    According  to  the  technology
developer, installed applications include metals removal
from plating companies and manufacturing  operations,
steam cleaning, bilge water treatment, drilling  fluids,
groundwater, mine waters, paint booths, and food industry
wastes.  Additional testing has been performed on many
other industrial wastewaters.
The treatment unit used in this demonstration is trailer
mounted and ready for use. It can be mobilized to any site
on short notice for testing. GEC is currently constructing
a transportable treatment unit that will be  capable of
treating wastewater at a rate of approximately 50 gpm. The
unit will be mounted on a trailer that can be transported by
a semitractor.  It is not known  when this unit will be
available for service. Waste streams greater than 50 gpm
will require a larger CURE system.  These systems are
custom designed for the application.
                                                   41

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                                            Section 6
                                           References
Barkley, N.P., C.W. Fan-ell, and T.W. Gardner-Clayson.
     1993.  Alternating Current Electrocoagulation for
     Superfund Site Remediation. J. Air & Waste Mgmt.
     Assoc. Volume 43, Number 5. Pages 784-769.

Dalrymple, C.W.  1994. Electrocoagulation of Plating
     Wastcwaters. American Electroplaters and Surface
     Finishers Society Environmental Protection Agency
     15th Conference on Pollution Prevention and Con-
     trol. January.

Drever, James I.  1988.  The Geochemistry of Natural
     Waters. Prentice Hall. Englewood Cliffs, NJ. Sec-
     ond edition.

EG&G Rocky Flats, Inc. (EG&G).  1991. Pond Sludge
     and Clarifier Sludge Waste Characterization Report.

Evans, G. 1990.  Estimating Innovative Technology Costs
     for the SITE Program. Journal of Air and Waste
     Management Association, 40:7, pages 1047 through
     1055.

Hydrologies, Inc.  1993. CURE - Electrocoagulation
     Wastewater Treatment System, USEPA Superfund
     Innovative Technology Evaluation (SITE) Program,
     Proposal No. SITE-008,05.

Jenke, Dennis  R. and Frank  E. Diebold.   1984.
     Electroprecipitation Treatment of Acid Mine Waste-
     water. Water Research. Volume 18, Number 7. Pages
     855-859.

Office of Federal Register. 1993. Code of Federal Regu-
     lations Title 40, Protection of Environment.  U.S.
     Government Printing Office. Washington, D.C. July
     1993.
Renk, R.R.  1989. Treatment of Hazardous Wastewaters
    by Electrocoagulation. Proceedings Ninth National
    Symposium on Food Processing Wastes, Denver,
    Colorado, Page 264. EPA-600/2-78. August.

Rockwell International. 1988. Rockwell International Cor-
    poration, Resource Conservation and Recovery Act,
    Post Closure Care Permit Application, Appendix 1-
    2, Solar Evaporation Ponds. July. Golden, CO.

Sawyer, ClairN. and Perry L.McCarty.  1978. Chemistry
    for Environmental Engineering.  McGraw-Hill Book
    Co.  New York. Third edition.

U.S. Department of Energy (DOE).   1980. U.S. Depart-
    ment of Energy, Rocky Flats Plant, Final Environ-
    mental Impact Statement, DOE/EI5-0064.

U.S. Environmental Protection Agency (EPA). 1991. Fed-
    eral Facility Agreement and Consent Orders.  Den-
    ver, Colorado. January.

EPA.  1994. Test Methods for Evaluating Solid Waste,
    Volumes IA-IC:  Laboratory  Manual, Physical/
    Chemical Methods; and Volume II:  Field Manual,
    Physical/Chemical Methods, SW-846, Third Edition
    (revision 3), Office of Solid Waste and Emergency
    Response, Washington, D.C.

EPA.  1995a.  Superfund Innovative Technology Evalua-
    tion Program CURE Electrocoagulation Technology
    Treatability Study Report.  July  10.

EPA.  1995b. Final Quality Assurance Project Plan for
    General Environmental Corporation CURE Electro-
    coagulation Technology Demonstration at the Rocky
    Flats Environmental Technology Site, Golden, Colo-
    rado. July.
                                                  42

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EPA.  1995c.  Final Health and Safety Plan, CURE SITE
    Demonstration, Rocky Flats Environmental Technol-
    ogy Site, Golden, Colorado.  August.
Vik, EilenA., Dale A. Carlson, Arild S. Eikum, andEgilT.
    Gjessing.  1984.  Electrocoagulation of Potable Wa-
    ter. Water Research. Volume 18, Number 11. Pages
    1355-1360.
                                                   43

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                                            Appendix A
                            Vendor Claims for the Technology
 This appendix presents the claims made by the vendor,
 General Environmental Corporation (GEC), regarding the
 CURE technology under consideration. This appendix
 was written solely by GEC, and the statements presented
 herein represent the vendor's point of view based on
 demonstrations and commercial  operation performed
 since 1990.  Publication here does not indicate EPA's
 approval or endorsement of the statements made in this
 section; EPA's point of view is discussed in the body of
 this report.

 The demand for improved methodologies and technologies
 to remove metallic pollutants from water has increased
 dramatically during the past few years due in part to
 expanded waste management activities; stricter National
 Pollutant  Discharge Elimination  System (NPDES) and
 publicly  owned treatment works  (POTW)  discharge
 permit limits; the federal government's commitment to
 remediate National Priorities List (NPL) radioactive sites;
 increased public awareness of environment;  economic
 factors; and legal liability issues. The U.S. Department of
 Energy (DOE) has outlined a long-term plan committing
 the agency to clean up 45 years  worth of accumulated
 contamination at nuclear weapons sites and facilities. As a
 result,  DOE has scheduled environmental  remediation
 activities for more than 3,700 radionuclide and hazardous
 chemical waste sites. These DOE sites taken together with
 the thousands  of Superfund  sites  with  metal (and
 sometimes radionuclide)  contamination  represent  a
 massive  remediation  problem   that  will present  a
 tremendous fiscal  and technological challenge  in the
 future.

 At an estimated two-thirds of the DOE and Superfund
 sites, groundwater,  stored water, pond water, or sludges
 and soils are contaminated by metals.  DOE's 26 NPL
 radioactively  contaminated sites  essentially  all have
metals and radionuclide  problems.  They  range from
uranium and  thorium, to low-level radioactive wastes
(LLRW), to nuclear weapons production and processing
wastes  representing  uranium,  enriched  uranium, and
transuranic (TRU) materials. Federal statutes require that
remediation restoration of these federal sites be carried out
in compliance with the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA)
and the Superfund Amendments and Reauthorization Act
(SARA).

CERCLA as amended  by SARA establishes a cleanup
program intended to:

•    Encourage the use  of cost-effective methods

•    Promote remedial  actions that should yield perma-
     nent solutions

•    Minimize secondary waste streams

•    Use alternative treatment technologies

     Conform to applicable or relevant and
     appropriate requirements (ARAR)

•    Protect human health and the environment

The chemistry of heavy metal and radionuclide pollutants
varies from site to site, presenting a remediation challenge
for achieving strict discharge standards.  Conventional
filtration, sorption, and ion exchange methods have proved
useful for removing macro- to micro-particle inorganic
metallic forms from water, but are limited by performance
and  cost  when large  volumes of trace metals and
radionuclides must be removed.  Particle filtration is not
efficient for removing  trace micromolecular and  ionic
metallic  forms  from  water.    Microfiltration  readily
removes 0.025- to 10-micron particles from water, but has
generally been limited in the molecular to ionic range.
                                                  44

-------
Ultrafiltration is widely used for treating small volumes of
liquids  containing low total suspended solids  (TSS)
concentrations, but is limited in throughput and capacity
for most metals and radionuclide remedial applications.
Ion exchange methods have broad utility for the removal of
anionic and  cationic soluble  metallic  ions,  but have
microchanneling,  bed, and  residual problems,  higher
operational   costs,   and higher   disposal  costs   for
radionuclide-contaminated spent bed material.  Reverse
osmosis is highly efficient for removing a wide range of
soluble inorganic metallic ions, but can be expensive to
operate  and may  not  remove  trace  metals  and
radionuclides existing as complexed, chelated forms. In
addition,  the  salt  brine  waste  produced  by  this
methodology contributes to the waste disposal problem.

A.1  CURE System

The  CURE  treatment  system  is  a  refinement of
electrocoagulation technology that has existed  since the
early  1900s.  Electrocoagulation uses electricity to
destabilize contaminants and allow van der Waals' force to
coagulate  and   precipitate  the   contaminants.    In
conventional coagulation and  precipitation, a  chemical
amendment  is added to the contaminated water.  The
amendment  destabalizes  and  binds  with  oppositely
charged  contaminants  in  solution, causing  them to
coagulate and precipitate.  By eliminating the chemical
additives, the residual wastes are reduced.

The CURE system, a patented electrocoagulation process,
allows  continuous  water  flow  through  concentric
electrocoagulation tubes. The system circumvents some
of the performance limitations of conventional methods
, used to remove metals and radionuclide pollutants  from
water,  allowing higher flow rates and greater removal
efficiencies.  In  addition, residual wastes produced by
treatment are reduced and  less subject to leaching that
 other methods.

Electrocoagulation does not remove materials that do not
 form precipitates, such as  sodium and potassium.   If a
 contaminant does not form a precipitate, electrocoagulation
 will not cause it to flocculate. Therefore, electrocoagulation
 will  not  remove highly soluble  contaminants, such as
 benzene, toluene, or similar organic compounds.

 General Environmental Corporation (GEC) has  refined
 this  system for  commercial applications.   The trailer
 mounted system is  self  contained and capable  of
installation in limited space areas and the configuration
can be customized to specific applications by altering the
tube materials used and flow sequencing.

A.2  Design and Product Improvements

The  Rocky  Flats Environmental  Technology  Site
(RFETS) SITE demonstration of the CURE system in
August  and September  1995 -showed that the basic
engineering and  system design  configuration were
adequate.  Still, several system refinements are planned to
improve the equipment for higher flow rates (up to  100
gallons  per minute [gpm]), improve system reliability,
increase performance efficiency, and reduce operational
costs. Examples of planned improvements to the CURE
SITE demonstration configuration are outlined below.

     Commercial applications can be custom designed with
     additional banks of electrocoagulation tubes which
     will allow for increased flow rates.

•    A  redundant set of electrocoagulation tubes can be
     installed allowing tube servicing and replacement with
     no operational down time.

•    The clarifier will be replaced with one engineered to
     meet  specific requirements of the application and
     anticipated flow rates. Due to time and budget limi-
     tations an existing conical clarifier was used for the
     CURE demonstration in place of the slant-plate clari-
     fier engineered for the system. Smaller clarifier vol-
     umes and increased clarifier performance will result
     from the future replacement.

•    The bag filter used during the CURE demonstration
     will be replaced by a filter press which will increase
     the system capacity and reduce delays associated with
     the bag filter.

A.3 Applications of the System

The CURE system can  be used as an  in-line system
mounted on a trailer of skid. Examples of commercial and
government project applications are provided below.

 •    Remediation of metals and radionuclides from
     groundwater, wastewater, and washing operations

 •    Treatment of manufacturing wastewater
     containing metals and oil
                                                    45

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 »    Oil and water separation from process
     wastewaters

 •    Removal of metals and oil from waters

 Several  case  studies discussing  these application are
 presented in Appendix B.

 A.4  Factors that  Decrease Performance

 Bench- and pilot-scale testing should be carried out at each
 project to achieve high percent removal  efficiency for
 identified pollutants.  These tests enable system operators
 to optimize the  system parameters and identify the
 presence of competing or inhibiting chemical or physical
 factors. For the CURE  system, several factors have been
 identified that can limit the technology's performance and
 increase treatment costs.

 Operation of the CURE  electrocoagulation system may be
 affected by wastewater characteristics such as hydrogen
 ion concentration (pH), oxidation/reduction potential
 (Eh), specific conductance, temperature, and the amount
 of total dissolved and suspended solids (TDS and TSS).
 Solution   characterization  is therefore  important  to
establish maximum contaminant precipitation, minimize
power use, reduce sludge formation, curtail tube scaling,
and limit anode deterioration.
A.5  Advantages of Methodology

The  CURE  system  offers  several  advantages  over
conventional filtration, ion exchange, reverse osmosis,
and chemical coagulation methods for the treatment and
remediation of metallic cater pollutants.  Examples of
advantages include:

•    Efficient equipment design allows versatile system
     installation in space limited areas.

•    Generation of substantially lower quantities of re-
     sidual waste  per unit volume of water treated than
     other methods which translates to lower land disposal
     costs for hazardous and radioactive wastes.

     Residual wastes capable of passing the EPA toxicity
     characteristic leaching procedure (TCLP) allowing for
     less expensive disposal costs.

     System capable of operating without additional addi-
     tives which results in less residual waste
     production.

•    Demonstrated ability to treat a variety of
     contaminants including metals, colloids, suspended
     solids, oils, dyes, and organics.
                                                   46

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                                           Appendix B
                                          Case Studies
This appendix contains representative examples provided
by the technology developer, GEC, of the cleanup and
recovery  (CURE)  electrocoagulation  technology.
Analytical test data for estimating performance are also
presented  by  GEC,  where  available.   .Additional
documentation on these studies may be obtained from
GEC. Publication here does not indicate EPA's approval
or endorsement of the statements made  in this section;
EPA's point of view is discussed in the body of this report.

The following are case  studies that represent a wide
spectrum of metals and radionuclide treatment conditions
for industrial wastewater and U.S. Department of Energy
(DOE) facility wastes.

B.1   Municipal Wastewater Treatment

An Iron Ore  Treatment Plant  near  Denison, Texas,
employs approximately 13,000 people.  The plant uses
orbital aeration basins for primary treatment of municipal
wastewater, followed  by  clarification and  aerobic
digestion.  The resulting sludge is dried in open air beds
then removed for disposal.

The plant had difficulty operating within the scope of its
permit due to an increase in influent volume due to growth.
The facilities inability to treat additional influent also
affected the economic growth of Denison.

The CURE system was tested at the Iron Ore Treatment
Plant. It treated effluent at approximately 200 gallons per
minute. The treated waste stream was allowed to settle in
a 27,000-gallon vertical clarifier  for approximately 2
hours. Clear water was then drawn off and discharged to
the second ring of the plant's orbital system. A very high
quality and low water sludge was passed directly to the
drying beds, bypassing polymer application and treatment
in  anaerobic digesters.  The CURE system reduced the
suspended solid levels by 98 percent, to a range of 1,3 00 to
5,000 parts per million (ppm).

Treatment goals were achieved by running the CURE
system for approximately 12 hours per day, five days  a
week. In a 24-hour period, the CURE system processed an
average of 144,000 gallons of effluent. At this level of
processing, the plant operated at the  required level of
efficiency.

The  CURE system increased the capacity of the plant
while bringing plant  effluent into   compliance  with
discharge standards. The CURE system reduced capital
expense, enhanced treatment capability, and  improved
throughput.  The CURE system was used until a new,
larger capacity wastewater treatment plant was built.

B.2    Treatment of Manufacturer
        Wastewater

A tractor manufacturer generated approximately 30,000
gallons  of wastewater per day from the production of
approximately 30 to 50 units annually.  The waste stream
consisted of water-borne contamination including  zinc,
chrome, oil and grease, paint sludge, and a material similar
to cosmoline which is used for temporary  protection of
unfinished  metals.  Because  of this wide  range of
contaminants,  a multiple pass CURE system treatment
was  designed using anodes of different materials.

Following treatment by the CURE system, the effluent
flowed to a dual clarifier. Approximately 2 to 3 ppm of
polymer was added to enhance the settling characteristics
of the sludge.

The clear water effluent was discharged to the publicly
owned treatment works. The sludge was passed through a
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 filter press, then transported to  a permitted disposal
 facility. The system performed as designed, with all levels
 of contaminants reduced to or below target values. Zinc,
 the  primary  constituent  in the effluent stream,  was
 consistently measured at  0.15 to  0.2 ppm, well below
 discharge limits.

 The CURE system replaced the manufacturer's chemical
 precipitation system, which was extremely labor intensive
 and costly at approximately $0.125 per gallon. The CURE
 system, including labor, capital amortization, maintenance,
 and consumable materials, was treating the wastestream
 for approximately $0.055 per gallon.

 B.3   OH and Water Separation of Steam
       Cleaner Wastewater

 Several CURE systems have been installed in facilities
 that use steam equipment to remove oil, dirt, grease, and
 other materials from oil field equipment.  The system is
 particularly valuable where there is a problem with the
 separation of  oil and water containing concentrations of
 metals.

 At these facilities, the CURE system  is the central
 treatment element,  with pH adjustment  preceding and
 clarification following electrocoagulation. The following
 results presented in Table B-l show the effectiveness of
 the CURE process on this type of waste. Cost reductions
 of up to $3,000 per month are not unusual.

 B.4   Treatment of Ship Bilgewater

 In August 1992, the U.S. Coast Guard (USCG) approved
 the use of the  CURE system for the treatment of 176,200
 gallons  of ship bilgewater at Kodiak Island near
 Anchorage, Alaska. The ship bilgewater was contaminated
with high concentrations of oil and metals. A summary of
 contaminant removal efficiencies  for  raw and treated
bilgewater samples is shown in Table B-2.  The CURE
 process was effective in removing oil and metals with
 removal efficiencies ranging between 71 and 99 percent.

 Effluent samples were taken following treatment by the
 CURE system and prior  to  entering  the 300-  gallon
 clarifier.   Because of the small  clarifier and limited
 retention  time, an anionic polymer was added  to the
sedimentation as a coagulant aid. Following retention in
the clarifier, the effluent passed through activated carbon
filters  for final polishing  and removal of any  trace
hydrocarbons.
The volume of the waste was reduced by 98 percent, from
46,500 gallons of bilgewater to less than 600 gallons of
sludge.

The mobility of the CURE equipment eliminated the need
to transport the bilgewater for treatment off the island
resulting in an estimated cost savings of $185,000.  The
average cost of treating the bilgewater on-site, estimated at
$0.45 per gallon was approximately 10 percent of the cost
for treatment on the island.

B.5   Los Alamos National Laboratory
       Treatability Study

In November 1994, GEC tested the CURE system on
wastewater at the  Los Alamos National Laboratory
(LANL) in Los Alamos, New Mexico.  The primary
objective  of  the  tests  was  to compare  the  CURE
electrocoagulation process with the conventional methods
of chemical treatment.

The wastewater treated was  a grab sample  from the
influent to LANL hazardous wastewater treatment plant
and contained plutonium, americium, and various other
metals.  The focus  of the treatability study was on the
radionuclides.

The CURE process was more efficient than the chemical
treatment process in one of three test  runs.  However,
LANL  was  pleased with  the results and requested
additional  testing  of the CURE system.  Table  B-3
summarizes the results of the testing.

B.6   Rocky Flats Environmental
       Technology Site Treatability Study

In April 1995, a bench-scale study was conducted by GEC
testing the ability of the CURE system to remove uranium,
plutonium, and americium from water derived from the
U.S. Department of Energy's Rocky Flats Environmental
Technology site solar evaporation ponds (SEPs).

As part of the manufacturing processes at RFETS near
Golden, Colorado, wastes were produced that contained
uranium, plutonium-23 9/240, americium-241, and other
contaminants. Some of this waste was collected in SEPs.
The SEPs stored and treated liquid process waste having
                                                 48

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less than 100,000 picoCuries per liter of total long-lived
alpha activity. Water decanted from the sludge and liquid
from the A and B SEPs was treated for this bench-scale
study.

Testing of the CURE system using decant water from the
SEPs indicated  that  the technology is capable  of
consistently  removing more  than 95 percent  of the
uranium, plutonium, and americium.
Table B-1. Treatment of Steam Cleaner Wastewater
               Element
Before Treatment
      (ppm)
      NOTES:

      ppm   parts per million
After Treatment
     (ppm)
Percent Removal
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
<0.01
0.30 -
8.0
<0.01
0.141
7.98
0.13
6.96
7.4
0.003
0.18
0.4
< 0.005
<0.01
<0.10
0.23
19.4
0.014
<0.01
<0.10
<0.01
0.031
0.05
<0.05
<0.05
1.74
< 0.001
0.035
<0.05
< 0.005
<0.01
<0.10
<0.01
1.20
99
97
99
0
78
99
62
99
76
67
81
87
0
0
0
96
94
                                                  49

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Table B-2. Contaminant Removal Efficiencies
                                     Concentration (mg/L)

                                          Untreated
Treated
% Removal
Contaminant
Petroleum hydrocarbons
Heavy Metals
Aluminum
Boron
Iron
Zinc
Dissolved Cations
Calcium
Magnesium
Manganese
Sodium
Potassium
Dissolved Anions
Phosphorus

72.5

4.16
4.86
95:4
3.41

293
943
0.93
8,690
287

5.38
. . *«,
ND(0.2)

0.74
1.41
ND(l.O)
, 	 NP(0.5)

137
300
ND
5,770
222

1.43

99.0

82.0
71.0
99.0
99.0

53.2
68.2
99.0
33.6
23.0

73.4
NOTES:
mg/L  milligrams per liter
ND    not detected
                                               50

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Table B-3. Analytical Results for Radionuclides in LANL Wastewater
Sample
No.
Raw
Elec-4
Elec-5
Elec-6
Jar-1
Jar-2
Jar-3
Plutonium
pCi/L
15,560
3,2
32.8
10,400
18.6
35.4
4,310
After
Treatment
DCi/L
N/A
0.0006
0.0688
6,990
0.0223
0.0814
1,190
%
Removal
N/A
99.98
99.79
32.98
99.88
99.77
72.31
Americium
pCi/L
1,970
2.8
12.4
1,670
6.9
1.9
783
After
Treatment
pCi/L
N/A
0.00392
0.07812
1,423
0.0241
0.00190
311
% Removal
N/A
99.86
99.37
15.00
99.65
99.90
60.23
    NOTES:

    PCi/L    picocuries per liter
    N/A     not applicable
                                                        51
6U.S. GOVERNMENT PRINTING OFFICE: 1998-653-686

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