/EPA
United States
Environmental Protection
Agency
Evaluation of Soil Amendment
Technologies at the
Crooksville/Roseville Pottery
Area of Concern
STAR Organics Soil Rescue
Innovative Technology
Evaluation Report
SUPERFUND INNOVATIVE
TECHNOLOGY EVALUATION
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EPA/540/R-99/501
March 2003
Evaluation of Soil Amendment
Technologies at the Crooksville/Roseville
Pottery Area of Concern
STAR Organics Soil Rescue
Innovative Technology Evaluation Report
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
Recycled/Recyclable
Printed with vegetable-based ink on
paper that contains a minimum of
50% post-consumer fiber content
processed chlorine free.
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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-C5-Q037 to TetraTech EM Inc. It has been subjected to the Agency's peer and administrative
reviews and has been approved for publication as an EPA document. Mention of trade names or commercial
products does not constitute an endorsement or recommendation for use.
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Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives to formulate
and implement actions leading to a compatible balance between human activities and the ability of natural systems
to support and nurture life. To meetthis 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 (NRMRL) is the Agency's centerfor investigation
of technological and management approaches for preventing and reducing risks from pollution that threaten
human health and the environment. The focus of the Laboratory's research program is on methods and their
cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface resources; protection
of water quality in public water systems; remediation of contaminated sites, sediments and ground water;
prevention and control of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both
public and private sector partners to foster technologies that reduce the cost of compliance and to anticipate
emerging problems. NRMRL's research provides solutions to environmental problems by: developing and
promoting technologies that protect and improve the environment; advancing scientific and engineering
information to support regulatory and policy decisions; and providing the technical support and information transfer
to ensure implementation of environmental regulations and strategies at the national, state, and community levels.
This publication has been produced as part of the Laboratory's strategic long-term research plan. It is
published and made available by EPA's Office of Research and Development to assist the user community and
to link researchers with their clients.
Hugh McKinnon, Director
National Risk Management Research Laboratory
in
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Abstract
Star Organics, L.L.C., of Dallas, Texas (Star Organics), has developed Soil Rescue to treat soil contaminated
with metals. StarOrganics claims that Soil Rescueforms metal complexes that immobilize toxic metals, thereby
reducing the risk to human health and the environment.
The Superfund Innovative Technology Evaluation (SITE) Program evaluated an /nsrfuapplication of the technology
during a demonstration at two lead contamination sites in Roseville, Ohio, in September 1998. For the
demonstration, Soil Rescue was applied to 10 experimental units at a trailer park and one experimental unit at
an inactive pottery factory.
Primary objective 1 (P1) was to evaluate whether Soil Rescue can treat soil contaminated with lead to meet the
Resource Conservation and Recovery Act (RCRA)/Hazardous and Solid Waste Amendments (HSWA) alternative
universal treatment standards (UTS) for land disposal of soils contaminated with lead. The alternative UTS for
soil contaminated with leadis determined from the results of the toxicity characteristic leaching procedure (TCLP).
The alternative UTS is met if the concentration of lead in the TCLP extract is no higher than one of the following:
(1) 7.5 milligrams per liter (mg/L), or (2) 10 percent of the lead concentration in the TCLP extract from the untreated
soil. Contaminated soils with TCLP lead concentrations below the alternative UTS meet the RCRA land
disposal restrictions (LDR), and thus are eligible for disposal in a land-based RCRA hazardous waste disposal
unit. The alternative UTS is defined further under Title 40 of the Code of Federal Regulations (CFR), Chapter I,
part268.49 (40 CFR268.49). To meetthatobjective, soil samples were collected before and afterthe application
of Soil Rescue. The untreated and treated soil samples were analyzed for TCLP lead concentrations to evaluate
whether the technology met objective PI. Analysis of the data demonstrated Soil Rescue reduced the mean
TCLP lead concentration at the inactive pottery factory from 403 mg/L to 3.3 mg/L, a reduction of more than 99
percent. Therefore, the treated soil meets the alternative UTS for soil at the inactive pottery factory. Data from the
trailer park were not used to evaluate P1 because TCLP lead concentrations in all treated and untreated soil
samples from this location were either at or slightly higher than the detection limit of 0.05 mg/L.
Primary objective 2 (P2) was to evaluate whether Soil Rescue could decrease the soil lead bioaccessibility by
25 percent or more, as defined by the Solubility Bioaccessibility Research Consortium's (SBRC) Simplified Iri-
Vitro Test Method for Determining Soil Lead and Arsenic Bioaccessibility (simplified in vitro method [SIVM]).
However, EPA Lead Sites Workgroup (LSW) and Technical Review Workgroup for lead (TRW) atthis time, do not
endorse an in-vitro test for determining soil lead bioaccessibility (Interstate Technology and Regulatory
Cooperation [ITRC] 1997). To meet objective P2, soil samples were collected before and afterthe application of
Soil Rescue. The soil samples were analyzed for soil lead bioaccessibility to evaluate whether the technology
met objective P2. Analysis of the data demonstrates that Soil Rescue reduced the soil lead bioaccessibility by
approximately 2.9 percent, which is less than the project goal of at least a 25 percent reduction in soil lead
bioaccessibility. However, it was recognized early on that meeting this goal would be difficult because the SIVM
test procedure used in the demonstration involves a h ighly acidic sample digestion process, which may be revised
in the future, because it may be exceeding the acid concentrations that would be expected in a human stomach.
IV
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Contents
Notice...... ;........ ii
Foreword jjj
Abstract iv
Acronyms, Abbreviations, and Symbols xi
Table of Conversion Factors xiii
Acknowledgments . ; xiv
Executive Summary xv
1.0 Introduction 1
1.1 Description of SITE Program and Reports 1
1.1.1 Purpose, History, Goals, and implementation of the SITE Program 1
1.1.2 Documentation of the Results of SITE Demonstrations i; 2
1.2 Description of Soil Rescue .'. 2
1.3 Overview and Objectives of the SITE Demonstration 2
1.3.1 Site Background 2
1.3.2 Site Location 3
1.3.3 SITE Demonstration Objectives 3
1.3.4 Demonstration Activities .,.„ 6
1.3.5 Long-term Monitoring 6
1.4 Key Contacts 6
2.0 Technology Effectiveness Analysis 8
2.1 Predemonstration Activities 8
2.2 Demonstration Activities 8
2.2.1 Activities Before Treatment 8
2.2.2 Treatment Activities 12
2.2.3 Activities AfterTreatment 12
2.3 Laboratory Analytical and Statistical Methods : 12
2.3.1 Laboratory Analytical Methods 12
2.3.2 Statistical Methods 16
2.3.2.1 Determination of the Distributions of the Sample Data 17
2.3.2.2 Parametric and Distribution-free Test Statistics ; 17
2.4 Results of the SITE Demonstration 19
2.4.1 Evaluation of P1 19
2.4.2 Evaluation of P2 ;..... ; 20
2.4.3 Evaluation of Objective S1 21
2.4.4 Evaluation of S2 41
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Contents (Continued)
2.4.5 Evaluation of Objective S3 41
2.4.6 Evaluation Of Objective S4 42
2.5 Quality Control Results 42
2.5.1 Completeness '. 43
2.5.2 Comparability and Project-Required Detection Limits 43
2.5.3 Accuracy and Precision 43
2.5.4 Representativeness 43
3.0 Technology Applications Analysis :.. 45
3.1 Description of the Technology 45
3.2 Applicable Wastes 45
3.3 Method of Application 45
3.4 Material Handling Requirements 46
3.5 Limitations of the Technology 46
3.6 Regulatory Requirements '. 46
3.6.1 CERCLA 46
3.6.2 RCRA 46
3.6.3 OSHA ...47
3.6.4 CWA ...47
3.7 Availability andTransportability of the Technology 47
3.8 Community Acceptance by the State and the Community 48
4.0 Economic Analysis 49
4.1 Factors that Affect Costs 49
4.2 Assumptions of the Economic Analysis 49
4.3 Cost Categories 51
4.3.1 Site Preparation Costs 51
4.3.2 Permitting and Regulatory Costs 52
4.3.3 Mobilization Costs 52
4.3.4 Equipment Costs 53
4.3.5 LaborCosts 53
4.3.6 Supplies and Materials Costs 54
4.3.7 Utilities Costs 54
4.3.8 Effluent Treatment and Disposal Costs 54
4.3.9 Residual Waste Shipping and Handling Costs 54
4.3.10 Analytical Services Costs 55
4.3.11 Equipment Maintenance Costs 55
4.3.12 Site Demobilization Costs 55
4.4 Summary of the Economic Analysis 56
5.0 Technology Status •— 57
6.0 References • 58
VI
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Contents (Continued)
Appendices
A Vendor Claims.
59
vii
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Figures
1-1. Location of demonstration sites in Roseville, Ohio • 4
2-1. Trailer park sampling locations and patterns ••••• 10
2-2. Inactive pottery factory sampling locations and patterns 11
2-3. MEP lead results for experimental unit Gat the trailer park 25
2-4. MEP lead results for sampling location 1 at the inactive pottery factory 25
2-5. MEP lead results for sampling location 2 at the inactive pottery factory 26
2-6. MEP lead results for sampling location 3 at the inactive pottery factory 26
2-7. MEP lead results for sampling location 4 at the inactive pottery factory 27
2-8. MEP lead results for sampling location 5 atthe inactive pottery factory 27
viii
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ES-1
2-1.
2-2!
2-3.
2-4.
2-5.
2-6.
2-7.
2-8,
2-9.
2-10.
2-11.
2-12.
2-13.
2-14.
2-15.
2-16.
2-17.
2-18.
2-19.
2-20.
2-21.
2-22.
Tables
Evaluation of Soil Rescue by Application of the Nine Superfund Feasibility Study Criteria xvii
Summary of Maximum Concentrations of Lead Observed During Predemonstration,,
Sampling Activities '.
Analytical Laboratory Methods
Summary of Extraction Procedures
Summary of Statistical Procedures Used to Evaluate Each of the Objectives of the
Demonstration
TCLP Lead Results forthe Inactive Pottery Factory Site ...
TCLP Lead Summary and Test Statistics forthe Inactive Pottery Factory Site.
TCLP Lead Results fortheTrailer Park Site
Soil Lead Bioaccessibility Results...
Parametric Test Statistics, Soil Lead Bioaccessibility Data
Bootstrap Statistical Results for Bioavailable Lead Difference Data
MEP Analytical Results
Summary of Percent Frequency of Lead Phases Statistical Data
Sequential Serial Soil Extracts Results, Trailer Park ,
Sequential Serial Soil Extracts Results, Inactive Pottery Factory
Sequential Serial Soil Extracts: Summary Statistics ,
Trailer Park Eh Analytical Results
Inactive Pottery Factory Eh Analytical Results ,
Eh Summary Statistics
Trailer Park pH Analytical Results
Inactive Pottery Factory pH Analytical Results
pH Summary Statistics -.
CEC Analytical Results for Soil from the Trailer Park
..9
13
14
.1,8
20
20
20
21
22
22
23
28
30
30
31
31
31
32
33
33
33
33
IX
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Tables (Continued)
2-23. CEC Analytical Results for Soil from the Inactive Pottery Factory 34
2-24. Lead Analytical Results for Nitric Acid Digestion for Soil from the Trailer Park 35
2-25. Lead Analytical Results for Nitric Acid Digestion for Soil from the Inactive Pottery Factory 35
2-26. Summary Statistics for Nitric Acid Digestion j 35
2-27. Lead Analytical Results Using Hydrofluoric Acid Digestion for the Trailer Park 36
2-28. Lead Analytical Results Using Hydrofluoric Acid Digestion forthe Inactive Pottery Factory 36
2-29. Summary Statistics For Hydrofluoric Acid Digestion 36
2-30. SPLP Lead Analytical Results for Soil from the Trailer Park 37
Summary of Results for Objective S1 38
2-31. SPLP Lead Analytical Results for Soil from the Inactive Pottery Factory 39
2-32. SPLP Lead Summary Statistics for Soil from the Inactive Pottery Factory 39
2-33. Total Phosphates Analytical Results for Soil from the Trailer Park 40
2-34. Total Phosphates Analytical Results for Soil from the Inactive Pottery Factory 40
2-35. SPLP Phosphates Analytical Results for Soil from the Trailer Park .; 40
2-36. SPLP Phosphates Analytical Results for Soil from the Inactive Pottery Factory 40
2-37. Phosphate Summary Statistics 41
2-38. Air Monitoring Results 42
4-1. Cost Distribution for Soil Rescue 50
4-2. Site Preparation Costs 51
4-3. Mobilization Costs 52
4-4. Equipment Costs ••••• 53
4-5. LaborCosts '. '. 53
4-6. Supplies and Materials Costs 54
4-7. Site Demobilization Costs 56
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ACG1HTLV
ASTM
ARAR
BS
CaC03
CFR
CEC
CRPAC
cm3
DQO
DUP
Eh
EPA
EP-TOX
Gl
HSWA
1CP-AES
ITER
LCS
LCSD
MS
MSD
MEP ;
Meq/g
mg/kg
mg/L
mV
NAAQS
NCP
Acronyms, Abbreviations, and Symbols
American Conference of Governmental Industrial Hygiene Threshold Limit Value
American Society for Testing and Materials
Applicable or relevant and appropriate requirements
Blank spike
Calcium carbonate
Code of Federal Regulations
Cation exchange capacity
Crooksville/Roseville Pottery Area of Concern
Cubic centimeter
Data quality objective
Duplicate
Oxidation reduction potential
U.S. Environmental Protection Agency
Extraction procedure toxicity test
U.S. Environmental Protection Agency Regional Geographic Initiative
Hazardous and Solid Waste Act
Inductively coupled plasma-atomic emission spectrometry
Innovative technology evaluation report
Laboratory control samples
Laboratory control sample duplicates
Matrix spike
Matrix spike duplicate
Multiple extraction procedure
Micrograms per deciliter
Milliequivalents per gram
Milligram per kilogram
Milligram per liter
Millivolt
National Ambient Air Quality Standard
National Oil and Hazardous Substances Pollution Contingency Plan
xi
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Acronyms, Abbreviations, and Symbols (continued)
NIOSH REL National Institute for Occupational Safety and Health recommended exposure limit
NPDES National Pollutant Discharge Elimination System
NRMRL National Risk Management Research Laboratory
OEPA Ohio Environmental Protection Agency
ORD Office of Research and Development
OSHA Occupation Safety and Health Administration
OSHA PEL Occupation Safety and Health Administration permissible exposure limit
OSWER Office of Solid Waste and Emergency Response
PBET Physiologically based extraction test
%R Percent recovery
POTW Publicly owned treatment works
PPE Personal protective equipment
PRDL Project-required detection limits
PRP Potentially responsible party
QAPP Quality assurance project plan
QA/QC Quality assurance and quality control
RCRA Resource Conservation and Recovery Act
RMRS Rocky Mountain Remediation Services, L.L.C.
RPD Relative percent difference
RPM Remedial Project Manager
SARA Superfund Amendments and Reauthorization Act
SBRC Solubility/Bioavailability Research Consortium
SITE Superfund Innovative Technology Evaluation
SIVM Simplified in-vitro method
SPLP Synthetic precipitation leaching procedure
SVOC Semivolatile organic compound
TCLP Toxicity Characteristic Leaching Procedure
TER Technology Evaluation Report
pg/kg Microgram per kilogram
pg/L Microgram per liter
UTS Universal treatment standard
VOC Volatile organic compound
yd3 cubic yard
XII
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Table of Conversion Factors
Length:
Area:
Volume:
Mass:
Energy
Power
Temperature:
To Convert from
inch
foot
mile
square foot
acre
gallon
cubic foot
pound
kilowatt-hour
kilowatt
(° Fahrenheit - 32)
to
centimeter
meter
kilometer
square meter
square meter
liter
cubic meter
kilogram
megajoule
horsepower
0 Celsius
Multiply by
2.54
0.305
1.61
0.0929
4,047
3.78
0.0283
0.454
3.60
1.34
0.556
XIII
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UTS is defined further in Title 40 of the Code of
Federal Regulations (CFR), Chapter I, part
268.49 (40 CFR 268.49).
• PrimaryObjective2 (P2) - Evaluate whether Soil
Rescue can decrease the soil lead
bioaccessibility by 25 percent or more, as defined
by the Solubility/Bioaccessibility Research
Consortium's (SBRC) In-Vitro Method for
Determination of Lead and Arsenic
Bioaccessibility (simplified in-vitro method
[SIVM]) (Note: the EPA Lead Sites Workgroup
(LSW) andTechnical Review Workgroupfor lead
(TRW) at this time do not endorse an in vitro test
for determining soil lead bioaccessibility [ITRC
1997]).
The secondary objectives of the demonstration were:
* Secondary Objective 1 (S1) - Evaluate the long-
term chemical stability of the treated soil.
• Secondary Objective 2 (S2) - Demonstrate that
the application of Soil Rescue did not increase
the public health risk of exposure to lead.
• Secondary Objective 3 (S3) - Document baseline
geophysical and chemical conditions in the soil
before the application of Soil Rescue.
• Secondary Objective 4 (S4) - Document the
operating and design parameters of Soil Rescue.
SITE Demonstration Results
Summarized below are the significant results of the
SITE demonstration:
• Soil Rescue reduced the mean TCLP lead
concentration from 403 mg/L to 3.3 mg/L, a
reduction of more than 99 percent. Therefore, the
treated soil meets the alternative UTS for soils
contaminated with lead, as specified at CFR
268.49.
• Analysis of the data'generated by application of
the SIVM demonstrated that Soil Rescue
reduced the soil lead bioaccessibility by
approximately 2.9 percent. However, it was
recognized early on that meeting this goal would
be difficult because the SIVM test procedure
used in thedemonstrationinvolvesahighly acidic
sample digestion process, which may be revised
in the future, because it may be exceeding the
acid concentrations that would be expected in a
human stomach.
Soil treated with Soil Rescue appears to exhibit
long-term chemical stability, as indicated by the
results of most of the 11 analytical procedures
that were conducted; to predict the long-term
chemical stability of the treated soil. However, the
results of some of the analytical procedures
suggest that Soil Rescue does not appear to
exhibit long-term chemical stability.
In summary:
Long-term soil chemical stability was indicated
for soils treated by Soil Rescue at both test
locations, as indicated by the analytical results
of the multiple extraction procedure (MEP), pH,
and cation exchange capacity (CEC) test
procedures. The CEC results are considered to
be qualitative, because this test was conducted
on only a single sample from each location.
Long-term chemical stability was indicated at one
site, but not indicated at the other, by the
analytical results of procedures for evaluating
acid neutralization capacity, and teachable lead
by the simulated precipitation leaching
procedure (SPLP). The results from the
procedure for evaluating lead speciation by
sequential extraction indicated chemical stability
inconclusively at one site, but notatallatthe other.
The results of tests on acid neutralization
capacity are considered to be qualitative,
because this test was conducted on only a single
sample from each location.
The analytical results from the lead speciation
test by scanning electron microscopy
(conducted only on soils from the trailer park)
were inconclusive, in that some soluble phases
of lead were reduced, while the organic matter
phase of lead was increased (organically bound
lead can be released if the organic phase is
biologically degraded by microbes in the soil).
At both locations, long-term chemical stability
was not indicated for soils treated by Soil Rescue,
as indicated by the analytical results from
oxidation-reduction (Eh) analysis, two types of
total lead analyses (one using nitric and the other
using hydrofluoric acid); analysis for total
phosphates; and analysis for teachable
phosphates by the SPLP (It should be noted that
XVI
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the tests involving two types of total lead analysis
were extremely aggressive tests, thus meeting
the acceptance criteria established for these
tests was not as important as meeting the
acceptance criteria of othertests involving long-
term chemical stability).
On the basis of information obtained from the
SITE demonstration, Star Organics, and other
sources, an economic analysis examined 12cost
categories for a scenario in which Soil Rescue
was applied at full scale to treat 807 cubic yards
(yd?) of soil contaminated with lead at a 1 -acre
site at CRPAC. The cost estimate assumed that
the concentrations of lead in the soil were the
same as those encountered during the Roseville
demonstration. On the basis of those
assumptions, the cost was estimated to be
$40.27 per yd3 of treated soil, which is a site-
specific estimate.
Superfund Feasibility Study Evaluation
Criteria for the Soil Rescue Technology
Table ES-1 presents an evaluation of Soil Rescue with
respect to the nine evaluation criteria used for
Superfund feasibility studies that consider remedial
alternatives for superfund Sites.
Table ES-1. Evaluation of Soil Rescue by Application of the Nine Superfund Feasibility Study Criteria
Criterion
1.
2.
3.
4.
5.
6.
7.
8.
9.
Overall Protection of Human
Health and the Environment
Compliance with Applicable or
Relevant and Appropriate
Requirements (ARAR)
Long-term Effectiveness and
Permanence
Short-term Effectiveness
Reduction of Toxicity, Mobility, or
Volume Through Treatment
Implementability
Cost
Community Acceptance
State Acceptance
Discussion
The technology is expected to significantly lower the leachability of lead from soils
as indicated by the TCLP results, thereby reducing the migration of lead to
groundwater and the potential for exposure of all receptors to lead; however, the
technology did not significantly reduce soil lead bioaccessibility, as determined by
the SIVM.
During the SITE demonstration, Soil Rescue reduced the mean TCLP lead
concentration from 402 mg/L to 3.3 mg/L, a reduction of more than 99 percent
Further, the treated TCLP lead concentrations were less than the alternative UTS
for lead in soil. Therefore, the treated soil met the land disposal restrictions (LDR)
for lead-contaminated soil, as specified in 40 CFR 268.49. However, the
technology's ability to comply with existing federal, state, or local ARARs should be
determined on a site-specific basis.
The analytical results of procedures for the multiple extraction procedure (MEP)
lead, pH, and cation exchange capacity (CEC) suggest long-term chemical stability
of the treated soil. The analytical results of a number of other procedures do not
suggest long-term chemical stability of the treated soil. Those procedures included
two types of total lead analyses, analysis for total phosphates, and analysis for
SPLP phosphates. The results related to long-term effectiveness from the test for
lead speciation by scanning electron microscopy and lead speciation by sequential
extraction, Eh, acid neutralization and SPLP lead were inconclusive.
Short-term effectiveness is high; surface runoff controls may be needed at some
sites.
The mean TCLP lead concentration was reduced from 403 mg/L to 3.3 mg/L,
reducing the mobility of the lead in the soil.
The technology is relatively easy to apply. Contaminated areas can be treated with
a fertilizer sprayer for treating soils to a depth of 6 inches and a pressure injection
apparatus for treating depths of more than 6 inches.
For full-scale application of the technology at a 1-acre site contaminated with lead
in the top 6 inches of soil, estimated costs are $32,500, which is $40.27 per cubic
yard of soil treated.
Community acceptance of Soil Rescue likely will be a site-specific issue.
State acceptance of Soil Rescue likely will be a site-specific issue.
XVII
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Section 1
Introduction
This section provides background information about the
Superfund Innovative Technology Evaluation (SITE)
Program and reports related to it; describes Soil Rescue;
presents the objectives of the SITE demonstration; and
provides information about key contacts.
1.1 DESCRIPTION OF SITE PROGRAM
AND REPORTS
This section provides information about the purpose,
history, goals, and implementation of the SITE program,
and about reports that document the results of SITE
demonstrations.
1.1.1 Purpose, History, Goals, and
Implementation of the SITE Program
The primary purpose of the SITE program is to advance
the development and demonstration, and thereby establish
the commercial availability, of innovative treatment
technologies applicable to Superfund andother hazardous
waste sites. The SITE program was established by the
U.S. Environmental Protection Agency's (EPA) Office
of Solid Waste and Emergency Response (OSWER) and
Office of Research and Development (ORD) in response
to the Superfund Amendments and Reauthorization Act of
1986 (SARA), whichrecognizes the need for an alternative
or innovative treatment technology research and
demonstration program. The SITE programis administered
by ORD's National Risk Management Research
Laboratory (IvIRMRL) in Cincinnati, Ohio. The overall
goal of the SITE program is to carry out a program of
research, evaluation, testing, development, and
demonstration of alternative or innovative treatment
technologies that can be used in response actions to
achieve more permanent protection of human health and
the environment.
Each SITE demonstration evaluates the performance of a
technology in treating a specific waste. The waste
characteristics at other sites may differ from the
characteristics of those treated during the SITE
demonstration. Further, the successful field demonstration
of a technology at one site does not necessarily ensure that
it will be applicable at other sites. Finally, data from the
field demonstration may require extrapolation to estimate
(1) the operating ranges under which the technology will
perform satisfactorily and (2) the costs associated with
application of the technology. Therefore, only limited
conclusions can be drawn from a single field demonstration,
such as a SITE technology demonstration.
The SITE program consists of four components: (1) the
Demonstration Program, (2) the Emerging Technology
Program, (3) the Monitoring and Measurement
Technologies Program, and (4) the Technology Transfer
Program. The SITE demonstration described in this
innovative technology evaluation, report (ITER) was
conducted under the Demonstration Program. The objective
of the Demonstration Program is to provide reliable
performance and cost data on innovative technologies so
that potential users can assess a given technology's
suitability for cleanup of a specific site. To produce useful
andreliabledata, demonstrations are conductedat hazardous
waste sites or under conditions that closely simulate actual
conditions at waste sites. The program's rigorous quality
assurance and quality control (QA/QC) procedures provide
for obj ective and carefully controlled testing of field-ready
technologies. Innovative technologies chosen for a SITE
demonstration mustbe pilot- or full-scale applications and
must offer some advantage over existing technologies.
Implementation of the SITE program is a significant,
ongoing effort that involves OSWER; ORD; various EPA
regions; andprivatebusiness concerns, includingtechnology
developers and parties responsible for site remediation.
Cooperative agreements between EPA and the innovative
technology developer establish responsibilities for
conducting the demonstrations and evaluating the
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technology. The developer typically is responsible for
demonstrating the technology at the selected site and is
expected topayany costsoftransportation, operation, and
removal of related equipment. EPA typically is responsible
forprojectplannmgjSitepreparation, provision oftechnical
assistance, sampling and analysis, QA/QC, preparation of
reports, dissemination of information, and transportation
and disposal of treated waste materials.
1.1.2 Documentation of the Results of
SITE Demonstrations
The results of each SITE demonstration are reported in an
HER and a technology evaluation report (TER). The
rrERisintendedforusebyEPAremedialprojectmanagers
(RPM) and on-scene coordinators, contractors, and others
involvedintherernediationdecision-makingprocessandin
the implementation ofspecificremedial actions. The ITER
is designed to aid decision makers in determining whether
specific technologies warrant further consideration as
options applicable to particular cleanup operations. To
encourage the general use of demonstrated technologies,
EPA provides information about the applicability of each
technology to specific sites and wastes. The ITERprovides
information about costs and site-specific characteristics.
It also discusses the advantages, disadvantages, and
limitations of the technology.
The purpose of the TER is to consolidate all information
and records acquired during the demonstration. The TER
presents both a narrative and tables and graphs that
summarize data. The narrative discusses predemonstration,
demonstration, andpostdemonstrationactivities, as well as
any deviations from the quality assurance project plan
(QAPP) for the demonstration during those activities and
the effects of such deviations. The data tables summarize
the QA/QC data. EPA does not publish the TER; instead,
a copy is retained as a reference by the EPA project
manager for use in responding to public inquiries and for
recordkeeping purposes.
1.2 DESCRIPTION OF SOIL RESCUE
Soil Rescue consists of a mixture of weak organic acids
andphosphoryl esters that act as metal-complexing agents.
In the complexation reaction, coordinate covalent bonds
are formed among the metal ions, the organic acids and
esters, and the soil substrate. Soil Rescue can be applied
to the surface or pressure-injected to a depth of 15 feet into
contaminated soil. If necessary, the application can be
repeated until the concentrations of leachable metals in the
soil are reduced to a level lower than applicable cleanup
standards. In the demonstration described in this report,
Soil Rescue was evaluated for effectiveness after one
application.
SoilRescuedoesnotdestroyorremove toxic concentrations
of metals. Star Organics, L.L.C. (Star Organics), developer
of the technology, claims that the metal complexes Soil
Rescue forms immobilize the metal, reducing the
concentrations of leachable metals in soil to levels that are
lower than those required under applicable regulations and
reducing the risks posed to human health and the
environment. Star Organics claims that Soil Rescue has
been designed to stabilize toxic metals in soils, sludges, and
other waste streams. Star Organics claims that Soil
Rescue has been effective in treating metals in soils from
oil fields, such as barium and sodium, and that Soil Rescue
has been tested on soils contaminated with antimony,
thallium, selenium, arsenic, copper, zinc, and cadmium.
Section 3.0 of this ITER presents a detailed discussion of
Soil Rescue.
1.3 OVERVIEW AND OBJECTIVES OF
THE SITE DEMONSTRATION
This section provides information about (1) the site
background and location, (2) the objectives of the SITE
demonstration, (3) demonstration activities, and (4) long-
termmonitoring activities.
1.3.1 Site Background
The villages of Crooksville and Roseville, located along the
Muskingum and Perry County line in eastern Ohio, are
famous for a long history of pottery production. During the
100-year period of pottery manufacturing in those villages,
broken and defective (off-specification [off-spec]) pottery
was disposed of in several areas. Disposal practices were
not monitored or documented clearly. Sampling conducted
in the region by the Ohio Environmental Protection Agency
(OEPA) in 1997 identified 14 formerpotteries and pottery
disposal sites at which significant lead contamination was
present. Results of analysis of the soil samples collected by
OEPA in 1997 indicated elevated levels of lead in shallow
soils throughout the area (OEPA 1998) identified as the
Crooksville/RosevillePotteryAreaofConcern(CRPAC).
Much of the lead contamination is associated with the
disposal of unused glazing materials or of off-spec pottery
that was not fired in a kiln.
hi 1996, OEPA entered into a cooperative agreement with
EPA to conduct an investigation of the CRPAC under a
regional geographic initiative (Gl). The GIprogramprovides
grants for proj ects that an EPA region, a state, or a locality
-------
has identified as high priority and at which the potential for
risk reduction is significant. The GI program allows EPA
regions to address unique, multimedia regional
environmental problems that may pose risks to human
health or to the environment, such as the widespread lead
contamination found at the CRPAC.
The purpose of the GI of the investigation of the CRPAC
was to determine whether the long history of pottery
operations there, from the late 1800s through the 1960s,
caused any increases over background levels of
concentrations ofheavy metals in soil, groundwater, surface
water, or air. The results of analysis of soil and groundwater
samples collected in 1997 indicate elevated levels of lead
are present in shallow soils and groundwater throughout
the CRPAC (OEPA 1998).
1.3.2 Site Location
OEPA selectecLfour potential demonstration sites in the
CRPAC on the basis of the analytical results for samples
collected as part of the GI. Before the demonstration was
conducted, SITE personnel collected and analyzed soil
samples from the potential demonstration sites to determine
the extent of the lead contamination at those sites.
On the basis of the analytical results and discussions with
representatives of OEPA, two sites in the CRPAC were
selected for the SITE demonstration project. One site is a
formertrailer parkin Roseville, Ohio, which is one of many
residential areas in the CRPAC that have been affected by
the disposal of the pottery waste. The other site, also in
Roseville, Ohio, is located in an industrial area, adj acent to
an inactive pottery factory. Figure 1-1 shows the locations
of the demonstration sites.
1.3.3 SITE Demonstration Objectives
OEPA applied to the SITE program for assistance in
evaluating innovative, cost-effective technologies that
could be applied at the CRPAC. OEPA was considering
excavating the soil and stabilizing it with Portland cement;
however, the agency also sought to evaluate an innovative
technology that could be applied in lieu of soil excavation
and that was lower in cost than the cement-based soil
stabilization technology. OEPA indicated that children in
the CRPAC exhibited higher blood concentrations of lead
than children in areas that are not affected by the waste
disposal practices of the pottery factories. Therefore,
OEPA also Was interested in identifying a technology that
could reduce the risk of direct exposure to lead in the soil
at the CRPAC. To meet OEPA's needs, the SITE
program recommended the evaluation of Soil Rescue
because it is a technology that can be applied in situ with
standard construction or farm equipment. EPArefmed the
objectives of the demonstration project during a meeting
with OEPA on March 19,1998. During and following this
meeting, EPA and OEPA established primary and
secondary objectives for the SITE demonstration. The
objectives were based on EPA's understanding of the
technology; information providedby the developers of Soil
Rescue; the needs identified by OEPA; and the goals of
the SITE demonstration program, which include providing
potential users of Soil Rescue with technical information to
be used in determining whether the technology is applicable
to other contaminated sites.
The obj ectives of the demonstration originally were defined
in the EPA-approved Q APP dated November 1998 (Terra
Tech 1998). The two primary objectives are structured to
evaluate the ability ofthe technology to reduce the leachable
and bioaccessible concentrations of lead in soils,
respectively. The secondary objectives are structured to
evaluate the technology's ability to meetother performance
goals not considered critical, to document conditions at the
site, to document the operating and design parameters of
the technology, and to determine the costs of applying the
technology.
Primary Objectives
Two primary objectives were developed for the
demonstration.
• Primary objective 1 (PI) was to evaluate whether
leachable lead in soil can be reduced to concentrations
that comply with the alternative UTS for lead in
contaminated soil, which are codified at 40 Code of
Federal Regulations (CFR) part 268.49 and are
included in the land disposal requirements (LDR) set
forth under the Resource Conservation and Recovery
Act (RCRA)/Hazardous and Solid Waste
Amendments (HSWA).
• Primary objective 2 (P2) was to determine whether
the portion of total lead in soil that is "bioaccessible,"
as measured by an experimental method, could be
reduced by at least 25 percent. However, it was
recognized early on that meeting this goal would be
difficult because the SF/M test procedure used in
the demonstration involves a highly acidic sample
digestion process, which may be revised in the future,
because it may be exceeding the acid concentrations
that would be expected in a human stomach.
Each ofthe objectives is described below.
Concentrations of lead in contaminated soils that are the
subject of cleanup actions often meet the definition of a
-------
Figure 1-1. Location of demonstration sites in Roseville, Ohio.
-------
hazardous waste under RCRA/HSWA. Sometimes, the
goals for such cleanup actions include a requirement that
the soil be treated, either in situ or ex situ, to the point that
it is in compliance with the LDRs set forth under RCRA/
HS WA. A common reason for including such a treatment
goal is to ensure that the lead in treated soil is immobilized
sufficiently to make it unlikely that the soil will migrate to
groundwater. A treated soil is deemed to be in compliance
with the LDRs for lead if the concentration of lead, as
measured by a TCLP analysis, is 90 percent lower than the
concentration of untreated soil or the treated soil is less
than or equal to 7.5 milligrams per liter (mg/L). Objective
PI for this demonstration required that the mean
concentration of TCLP lead in the treated soil be 90
percent lower than the concentration in untreated soil or
less than or equal to 7.5 mg/L. In addition, the objective
required the use of statistical analyses of mean
concentrations of TCLP lead, in which the alpha level was
set at 0.05.
Bioaccessibility of lead is not normally measured at
contaminated sites. The treatment goals for sites at which
the soil is contaminated with lead usually are based on the
results obtained from lead exposure models that can
calculate amaximum total concentration of lead in soil that
will not cause blood concentrations of lead in children that
exceed the widely accepted threshold level of 10
micrograms per deciliter (ug/dL). Such models often
include a factor that determines the portion of total lead
(after ingestion) that is bioavailable.Bioavailabilityrefers
to that portion of total soil lead that is absorbed into the
bloodstream from the ingestion of the soil (Interstate
Technology andRegulatory Cooperation [ITRC] 1997); it
is determined through the use of a number of techniques
approved by EPA that incorporate the results of in-vivo
tests. "Bioaccessibility" of soil lead has been proposed as
atermthatrefers to theresults of simpler, in-vitro tests that
can be used as indicators of the bioavailability of soil lead.
One such test method is the In-Vitro Method for
Determination of Lead and Arsenic Bioaccessibility (or
simplified in vitro method [SFVM]), which was developed
by the Solubility/Bioaccessibility Research Consortium
(SBRC) (ITRC 1997). The test simulates digestion of
ingested lead in soil, using a combination of chemicals
found in the human stomach. Although the EPA Lead
Sites Workgroup (LS W) and Technical Review Workgroup
(TRW) for lead currently do not endorse an in vitro test for
determining soil lead bioavailability (ITRC 1997), such
tests, if endorsed in the future, have the potential for use
in rapid evaluation of the ability of soil treatment chemicals
to reduce the total concentrations ofbioavailable lead. The
SIVMcurrentlyisundergoingvalidation studies. Inprevious
studies, the test results correlated well with results of
analysis by in vivo for soil lead tests based on the Sprague-
Dawley rat model and a swine model (ITRC 1997).
Primary obj ective P2 was to evaluate whether Soil Rescue
could decrease the bioaccessibility of soil lead (as measured
by the SIVM) by 25 percent or more. In addition, the
objective required the use of statistical analyses of mean
percent lead concentrations, in which the alpha level was
set at 0.05.
Secondary (S) Objectives
Secondary obj ectives were established to collect additional
data considered useful, butnot critical, to the evaluation of
Soil Rescue. The secondary objectives of the demonstration
were as follows:
• Secondary Objective 1 (S 1) - Evaluate the long-term
chemical stability of the treated soil.
• Secondary Objective 2 (S2) - Demonstrate that the
application of Soil Rescue did not increase the public
health risk of exposure to lead.
• Secondary Objective 3 (S3) - Document baseline
geophysical and chemical conditions in the soil before
the addition of Soil Rescue.
• Secondary Objective 4 (S4) - Document operating
and design parameters of Soil Rescue.
S1 was to determine whether Soil Rescue can enhance the
long-term chemical stability of the treated soil. Long-term
chemical stabilityisdemonstratedmostconyincinglythrough
an extended monitoring program. However, the results of
such programs may not be available for several years.
Therefore, a number of alternative analytical procedures
were selected and applied to untreated and treated soils
collected from both sites. Those procedures included the
multiple extraction procedure (MEP), lead speciation
using a scanning electronmicroscope (SEM), lead speciation
with a sequential extractionprocedure, oxidation-reduction
potential (Eh), pH, cation exchange capacity (CEC), acid
neutralization capacity, total lead (as determined by two
different methods), leachable lead by the synthetic
precipitation leachingprocedure (SPLP), total phosphates,
and SPLP-leachable phosphates. The evaluation was
accomplished by comparing the results of the analytical
procedures on soil samples collected from both sites
before and after application of Soil Rescue. Section 2.3 of
this ITERprovides additional details about each analytical
procedure and the criteria applied in interpretingthe results
obtained.
-------
S2 was to determine whether the dust generated during the
application of Soil Rescue may increase risks to the public
health posed by inhalation of lead during full-scale
implementation. The evaluation was accomplished by
analyzing residuals from air samples that were drawn
through filters during those demonstration activities that
couldcreatedustandcomparingthe analytical results with
the National Ambient Air Quality Standard (NAAQS) for
lead.
S3 was to evaluate baseline geophysical and chemical
properties of the soil at both sites. The objective was
accomplished by classifying soil samples from both sites
andanalyzingthemfor volatile organic compounds (VOC),
semivolatile organic compounds (SVOC), oil and grease,
and humic and fulvic acids.
S4 was to estimate the costs associated with the use of Soil
Rescue. The cost estimates were based on observations
madeand data obtained during and afterthe demonstration,
as well as data provided by Star Organics.
1.3.4 Demonstration Activities
Personnel of the SITE program evaluated the obj ectives of
the demonstrationby collecting and analyzing surficial soil
samples before and after Soil Rescue was applied. Soil
samples collected from the inactivepottery factory and the
trailer park were used in determining success in
accomplishing objective PI. In the case of P2, only soil
samples collected from the trailer park were used. In
general, five types of data were obtained: (1) TCLP lead
concentrations in untreated and treated soils; (2)
bioaccessibility levels oflead in untreated and treated soils;
(3) various levels of parameters for evaluating the long-
term chemical stability of untreated and treated soils; (4)
concentrations oflead in air during sampling and treatment
activities; and (5) levels of baseline geophysical and
chemical parameters in untreated soils. The sampling
program was designed specifically to support the
demonstration objectivespresentedin Section 1.3.3. Section
2.0 of this FTER discusses the results of the evaluation.
1.3.5 Long-Term Monitoring
A long-term monitoring program was established; under
thatprogram, additional samples of soil are to be collected
quarterly and analyzed for soil leadbioaccessibility, TCLP
lead, concentrations of SPLP lead, and concentrations of
lead in groundwater. Water samples will be collected
quarterly froinlysimeters installed in experimental units at
both sites and analyzed for lead. Samples of grass will be
collected from experimental units at the trailer park.
Information obtained through the long-term monitoring
effort will be presented in reports to be issued periodically
as the long-term monitoring program proceeds.
1.4 KEY CONTACTS
Additional information about the SITE program, Soil
Rescue, Star Organics, OEPA, and the analytical
laboratories is available from the following sources:
EPA Project Manager
Edwin Earth
LRPCD
Office of Research and Development
U.S. Environmental Protection Agency
26 W. Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7669
(513) 569-7571 (fax)
e-mail: barth.ed@epamail.epa.gov
EPA QA Manager
Ann Vega
Office of Research and Development
U.S. Environmental Protection Agency
26 W. Martin Luther King Drive
Cincinnati, OH 45268
(513)569-7635
(513) 569-7585 (fax)
e-mail: vega.ann@epamail.epa.gov
Technology Developer
Kevin Walsh
Star Organics, L.L.P.
3141 Hood Street
Suite 350
Dallas, TX 75219
(214) 522-0742, ext. 122
(214) 522-0616 (fax)
e-mail: kwalsh5@hotmail.com
Tetra Tech Project Manager
Mark Evans
Tetra Tech EM Inc.
1881 Campus Commons Drive, Suite 200
Reston,VA20191
(703)390-0637
(703) 391-5876 (fax)
e-mail: evansm@ttemi.com
Tetra Tech QA Manager
Greg Swanson .
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Tetra Tech EM Inc.
591 Camino de la Reina, Suite 640
San Diego, CA 92108
(619)718-9676
(619) 718-9698 (fax)
e-mail: swansog@ttemi.com
Analytical Laboratory Managers
Jamie McKinney ;
Quanterra Analytical Services
5815 MiddlebrookPike
Knoxville,TN 37921
(423)588-6401
(423) 584-4315 (fax) ,
e-mail: mckinney@quanterra.com
John Drexler
Department of Geology
University of Colorado
2200 Colorado Avenue,
Boulder, CO 80309
(303)492-5251
(303) 492-2606 (fax)
e-mail: drexlerj@spot.colorado.edu
David Germeroth
Maxim Technologies, Inc.
1908 Innerbelt Business Center Drive
St. Louis, MO 63114-5700
(314)426-0880
(314) 426-4212 (fax)
e-mail: dgermero.stlouis@maximtnail.com
Steve Hall
Kiber Environmental Services
3145 Medlock Bridge Road
Norcross,GA 30071
(770) 242-4090, ext. 285
(770) 242-9198 (fax)
e-mail: stevehall@kiber.com
Rob Liversage
Data Chem Laboratory
43 88 Glendale-Milford Road
Cincinnati, OH 45242
(513)733-5336
(513) 733-5347 (fax)
e-mail: rob@datachemlabs.com
Ohio EPA
AbbyLavelle
Southeast District Office ,
Ohio Environmental Protection Agency
2195 Front Street
Logan, OH 43139-9031
(740)380-5296 ,
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Section 2
Technology Effectiveness Analysis
This section addresses the effectiveness of Soil Rescue as
observed during the demonstration of the technology at the
selected sites at the CRPAC. Section 2.1 describes the
predemonstration activities thatlead to the selection of the
two locations for the demonstration; Section 2.2 presents
theactivitiesconductedduringthedemonstration, including
the establishment of experimental units at each
demonstration site, and the collection of untreated and
treated soil samples; Section 2.3 describes the laboratory
analytical and statistical methods used to evaluate
demonstration objectives; Section 2.4 presents results of
the demonstration; and Section 2.5 provides a summary of
results obtained from the analysis of quality control samples
that were collected during the demonstration.
2.1 PREDEMONSTRATION ACTIVITIES
Predemonstration activities includedpreliminary sampling
at four candidate locations, followed by selection of two
demonstrations sites. In March 1998, site personnel
collected soil samples from four locations that had been
identified by OEPA as potential demonstration sites.
Three of the locations were at pottery factories, and the
other location was at a former trailer park that had been
constructed on property contaminated with pottery wastes.
At all four locations, field measurements of total lead
concentrations were made with an x-ray fluorescence
(XRF) analyzer, and additional samples were collected for
laboratory analysis of total lead, leachable lead (by the
TCLP and SPLP), and soil lead bioaccessibility (by the
SIVM). Table 2-1 presents the highest concentrations of
lead measured at each of the four locations. The highest
concentrations of lead measured in the field by XRF
analyzers are higher than thosemeasured in the laboratory
because samples for laboratory measurements were not
collected at exact locations where the highest field
concentrations of lead were detected. As Table 2-1
indicates, the two locations selected for the SITE
demonstration were the inactivepottery factory inRoseville,
Ohio, and the trailer park, also in Roseville. The principal
reasons for the selection of the inactive pottery factory in
Roseville were that it appeared to have higher
concentrations of lead than any of the other locations and
it was more readily accessible than the other pottery
factories. The trailer park was selected for the SITE
demonstration primarily because use of that site would
allow evaluation of the Soil Rescue technology at sites at
which concentrations of lead in soil were lower than those
at the pottery factories. At the time the selection was
made, there was some concern that the concentrations of
lead at the trailer park might be too low because they did
not exceed 400 mg/kg, the residential preliminary
remediation goal (PRO) for lead established by EPA
(EPA 2000). However, previous field sampling conducted
by OEPA with XRF analyzers had indicated that total
concentrations of lead in the soil at the trailer park were
well above 400 mg/kg.
2.2 DEMONSTRATION ACTIVITIES
Section 2.2.1 discusses demonstration activities that were
conducted before treatment. Sections 2.2.2 and 2.2.3,
respectively, provide detailed descriptions of the
demonstration activities that were conducted during and
after the demonstration.
2.2.1 Activities Before Treatment
SITE personnel identified a total of 10 experimental units
at the trailer park, and only one experimental unit at the
inactive pottery factory. All the experimental units were
identified through application of the provisions of a
judgmental plan based on knowledge of the site and total
lead measurements taken with a field XRF.
SITE Program personnel removed the vegetation (sod)
from theexperimental units. To facilitatethehornogenization
of the soil and the collection of samples, the soil in the ten
experimental units at the trailer park was mixed with a
garden tiller to a depth of approximately 6 inches. The soil
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Table 2-1 . Summary of Maximum Concentrations of Lead Observed During Predemonstration
Sampling Activities
Site Name and Location
Trailer Park, Roseville,
Ohio2
Inactive Pottery Factory,
Roseville, Ohio2
Active Pottery Factory,
Roseville, Ohio
Inactive Pottery Factory,
Crooksville, Ohio
Maximum Lead Concentrations1 ' ;
Total
Field
(mg/kg)
300
23,100
14,500
2,654
Total
Laboratory
(mg/kg)
134
8,170
1,080
793
Leachable
via TCLP
(mg/L)
32.0
48.6
57.9
77,1
Leachable
via SPLP
(mg/L) '
<0.50
<0.50
<0.50
<0.50
Bioaccessible
via S1VM (%)
47
31
42
76
'The results reported represent the maximum concentrations detected, rather than a single sample
from any one location. Total lead measurements in the field were made with XRF analyzers; total
lead measurements in the laboratory were made by nitric acid digestion (SW-846 3050B). TCLP
= toxicity characteristic leaching procedure; SPLP = synthetic precipitation leaching procedure;
SIVM= simplified in-vitro method). ,.
The trailer park and the inactive pottery factory, both located irt Roseville, Ohio, were selected for
the SITE demonstration.
in the one experimental unit at the inactive pottery factory .
was homogenized by mixing soil with abackhoe to a depth
of 6 inches. The 10 experimental units in the trailer park
were assigned letters (C,G,K,L,M,N,O,Q,R,T), as was
the experimental unit adjacent to the inactive pottery
factory (U). Each of the 10 units in the trailer park
measured 5 feet wide by 5 feet long, and the single unit at
the inactive pottery factory unit measured 3 feet wide by
6 feet long. The depth of the demonstration in all units was
limited to the upper 6 inches of soil. Figure 2-1 shows the
locations of the experimental units at the trailer park, and
Figure 2-2 shows the location of the experimental unit at
the inactive pottery factory.
To establish the conditions present before the application
of Soil Rescue, soil samples were collected from each
experimental unit. However, the samples were collected
differently atthe two locations. Atthe trailer park, composite
samples were collected from each of the 10 experimental
units; at the inactive pottery factory, five grab samples
were collected from the single experimental unit. Specific
sampling procedures are described below for the trailer
park and the inactive pottery factory.
The composite soil samples for each experimental unit at
the trailer park were prepared by collecting an aliquot of
soil from each corner and from the middle of the
experimental unit, as Figure 2-1 shows. Each aliquot was
placed in a stainless-steel bowl (approximate volume: 64
ounces) with a stainless steel spoon or trowel. The
technology was not to be evaluated for its ability to treat
pottery chips; therefore, the soil samples were screened
through abrass 3/8-inch sieve intoaplastic 5-gallon bucket
to remove pottery chips from the samples. Particles larger
than 3/8 inch were returned to the stainless steel bowl, and
the percentage of the particles, on the basis of volume, that
did not pass through the sieve was estimated and recorded
in the logbook. The composite sample was hand-mixed in
the bucket with a stainless-steel spoon for one minute
before the sample containers were filled. After mixing,
fractions for the various analyses were prepared by filling
the sample containers with the composited soil. Field
duplicate samples were collected from two of the
experimental units at the trailer park.
The five grab soil samples collected from the single
experimental unit at the inactive pottery factory were
collected before treatment from each corner and the from
middle of the experimental unit, as shown in the inset
diagram on Figure 2-2. Each grab soil sample was placed
in a separate stainless-steel bowl (approximate volume: 64
ounces) with a stainless-steel spoon or trowel. The grab
soil sample was sieved through a brass 3/8-inch sieve into
a plastic 5-gallon bucket. Particles larger than 3/8 inch
were returned to the stainless steel bowl, and the percentage
of the particles, on the basis of volume, that did not pass
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• Experimental Unit and
Designation
| | Trailer
r1
CO
a
Sampling Locations Within Units
Untreated and Treated Soil
0 50 100
Graphic Scale (ft)
5 feet
5 feet
Figure 2-1. Trailer park sampling locations and patterns.
10
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t
Inactive Pottery Factory Building
149'
(not to scale)
Sampling Locations for Untreated Soil
*! 02
' m 5 ' '
Experimental Unit U
Sampling Locations for Treated Soil
06 ^5 £7
®3 ®9 94
Experimental Unit U
o
Legend
Experimental Unit U
Sampling Location
Downspout Location
Figure 2-2. Inactive pottery factory sampling locations and patterns.
11
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through the sieve was estimated and recorded in the
logbook. Each grab sample was hand-mixed in the bucket
with a stainless-steel spoon for one minute before the
sample containers were filled. The grab samples from
various locations were not composited. One field duplicate
sample was collected from one of the grab soil samples in
one of the sampling buckets.
2.2.2 Treatment Activities
After completing the activities described in Section 2.2.1,
Star Organics, using a pressurized wand, applied Soil
Rescue to the soil in each experimental unit to a depth of
two feet.
2.2.3 Activities After Treatment
SITE personnel evaluated the effectiveness of the treatment
bycollectingandanalyzingsoilsamplesafterthetechnology
was applied and comparing the data from those samples
with the data on the untreated soil. Soil samples were
collected from the experimental units treated with Soil
Rescue after a minimum of 72 hours after treatment.
Sampling of treated soils at the trailer park consisted of
collecting and compositing five soil aliquots from each
experimental unit in the same manner in which the samples
of untreated soil were collected. At the inactive pottery
factory, grab samples of treated soils were collected from
the single experimental unit in the same manner in which
the samples of untreated soil were collected, except that
nine grab samples were collected instead of five (see
Figure 2-2) to obtain amore precise estimate of the treated
sample mean.
2.3 LABORATORY ANALYTICAL AND
STATISTICAL METHODS
The SITE program samples collected during the
demonstration were analyzed by methods described in the
QAPP approved by EPA (Tetra Tech EM Inc. [Tetra
Tech] 1998). Statistical analyses were performed on
selectedanalytical data to demonstrate whether the criteria
set forth in the primary and secondary objectives were
met. The following section presents a brief description of
the analytical procedures and statistical methods used to
evaluate the samples that were collected during the
demonstration.
2.3.7 Laboratory Analytical Methods
Several analytical methods were used to evaluate the
project objectives on the basis of the specific analyses of
interestand the minimum detectable concentrations needed
to achieve the project objectives. Whenever possible,
methods approved by EPA were selected to analyze the
soil samples collected during the demonstration. The
followingreferences were used in performing the standard
analytical procedures approved by EPA:
• EPA. 1996. Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods, Laboratory Manual,
Volume 1A through 1C and Field Manual, Volume 2,
SW-846, Third Edition, Update IE. EPA Document
Control No 955-001-00000-1. Office of Solid Waste
Washington, DC, December. (For convenience,
analytical methods from this reference are referred
to as SW-846, followed by their respective analytical
method number.)
• EPA. 1983. Methods for Chemical Analysis of Water
and Wastes, EPA-600/4-79-020 and subsequent
EPA-600/4-technical additions. Environmental
Monitoring and Support Laboratory, Cincinnati, Ohio.
(For convenience, analytical methods from this
reference are referred to as MCAWW followed by
their respective analytical method number.)
When standard methods were not available, or when the
standardmethodsdidnotmeet the project objectives, other
published methods were used to analyze the soil samples.
The nonstandard methods were evaluated and approved
for use by EPA NRMRL before the soil samples were
analyzed. Table 2-2 lists the parameters, matrices, method
references, and method titles for the analytical laboratory
procedures used to evaluate the SITE demonstration
samples. Brief descriptions of the extraction procedures,
lead analytical procedures, and nonstandard analytical
procedures used in the demonstration are providedbelow.
Standard Extraction Procedures
Three standard extraction procedures approved by EPA
were used to analyze soil samples to determine the
concentrations of lead that will leach umder various
conditions - the TCLP, the MEP, and the SPLP. The
TCLP is used to determine the mobility of contaminants in
solids and multiphase waste; it simulates the initial leaching
that a waste would undergo in a sanitary landfill. The MEP
was designed to simulate both the initial and the subsequent
leaching that a waste would undergo in an improperly
designed sanitary landfill, where it would be subjected to
prolonged exposure to acid precipitation. The SPLP is
designed to simulate the initial leaching that a waste would
undergo if it were disposed of in amonofill, where it would
be subj ected to exposure to acid precipitation (EPA 1996).
The multiphase steps in performing the extraction
procedures are described below.
12
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Table 2-2. Analytical Laboratory Methods
Parameter
TCLP Lead
Soil Lead Bioaccessibility
MEP Lead
Lead Speciation by Scanning
Electron Microscopy
Lead Speciation by Sequential
Soil Serial Extractions
Eh
pH
CEC
Acid Neutralization Capacity
Total Lead using Nitric Acid
Digestion:
Oil and Grease
Total Lead
Hydrofluoric Acid Digestion
SPLP Lead
Phosphates
Humic and Fulvic Acid
Soil Classification
VOCs
SVOCs
Matrix
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Plants, Water, Filters
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Soil
Method Reference
SW-846 1311
SIVM (SBRC 1998)
SW-846 1320
Standard Operating Procedure
for Metal Speciation (University
of Colorado 1998)
Sequential Extraction
Procedure for the Speciation of
Particulate Trace Metals
(Tessier 1979)
SW-846 9045C
SW-846 9045C
Soil Sampling and Methods of
Analysis (Canadian Society of
Soil Science 1993)
Environment Canada Method
No. 7
SW-846 3050B, followed by
SW-846 601 OB
EPA Method 1664
SW-846 3052, followed by SW-
846 601 OB
SW-846 1312
SW-846 9056
Soil Sampling and Methods of
Analysis (Canadian Society of
Soil Science, 1993)
ASTM D2487-93
SW-846 8260B
SW-846 8270C
Title of Method
Toxicity Characteristic Leaching
Procedure
n Vitro Method for Determination of
Lead and Arsenic Bioaccessibility
Multiple Extraction procedure
Standard Operating Procedure for
Metal Speciation (Draft)
Sequential Extraction Procedure for the
Speciation of Particulate Trace Metals
Soil and Waste pH
Soil and Waste pH
Exchangeable Cations and Effective
CEC by the BaCI2 Method
Acid Neutralization Capacity
Acid Digestion of Sediments, Sludges,
and Soils,
Inductively Coupled Plasma-Atomic
Emission Spectrometry (ICP-AES)
Method 1664: N-Hexane Extractable
Material (HEM) and Silica Gel Treated
N-Hexane Extractable Material (SGT-
HEM) by Extraction and Gravimetry
(Oil and Grease and Total Petroleum
Hydrocarbons)
Microwave Assisted Acid Digestion of
Siliceous and Organically Based
Matrices, Inductively Coupled Plasma-
Atomic Emission Spectrometry
Synthetic Precipitation Leaching
Procedure
Determination of Inorganic Anions by
Ion Chromatography
Soil Humus Fractions
Standard Classification of Soils for
Engineering Purposes (Unified Soil
Classification System)
Volatile Organic Compounds by Gas
Chromatograpn/Mass Spectrometry
Semivolatile Organic Compounds by
Gas Chromatography/Mass
Spectrometry: Capillary Column
Technique
13
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The basic steps in performing the extraction procedures
are:
* Determine the appropriate solution by reviewing
preliminary analyses of the soil's solid content and
pH of the soil
• Prepare the appropriate extraction fluid (consisting
of one or more concentrated acids, depending on the
procedure), diluted with distilled deionized water
• Place a specified quantity of the soil sample in an
extraction vessel with a predetermined quantity of
extraction fluid
• Rotate the vessel at the specified rotations per minute
(rpm) for the appropriate amount of time (18 to 24
hours)
• Maintain the temperature as described in the methods
• Separate the material by filtering the content of the
vessel through a glass fiber filter
• Analyze the resulting liquid for lead concentrations of
lead by the procedures set forth in SW-846 methods
3050Band6010B
Extraction Procedure for Bioaccessible Lead
The extraction procedure for soil lead bioaccessibility is
presented in the SIVM. The steps in the procedure are:
• Air dry the soil sample, grind it with a mortar and
pestle, and sieve it with a less than 250 microns (um)
sieve
• Analyze the sample for total lead using a XRF analyzer
• Add the sample to an aqueous extraction fluid
consisting of deionized water, glycine as a buffer,
and concentrated hydrochloric acid
• Maintain the sample and extraction fluid at a pH of
1.50, ±0.05, and tumble both in a water bath at 37° C
for one hour, using a modified TCLP apparatus
• Collect 15 milliliters (mL) of extract from the
extraction vessel into a 20-cubic-centimeter syringe
and filter through a 0.45-micrometer (urn) cellulose
acetate disk filter into a 15-mL polypropylene
centrifuge tube
• Analyze the filtered extract for lead using ICP-AES
according to SW-846 Method 601 OB
Table 2-3 summarizes the acids used in extraction fluids
and other operational parameters of the extraction
procedures.
Lead Speciation by Scanning Electron
Microscopy
The percent frequency of various lead species (hereafter
referred to as lead phases) in soil samples before and after
treatment was determined by application of the metal
speciation procedure developed by Dr. John Drexler
(University of Colorado 1998). The procedure uses an
electron microprobe (EMP) technique to determine the
frequency of occurrence of metal-bearing phases in soil
samples.
The EMP used for this analysis is equipped with four
wavelength dispersive spectrometers (WDS), an energy
dispersive spectrometer (EDS), a backscatter electron
imaging (BEI) detector for taking photomicrographs, and
a data processing system. Two of the spectrometers were
equipped with synthetic "pseudocrystals" that have been
developed recently for WDS applications. The
pseudocrystals are known as layered dispersive elements
(LDE). The materials are composed of alternating layers
of boron and molybdenum of varying thicknesses and are
designed to optimize the separation of individual wavelengths
in the x-ray characteristic radiation spectrum. The first of
Tabte 2-3. Summary of Extraction Procedures
Method
TCLP
MEP (first extract)
MEP (second through
ninth extracts)
SPLP
SIVM
Extraction Fluid
Acetic acid
Acetic acid
Sulfuric and nitric acids
Sulfuric and nitric acids
Hycrochloric acid
pH of Fluid
4.93 ± 0.05
5.0 ±0.2
3.0 ±0.2
4.20 ± 0.05
1.50 ±0.05
Temperature
23°C ± 2°C
20°C - 40°C
20°C - 40°C
23°C ± 2°C
37°C
Time of Extraction
1 8 ± 2 hours
24 hours
24 hours
18 ±2 hours
1 hour
14
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the materials to be produced for WDS applications (LDE-
1) was used in one of the spectrometers for the
determination of oxygen. Another spectrometer was
equipped with a LDE designed to detect carbon (LDE-C).
Lead speciation was determined by using the BMP to
perform point counts on the samples. Point counting is a
method of determining the volume fractions of constituent
phases in a sample from the relative areas, as measured on
a planar surface. The EMP analyzes a sample oil a point-
by-point basis to determine how much of a given phase is
present in a sample. The point counts were performed by
crossing each sample from left to right and from top to
bottom with the electron beam. The amount of vertical
movement for crossing depends on the magnification used
and the size of the cathode-ray tube. In all cases, the
movement was kept to a minimum so that no portion of the
sample was missed. Two magnification settings were
used for each sample, one ranging from 40 to 100 X and
the other ranging from 300 to 600 X. The second
magnification allowed the identification of the smallest
identifiable phases (1 to 2 urn). The precision of the EMP
lead speciation data was determined from duplicate analysis
performed every 20 samples.
Lead Speciation by Sequential Extractions
The lead phases in the soil samples from both sites were
identified by application of Tessier's sequential extraction
procedure (Tessier 1979). The soil samples were analyzed
by the Laboratory for Environmental and Geological
Studies at the University of Colorado, Boulder.
The soil samples were air-dried, ground with a mortar and
pestle, and sieved to less than 250 um. The procedure uses
sequential chemical extractions with different reagents to
determine the concentration of lead that partitions into
each of several discrete metal phases. The phases include
exchangeable lead, lead bound to carbonates, lead bound
to iron oxide, lead bound to manganese oxide, lead bound
to organic matter, and residual lead. Approximately one
gram of the sample aliquot (dried weight) was used for the
' initial extraction. The reagent used to extract the
exchangeable lead phase was magnesium chloride (MgCl2)
at a pH of 7.0. For the second extraction, a solution of
sodium acetate and acetic acid at a pH of 5.0 was used to
extract the lead bound to carbonates. For the third
extraction, ;a hydroxyl amine hydrochloride in 25 percent
acetic acid;(pH ~ 2) solution was used to extract the lead
bound to iron and manganese oxides. For the fourth
extraction, hot hydrogen peroxide in a nitric acid solution
and subsequently ammonium acetate were used to extract
the lead bound to organic matter. For the final extraction,
a solution ofhydrofluoric and perchloric acid solution was
used to extract the lead bound to primary and secondary
minerals (the residual phase).
Oxidation-Reduction Potential
The soil samples were prepared for determining Eh using
the sample preparation procedures set forth in SW-846
Method 9045C. The method consisted of preparation of a
soil suspension by adding 20 mL of reagent water to 20
grams of soil. The mixture was covered and stirred for five
minutes. The soil suspension was allowed to stand for one
hour to allowmost of the suspended clay to settle out of the
suspension. The Eh then was measured according to
American Society for Testing and Materials (ASTM) Test
Method D1498-93, "Standard Practice for Oxidation-
Reduction Potential of Water." A meter capable of
reading millivolts (mV) with a reference electrode and an
oxidation-reduction electrode was used to take the
measurements. The meter first was allowed to warm up
for two to three hours before measurements were taken.
After the meter was checked-for sensitivity "and the
electrodes were washed with deionized water, the
electrodes were placed into the sample. While the sample
was agitated with a magnetic stir bar, successive portions
of the sample were measured until two successive portions
differed by no more than 10 mV.
pH
The pH was evaluated by application of the procedures set
forth in SW-846 Method 9045C. The method' consisted of
the preparation of a soil suspension by adding 20 mL of
reagent water to 20 grams of soil. The mixture was
covered and stirred for five minutes. The soil suspension
was allowed to stand for one hour to allow most of the
suspended clay to settle out of the suspension. A pH meter
was allowed to warm up for two to three hours before
measurements were taken. After the meter was checked
for sensitivity and the electrodes were washed with
deionized water, the electrodes were placed in the clear
supernatant portion of the sample. If the temperature of
the sample differed by more than 2EC from that of the
buffer solution, the pH values measured were corrected
for the temperature difference.
Cation Exchange Capacity
One sample from the untreated and treated soil samples
from each site was selected for evaluation of CEC, which
was determined by the barium chloride (BaCl2) method.
The Bad method provides a rapid means of determining
15
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the exchangeable cations and the "effective" CEC of a
wide range of soil types. By that method, CEC is calculated
as thesum of exchangeable cations (Ca, Mg, K, Na, Al, Fe,
and Mn). The procedure consisted of the following steps:
« The soil sample was air-dried, ground using a mortar
and pestle, and sieved to less than 250 um
• Approximately 0.5 gram of soil was placed into a 50-
mL centrifuge tube with 30.0 mL of 0.1 molar BaCl2,
and the mixture was shaken slowly on an end-over
end shaker at 15 rpm for 2 hours
• The mixture was centrifuged for 15 minutes, and the
supernatant portion was filtered through a Whatman
No. 41 filter paper
• The cations were analyzed with an atomic absorption
spectrophotometer
Acid Neutralization Capacity
The acidneutralization capacity of the soil was determined
by application of EnvironmentCanadaMethodNo. 7. The
soil samplewas air-dried, groundusingamortarandpestle,
and sieved to less than 250 um. The amount of neutralizing
bases, including carbonates, was then determined by
treating each sample with a known excess of standardized
hydrochloric acid. The sample and acid were heated to
allow completion of the reaction between the acid reagent
and the neutralizers in the soil sample. The calcium
carbonate equivalent of the sample was obtained by
determining the amount of unconsumed acid by titration
with standardized sodium hydroxide.
Lead Analytical Procedures
Two procedures were used to determine the lead
concentrations in the soil. One analytical procedure used
a nitric acid solution to measure all but the most stable
forms of lead in the sample, and the other procedure used
hydrofluoric acid to measure all of the lead in the sample.
The nitric acid digestion procedure involved digesting
approximatelyonegramofsoilwithasolutionofnitricacid,
hydrogen peroxide, and hydrochloric acid. The mixture
was heated to 95°C, ± 5°C, for approximately two hours.
The digestate was filtered through Whatman No. 41 filter
paper into a flask and analyzed for lead ICP-AES, as
described in SW-846 Method 6010B.
Thehydrofluoric acid digestion procedure involved heating
approximately one gram of soil in a solution containing
nitric and hydrofluoric acids to 180°C, ± 5°C, for
approximately 9.5 minutes. The digestate was filtered
through Whatman No. 41 filter paper into a flask, and the
filtrate was analyzed for lead by ICP-AES, as described
in SW-846 Method 6010B.
Soil Classification
Soil classification consisted of determining the particle size
distribution, liquid limit, and plasticity index of the soil
samples. That information was used to classify the soil
according to basic soil group, assigning a group symbol and
name. The particle size distribution was determined by
sieving the dried soil samples through a series of sieves and
determining the percentage by weight that was retained on
the sieves. The liquid limit is the water content (measured
as percent moisture) at which a trapezoidal groove cut in
moist soil (in a special cup) closes after being tapped 25
times on a hard rubber plate. The plastic limit is the water
content at which the soil breaks apart when rolled by hand
into threads of 1/8-inch diameter. The plasticity index is
determined by first determining the liquid andplastic limits
and then subtracting the plastic limit from the liquid limit.
Humic and Fulvic Acids
Humic and fulvic acids were extracted from the soil
samples and quantified through the use of a sodium
hydroxide solution, as described below:
• Air dry 15 g of soil, grind it to less than 250 jam, and
place it in a 250-mL plastic centrifuge bottle
• Add 150 mL of 0.5 molar hydrochloric acid, let the
mixture sit for one hour, and then centrifuge it for 15
minutes and discard the supernatant portion
• Add 150 mL of deionized water to the centrifuge
bottle and mix it to wash the soil of remaining acid;
centrifuge again for 15 minutes and discard the
supernatant portion
• Add 150 mL of 0.5 molar sodium hydroxide to the
centrifuge bottle and flush the head space with
oxygen-free nitrogen gas
• Place the bottle on an end-over-end shaker for 18
hours
• Centrifuge the mixture for 15 minutes, decant the
supernatant portion, and separate that portion into the
humic and fulvic fractions by acidifying the extract to
a pH of 1.5; the precipitate is the humic acid fraction,
and the supernatant portion is the fulvic acid fraction
2.3.2 Statistical Methods
This section provides a brief overview of the statistical
methods that were used to evaluate the data from the SITE
demonstration. The methods included assessing the
16
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distribution of sample data and calculating specific calculated differences, and Sy2 represents the calculated
parametric and distribution-free statistics. -• . variance.
2.3.2.1 Determination of the Distributions of
the Sample Data
A preliminary assessment of distribution of data was
conducted to determine the approximate statistical
distribution of the sample data whenparametric hypothesis
tests were performed. For the evaluation of the data
collected for theprimary and secondary objectives, sample
data distributions were determinedbythefollowingmethods:
(1) common graphical procedures, including histograms,
box-plots, stem-and-leafplots, and quartile-quartile plots,
and (2) formal testing procedures, such as the Shapiro-
Wilk test statistic, to determine Whether a given data set
exhibits anormal distribution.
2.3.2.2 Parametric and Distribution-Free Test
Statistics
Various testing procedures were employed to determine
whether there were any significant differences between
concentrations of leadandconcentrations of otheranalytes
of interest in the treated soil and the untreated soil. Table
2^4 summarizes the statisticalprocedures used in evaluating
the analytical results associated with each of the obj ectives
of the SITE demonstration. As the table shows, all the
parametric statistical procedures used to evaluate the data
from the demonstration involved the Student's t-tests.
Paired Student t-tests were conducted on data collected
from the trailer park, and Unpaired Student t-tests were
required on data from the pottery factory because of the
unequal sizes of samples of treated and untreated soils
from that location (see Figure 2-2). In addition, the formula
for the Student's t-test was adjusted for evaluation of P2,
because the estimator used for that objective (percent
reductionofpercentbioavailablelead)requiredmanipulation
to avoid the creation of a Cauchy (nonnorrnal) distribution,
which cannot-be evaluated by a Student's t-test. Data
points obtained from the trailer park, for evaluation of P2
(sufficient data from the pottery factory were not available
forapplicationofameaningfulStudent'st-testforevaluatibn
of P2) were evaluated in a paired Student's t-tests, using
the folTowingformula;
The calculation results in the following t-test statistic:
ym
which follows a t-distribution with n-1 degrees of freedom.
The test then can be used to determine whether the
observed mean difference varies significantly from 0.
The formula used for testing for a 100(l-rO ,) percent
reduction in the arithmetic mean contaminant levels
between normally distributed (paired) data on treated and
untreated soils for P2 was:
" •£
CK = CT- Cu(\ - ro) where Cr = £ 'xafl n arid Cv = £ *•<* / «
• - ,-=i : ;=i • ;
where xth and xuh represent the ith observations about
the treated and untreated soils, n represents the sample
size, CT and Cy represent the arithmetic mean of
observations about the treated and untreated soils, r0
represents the proportional! ty reduction factor (for example,
if testing for a 25 percent reduction, r0= 0.25), and CR
.represents the computed test statistic. The variance for
the estimate was calculated as follows:
Var(CR) = [&-2 + (1- rtfSu2 -2(1- ro)5w]/»
where S/ and S.J fepresentthe calculated sample variance
for the treated and untreated soils, S^ represents the
calculated sample eavariance between fc soils,, and the
term Var( ) symbolizes "the variance af."' However, the
following more convenient calculation wasapplfed to the
individual, paired observations :
y, = x,j - (1 - ro)*,/ , y«=
, and
(yi - ymff(n - 1)
yi = Xii - Xui
,. art<$
where xti and xui represent the ith observations about
treated and untreated soils, n represents the sample size,
yi represents the calculated difference between the ith
observations, ym represents the arithmetic mean of the
where all terms are defined asbefore, since it can be easily
shown that: ^ , , ....
ym = CR and Sy2 = Var(CR).
That calculation resulted in the following t-test statistic:
ym .......
wriichfollowsat-distributionwithn-7degreesoffreedom.
Bootstrap resampling analysis, adistribution-free analysis,
was performed when assumptions about the distribution of
the sample data were not met. Bootstrap resampling was
used to estimate means, confidence intervals, or construct
hypothesis tests. Bootstrap resampling techniques also
17
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Table 2-4. Summary of Statistical Procedures Used to Evaluate Each of the Objectives of the Demonstration
Objective
P1: Determine whether teachable lead in
son can be reduced to concentrations that
comply with the alternative UTS for
contaminated soil that are codified at 40
CFR part 268.49'.
P2: Determine whether the portion of total
lead in soil that is "bioaccesslble," as
measured by an experimental method, can
be reduced by at least 25 percent2.
S1: Evaluate the long-term chemical
stability of the treated soil.
Test Method/ Test Variable
TCLP/Mean concentration of lead in extract
(mg/L)
SIVM/Mean percentage of total lead
extracted by the method
MEP/Mean lead concentration in each
extract (mg/L)
SEM lead speciation/Percent distribution of
lead among various lead phases3
Sequential extraction/Mean concentration of
ead in each phase (mg/L)
Eh (mV)
PH
CEC/Milliequivalents per gram (meq/g)
Acid neutralization capacity/meq/g
"otal lead-nitric acid/Mean lead
concentration of lead (mg/kg)
Statistical Method/Acceptance Criterion for
Meeting the Objective
Student's t-test formula at the 0.05 level of
significance/Mean concentration of the
treated soil must be less than 7.5 mg/L or
90 percent of the mean concentration in
untreated so.il, whichever is the higher
value.
Student's t-test formula at the 0.05 level of
significance/Mean percentage of total lead
in the extract from Ihe treated soil must be
at least 25 percent lower than the mean
percentage of total lead in the extract from
the untreated soil.
Review of test results/Concentrations of all
extracts from the treated soils must be lower
than 5 mg/L (a nominal concentration that
would be expected to meet or exceed
cleanup goals at some sites).
Review of test results/Percent frequencies
of more soluble and less soluble phases of
ead in the treated and untreated soils must
be lower and higher, respectively.
Student's t-test formula at the 0.05 level of
significance/Mean concentrations of the
nore soluble and less soluble phases of
ead in the treated and untreated soils must
be lower and higher, respectively.
Student's t-test formula at the 0.05 level of
significance/Mean Eh of the treated soil
must be lower than that of the untreated
soil.
Student's t-test formula at the 0.05 level of
significance/Mean pH of the treated soil
must be higher than that of the untreated
soil and 7.0.
Review of test results/CEC must be
ncreased, as indicated by a qualitative
eview of statistical summary data.
Review of test results/Neutralization
capacity must be increased, as indicated by
a qualitative review of statistical summary
data.
Student's t-test formula at the 0.05 level of
significance/Mean concentration of lead in
le treated soil must be lower than that in
the untreated soil.
(continued)
18
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Table 2-4. Summary of Statistical Procedures Used to Evaluate Each of the Objectives of the Demonstration (continued)
Objective
•
S2: Demonstrate that the application of Soil
Rescue did not increase the public health
risk of exposure to lead.
i
S3: Document baseline geophysical and '
chemical conditions in the soil before the
application of Soil Rescue.
S4: Document operating and design
parameters for Soil Rescue.
Test Method/ Test Variable
Total lead-hydrofluoric acid /Mean
concentration of lead (mg/kg)
SPLP lead/Mean concentration of lead in
the extract (mg/L)
Total phosphate/Mean concentration of
phosphate
SPLP phosphate/Mean concentration of
phosphate in the extract (mg/L)
Total lead/Mean concentration of lead in the
air (mg/m3)
Soil classification, total VOCs, SVOCs, oil
and grease, and humic and fulvic acids
Cost analyses
Statistical Method/Acceptance Criterion for
Meeting the Objective
Student's t-test formula at the 0.05 level of
significance/Mean concentration of lead in
the treated soil must not be higher or lower
than that in the untreated soil.
Student's t-test formula at the 0.05 level of
significance/Mean concentration of lead in
the extract of the treated soil must be less
than 5 mg/L (a nominal concentration that
would be expected to meet or exceed
cleanup goals at some sites).
Review the results/Mean concentration of
total phosphates in the treated soil must not
be significantly higher or lower less than
that in the untreated. soil.
Review the results/Mean concentration of
phosphate in the extract of the treated soil
must be less than or equal to that of the
untreated soil.
Review of test results/Concentrations of
airborne lead must not exceed NAAQS
limits for lead.
Review of test results/Identify results that
appear unusual in light of the location and
history of the site (no specific acceptance ,
criteria were established for S3).
Present cost data/No specific acceptance
criteria were established for S4.
Notss* * ' ' ' *
'Objective.P1 was evaluated statistically only on analytical results from the inactive pottery factory; only three samples pertinent to that
objective were collected from the trailer park. '
Achievement of P2 was evaluated only at the trailer park.
3SEM lead speciation was conducted only on soils collected from the trailer park.
were used to check the results produced by various
parametric tests. A bootstrap analysis was performed on
the soil lead bioaccessibility data on #19 paired samples.
The bootstrap analysis was performed by drawing N
samples of size n from the observed individual percent
reduction (PR) sample values defined as:
PR/=100|l- —
V ~V •
\ AUl'
where xtiandxui once again represent the zY/z observations
about treated and untreated soils,« represents the sample
size, and TVrepresents the number of times the simulations
were performed ( N= 1000 and n = 10 for this study). The
bootstrap samples then were used to calculate: (1) the
observed mean percent reduction; (2) a 100(l-alpha)%
confidence interval for this mean estimate, using the
observed bootstrap cumulative distribution function; and
(3) the proportion of sample means that exceed a given
100(1- r0)% threshold (that calculation represents a
bootstrap version of a hypothesis test).
2.4 RESULTS OF THE SITE
DEMONSTRATION
The following sections present the analytical data relevant
to each objective of the demonstration and the results of
evaluations of those data, including summaries of statistical
calculations. Section 2.4.1 addresses PI, Section 2.4.2
addresses P2, and sections 2.4.3 through 2.4.6 address S1
through S4, respectively.
2.4.1 Evaluation of P1
Determine whether leachable lead iri soil can be reduced
to concentrations that comply with the alternative UTS for
contaminated soil that are codified at 40 CFRpart 268.49.
The treatment standards for contaminated soil that are
codified at 40 CFR part 268.49 require that the
concentrations of lead in the treated soil, as measured by
the TCLP, must be less than 7.5 mg/L or at least 90 percent
lower than those in the untreated soil, whichever is the
19
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higher concentration. Soil samples were collected from
the experimental unitat the inactive pottery factory before
and after treatment to assess the Soil Rescue treatment
process. Table 2-5 summarizes the TCLP lead data for the
inactive pottery factory site.
The results of the statistical analysis of those data, shown
in Table 2-6, demonstrate that the mean concentration of
TCLP lead in treated soil from the inactive pottery factory
was significantly less than 7.5 mg/L; in fact, the results
reflectaprobabilityofless than 0.005 (or 1 in500)thatthe
actual mean concentration of TCLP lead in the treated
soils is higher than 7.5 mg/L. Therefore, it was concluded
that Soil Rescue achieved the first primary objective (PI)
of the SITE demonstration. In addition, Soil Rescue
exceeded PI in that the mean concentration of TCLP lead
in the untreated soil was reduced by more than 99 percent.
Data from the trailer park were not used to evaluate P1 on
a formal statistical basis; however, concentrations of
TCLP lead were measured in untreated and treated soil at
3 of the 10 experimental units at that location. The
analytical results for TCLP lead from two of those
experimental units indicate similar reductions in
concentrations of TCLP lead. No reductions in
concentrations of TCLP lead could be identified for
samples collected at the third experimental unit, because
the concentrations of TCLP lead in both untreated and
treated soils from that unit were lower than detection
limits. Table 2-7 summarizes the TCLP lead results from
the trailer park.
Table 2-6. TCLP Lead Summary and Test Statistics for the
Inactive Pottery Factory Site
Untreated
Mean
(mg/L)
403
Treated
Mean
(mg/L)
3.3
Percent
Reduction
99%
Treated
95% UCL
(mg/L)'
3.484
Probability
That the
Actual
Treated
Mean Is
>7.5 mg/L
(Students
t-test)
<0.005
Table 2-6. TCLP Lead Results for the Inactive
Pottery Factory Site
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/L)
453
376
411
364
411
n/s
n/s
n/s
n/s
Treated
(mg/L)
3.2
3.0
3.6
3.5
3.1
4.0
2.9
3.2
3.2
Note: n/s = Not sampled (see Figure 2-2).
2.4.2 Evaluation of P2
Determine whether the portion of total lead in soil that
is "bioaccessible," as measured by an experimental
method, can be reduced by at least 25 percent.
The objective was evaluated by collecting samples of
untreated and treated soil from the trailer park for soil lead
bioaccessibility and analyzing the samples by the SBRC' s
SIVM. Table 2-8 presents the results of the SIVM
analysis of the untreated and treated soil samples. Soil lead
bioaccessibility is the ratio of the amounts of lead that is
solubilized during the extraction to the total amount of lead
in the soil sample. The concentrations of bioaccessible
lead in the untreated soils (mg/kg) are calculated on the
basis of total lead measured in the extract and the mass of
the soil extracted during the test. The concentrations then
are divided by the total concentration of lead measured in
the untreated soil to arrive at the percentage ofbioaccessible
lead in the untreated soils. Identical measurements and
calculations are used to calculate the percentage of
bioaccessible lead in the treated soils.
Data analysis for the objective consisted of performance
of an assessment of data distribution and a parametric test
(t-test). An assessment of the results of the validity of the
parametric test was performed by the conduct of a
distribution-free test (bootstrap analysis).
Table 2-7. TCLP Lead Results for the Trailer Park
Site
Experimental
Unit
G
L
T
Sampling
Location
Comp
Comp
Comp'
Untreated
(mo/L)
13.2
11.9
<0.50
Treated
(mg/L)
1.3
1.4
<0.50
Note: Comp = Composite of five sampling locations
within an experimental unit (see Figure 2-1).
20
-------
Table 2-8. Soil Lead Bioaccessibility Results
Unit
C
G
K
L
M
;N
o
Q
R
T
Untreated Results
Total
Lead
(mg/kg)
645.97
6446.73
2394.56
7775.47
2941.40
2303.51
2378.06
726.82
1406.92
339.34
Bioaccessible
.Lead (mg/kg)
325.29
4536.05
1378.70
5209.88
1714.58
1338.74
1140.08
381.79
649.48
148.68
Percentage
Lead
50.4%
70.4%
57.6%
67.0%
58.3%
58.1%
47.9%
52.5%
46.2%
43.8%
Treated Results
Total Lead
(mg/kg)
587.41
8751.09
2525.71
7255.24
2862.71
1680.93
2980.51
824.93
1397.99
348.95
Bioaccessible
Lead (mg/kg)
259.79
6025.50
1617.51
4780.36
1807.93
953.83
1553.04
344.46
699.90
113.34
Percentage
Lead
44.2%
68.9%
64.1%
65.9%
63.2%
56.8%
52.1%
41.8%
50.1%
32.5%
Summary
Percent
Reduction
12.2%
2.1%
-11.2%
1.7%
-8.3%
2.4%
-8.7%
20.5%
-8.5%
25.9%
The assessment of data distribution suggested that the soil
lead bioaccessibility data followed a normal distribution
(for both untreated and treated soils). Therefore, the
standard t-test formula for testing for a 100 (l-rO)%
reduction in the arithmetic mean was used, with rO equal
to 0.25. Table 2-9 presents a summary of the parametric
test statistics, which can be used to determine whether a
reduction of at least 25 percent in the soil lead
bioaccessibility has been achieved. To conclude that
reduction of at least 25 percent has occurred at a
significance level of alpha 0.05, the observed t-sewe
should be less than -1.812. On the basis of that criterion,
the percent reduction achieved appears to be less than 25
percent.
An assessmentofthe validity oftheresultsoftheparametric
test was performed through the conduct of a bootstrap
analysis of the sample values. For the bootstrap analysis,
samples of size 10 were drawn with replacement 1,000
times from the Soil Rescue soil lead bioaccessibility data.
Table 2-10 summarizes the results of that analysis.
The calculatedpercentreductionin soil leadbioaccessibility
was 2.92 percent, with a calculated standard deviation of
3.99 percent and a 95 percent confidence interval of-4.8
percent to 11.2 percent. None of the 1,000 bootstrap
calculations were found to exceed a percent reduction
value of 25 percent. Therefore, the results of the bootstrap
analysis support the results of the parametric test, which
indicate that Soil Rescue did not appear to achievef he goal
of at least 25 percent reduction in soil lead bioaccessibility
in soils from the trailer park.
2.4.3 Evaluation of Objective S1
Demonstrate the long-term chemical stability of the
treated soil.
Various analytical procedures that are indicative of long-
term chemical stability/were selected for use in evaluating
SI. For the demonstration, tfceloHg-termchemical stability
ofthe treated soil was evaluatedbycomparingthe analytical
results for the untreated soil samples with those for the
treated soil samples, using leaching procedures, lead
speciation methods, and other inorganic chemical
procedures, including the MEP, lead speciationby scanning
electron microscopy, lead speciationby the sequential soil
serial extraction procedure, Eh, pH, cation exchange
capacity, acid neutralization capacity, total lead in soil (as
determined by two methods), leachable lead by the SPLP,
total phosphates, andleachablephosphates.Thediscussions
below describe the analytical methods, how the methods
were used to indicate long-term chemical stability, and the
analytical results for each method.
MEP
The MEP was designed to simulate both the initial and
subsequent leaching that a waste would undergo in a
21
-------
Table 2-9. Parametric Test Statistics, Soil
Lead Bioaccessibillty Data
Statistic
Value of Cn<
Standard deviation
t-scoro (H0: Cn greater
than or equal to 0)
Level of significance
Data
12.53%
7.2
5.499
0.9999
Note:
1 cn ~ c( ' Cu (1-r0 ) (see Section 2.3.2.2)
Table 2-10. Bootstrap Statistical Results for Bioavailable
Lead Difference Data
Statistic
Mean
Standard deviation
95% confidence interval
Number of percent reduction samples > 25%
Data
2.92%
3.99%
(-4.8%, 11.2%)
0/1,000
sanitary landfill. The criterion established for determining
whemermeresultsofmeMEP demonstrate achievements
of SI (long-term chemical stability) required that the
concentrations of lead leached from the treated samples
were less than 5.0 mg/L. The criterion is a nominal
concentration that would be expected to meet or exceed
cleanup goals at some sites; therefore, it is not provided in
any federal laws or regulations. Although the MEP was
not designed for use on untreated soils, the demonstration
plan included analysis of untreated soils using the MEP to
provide a basis of comparison with the test results on the
treated soils.
Table 2-11 lists the analytical results for the MEP. The
data on untreated soil from experimental unit G at the
trailer park indicated that the analytical results for the
MEP exceeded 5.0 mg/L for days 5 and 6 of the 11-day
extraction period. The data on treated soil from the trailer
park indicated that the MEP analytical results were
consistently less than 5.0 mg/L for the extraction period.
Figure 2-3 shows the MEP results for the sample of
untreated soil from unit G that were higher than or equal
to 5.0 mg/L withthe correspondingresults for treated soils.
For the five sampling locations at the inactive pottery
factory, results for samples of untreated soil were higher
than orequaltoS.Omg/L.Thedataon treated soil fromthe
inactive pottery factory indicated that the analytical results
for the MEP were consistently less than 5.0 mg/L for the
extraction period.Figures2-4through2-8showtheresults
for the samples of untreated soil from the inactive pottery
factory thatwerehigherthan or equal to5.0mg/L, with the
corresponding results for treated soil.
On days 7 or 8, the extractions are repeated until
concentrations decrease, or until Day 12. Results for Days
10 to 12 were not recorded if there was no increase in lead
concentrations from Days 7 or 8 to Day 9.
The analytical results for the MEP indicate that the lead did
not leach from the soil treated with Soil Rescue under
repetitiveprecipitationofacidrain conditions. Therefore,
the long-term chemical stability of the treated soil, as
measured by the MEP, appears to have been enhanced by
the addition of Soil Rescue.
Lead Speciation by Scanning Electron
Microscopy
This procedure used an BMP technique to determine the
frequency of occurrence of 18 lead-bearing phases in soil
samples from the trailer park location only. For the
demonstration, the mean of the percent frequency of each
lead phase was evaluated with regard to the effect the
change in that phase will have on the long-term chemical
stability of the treated soil. The long-term chemical stability
of a soil is enhanced if the application of Soil Rescue
increased the frequencyofthephaseshavinglowsolubilities
(such as the lead phosphate phase) and decreased the
frequency of the species that are highly soluble (such as
the lead metal oxide phase). Because of the volume of data
generated from the procedure (10 samples for each of 18
metal-bearing phases), the mean of the percent frequency
of each phase was determined to compare the analytical
results for untreated and treated soils. The unpublished
TER provides a table of the raw lead speciation data. The
TER is available upon request from the EPA work
assignment manager (see Section 1.4 for contact
information).
Table 2-12 shows the mean percent frequency !of each
metal phase for untreated and treated soils, as well as other
descriptive statistics. The data suggest that there were
potentially significant changes from untreated to treated
soils for only 5 of the 18 phases that were evaluated. The
frequency of the lead phosphate phase, and possibly the
glass phase, increased between the values for untreated
and treated soils, a condition that would be indicative of an
22
-------
N>
CO
Table 2-11.
Experimental
Unit
C
C
G
G
K
K
L
L
M
M
N
N
0
0
Q
Q
Q (Duplicate)
Q (Duplicate)
R
R
MEP Analytical Results
Untreated/
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Initial Extract
(mg/L)
<0.050
0.21
1.8
0.61
0.18
0.97
0.55
0.65
1.3
0.61
0.11
0.91
0.16
0.2
<0.050
0.09
0.075
0.078
0.1
0.39
Day1
(mg/L)
<0.050
0.12
0.38
0.62
0.11
0.4
0.19
0.81 ..
<0.050
0.37
0.12
0.43
0.075
0.13
0.062 .
0.061
<0.050
0.081
0.09
0.2
Day2
(mgl)
<0.050
<0.050
0.11
0.98
0.14
0.33
0.25
0.58
0.22 .
0.48
0.12
0.25
0.11
0.087
<0.050
0.071
<0.050
<0.050
0.086
0.15
Day3
(mg/L)
<0.050
<0.050
0.15
0.52
0.067
0.21
0,21
0.38
0.11.
0,26
<0.050
0.11
<0.050
0.23
<0.050
0,064
<0.050
0.061
<0.050
0.057
Day 4
(mg/L)
Day 5
(mg/L)
Trailer Park
<0.050
<0.050
0.057
0.24
<0.050
0.065
0.12
0.15
0.063
0.1
<0.050
0.072
<0.050
0.091
<0.050
<0,050
<0.050
<0.050
<0.050
<0.050
<0.050
<0.050
20
0.078
0.64
0.057
0.12
0.076
0.12
<0.050
0.088
<0.050
<0.050
0.1
0.077
<0.050
0.28
<0.050
<0.050
0.057
Day 6
(mg/L)
0.095
<0.050
7.4
0.22
1.7
0:25
0.072
<0.050
<0.050
<0.050
0.2
0.06
<0.050
0.11
0.21
<0.050
0,36
<0.050
<0.050
0.058
Day 7
(mg/L)
DayS
(mg/L)
Day 9
(mg/L)
0.064
<0.050
3.9
0.27
0.62
0.33
0.11
0.06
<0.050
<0.050
0.11
<0.050
<0.050
0.92
0.075
1.5
<0.050
<0.050
<0,050
0.073 ;
0.087
<0,050
2.3
0.34
1.3
0.33
0.11
0.12
0.38
0.06
0.6
0.061
0.3
0.059
0.22
<0.050
0.28.
<0.050
<0.050
0.095
<0.050
<0.050
3.3
0.14
0.49-
0,32
<0.050
0.12
0.056
<0.050
0.099
0.06
<0.050
<0.050
<0.050
<0.050
0.09
<0.050
0.094
0.092
DaylO1
(mg/L)
3.9
0.29
0.22
Note: 'After the initial daily extract, nine extractions are performed on each of ihe following nine days; if the lead concentration is hiqher in
Day 9 than the concentrations in Days 7 or 8, the extractions are repeated until concentrations decrease, or until Day 12 Results for Davs 1 0
to 12 were not recorded if there was no increase in lead concentrations from Days 7 or 8 to Day 9.
Day 11
(mg/L)
2.8
0.6
0.14
Day 12
(mg/L)
0.22
(continued)
-------
N>
Table 2-11. MEP Analytical Results (continued)
Experimental Unit
Untreated/
Treated
Initial Extract
(mgl)
Day1
(mgl)
Day 2
(mgl)
Day3
(mgl)
Day4
(mgl)
Day5
(mgl)
Day 6
(mgl)
Day 7
(mgl)
Day8
(mgl)
Day 9
(mgl)
DaylO1
(mgl)
Day 11
(mgl)
Trailer Park
T
T
Untreated
Treated
<0.050
<0.050
<0.050
<0.050
0.051
0.1
<0.050
<0.050
0.11
<0.050
0.14
<0.050
0.45
<0.050
0.26
1.1
0.33
<0.050
<0.050
<0.050
Inactive Pottery Factory
U Location 1
U Location 1
U Location 2
U Location 2
U Location 3
U Location 3
U Location 4
U Location 4
U Location 5
U Location 5
U Location 6
U Location 7
U Location 8
U Location 9
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Untreated
Treated
Treated
Treated
Treated
Treated
640
1.1
450
1
260
1.1
203
1.1
290
1
1.2
0.97
1
1.2
280
1.3
150
2.2
3.7
1.9
7.1
2.9 .
78
1.6
0.5
2.1
1.8
1.5
120
2.3
57
2.1
0.08
2.2
0.61
2.2
2.6
2.5
1.5
1.9
18 :
1.9
21
2.4
7.6
2
0.31
3.5
0,26
2.1
0.39
3.2
1.7
2.5
1.9
2.7
0.14
3.3
0.18
2.7
0.39
3.5
0.45
3.8
0.52
3.5
2.8
2.6
2.8
5.1
0.097
2.4
0.24
2.2
0.16
2.1
0.15
2.9
0.66
2.8
2
2.5
2.3
3.3
0.13
0.99
0,11
0.87
0.15
1.1
0,12
088
1.7
0.94
0.68
0.92
0.88
0.72
0.21
0.86
0,13
0.81
0.29
1
0.2
0.85
2.9
0.8
0.79
0.72
0.64
0.9
0.64
0.87
0.097
0.8
0.18
0.9
0.21
0.81
2.2
1.1
0.71
0.81
0.93
1.6
0.89
0.72
0.077
0.12
0.14
0.65
0.18
0.69
0.84
1.2
0.55
0.82
0.8
1.1
5.5
0.58
0.51
0.53
0.36
0.64
Note: 1After the initial daily extract, nine extractions are performed on each of the following nine days; if the lead concentration is higher in Day
9 than the concentrations in Days 7 or 8, the extractions are repealed until concentrations decrease, or until Day 12. Results for Days 1 0 to- 12
were not recorded if there was no increase in lead concentrations from Days 7 or 8 to Day 9.
0.67
-------
I
20
18
16
14
12
10
8
6
4-
2 .
0-
Pretreatment
EP-Tox
1.8
Day 1
0.38
Day 2
0.11
Day3
0.15
Day 4
0.057
Day 5
~20
Day 6
7.4
Day 7
3.9
Day8
2.3
Day 9
3.3
Day 10
3.9
Day 11
2.8
Post-treatment
0.61
0.62
0.98
0.52
0.24
0.078
0.22
0.27
0.34
0.14
Extraction Day
Figure 2-3. MEP lead results for experimental unit G at the trailer park.
OHU
1
780 -
120 ~
! 20 -
18 -
Ifi -
14 -
i 12 -
£
£ 10 -
8 -
f. -
4 -
2 -
0-
O Pretreatment
• Post-treatment
•\
A
A
EP-Tox
640
1.1
•\
'N
^m
Day 1
280
1.3
A
Day 2
120
2.3
i — i
' •
1
• _• _• r— n J—lrnm r—i
Day 3 Day 4 Day 5 Day 6 Day 7 Day 8 Day 9 Day 10 Day 11
21 0.14 0.097 0.13 0.21 0.64 0.89 5.5 0.67
2.4 3.3 2.4 0.99 0.86 0.87 0.72
Extraction Day
Figure 2-4. MEP lead results for sampling location 1 at the inactive pottery factory.
25
-------
450-
150-
57-
20-
18-
16-
14-
t!2
10-
8 -^
6~
4-
2-
o -
D Pretreatment
• Post-treatment
^
al
=
EP-Tox
450
1
!
*1
F
Dayl
150
2.2
^
i
i
I 1 " '
,
...
" L m mm
• I I
M • H • • H n "«
Day 2 Day 3 Day 4 Day 5 Day 6 Day 7 Day 8 Day 9 Day 10
57 7.6 0.18 0.24 0.11 0.13 0.097 0.077
2.1 2 2.7 2.2 0.87 0.81 0.8 0.12 0.58
Extraction Day
Figure 2-5. MEP lead results for sampling location 2 at the inactive pottery factory.
260-
20-
18-
16-
14-
^ 12
S 10
8-
6 ~
4
2 -
o-
SH Pretreatment
; • Post-treatment
-
-
i
[— 1
,
1 •
•"•' •
EP-Tox Day 1 Da;
260 3.7 0.
1.1 1.9 2.
y 2 Day 3
08 0.31
2 3.5
,.
• _
Jl •
Day 4 Day 5 Day 6
0.39 0.16 0.15
3.5 2.1 1.1
B[ m m
Day 7 Day 8 Day 9
0.29 0.18 0.14
1 0.9 0.65
Extraction Day
Figure 2-6. MEP lead results for sampling location 3 at the inactive pottery factory.
26
-------
203
20
18
16
14
12
10
8
6
4
2
0
Extraction Day
Figure 2-7. MEP lead results for sampling location 4 at the inactive pottery factory.
290
78
20
18
16
14
12
10
8
6
4
2
0
EP-Tox
Day 1
Day 2
Day 3
Day 4
Day 5
Day 6
Day?
Day8
Day 9
Day 10
Pretreatment
290
78
2.6
0.39
0.52
0.66
1.7
2.9
2.2
0.84
Post-treatment
1.6
2.5
3.2
3.5
2.8
0.94 0.8
1.1
1.2
0.51
Extraction Day
Figure 2-8. MEP lead results for sampling location 5 at the inactive pottery factory.
27
-------
Tabte 2-12. Summary of Percent Frequency of Lead Phases Statistical Data
Phase of Lead
Angles! te
Barite
Brass
Cerussite
Clay
Fe-Ox!de*
Fe-Pb Sulfata
Galena
Glass2
Mn-Oxide*
Organic*
Pb Vanadate
PbMO
PbSiO,
Phosphate1
Si-Phosphate
Slag
Solder
Untreated
Mean
0.02
0.1
0
0.41
0
44.77
0.17
0
39.11
8.39
1.88
0
1.93
0.58
0.09
0
2.28
0.02
Standard Deviation
nc'
nc
nc
1.2
nc
15.09
nc
nc
16.15
11.25
455
nc
1.08
137
0.19
nc
nc
nc
Number of Zero Values
9
8
10
8
10
0
7
10
0
3
7
10
0
6
8
10
5
9
Treated
Mean
0.01
1
0.13
0.67
0
21.09
0
0
52.52
2.46
12.23.
0.01
1.52
1.51
5.2
0.07
1.86
0.04
Standard Deviation
nc
nc
nc
1.7
nc
14.47
nc
nc „ .
20.55 .
5.63
16.36
nc
1.07
2.64
4.58
nc
nc
nc
Number of Zero Values
9
6
8
4
10
0
10
10
0
7
3
9
0
3
1
9
6 '
8
' nc s not calculated. Standard deviations were not calculated for data on lead phases that were associated with five or more zero-
valus data points for both the untreated and treated soils. i
1 Appears to be a significant difference between treated and untreated soils.
increase in the long-term chemical stability of the soil. Also
indicative of chemical stability are the apparentreductions
in the iron oxide and manganese oxide phases of lead. The
results also indicate that there was an increase in the
organic lead phase, which indicates a reduction in stability
from the untreated to the treated soils. Application of Soil
Rescue appears to increase the organic lead phase;
however, it also appears to increase the less-soluble
phosphate phase and reduce the soluble oxide phases of
lead in the treated soil. Because of the nature of the
speciation test, it is not possible to identify the netresult of
the changes in the frequencies of those five phases.
Therefore, the lead speciationresults werenotunanimously
consistent with the attainment of objective S1; however, it
appears that those results suggest that Soil Rescue can
enhance the long-term stability of treated soil.
Lead Speciation by Sequential Extraction
This procedure uses sequential chemical extractions with
different reagents to determine the concentration of lead
that partitions into each of several discrete metal phases.
The phases include exchangeable lead, lead bound to
carbonates, lead bound to iron oxide, lead bound to
manganese oxide, lead bound to organic matter, and
residual lead.
The lead in the exchangeable phase, carbonates phase,
iron oxide phase, manganese oxide phase, and organic
matter phase is subject to release to the environment in a
soluble form because of such changes in soil conditions as
pH and Eh. The residual phase contains principally primary
and secondary minerals that may hold the lead within their
crystal structures. Therefore, long-term stability was
evaluated by comparing the concentrations of lead in each
28
-------
phase of the untreated samples with the concentrations of
lead in each phase of the treated samples. Long-term
stability would be suggested if there are decreases in the
concentrations of lead in the exchangeable phase,
carbonates phase, iron oxide phase, manganese oxide
phase, and organic matter phase, with an increase in the
residualphase.
Tables 2-13 and Table 2-14 present the results of the
sequential extractions on soil samples from the trailer park
and the inactive pottery factory, respectively. On the basis
of an assessment of graphical data distribution, the
sequential extractiondataappear to bedistributednormally.
Therefore, the data on untreated soils from the trailer park
and the inactive pottery factory were analyzed separately
throughapplicationofaseries of individual t-tests extraction.
Table 2-15 displays the summary statistics associated with
the sequential extraction data from both locations. Those
statistics include the estimated means for the untreated
and treated soils, the calculated percent change in those
means, and the level of significance of each t-score. Note
that, because a total of six simultaneous t-tests were
performed, a Bonferroni correction was used to preserve
the overall Type 1 error rate. Therefore, no t-score should
be considered statistically significant at the 0.05 level
unless the corresponding level of significance is less than
0.05/6 = 0.0083.
As Table 2-15 shows, the results of the sequential serial
soil extractions indicate reductions in the concentrations of
four of the six lead phases (exchangeable, carbonate,
manganese oxide, and iron oxide) and increases in the
other two lead phases (organic matter andresidual) in soils
from both sites. Those results are consistent with those
obtained for lead speciation by the SEM procedure
(presented in the previous section).
Of the results for the 12 Student t-tests, 8 appear to be
statistically significant. The four other results were almost
statistically significant; therefore, the changes in the treated
soils that these other four tests indicated probably occurred.
The four results that were not found to be significant at the
0.05 level of significance include increases in exchangeable
and organic matter phases at the trailer park and increases
in residual concentrations at both locations. There are
significant decreases in the mean concentrations of lead
bound to carbonates and lead bound to iron and manganese
oxide phases at both sites. Soil from the trailer park also
exhibited a significant decrease in lead bound to the
exchangeable phase. S oil from the inactive pottery factory
exhibited a significant increase in the organic matter
phase.
The results of the statistical analysis indicate that Soil
Rescue increased the mean concentrations of the residual
phases of lead at both site locations; however, such
increases do not appear to be significant at the 0.05 level
of significance. Those results also indicate that the
application of Soil Rescue significantly reduced the
concentrations of three soluble lead phases (carbonate,
manganese oxide, and iron oxide) at both sites, with
significant and almost-significant reductions of another
highly soluble leadphase (exchangeable). Finally, the data
indicate that significantandalmost-significantincreasesof
another soluble lead phase (organic matter) occurred at
both locations. Therefore, the lead speciation results were
notunanimouslyconsistentwith the attainmentofobjective
SI.
Eh
Eh was evaluated to determine whether the treated soil
exhibits an oxidizing or reducing environment. Reducing
conditions favor retention of lead in the soil, which may
increase the long-term stability of the treated soil. The
long-term stability of the treated soil was evaluated by
comparing the Eh values for untreated soil with the values
for treated soils and by determining whether the soil
exhibited an oxidizingorreducing environment. Adecrease
in the Eh values would suggest long-term stability of the
treated soil.
Table 2-16 presents the Eh data for untreated and treated
soil from the trailer park, and Table 2-17 presents the Eh
data for untreated and treated soil from the inactive pottery
factory. These Eh data appear to be normally distributed,
based on a graphical data distribution assessment.
Table 2-18 presents the summary statistics associated
with the analysis. Included in that table are the observed
Eh means for untreated and treated soils, the estimated
mean differences, and the levels of significance of the
corresponding t-scores for the soil from the trailer park.
The increase in the Eh mean level from the untreated to the
treated soil appears to be statistically significant. The Eh
results from the trailer park therefore indicate that the
application of Soil Rescue has increased the Eh of the soil,
which does not indicate long-term stability of the soil
treated with Soil Rescue at the trailer park. For the soil
from the inactive pottery factory, the decrease in the Eh
mean from the untreated to the treated soil appears not to
be significant and therefore would not indicate long-term
29
-------
Tabte 2-13. Sequential Serial Soil Extracts Results, Trailer Park
Unit
C
G
K
L
M
N
o
Q
R
T
Sampling Location
Comp
Comp
Comp
Comp
Comp
Comp
Comp
Comp
Comp
Comp
Untreated
1
3.46
80.4
37.5
60.9
11
132
2.86
12.4
20
5.55
2
2.65
81.42
36.66
105.4
70.49
18.57
36.3
8.08
12.22
225
3
1.657
23.25
6.985
9.039
15.97
11.93
3.897
3.724
5.485
1.127
4
6.19
62.5
30.22
88.69
32.64
23.76
29.59
5.68
14.22
4.89
5
7.29
61.75
15.44
42.98
14.96
22.06
19.47
7.18
9.494
3.24
6
187
2026
781
2386
543
504
516
1889
325
71
Treated
1
0.13
3.62
3.03
15.14
6.53
0.7
0.62
0.46
1.04
0.11
2
9.35
22.72
7.92
57.48
18.37
3.06
0.85
1.59
4.49
0.43
3
0.103
8.935
5.131
3.949
12.4
1.331
2.094
0.125
1.006
0.1
4
2.27
46.62
20.64
81.28
31.92
13.03
20.47
3.33
9.22
0.84
5
9.99
245.5
52.23
125.1
33.23
36.29
48.96
16.72
24.63
5.76
6
381
4,064
2,583
3,903
790
799
1,371
551
786
220
Note' 1 = Exchangeable phase (mgA. Pb), 2 = Carbonate phase (mg/L Pb), 3 = Manganese oxide phase (mg/L Pb), 4 = Iron
oxide phase (mgA. Pb), 5 - Organic matter phase (mgA. Pb), 6 = Residual phases ( mg/L Pb).
Tabte 2-14. Sequential Serial Soil Extracts Results, Inactive Pottery Factory
Unit
u
u
U
U
u
u
u
u
u
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
1
133.7
117.7
180.4
141.6
1203
n/s
n/s
n/s
n/s
2
1,506
1,349
2,213
1,506
1,078
n/s
n/s
n/s
n/s
3
230.3
142.7
261.3
183.4
195.9
n/s
n/s
n/s
n/s
4
515.7
579.9
766.9
600.8
663.9
n/s
n/s
n/s
n/s
5
255.2
230.3
215.5
285
240.7
n/s
n/s
n/s
n/s
6
14,446
13,491
13,600
13,328
13,872
n/s
n/s
n/s
n/s
Treated
1
22.99
22.1
30.18
32.17
34.59
23.82
14.54
30.89
44.26
2
255.7
188.5
255.6
332.4
156.9
304.10
183.20
186.70
233.60
3
13.83
6.39
17.92
22.42
16.99 ;
18.24
11.52
8.21
56.17
4
194.8
213.2
159.6
198.7
226.5
254.00
213.60
192.30
175.80
5
1,326
1,329
1,662
1,579
1,348
1,485
1,234
1,107
1,294
6
15,749
18,054
23,739
18,002
17,223
18,157
16,384
15,216
10,843
Note: 1 - Exchangeable phase (mgA. Pb); 2 = Carbonate phase (mgA. Pb); 3 = Manganese oxide phase (mgA. Pb); 4 = Iron oxide phase
(mgA. Pb), 5 = Organic matter phase (mgA. Pb); 6 = Residual phases ( mgA. Pb); n/s = not sampled.
30
-------
Table 2-15. Sequential Serial Soil Extracts: Summary Statistics
Phase
Untreated Mean
(mg/L Pb)
Treated Mean
(mg/L Pb)
Mean Difference
(Untreated - Treated)
Significance level
Trailer Park
Exchangeable
Carbonate
Manganese Oxide
Iron Oxide
Organic Matter
Residual
24.73
37.41
8.31
29.84
20.39
922.8
3.14
12.63
3.5
22.96
59.86
1,545
21.59
24.78
4.81
6.88
-39.47
-622.2
0.009
0.004'
0.0031
0.0005'
0.03
0.02
Inactive Pottery Factory
Exchangeable
Carbonate
Manganese Oxide
Iron Oxide
Organic Matter
Residual
138.73
1,530.45
202.72
625.44
385.6
13,751
28.39
232.99
19.08
203.18
1,373.9
17,040.78
110.34
1,297.46
183.64
422.26
-988.3
-3,289.78
0.0002'
0.001'
0.0002'
0.0002'
0.00000001'
0.009
Notes:
Hypothesis associated with significance level is H0: mean untreated - mean treated = 0.
1 Significant difference between treated and untreated soil (A significance level of 0.0083 or lower is
needed to declare a significant difference, based on a Bonferroni correction needed to preserve the
significance level of 0.05).
Table 2-16. Trailer Park Eh Analytical Results
Experimental
Unit
C I
G :
K
L
M
N
O
Q :
R
T
Sampling
Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
Eh (mV)
620
690
620
570
490
600
570
500
550
570
Treated
Eh (mV)
590
580
530
770
1,100
700
800
810
820
670
Table 2-17. Inactive Pottery Factory Eh Analytical
Results
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated Eh
(mV)
530
890
590
650
550
n/s
n/s
n/s
n/s
Treated Eh
(mV)
530
610
560
570
530
540
540
580
570
Note: n/s = not sampled.
31
-------
Table 2-18. Eh Summary Statistics
Statistic
Untreated Mean (Standard deviation)
Treated Mean (Standard deviation)
Mean Difference (Untreated - Treated)
Significance level
Trailer Park Data (mV)
578 (59)
737(165)
159
0.02
Inactive Pottery Factory Data (mV)
642(146)
559 (27)
-83
0.14
Note: Hypothesis associated with significance level is Ho: mean untreated - mean treated =
t-test was conducted on data from the trailer parlc, and an unpaired t-test assuming unequal
between treated and untreated samples was conducted on the data from the pottery factory.
0. A paired
variances
stability. Overall, the results suggestthatthe application of
Soil Rescue may either increase or not significantly affect
the Eh of the treated soil; however, such changes in Eh did
not appear to bring along increases in lead-oxide and
manganese-oxide phases of lead, as evidenced by the
reductions in the phases observed in the data from two lead
speciation evaluations (discussed above). In summary,
long-term chemical stability was not indicated for soils
treated by Soil Rescue by the analytical results from
oxidation-reduction (Eh) analysis.
pH
In general, the maximum retention of lead is achieved in
soils that are characterized by a pH higher than 7.0, and the
solubility of lead is generally lower in soils that have a pH
between 7.0 and 10.0. Therefore, the pH values of
untreated and treated soils were evaluated to determine
whether the pH was higher than 7.0 in the samples of
treated soil and to determine whether the pH values had
increased after treatment with Soil Rescue.
Table 2-19 presents the analytical results forpH in the soil
from the trailer park. Table 2-20 displays the pH analytical
results for pH in the soil from the inactive pottery factory.
On the basis of an assessment of data distribution, the pH
data appear to be distributed normally; however, pH is the
negative log of hydrogen ion activity. Therefore, pH data
on the untreated and the treated soils were converted to
molar concentration units andthen were analyzed separately
for the trailer park and the inactive pottery factory, through
the use of individual t-tests.
Table 2-21 shows the summary statistics associated with
the analysis. Included in the table are the observed pH
means for untreated and treated soils, the estimated mean
differences, and the levels of significance ofcorresponding
t-scores. Note that the increase in pH mean levels from
untreated to treated soils at each site appears to be
statistically significant. In addition, 4 of 10 pH values for
treated soils from the trailer park are within the optimum
range, and all pH values for treated soil from the inactive
pottery factory are within the optimum range of 7.0 to 10.0.
On the basis of those results, the application of Soil Rescue
appears to have enhanced the long-term stability of the
treated soil.
Cation Exchange Capacity
The objective of the tests for CEC was to determine if Soil
Rescue could increase the CEC, which would indicate an
increase in the ability of the soil to prevent migration of
lead. The analytical results for CEC from one untreated
soil sample were compared with those from one treated
soil sample collected at both the trailer park and the
inactive pottery factory to determine whether' the cations
in Soil Rescue changed the mobility of the lead in the soil.
Table 2-22 displays the CEC data from the trailerpark, and
Table 2-23 displays the CEC data from the inactive pottery
factory. The CEC data for the trailer park show an
increase from the result for untreated soil of 0.12 meq/g to
the result for treated soil of 0.22 meq/g. CEC data for the
inactive pottery factory also show an increase in the CEC
from theresult for untreated soil of 0.09 meq/g to the result
for treated soil of 0.26 meq/g.
At both sites, the availability of exchangeable potassium
showed the largest increase. The total observed increases
in the available cations would be expected to reduce the
migration rates and the total distances of migration of the
total masses of lead in the soils at both sites. Therefore,
improvements in the CEC indicate that the application of
Soil Rescue appears to have enhanced the long-term
stability of the treated soil. However, the results are not
quantitative because CEC tests were conducted on only
one sample from each site. ;
32
-------
Table 2-1 9. Trailer Park pH Analytical Results
Experimental Unit
C
G
K
L
M
N
O
Q
R
T
Sampling Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
5.9
6.2
5.9
6.5
6.9
6.3
7.8
5.3
5.3
4.8
Treated
6.8
7.5
6.5
6.7
6.7
7.8
6.8
7.2
7.9
6.6
Table 2-20. Inactive Pottery Factory pH Analytical Results
Experimental Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
6.9
7.5
7.4
7.5
7.4
n/s
n/s
n/s
n/s
Treated
8.2
8.0
7.8
7.7
7.9
8.2
7.8
7.9
8.1
Note: n/s = Not sampled
Table 2-21 . pH Summary Statistics
; •• Statistic
Untreated Mean1
Treated Mean1
Mean Difference (Untreated - Treated)
Significance level
Trailer Park Data
Inactive Pottery Factory Data
5.52 7.27
6.85 7.92
1.33 0.65
0.041 0.049 •
Notes:
Hypothesis associated with significance level is Ho: mean untreated - mean treated = 0. A paired t-test was conducted
on data from the trailer park, and an unpaired t-test assuming unequal variances between treated and untreated
samples was conducted on the data from the pottery factory.
'Mean values are reported as pH; however, they were calculated based on molar concentration units obtained by
conversion of the individual pH unit measurements shown in tables 2-1 9 and 2-20.
Table 2-22. CEC Analytical Results for Soil from the Trailer Park
Untreated/
Treated
Untreated
Treated
Na (meq/g)
0.0022
0.0023
Al (meq/g)
0.0022
0.0001
Ca (meq/g)
0.0987
0.0544
Mg (meq/g)
0.0129
0.0108
K (meq/g)
0.0046
0.1475
Fe (meq/g)
0.0000
0.0000
Mn (meq/g)
0.0003
0.0048
Total (meq/g)
0.1190
0.2199
Note: meq/g = milliequivalents per gram = weight of element in soil (mg) -T- (atomic weight [g] •=- valence) per gram of soil.
33
-------
Table 2-23. CEC Analytical Results for Soil from the Inactive Pottery Factory
Untreated/
Treated
Untreated
Treated
Na (meq/g)
0.0038
0.0141
Al (meq/g)
0.0001
0.0001
Ca (meq/g)
0.0759
0.0406
Mg (meq/g)
0.0083
0.0150
K (meq/g)
0.0010
0.1880
Fe (meq/g)
0.0000
0.0000
Mn (meq/g)
0.0000
0.0047
Total (meq/g)
0.0893
0.2626
Note: meq/g = milliequlvalents per gram = weight of element in soil (mg) x 4- (atomic weight [g] •=• valence) per gram of soil.
Aoid Neutralization Capacity
One soil sample was collectedbefore and another after the
application of Soil Rescue at the trailer park and the
inactive pottery factory; all four samples were analyzed
for acid neutralization capacity. Increasing the acid
neutralizationcapacityprovidesmoreligandsforformation
of the more stable lead complexes, thereby enhancing the
long-termstabilityoftreatedsoil.Dataonacidneutralization
capacity for soil from the trailer park indicate that there
was an increase fromtheresult for untreated soil of 0.0846
meq/g to the result for treated soils of 0.1214 meq/g. The
data on acid neutralization capacity data for the inactive
pottery factory indicate that there was a decrease from the
data on the result for untreated soil of 0.6329 meq/g to the
result for treated soil of 0.5013 meq/g. Because the
analytical results were not consistent at the two sites, the
data do not suggest that the long-term stability of the
treated soil was enhanced by the application of Soil
Rescue.However,theresultsarenotstatistically conclusive
because only one pair of soil samples was collected at each
location.
Total Lead in Soil
Two analytical procedures were used to determine total
concentrations of lead in the soil. One procedure, SW-846
Method 3050B, uses anitric acid solution to digest the lead.
The solution is a very strong acid that dissolves almost all
of lead in a sample that could become "environmentally
available" (EPA 1996); however, the method is not a total
digestion technique. Leadbound in silicates and lead bound
to organics may not be dissolved by this method. Therefore,
a portion of each soil sample was also digested by
hydrofluoric acid. Thatprocedure digests the siliceous and
organic matrices and other complex matrices to produce
a total concentration of lead.
Both procedures were used to determine whether Soil
Rescue forms complex matrices that are not dissolved
readily. Binding of the lead into complex matrices should
reduce the concentration of lead that is environmentally
available. If the concentration of lead determinedbynitric
acid digestion decreases after treatment while the
concentration of lead determined by hydrofluoric acid
digestion does not change significantly, the riskof exposure
to environmentally available lead is reduced. If the
concentration of lead determined by nitric acid digestion
increases after treatment while the concentration of lead
determined by hydrofluoric acid digestion does not change
significantly, theriskofexposuretoenvironmentallyavailable
lead is increased. If the concentration of lead, determined
by both procedures does not change significantly, the risk
of exposure to environmentally available lead is unchanged.
However, if the concentration of lead determined by
hydrofluoric acid digestion increases significantly, the
distribution oflead in complex matrices may follow a non-
normal pattern. It should be noted that these tests were
extremely aggressive tests, thus meeting the acceptance
criteria established for these tests was not as important as
meeting the acceptance criteria of other tests involving
long-term chemical stability.
Table 2-24 lists the concentrations oflead determined by
nitric acid digestion of untreated and treated soil from the
trailer park, and Table 2-25 lists the concentrations oflead
acid digestion of untreated and treated soil from the
inactive pottery factory. The data appear to be distributed
normally, as indicated by a graphical assessment of data
distribution. Therefore, the differences between total lead
in treated and untreated soils were analyzed separately for
the trailer park and the inactive pottery factory, through the
use of separate Student t-tests.
Table 2-26 displays the summary statistics associated with
the analysis. The statistics include the estimated untreated
and treated mean concentratipns of lead, the calculated
percent change in the means, and the levels of significance
of the t-scores. The observed mean concentration oflead
in soil from the trailer park increased from 1,802.8 mg/kg
to 2,168.9 mg/kg, while the mean concentration oflead in
soil from the inactive pottery factory decreased from
34,740 mg/kg to 31,422.2 mg/kg. However, the
corresponding t-scores indicate that neither of the observed
34
-------
Table 2-24. Lead Analytical Results for Nitric Acid
Digestion for Soil from the Trailer Park
Experimental
'. Unit
C
G
K
L
M ;
N
o
Q
R
T
Sampling
Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
(mg/kg)
345
4,330
2,170
4,440
2,200
1,320
1,550
496
907
270
Treated
(mg/kg)
409
4,900
1,580
9,260
1,480
1,090
1,510
478
766
216
Table 2-25. Lead Analytical Results for Nitric Acid
Digestion for Soil from the Inactive Pottery Factory
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/kg)
40,600
28,200
41,100
36,300
27,500
n/s
n/s
n/s
n/s
Treated
(mg/kg)
30,900
22,400
42,700
29,500
26,800
43,300
34,200
22,300
30,700
Note: n/s = not sampled.
Table 2-26. Summary Statistics for Nitric Acid Digestion
Statistic
Untreated mean
(Standard deviation)
Treated mean
(Standard deviation)
Mean Difference
(Untreated - Treated)
Level of significance
Trailer Park
Data (mg/kg)
1,802.8(1,524)
2,168.9(2,826)
-366.1
0.2
Inactive Pottery
Factory Data (mg/kg)
34,740.0 (6,565)
31,422.2(7,636)
3,317.80
0.2
Note: Hypothesis associated with significance level is H0: mean
untreated - mean treated = 0. A paired t-test was conducted on
data from the trailer park, and an unpaired t-test assuming
unequal variances between treated and untreated samples was
conducted on the data from the pottery factory.
differences is statistically significant. Therefore, the
statistical analysis of the data suggests that, for both sites,
there areno significant differences inmean concentrations
of total lead between untreated and treated soils using the
nitric acid digestion method for total lead.
Table 2-27 presents the concentrations oflead determined
by hydrofluoric acid digestion of untreated and treated soil
from the trailer park, and Table 2-28 presents the
concentrations oflead determined by hydrofluoric acid
digestion of untreated and treated soils from for the
inactive pottery factory. The data also appear to be
distributednormally, and the estimates of sample variance
for the data from both locations again appear to be
approximately equivalent. Therefore, separate Student t-
tests were performed on the data from the pottery factory
and the data from the trailer parkto compare the differences
in total concentrations of lead in untreated and treated
soils.
Table 2-29 displays the summary statistics associated with
the analyses. The statistics again include the estimated
mean concentrations oflead for untreated and treated soil,
the calculated percent change in the means, and the level
of significance of the t-scores. The observed mean
concentration oflead in soil from the trailer parkincreased
35
-------
Tabte 2-27. Lead Analytical Results Using
Hydrofluoric Acid Digestion for the Trailer Park
Experimental
Unit
C
G
K
L
M
N
O
Q
R
T
Sampling
Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
(mg/kg)
413
4,080
2,010
6,140
838
1,060
808
507
825
301
Treated
(mg/kg)
398
13,000
2,660
6,420
2,740
1,150
1,710
450
772
275
Table 2-28. Lead Analytical Results Using Hydrofluoric
Acid Digestion for the Inactive Pottery Factory
Experimental
Unit
U
U
U
U :
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/kg)
42,900
49,100
55,700
47,000
47,800
n/s
n/s
n/s
n/s
Treated
(mg/kg)
47,800
39,400
42,300
33,700
27,200
40,900
33,200
31,800
35,800
Note: n/s = not sampled.
Table 2-29. Summary Statistics for Hydrofluoric Acid Digestion
Statistic
Untreated Mean (Standard deviation)
Treated Mean (Standard deviation)
Mean Difference (Untreated - Treated)
Significance level
Trailer Park Data (mg/kg)
1,698.2(1,921)
2,957.5 (3,981)
-1,259.30
0.092
Inactive Pottery Factory
Data (mg/kg)
48,500 (4,645)
36,900 (6,279)
11,600
0.002
Note: Hypothesis associated with signif canoe level is Ho: mean untreated - mean treated = 0. A paired t-
test was conducted on data from the trailer park, and an unpaired t-test assuming unequal variances
between treated and untreated samples was conducted on the data from the pottery factory.
from 1,698.2 mg/kg to 2957.5 mg/kg, while the mean
concentration of lead in soil from the pottery factory
decreased from 48,500 mg/kg to 36,900 mg/kg. The
changein the mean concentrations ofleadisnot statistically
significant at the trailer park, according to the t-score
value, which is the expected outcome of the analysis.
However, the decrease in total concentrations of lead at
the inactive pottery factory is considered significant.
Therefore, the statistical analysis of those data suggests
that there was no difference in concentrations of lead
between treated and untreated soils for soils from the
trailerparkand a significant decrease inmean concentration
oflead in treated soil from thepottery factory, as determined
by the hydrofluoric acid digestion method. The reason for
the significant decrease is unknown; however, it is possible
that the drop in total lead concentrations (as measured by
the hydrofluoric acid digestion method) at the inactive
pottery factory may have been the result of the sampling
efforts conducted on the untreated soils, which may have
removed some hot spots of high lead concentrations that
were bound in stable matrices (therefore, no more of such
materials may have remained when the soils were sampled
after the application of Soil Rescue).
SPLP Lead
The SPLP concentrations oflead in untreated soil were
compared with the SPLP concentrations oflead in treated
soil to determine whether the application of Soil Rescue
decreased the solubility of the lead in the soil. The criterion
selected for determining whether the application of Soil
Rescue had an effect on the soil was a concentration of
SPLP lead in treated soil of less than 5.0 mg/L.
Table 2-30 lists the concentrations of SPLP lead in
untreated and treated soil from the trailer park. The
36
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Table 2-30. SPLP Lead Analytical Results for Soil from the Trailer Park
Experimental Unit
C
G ,
K
L
M
N
O
Q
R'
T
Sampling Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated (mg/L)
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
Treated (mg/L)
<0.50
3.1
<0.50
<0.50
1.2
<0.50
0.67
<0.50
<0.50
<0.50
concentrations of SPLP lead in untreated soil from the
trailer park all were lower than the detection limit of 0.5
mg/L. Of the 10 samples of treated soil from the trailer
park, 3 contained concentrations of SPLP lead that were
higher than the detection limit, but none of those
concentrations exceeded the criterion of 5.0 mg/L. The
concentrations of SPLP lead in untreated soil from the
trailer park indicate that the contaminated soil would not
require treatment.
A parametric statistical analysis of the concentrations of
SPLP lead in treated soil cannot be performed because of
the excessivenumber ofnondetects. However, the following
nonparametric argument can be made to support a
conclusion that SPLP mean concentration of SPLP lead in
treated soil does not exceed 5.0 mg/L. If the mean was
greater than or equal to 5.0 mg/L, the probability of
observing an individual concentration of SPLP lead higher
than 5.0 mg/L would be at least 0.5. Therefore, the
probability of observing 10 independent samples of treated
soil at less than 5.0 mg/L could be no more than (0.5) 10 =
0.00098. Therefore, the hypothesis that the mean
concentration of SPLP lead in treated soil from the trailer
park exceeds 5.0 mg/L is rejected at a 0.001 level of
significance. The statistical analysis of untreated and
treated soil from the trailerparkdidnot indicate a statistically
significant change in concentrations of SPLP lead.
Table 2-31 lists the concentrations of SPLP lead from the
inactive pottery factory. The concentrations of SPLP lead
in untreated soil from the inactive pottery factory all were
lower than the detection limit of 0.5 mg/L. All the
concentrations of SPLP lead in treated soil from the
inactive pottery factory exceed the regulatory limit of 5
mg/L. Table 2-32 shows the pertinent summary statistics
for SPLP data on treated soil from the inactive pottery
factory. The statistics include the estimated mean, standard
deviation, and 95 percent upper confidence limit (UCL) for
the SPLP data on treated soil, assuming that the data are
distributed normally. The estimated mean concentration of
SPLP lead in soil from the inactive pottery factory was
8.78 mg/L, with a 95 percent UCL of 9.76 mg/L. Because
the UCL estimate is significantly higher than 5.0 mg/L, the
concentrations of SPLP lead in the treated soil indicate
that the treated soil may leach small amounts of lead. In
fact, the mean concentrations of SPLP lead in the treated
soils from the inactive pottery factory appear to be
significantly higher than the mean concentrations of TCLP
lead (3.3 mg/L; see Table 2-6) in those same treated soils.
These results are unexpected, since the TCLP generally
results in higher concentrations of leachable lead than the
SPLP. Those differences cannot be explained without
further testing. However, the different acids used for the
TCLP and the SPLP (acetic for CLP; sulfuric and nitric
for the SPLP) may have contributed to the differences.
Further, the results of the MEP tests (in which acetic acid
is used initially, followed by sulfuric and nitric acids) that
were conducted on soils from the inactive pottery factory
and shown in Table 2-11 indicate that the concentrations
of lead leached from both untreated and treated soils by
sulfuric and nitric acids are much higher than those shown
in Table 2-31.
37
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Summary of Results for Objective S1
Procedure
MEP
Lead speclation by SEM
Lead speciaSon by sequential
extractions
Eh
pH
CEC1
Actd neutralization capacity1
Total lead by nitric acid
digestion compared with total
lead by hydrofluoric acid
digestion
SPLP lead
Total phosphate
SPLP phosphate
Results
All results met the acceptance
criteria for SI (see Table 2-4).
Results for 4 of 18 phases of
lead met the acceptance criteria
for S1 , and results for one
phase did not meet the criteria.
Results for the other 13 phases
did not appear to be affected by
the treatment
Results for three of six phases
of lead at one site, and four of
six at the other site met the
acceptance criteria for S1 . One
phase did not meet the criteria,
and the four other phases did
not appear to be affected by the
treatment
The criterion for S1 was not
met for either site.
All results met the acceptance
criteria for S1 (see Table 2-4).
All results met the acceptance
criteria for S1 (see Table 2-4).
The criterion for S1 was met for
one site but was not met for the
other site.
None of the results met the
acceptance criteria for SI (see '
Table 2-4).
The acceptance criterion for S1
was met at one site but was not
met at the other site.
None of the results met the
acceptance criteria for S1 (see
Table 2-4).
None of the results met the
acceptance criteria for Objective
S1 (See Table 2-4).
Interpretation
Trailer Park
i Pottery Factory
Soil Rescue exhibits long-term stability, as indicated by the results
of this procedure. " •
Inconclusive: Lead in
phosphates and glass appears
to increase, and lead in oxide
phases appear to decrease after
addition of Soil Rescue;
however, lead in. organic matter
appears to increase.
Inconclusive: Soil Rescue
exhibits some long-term
stability, as indicated by the .
results of this procedure. Lead
in carbonate and oxide phases
was reduced, and . .
exchangeable lead may have
been reduced. However,
organic lead may have been
increased, and residual lead
appeared to be unchanged.
Soil Rescue did not increase
long-term stability, as indicated
by the results of this procedure.
This procedure was not
conducted on soils from this
location.
Soil Rescue did not increase
the long-term stability, as
indicated by this procedure.
Exchangeable lead and lead in
carbonate and oxide phases
were reduced, and residual lead
may have been increased.
However, organic lead
increased.
Soil Rescue did not increase
long-term stability, as indicated
byithe results of this procedure.
Soil Rescue increased long-term stability, as indicated by the
results of this procedure.
Soil Rescue increased long-term stability, as indicated by the
results of this procedure.
Soil Rescue increases long-
term stability, as indicated by
the results of this procedure.
Soil Rescue did not exhibit
long-term stability, based on the
results of this procedure.
Soil Rescue does not increase long-term stability, as indicated by
the results of this procedure.
Soil Rescue increases long-
term stability, as indicated by
the results of this procedure.
However, SPLP lead
concentrations were significantly
higher in the treated soils.
Soil Rescue did not exhibit
long-term stability, based on the
results of this procedure.
Soil Rescue does not increase long-term stability, as indicated by
the results of this procedure. However, the increase in
concentrations of phosphate in treated soils is related only
indirectly to long-term stability and therefore is not as meaninful as
the findings for most of the other procedures conducted. :
Soil Rescue does not increase long-term stability, as indicated by
the results of this procedure.
Note: ' These tests are considered to be qualitative, because only one sample at each site was tested by this procedure.
38
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Table 2-31 . SPLP Lead Analytical Results for Soil
from the Inactive Pottery Factory
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/L)
<0.50
<0.50
<0.50
<0.50
<0.50
n/s
n/s
n/s
n/s ,
Treated
(mg/L)
8.8
7.6
10.7
10.3
10.2
-8.9
7.0
6.5
9.1
Note: n/s = not sampled.
In summary, on the basis of the criterion of 5 mg/L for
SPLP lead, the long-term stability of the treated soil
appears to have been reduced at the inactive pottery
factory by the application of Soil Rescue. The results for
treated soil from the trailer park are consistent with long-
term stability.
Phosphates
Soil Rescue contains phosphoryl esters used to formmetal
complexes. Phosphates may be released from the soil into
local streams through stormwater runoff. Therefore, two
analytical procedures were used to evaluate whether the
phosphates in Soil Rescue could be released into the
environment. The methods are comparison of the total
phosphate concentrations in untreated and treated soils at
both sites by SW 846 Method 9056 and comparisons of the
concentrations of phosphate that leach from untreated and
treated soil when the SPLP test (SW-846 Method 1312)
is applied (analyzing the SPLP extract for total phosphates
by SW-846 Method 9056).
Table 2-33 lists the total concentrations of phosphate for
soil from the trailer park, and Table 2-34 lists the total
concentrations of phosphates for soil from the inactive
pottery factory. The data from both sites clearly show
significant increases in the concentrations of phosphates
after the application of Soil Rescue.
Table 2-35 lists the concentrations of SPLP phosphates
for untreated and treated soils from the trailer park, and
Table 2-32. SPLP Lead Summary Statistics for Soil
from the Inactive Pottery Factory
Statistic
Mean (mg/L)
Standard Deviation
95% UCL
Data
8.78
1.49
9.76
Table 2-36 lists the concentrations of SPLP phosphates
for untreated and treated soil from the inactive pottery
factory. The data from both sites also clearly show a
significant increase in the concentrations of SPLP
phosphates after the application of Soil Rescue.
Table 2-37 displays the estimated means and 95 percent
confidence intervals for both sets of data on treated soil
from both sites. The estimated mean concentrations of
total phosphates were 701.4 mg/kg for the trailer park and
2,145 mg/kgfor the inactivepottery factory. Theestimated
mean concentrations of SPLP phosphates were 49.3 mg/
L and 107.7 mg/L for the trailer park and the inactive
pottery factory, respectively. On the basis of the data
obtained by conduct of analytical procedures, it appears
that phosphates from the application of Soil Rescue could
leach from the soil, a circumstance that could affect
nearby surface water.
The results of the conduct of most of the procedures
indicate that Soil Rescue appears to increase long-term
stability. However, the results of some of the procedures
suggest that Soil Rescue does not increase long-term
stability. Long-term stability of soil was indicated for soils
treated by Soil Rescue at both test locations, as shown by
the analytical results of the MEP, pH, and CEC test
procedures. In addition, long-term stability of the soil was
indicated at one site, but not at the other, by analytical
results of the following tests: lead speciation by sequential
extraction, Eh, acid neutralization capacity, and SPLP
lead. Theanalytical results or testingbythe lead speciation
by SEM (conducted only on soils from the trailer park)
were mixed in that some soluble species of lead were
reduced, while the organic matter phase of lead was
increased. Lead bound to organics can be released if the
organic phase is biologically degraded by microbes in the
soil. For both locations, long-term stability of soil was not
indicated for soils treated by Soil Rescue by the results of
separate analyses for total lead by nitric and hydrofluoric
acids (higher concentrations of total lead using the
hydrofluoric acid method would have indicated long-term
39
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Table 2-33. Total Phosphates Analytical Results for Soil
from the Trailer Park
Experimental
Unit
C
G
K
L
M
N
0
Q
R
Sampling
Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
(mg/kg)
<13.2
<12.7
<12.4
<12.1
<11.5
<12.1
<12.2
<11.5
<11.2
Treated
(mg/kg)
235
1,250
580
674
663
1,600
680
781
192
Table 2-34. Total Phosphates Analytical ResuJts for
Soil from the Inactive Pottery Factory
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/kg)
<12.7
<13.4
<13.0
<13.7
<13.5
n/s
n/s
n/s
n/s
Treated
(mg/kg)
2,180
2,270
1,950
1,620
3,530
1 ,730
2,340
1,550
2,110
Note: n/s = Not sampled
Table 2-35. SPLP Phosphates Analytical
Results for Soil from the Trailer Park
Experimental
Unit
C
G
K
L
M
N
O
Q
R
T
Sampling
Location
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Untreated
(mg/L)
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
Treated
(mg/L)
30.2
75.5
53.2
41.3
40.2
93.7
44.4
52.8
27.2
34.2
Table 2-36. SPLP Phosphates Analytical Results For
Soil from the Inactive Pottery Factory
Experimental
Unit
U
U
U
U
U
U
U
U
U
Sampling
Location
1
2
3
4
5
6
7
8
9
Untreated
(mg/L)
<1,0
<1.0
<1.0
<1.0
<1.0
n/s
n/s
n/s
n/s
Treated
(mg/L)
96.0
101
89.2
62.0
126
66.4
107
72.6
249
Note: n/s = Not sampled
40
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Table 2-37. Phosphate Summary Statistics
Location
Trailer Park
Pottery Factory
Data
Total
phosphates
(mg/kg)
SPLP
phosphates
(mg/L)
Total
phosphates
(mg/kg)
SPLP
phosphates
(mg/L)
Mean
701.4
49.3
2,145
107.7
95% Confidence
Interval
(430—973)
( 36-62)
( 1 ,757—2,532)
(71—145)
stability), total phosphates (significant increases in total
phosphates create a higher potential for environmentally
damaging releases of phosphates to surface waters), and
leachable phosphates as indicated by the SPLP.
2.4.4 Evaluation of S2
Demonstrate that the application of Soil Rescue does
not increase the public health risk of exposure to lead.
During the demonstration, it was necessary to remove
vegetation with a sod cutter and to prepare the soil for the
collection of samples before and after treatment. The
activities generateddust that was monitored withreal-time
devices. Air sampling devices were used to determine the
total concentrations of lead in the dust. Accomplishment of
S2 was evaluated by collecting air samples through filters
during tilling operations and calculating the exposure to
lead on the basis of total lead content of the air sampling
filters and the length of exposure. The concentration of
lead was determined by the nitric acid digestion method
described in Section 2.3.1. The exposure calculated was
compared with NAAQS for lead, which currently is 1.5
um/m3 of air, averaged over a period of three consecutive
months. Table 2-38 lists the exposures calculated for the
worker during the demonstration.
The only sample result in the detectable range, 24 mg/m3,
occurred on September 25,1998, on the east area sample.
The tilling activity at this plot and the corresponding
samplingperiod were 5 minutes in duration. These values
extrapolate to a concentration of 9.3 x 10-4 mg/m3 over a
3-month period, whichis lowerthan the NAAQS standard.
Assuming that the concentration was to remain constant
during extended remediation activities; however, the
NAAQS standard would be exceeded after approximately
135 hours. The application of Soil Rescue does not appear
to create a significant quantity of dust; however, air
monitoring was not conducted during that activity. If it is
determined that it is necessary to remove the soil or use
other techniques that may generate dust, air monitoring
with real-time devices correlated to actual concentrations
of lead in the air (for example, high-volume air samplers)
and, if appropriate, dust suppression measures should be
employed.
2.4.5 Evaluation of Objective S3
Document baseline geophysical and chemical
conditions of the soil before the addition of Soil
Rescue.
Soil samples collected from the locations at the trailer park
and the inactive pottery factory at which the demonstration
was conducted were analyzed to determine the soil
classification and to determine whether VOCs, SVOCs,
or oil and grease were present in the soils.
One soil sample from each of the demonstration sites was
analyzed by ASTM Method D 2487-93, Standard
Classification of Soils for Engineering Purposes, to
determine the soil classification. The soil type for both sites
has been identified as sandy silt, an organic clay having low
plastic limits and liquid limits of less than 50 percent.
The results of analysis for VOCs did not indicate the
presence of any VOCs in the soils at either site. The
analysis for SVOCs indicated the presence of the following
SVOCs in the soils at the inactive pottery factory:
benzo(a)anthracene (0.82 mg/kg), benzo(b)fluoranthene
(0.91 mg/kg), benzo(k)fluoranthene (0.77 mg/kg),
benzo(a)pyrene (0.69 mg/kg), chrysene (1.0 mg/kg),
fluoranthene (1.9 mg/kg), andpyrene (1.9 mg/kg). Those
SVOCs typically are found in crude oil, fuel oil, or used
motor oil. The soil in that area did show signs of staining
that may have been the result of the disposal of a small
quantity of waste oil. On the basis of the concentrations
detected and the current state regulations governing
petroleum releases, it does not appear that the SVOCs
present at the site require remediation. The technology
developer indicated that the SVOC would not interfere
with Soil Rescue. The analytical results for the soil at the
inactive pottery factory indicated that oil and grease were
present at a concentration of 3,680 mg/kg. The analytical
resultsfor the soil atthe trailer park didnot indicate that oil
and grease were present.
41
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Table 2-38. Air Monitoring Results .
Area
Area. Sample Southwest
Area Sample East
Area Sample Northeast
Area Sample North
Area Sample Southwest
Area Sample East
Area Sample Northeast
Area Sample North
Data
9/22/98
9/22/98
9/22/98
9/22/98
9/25/98
9/25/98
9/25/98
9/25/98
Time Sampled (minutes)
5
5
5
5
5
5
5
5
Flow Rate (L/minute)
10
10
10
10
10
10
10
10
Air Volume (L)
50.0
50.0
50.0
50.0
50.0
50.0
50.0
50.0
Lead Concentration
<4.0 \i g/m3
<4.0/y g/m3
<4.0pg/m3
<4.0 \i g/m3
<4.0 \i g/m3
24 p g/m3
<4.0/yg/m3
<4.0 fj g/m!>
Notes: p g/m3 = Micrograms per cubic meter of air -
The soil humus fractions (humic acid and fiilvic acid) were
determined from untreated samples collected from both
sites. Humus in soils contributes ligands that can bind with
the lead. These concentrations can be used to evaluate
whether the humus is contributing to the concentration of
theleadspeciesboundtoorganic fractions. Thatinformation
is important when a technology uses humic acids to bind
the lead. However, since Soil Rescue does not use humic
acids to bind the lead, the concentration of humic acids is
provided only as a description of the organic matter in the
soil. The concentration ofhumic acid in the soil atthe trailer
park was 2,400 mg/L, and the concentration ofhumic acid
in the soil at the inactive pottery factory was 1,400 mg/L.
The concentration offulvicacidin the soil atthetrailerpark
was 600 mg/L, and the concentration of fulvic acid at the
inactive pottery factory was less than 500 mg/L.
2.4.6 Evaluation of Objective S4
Document the operating and design parameters of
Soil Rescue.
On the basis of information obtained through the SITE
evaluation from Star Organics and from other sources, an
economic analysis examined 12 cost categories for a
scenario in which Soil Rescue was applied at full scale to
treat soil contaminated with lead at a Superfund site. For
the cost estimate, it was assumed that the site was one
acre in size and that the treatment was applied to a depth
of 6 inches, or approximately 807 cubic yards of soil. The
estimate assumed that the soil characteristics and lead
concentrations of lead at the site were the same as those
encountered during the CRPAC evaluation. With those
assumptions, the total costs were estimated to be $32,500
per acre or $40.27 per yd3. Costs for application of Soil
Rescue may vary significantly from that estimate,
depending on site-specific factors. ,
2.5 QUALITY CONTROL RESULTS
The overall quality assurance (QA) objective for the SITE
program demonstration, as set forth in the QAPP, was to
produce well-documented data of known quality as
measured by the precision, accuracy, completeness,
representativeness, and comparability of the data, and the
conformance of the data to the project-required detection
limits (PRDL) for the analytical methods. Specific QA
objectives were established as benchmarks by which
each of the criteria was to be evaluated. Section 3.0 of the
QAPP presented the QA objectives for thp critical
parameters.
This section discusses the quality control (QC) data with
respect to the QA objective of the project for critical
parameters. The results, and those for noncritical
parameters, can be found in the unpublished TER for this
SITE demonstration (Tetra Tech 2001). The TER is
available upon request from the EPA work assignment
manager (see Section 1.4 for contact information).
QA objectives for laboratory analysis of the critical
parameter bioavailable lead were evaluated on the basis
of analytical results from matrix spike sample s and matrix
spike duplicate samples (MS/MSD), blank spikes,
laboratory control samples (LCS), reagent blanks, bottle
blanks, and calibration criteria. QA objectives for laboratory
analysis of the critical parameter TCLP lead were evaluated
on the basis of MS/MSDs, i LCS/LCSD, and method
42
-------
blanks. Table 7-1 of the QAPP summarizes the internal
acceptance criteria for laboratory QC samples, as well as
corrective action procedures for the demonstration.
2.5.1 Completeness
The QA objective for data completeness specified by the
QAPP is that 100 percent of all planned measurements
will be obtained and will be valid. As discussed in Section
3.1, SITE programpersonnel did not collect an equipment
and field blank during the sampling of treated soil for
analysis for bioavailable lead. Analytical results for the
equipment and field blanks for untreated soils and
subsequent long-term monitoring blanks did not indicate
cross-contamination as a result of sample collection or
shipping procedures. Therefore, the deviation should not
affect overall data quality. All the soil samples specified in
the QAPP for TCLP lead analysis were collected and
analyzed. All samples were analyzed within the holding
times specified in the QAPP, and all the TCLP lead data
were considered usable. Therefore, the critical parameters
of bioavailable and TCLP lead data are considered 100
percent complete.
2.5.2 Comparability and Project-Required
Detection Limits
On the basis of consistent implementation of a reference
method, data on critical parameters (bioavailable lead and
TCLP lead) for samples of untreated and treated soil are
considered to be comparable. As specified by the QAPP,
the University of Colorado used the SBRC's, SIVM to
analyze soil samples for bioavailable lead, and Quanterra
used SW-846 Method 1311 (EPA 1996) to analyze soil
samples for concentrations of TCLP lead. The PRDLs
specified in Table 3-1 of the QAPP were achieved for all
samples collected during the demonstration.
2.5.3 Accuracy and Precision
Accomplishment of QA objectives for accuracy and
precision were evaluated on the basis ofMS/MSD percent
recoveries andrelativepercent differences (RPD). Percent
recovery and RPD values for LCS/LCSD and blank spike
(BS) samples also supported QA objectives for accuracy
and precision.
All the assessments of precision and accuracy for the
bioavailable lead data, including the RPD of the duplicates
and the percent recoveries of the MS and BS analyses,
were within the limits specified in the QAPP. Concentration
levels for spikingmet the criteria specifiedin the QAPP for
all analyses. Appendix B presents the QC data for the
critical and noncritical parameters.
One TCLP lead MS/MSD sample had a percent recovery
of 124 percent, which is outside the acceptable range of 80
to 120 percent. The batch of samples for which the MS/
MSD analysis was performed were all samples of untreated
soil. Therefore, the deviation should have no effect on the
overall quality of the data for the demonstration. The data
on untreated soil are not used to determine whether the
technology can meet objective PI, which is to reduce the
TCLP lead concentration to a level lower than the alternative
UTS lead in soil of 7.5 mg/L. The percent recovery of the
LCS/LCSDs were all within the acceptable range of 80 to
120 percent. All the RPDs for the MS/MSD and LCS/
LCSD samples were less than 20 percent and therefore
were acceptable.
2.5.4 Representativeness
The UmversityofColorado anal vzedmemodblanksamples
for bioavailable lead to confirm the representativeness of
the data on bioavailable lead by determining whether any
lead might have been introduced during preparation and
analysis of the samples. The levels of lead in the method
blank samples did not exceed the criteria set forth in the
QAPP for method blanks, which is 25 ug/L. Therefore, the
method blank analyses do not indicate that laboratory
contamination introduced detectable concentrations of the
critical parameter bioavailable lead into any of the samples,
and the reported concentrations of the critical parameter
bioavailable lead appear to be representative of actual
concentrations in the soil samples, as indicated by the
available QC data.
Quanterra analyzed method blank samples for TCLP lead
to confirm the representativeness of the TCLP lead data
by determining whether any lead might have been
introduced during sample preparation and analysis of the
samples. Quanterra did not detect any TCLP lead in any
of the method blanks at levels higher than the PRDL of
0.50 mg/L. Therefore, the method blank analyses do not
indicate that laboratory contamination introduced detectable
concentrations of the critical parameter TCLP lead into
any of the samples, and the reported concentrations of the
parameter TCLP lead appear to be representative of
actual concentrations in the soil samples, as indicated by
the available QC data.
Terra Tech prepared equipment blank samples and field
blank samples to determine whether any lead might have
been introduced by sample collection, handling, and
43
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packaging procedures. Section 2.5.1 of the TER
summarizes the blank sample preparation techniques. No
lead was detected in any of the blank samples at levels
higher than the PRDL of 100 ug/L.
The University of Colorado analyzed the equipment blank
andfieldblanksamplesforbioavailableleadtoconfirmthe
representativeness of the data on bioavailable lead by
determining whether any bioavailable lead might have
been introduced during sample collection, handling, and
packaging. The University of Colorado did not detect any
bioavailable lead in any of the equipment and field blanks
atlevelshigherthan the PRDL of 100 ug/L. Therefore, the
results of analysis of the equipment and field blanks do not
indicate that sample collection, handling and packaging
procedures introduced detectable concentrations of the
critical parameter bioavailable lead into any of the samples.
Quanterra analyzed the equipment blank and field blank
samples for TCLP lead to confirm the representativeness
of the TCLP lead data by determining whether any lead
might have been introduced during sample collection,
handling and packaging. Quanterra did not detect any
TCLP lead in any of the equipment and field blanks at
levels higher than the PRDL of 0.50 mg/L. Therefore, the
analysis of equipment and field blanks do not indicate that
sample collection, handling and packaging procedures
introduced detectable concentrations of the critical
parameter TCLP lead into any of the samples.
44
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Section 3
Technology Applications Analysis
This section describes the Soil Rescue technology. It
identifies the waste to which the technology is applicable
and discusses the method of application used during the
demonstration, materials handling requirements, the
limitations of the technology, potential regulatory
requirements, key features, the availability and
transportability of the technology, and acceptance of the
technology by state regulators and communities.
3.1 DESCRIPTION OF THE
TECHNOLOGY
Soil Rescue is added to soils or wastes contaminated with
toxic metals. Soil Rescue is an alkaline solvent made by a
proprietary method that involves the extraction of organic
acids and alcohols and the formation of phosphoryl esters
in a batch process. Raw materials for the proprietary
extractant include amedley of compost sources, which are
extracted in a ratio that Star Organics has tested and found
to provide the widest spectrum, and highest concentration,
of desirable complexing components. Star Organics claims
that Soil Rescue converts the metal contaminant from its
teachable form to an insoluble, stable, nonhazardous,
organometallic complex. Soil Rescue is a mixture of weak
organic acids and phosphoryl esters that act as metal-
complexing agents. In the complexation reaction, the
metal ions, the organic acids and esters, and the soil
substrate form coordinate covalent bonds. Star Organics
claims that the formation of metal complexes by Soil
Rescue reduces the waste stream's TCLP test results to
less than the regulatory levels, thereby reducing the risks
posed to human health and the environment (Star Organics
2000). The process generates no secondary wastes, and
minimal handling, transportation, and disposal costs are
incurred. '•_
3.2 APPLICABLE WASTES
Star Organics claims that Soil Rescue can treat heavy
metals in soils, sludges, mine tailings, andprocess residues
and other solid waste. Star Organics states that Soil
Rescue can stabilize the following heavy metals: barium,
cadmium, chromium, copper, lead, mercury, selenium, and
zinc (Star Organics 2000). Soil Rescue can be applied in
situ at sites at which soils are moderately permeable. A
second treatment may be necessary for more difficult
metals (selenium), depending on the amount of
contamination and the presence of competing metals in the
soil (toxicandnontoxie).
3.3 METHOD OF APPLICATION
Farm or construction equipment can be used to apply Soil
Rescue at large sites, and simple gardening or small
construction equipment can be used at small treatment
areas. For example, Soil Rescue was applied to the
surface of the experimental units and injected to a depth of
two feet with a pressurized sprayer.
Star Organics selects a site-specific concentration of Soil
Rescue by determining the density, volume, weight, and
amount of contaminationpresent in the soil through bench-
scale studies of soil samples. An evaluation of the soil
chemistry at the site must be performed to determine the
concentration of the contaminant throughout the site and
the concentration of other metals that may be present at
the site. Such site conditions as soil type, depth of
contamination, and moisture content must be evaluated to
determine the application procedure and equipment
requirements.
The site should be accessible to wheeled or tracked
vehicles and have sufficient space to store the equipment
necessary to apply the technology. No utilities are required
for the application of the technology. Potable water is
required for decontamination of equipment andpersonnel.
45
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3.4 MATERIAL HANDLING
REQUIREMENTS
Soil Rescue is nonhazardous and requires no special
handling procedures. All field equipment and personal
protection equipment (PPE) must be decontaminated
after the soil has been treated. For the CRPAC
demonstration, decontamination was accomplished with
soap, water, and Alconox, followed by a rinse with
deionized water. While Soil Rescue is expected to generate
little residual waste, any soil on the equipment, any fluids
used in the decontamination process, and any disposable
PPE must be treated as a potentially hazardous waste. The
waste should be characterized for proper disposal.
3.5 LIMITATIONS OF THE
TECHNOLOGY
In soils in which concentrations of other metals are high,
it may be necessary to reapply Soil Rescue until the
leachable concentration of the heavy metal is reduced to
a level that is lower than the applicable cleanup standard.
In addition, Soil Rescue appears to increase the potential
that phosphates will leach from the treated soils and affect
surface water.
3.6 REGULATORY REQUIREMENTS
This section discusses environmental regulations that may
pertain to the application of Soil Rescue. The applicability
of regulations to a particular remediation activity depends
on the type of remediation site and the type of waste
treated. Remedial managers also must address state and
local regulations, which may be more stringent. ARARs
for applications of Soil Rescue, although site-specific, may
include the requirements of following federal regulatory
programs: (l)tlie Comprehensive Environmental Response,
Compensation, and Liability Act(CERCLA); (2) RCRA;
(3) OSHA; and (4) the Clean Water Act (CWA).
3.6.1 CERCLA
CERCLA, as amended by the SARA, provides for federal
authority and funding to respond to releases or potential
releases of any hazardous substance into the environment,
as well as to releases of pollutants or contaminants that
may present an imminent or significant danger to public
health and welfare or to the environment. CERCLA is
pertinent to a consideration of Soil Rescue because it
governs the selection and application of remedial
technologies at Superfund sites.
In general, two types of responses are possible under
CERCLA: removal action and remedial action. Remedial
actions are governed by the; SARA amendments to
CERCLA. SARA states a strong regulatory preference
forinnovative technologies thatprovidelong-termprotection
and directs EPA to:
• Use remedial alternatives that permanently and
significantly reduce the volume, toxicity, or mobility
of hazardous substances, pollutants, or contaminants
• Select remedial' actions that protect human health
and the environment, are cost-effective, and involve
permanent solutions and alternative treatment or
resource recovery technologies to the maximum
extent possible
v Avoid off-site transport and disposal of untreated
hazardous substances or contaminated materials when
practicable treatment technologies exist [Section
SARA requires that on-site remedial actions comply with ,
federal andmore stringent state and local ARARs. ARARs
are determined on a site-by-site basis and may be waived
under any of six conditions: (1) the action is an interim
measure, and the ARAR will be met at completion; (2)
compliance with the ARAR would pose a greater risk to
health and the environment map 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 applied
consistently elsewhere; or (6) compliance with the ARAR
would not provide a balance between the protection
achieved at a particular site and demands on Superfund for
addressing other sites. The waiver options apply only to
Superfund actions taken on site, and justification for the
waiver must be demonstrated clearly (EPA 1988).
3.6.2 RCRA
RCRA, as amended by HSWA, regulates management,
and disposal of municipal and industrial solid wastes. EPA
and the states implement and enforce RCRA and state
regulations. Some of the RCRA Subtitle C (hazardous
waste) requirements under 40 CFR parts 254 and 265 may
apply at CERCLA sites because remedial actions generally
involve treatment, storage, or disposal ofhazardous waste.
However, requirements under RCRA may be waived for
CERCLA remediation sites, provided equivalent or more
stringent ARARs are met. :
RCRA regulations define hazardous wastes and regulate
their transportation, treatment, storage, and disposal . The
regulations are applicable to uses of Soil Rescue only if
hazardous wastes as defined under RCRA are present. If
soils are determined to be hazardous under RCRA (either
46
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because of a characteristic identified in RCRA or listing of
the waste, the remedial manager must address all RCRA
requirements governing the management and disposal of
hazardous waste. Criteria for identifying characteristic
hazardous wastes are set forth in 40 CFR part 261 subpart
C. Listed wastes from specific and nonspecific industrial
sources, off-specification products, cleanups of spills, and
other industrial sources are itemized 40 CFR part 261
subpart D.
Residual wastes generated during the application of Soil
Rescue must be stored and disposed of properly. If the
treated waste is a listed waste, residues of treatment must
be considered listed wastes (unless delisting requirements
under RCRA are met). If the residues are not listed
wastes, they should be tested to determine whether they
are characteristic hazardous wastes as defined under
RCRA. If the residues are not hazardous and do not
contain free liquids, they can be disposed of in a Subtitle D
facility. If the residues are hazardous, the following RCRA
standards apply:
• Standards and requirements for generators of
hazardous waste, including hazardous treatment
residues, are set forth at 40 CFR part 262. The
requirements include obtaining an EPA identification
number, meeting waste accumulation standards,
labeling wastes, and keeping appropriate records.
Part 262 allows generators to store wastes for as
much as 90 days without a permit. If residues of
treatment are stored on site for 90 days or more,
requirements set forth at 40 CFR part 265 are
applicable.
• Any on- or off-site facility designated for permanent
disposal of residues of hazardous treatment must be
in compliance with RCRA. Disposal facilities must
fulfill the permitting, storage, maintenance, and closure
requirements at 40 CFR parts 264 through 270. In
addition, any authorized state RCRA requirements
must be fulfilled. If treatment residues are disposed
of off site, transportation standards set forth at 40
CFR part 263 are applicable.
3.6.3 OSHA
OSHAregulationsat29 CFR parts 1900 through 1926 are
designed to protect the health and safety of workers.
Corrective actions undertaken under both Superfund and
RCRA must meet OSHA requirements, particularly those
set forth at Section 1910.120, Hazardous Waste Operations
and Emergency Response. Any more stringent state or
local requirements must also be met. In addition, health and
safety plans for site remediation projects should address
chemicals of concern and include monitoring practices to
ensure that the health and safety of works are protected.
PPE must be worn to protect field personnel from known
or suspected physical hazards, as well as air-, soil-, and
water-borne contamination. The levels of PPE to be used
for work tasks must be selected on a site-specific basis.
The level of PPE should be based on known or anticipated
physical hazards and concentrations of contaminants that
may be encountered at a particular site and their chemical
properties, toxicity, exposure routes, and contaminant
matrices. Personnel must wear PPE when site activities
involve known or suspected atmospheric contamination;
when site activities might generate vapors, gases, or
particulates; or when direct contact with substances that
affect the skin may occur. Full-face respirators may be
necessary to protect lungs, the gastrointestinal tract, and
eyes against airborne contaminants. Chemical-resistant
clothing may be needed at certain sites to protect the skin
from contact with chemicals that are absorbed through or
destructive to the skin.
The information providedby Star Organics and the results
of observations made during the demonstration project
indicate thatthe contaminants beingtreatedusuallyare the
determinating factor in the selection ofPPE for applications
of Soil Rescue. In general, latex or nitrile gloves, Tyvek
coveralls, boot covers, and goggles are recommended for
applying Soil Rescue to contaminated soils.
3.6.4 CWA
The CWA is designed to restore and maintain the chemical,
physical, andbiological quality ofnavigable surface waters
by establishing federal, state, and local discharge standards.
The CWA may affect application of the technology
because it governs the appropriate manner of managing
water used for decontamination activities. Depending on
the concentrations of the contaminants in the wastewater
and any permit requirements, contaminated water from
the decontamination procedures could be discharged to a
publicly owned treatment works (POTW). Each POTW
has a different limit for lead that is specified in the
POTW'sNationalPollutantDischargeElimination System
(NPDES) permit. The POTW will require disclosure of
the contents of the wastewater and will determine whether
contaminants will interfere with the treatment of the
wastewater.
3.7 AVAILABILITY AND
TRANSPORTABILITY OF THE
TECHNOLOGY
Soil Rescue is available from Star Organics, Dallas, Texas
(see Section 1.4 for the address and other contact
information). Soil Rescue is nonhazardous and was
47
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transported to theCRPACdemonstrationsitebyamedium-
duty truck. No special permit or licensing was required for
transport of the material, and there are no restrictions on
the transportation of the material. All equipmentnecessary
for the application of Soil Rescue is readily available from
local rental companies and need notbe obtained from Star
Organics.
3.8 COMMUNITY ACCEPTANCE BY
THE STATE AND THE COMMUNITY
State and community acceptance of Soil Rescue on the
part of state regulatory agencies andaffected communities
likely will be site-specific. Because no community outreach
program has been establishedfortheCRP AC, itis difficult
to predict how communities in the vicinity of the CRPAC
will accept Soil Rescue.
This economic analysis presents two cost estimates for the
application of Soil Rescue (not including profit) to
commercially remediate soil contaminated with lead. The
estimates are based on assumptions and costs provided by
Star Organics; data compiled during the SITE
demonstration; and additional information obtained from
current construction cost estimating guidance, as well as
experience under the SITE Program. Costs for the
technology can vary, dependingon soil conditions, regulatory
requirements, and other site- and waste-specific factors.
Two estimates are presented in this analysis to determine
the costs of applying Soil Rescue. The first estimate (Case
l)isbased on costs incurred duringthe SITE demonstration.
The total volume of soil treated at the ICRPAC
demonstration site was approximately 5 cubic yards. That
volume was spread over ten 5-foot-by-5-foot-by-0.5 foot
plots and one 6-foot-by-3-foot-by-0.5 footplot The second
estimate (Case 2) is for a hypothetical one-acre site at the
CRPAC that would be treated to depth of 0.5-foot. Case
2 represents a typical application of Soil Rescue. The cost
estimate for Case 2 is based on extrapolation of data from
the costs of the SITE demonstration. For Case 1, the total
volume of soil to be treated is 807 cubic yards. Two
scenarios are presented because of certain "fixed" costs
related to the use of the technology; the unit cost per
volume drops significantly when it is applied to larger
volumes of material.
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Section 4
Economic Analysis
This section summarizes factors that influence costs,
presents ; assumptions used in the analysis, discusses
estimated costs, and presents the conclusions of the
economic analysis. Table 4-1 presents the estimated costs
generated by the analysis. Costs have been distributed
among 12 categories that are applicable to typical cleanup
activities at Superfund and RCRA sites (Evans 1990).
Costs are presented in 1998 dollars, are rounded to the
nearest 100 dollars, and are considered to be minus 30
percent to plus 50 percent order-of-magnitude estimates.
4.1 FACTORS THAT AFFECT COSTS
Costs for implementing Soil Rescue can be affected by
site-specific factors, including the regulatory status of the
site, waste-related factors, total volume of soil to be
treated, site features, and soil conditions. The regulatory
status of the site typically depends on the type of waste
managementactivities that occurred atthe site, the relative
risk to nearby populations and ecological receptors, the
state in which the site is located, and other factors. The
site's regulatory status affects costs because it makes the
site subj ect to mandates related to ARARs and remediation
goals that may affect the system design parameters and
the duration of the remediation project. Certain types of
sites may be subject to more stringent monitoring
requirements than others, depending on the regulatory
status of the individual site. Soil conditions at the site
determine the possible treatment depth, which can affect
costs.
Factors related to the waste that affect costs include the
volume, distribution, and type of contamination at the site,
which have a direct effect on site preparation costs; the
amount of Soil Rescue needed; and the amount of time
necessary to treat the soil. The type and concentration of
the contaminant also will affect disposal costs for wastes
generated by the remediation effort.
The location and physical features of the site will affect the
cost of mobilization, demobilization, and site preparation.
Mobilization and demobilization costs are affected by the
distances that system materials must be transported to the
site. For high-visibility sites in densely populated areas,
stringent security measures and minimization of obtrusive
construction activities, noise, dust, and air emissions may
benecessary. Sitesrequiring extensive surficial preparation
(such as constructing access roads, clearing large trees, or
working around or demolishing structures) or restoration
activities also will incur higher costs than sites that do not
require such preparation. The availability of existing
electrical power and water supplies may facilitate
construction activities and lower costs. In the United
States significant regional variations may occur in the
costs of materials, equipment, and utilities.
4.2 ASSUMPTIONS OF THE ECONOMIC
ANALYSIS
For Case 1, existing technology and site-specific data from
the demonstration were used to present the costs of
applying Soil Rescue at the CRPAC demonstration site.
Certain assumptions were made to account for variable
site and waste parameters for Case 2. In general, most
system operating issues and assumptions are based on
information provided by Star Organics and observations
made during the SITE demonstration. For both cases,
costs were based oninformationprovidedby Star Organics,
observations made and data collected during the SITE
demonstration, current environmental restoration cost
guidance (R.S. Means [Means] 1998), and experience
under the SITE program.
For both cases, assumptions made about site- and waste-
related factors include:
• The two sites are located in the CRPAC, where
disposal of broken and "off-spec" pottery having
lead-based glazes has contaminated the soil with
lead.
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Table 4-1. Cost Distribution for Soil Rescue
Cost Categories
Case 1 (5 yd3)
Costs
Cost/yd3
% Costs
(1) Site Preparation
Rental Equipment
Labor and Per Diem
Total Site Preparation Costs
(2) Permitting and Regulatory
$30
$1,350
$1,400
—
$280
—
$10.94
—
(3) Mobilization
Mileage
Labor and Per Diern
Total Mobilization Costs
$300
$2,700
$3,000
$600
$23.44
(4) Equipment
Rental Equipment
Purchased Equipment
Total Equipment Costs
$100
$200
$300
$60
$2.34
(5) Labor
Labor
Per Diem
Total Labor Costs
$4,700
$800
$5,500
$1,100 ,
$42.97 :
(6) Supplies and Materials
Soil Rescue
Sampling Supplies
PPE and Decontamination Supplies
Misc. Field Supplies
Total Supplies and Materials Costs
(7) Utilities
(8) Effluent Treatment & Disposal
(9) Residual Waste Shipping
(10) Analytical Services
(11) Equipment Maintenance
$100
$200
$500
$200
$1,000
—
—
—
$1,600
—
$200
—
—
—
$320
—
$7.81
—
—
—
$12.50
—
Case 2 (807 yd3)
Costs
Cost/yd3
% Costs
$115
$1,350
$1,500 :
;
$1.86
—
$4.62
—
$300
$2,700
$3,000
$3.72
$9.23
$700
— '
$700 ,
$0.87
$2.15 ,
$6,200
$800
$7,000 '
$8.67
$21.54
$12,100
$400
$800
$300
$13,600
—
—
$1,000 i
$4,200 ;
—
$16.85
—
—
$1.24
$5.20
—
$41.85
—
—
$3.08
$12.92
—
(12) Site Demobilization
Mileage
Labor and Per Diem
Total Site Demobilization
Total Costs
$300
$2,700
$3,000
$15,880
$600
$3,160
$23.44
$100
$300
$2,700
$3,000 :
$32,500
$3.72
$40.27
$9.23
$100
Note: 1998 dollars.
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• The total volume of material treated for Case 1 is
approximately 5 cubic yards. The total volume of soil
to be treated for Case 2 is 807 cubic yards.
• There is an existing access road, and there are no
accessibility problems associated with the two sites.
• There are no structures on either site that require
demolition. No utilities are present that require
relocation or that restrict operation of heavy
equipment.
• For Case 1, it is assumed that the sod covering the
site can be removed with sod cutters and can be
replaced after the soil has been treated. For Case 2,
it is assumed that the some clearing and grubbing will
be necessary to prepare the site for the application of
Soil Rescue. ;
• Electricity for both sites can be provided by a portable
generator.
• For both cases, the highest levels of contaminated
soil extend from the ground surface to a depth of
approximately 6 inches below ground surface.
• This estimate assumes that the wastes generated
during the application of Soil Rescue are limited to
those produced during decontamination of equipment
used during the application. For Case 1, residual
waste will be disposed of on site. For Case 2, waste
generated during the decontamination activities can
be treated and disposed of at easily accessible
facilities. Wastewater can be discharged to a POTW
for $ 1 per gallon. Nonhazardous solid waste can be
transported and disposed of for $60 per ton.
For both cases, the assumptions about system design and
operating parameters include:
• Star Organics provides on-site personnel during all
phases of the treatment.
• A hourly labor rate of $47.40 is used for site
preparation and sampling activities. The rate
represents the average labor rate, based on the
demonstration. A labor rate of $54 per hour is used
for all other activities. That is the rate used by Star
Organics for a field chemist.
• A per diem of $80 per worker per day is assumed.
• Routine labor requirements consist of soil preparation,
sampling of untreated and treated soil, and application
of Soil Rescue.
• Maintenance costs are included in the equipment
rental cost.
• Soil Rescue is transported from the office of Star
Organics in Dallas, Texas, to the CRPAC.
• It is assumed that 22 samples are collected for Case
1, and 58 samples are needed for Case 2.
• Costs are presented as 1998 dollars.
• There are no utility costs for either case.
4.3 COST CATEGORIES
Table 4-1 presents cost breakdowns for each of the 12
cost categories for Soil Rescue: (1) site preparation, (2)
permitting and regulatory, (3) mobilization, (4) capital
equipment, (5) labor, (6) supplies andmaterials,(7) utilities,
(8) effluent treatment and disposal, (9) residual waste
shipping and handling, (10) analytical services, (11)
equipment maintenance, and (12) site demobilization.
Each of the 12 cost categories is discussed below. The
costs for each category have been rounded up to the
nearest $50 or $100.
4.3.1 Site Preparation Costs
For this economic analysis, it is assumed that preliminary
site preparation will be performed by the responsible party
(or site owner). The amount of preliminary site preparation
required will depend on the site. Site preparation
responsibilities include site design and layout, surveys and
site logistics, legal searches, access rights and roads,
preparation for support and decontamination facilities,
utility connections(ifneeded),andpotentiallyfixedauxiliary
buildings. Since such costs are site-specific, they are not
included in the costs of site preparation presented in the
estimates.
For this cost analysis, only site preparation costs specific
to the technology are included. Those costs are limited to
preparation of the site for the application of Soil Rescue by
removal of grass at the site with a sod cutter or by tilling
it into the soil. The treatment depth for both cases is 6
inches. Table 4-2 presents site preparation costs for both
cases.
Table 4-2. Site Preparation Costs
Cost Category
Rental equipment
Labor (24 hours total)
($47.40/hour x 8 hrs x 3 workers)
Per diem
($80/worker/day x 1 day x 3
workers)
Total Site Preparation Costs
Casel
$30
$1,100
$240
$ 1,400
Case 2
$115
$1,100
$240
$1,500
Note: 1998 dollars.
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For Case 1, it is assumed that sod covering the site will be
removed with sod cutters and stored until it can be
replaced after treatment. Site preparation costs for Case
lincluderentalcostsforsodremovalandtillingequipment,
labor, andper diem. Assuming that three workers earning
an estimated labor rate of $47.40 per hour can prepare the
site in 8 hours (one business day), the total labor cost
associated with site preparation activities for Case 1 is
approximately $1,100. Aper diem of $80 per worker per
day is assumed, adding an additional $240 to the total site
preparation cost. Weekly rental costs for the tiller and sod
cutters, determined from actual demonstration costs, are
approximately $200, bringing the daily rental cost to
approximately $30. Therefore, the total cost for site
preparation for Case 1 is estimated to be approximately
$1,400.
For Case 2, site preparation costs include costs associated
with rental of equipment to remove sod, labor, and per
diem. Since the sod would be removed with large,
production-sized equipment, it is assumed that the one-
acre site can be prepared in 8 hours and that all grass
covering the site will be tilled into the soil. Equipment for
the one-acre site would include a medium-duty tractor
with a plow. On the basis of several vendor quotes, the
weekly rental rate for the equipment is estimated to be
$800, making daily cost for the equipment approximately
$115. Assuming three that workers earning an estimated
labor rate of $47.40 per hour will perform the work, labor
costs associated with Case 2 will be $1,100. The total per
diemforthethreeworkersis$240.Thetotalsitepreparation
costs for Case 2 are an estimated $1,500.
4.3.2 Permitting and Regulatory Costs
Permitting and regulatory costs generally are the obligation
of the responsible party (or site owner), not that of the
vendor. Such costs may include the costs of permits,
system monitoring requirements, the development of
monitoring and analytical procedures, and health and
safety monitoring. Permitting and regulatory costs can
vary greatly because they are site- and waste-specific. In
applications of Soil Rescue under a soil remediation
program, permitting andregulatory costs will vary according
to whether remediation is performed at a Superfund or a
RCRA corrective action site. Remedial actions at Superfund
site must be consistent with ARARs of environmental
laws, ordinances, regulations, and statutes, including federal,
state, and local standards and criteria. Remediation at
RCRA corrective action sites requires certain monitoring
and recordkeeping that can increase the basic cost of
regulatory compliance.
No permitting costs are included in this analysis; however,
depending on the site, such costs may be a significant
factor because permitting can be expensive and time-
consuming. The costs are not included in the analysis
because no regulatory permits were required for Case 1.
Permits may be needed for air emissions if site preparation
activities produce significant quantities of dust. However,
air emissions can be controlled by wetting the soil to be
treated during tilling. Such costs are expected to be
negligible and are not included in the estimate. For Case 2,
it is assumed that no permitting and regulatory costs will be
incurred for air emissions or for the transportation and
disposal of residual waste. '
4.3.3 Mobilization Costs
Table 4-3 presents the mobilization costs for both cases.
Mobilization consists of mobilizing personnel and
transporting materials to the site. For both cases, it is
assumed that, some equipment and materials are
transported by a medium-duty truck from the office of Star
Organics in Dallas, Texas, toihe CRPAC. The distance
betweenDallas, Texas, and the CRPAC site in Crooksville/
Roseville, Ohio, is approximately 1,100 miles. Star Organics
mobilized two field personnel and one truck for the SITE
demonstration. It is assumed that for Case 2, two personnel
and onetruckalso will be mobilized. Assumingthe standard
government mileage reimbursement rate of 31 cents per
mile, mileage costs from Dallas, Texas, to the CRPAC
were approximately $300. The drive from Dallas, Texas,
to the CRPAC site requires approximately 20 hours of
driving time. Labor costs for mobilizing two personnel (for
a total of 40 hours of labor) earning an estimated labor rate
of $54 per hour are approximately $2,200. Assuming the
trip is completed in 3 days and aper diem of $80 per worker
per day, the total per diem charges for two people are
$480. The total mobilization cost for both cases is
approximately $3,000. Mobilization of personnel and
Table 4-3. Mobilization Costs ,
Cost Category
Mileage
Labor (40 hours total)
($54/hr x 20 hrs x 2 workers)
Per diem
• ($80/workef/day x 3 days x 2
workers)
Total Mobilization Costs
Note:
. Case 1
$300
$ 2,200
$480
$ 3,000
Case 2
$300
$ 2,200
$480
$ 3,000
1998 dollars.
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materials to other sites could be accomplished in a number
of ways. For example, materials could be shipped by a
carrier service and personnel flown to the site. Such
options should be explored to minimize the cost of
mobilization.
4.3.4 Equipment Costs
Table 4-4 presents equipment costs for both cases. Rental
equipment used during the SITE demonstration consisted
of a polypropylene storage tank, a pump, a generator, and
a tiller. The equipment was used over a two-day period.
The daily rental cost for the tiller is approximately $23
(when rented for one week). Therefore, the cost for the
tiller over the two-day period was $46. The total cost for
the rest of the rental' equipment for Case 1 was
approximately $400 per week, bringing the cost for this
equipment over the two-day period to approximately $57.
Therefore; the total cost for rental equipment was
approximately $ 100. Purchased equipment used for Case
1 consisted of a fertilizer sprayer and a pressure sprayer
for decontamination. The total cost of purchased equipment
for Case 1 was approximately $200. Therefore, total cost
for equipment for Case 1 is approximately $300.
It is assumed that for Case 2 the application of Soil Rescue
requires larger production-sized equipment. To minimize
costs, the equipment necessary for Case 2 should be
rented. Equipment for Case 2 is assumed to be a tractor
with both a plow and a fertilizer spreader and a pressure
washer for decontamination. For Case 2, it is assumed that
treatment will require three days. The daily rental cost for
the tractor and plow is approximately $115, bringing the
cost for the equipment to $345 for the three-day period.
The combined one-week rental rates for the pressure
washer and the fertilizer sprayer is estimated to be $800,
bringing the daily rental cost for the equipment to $ 115. For
the three-day time period assumed for Case 2, the cost for
the pressure sprayer and the fertilizer sprayer is $345.
Therefore,: the total cost of equipment for Case 2 is
estimated at approximately $700.
4.3.5 Labor Costs
Once the site has been prepared and the technology has
been mobilized, labor requirements for applyingSoil Rescue
are minimal. Table 4-5 summarizes labor costs. For both
cases, it is assumed that two field personnel will be
required for sampling activities, at an estimated labor rate
of $4-7.40 per hour. It also is assumed that two workers will
be required to perform the treatment activities, each at a
labor rate of $54 per hour. All workers will receive a per
diem of $80 per day to cover lodging, food, and expenses.
For Case 1, it is assumed that the amount of time required
to sarnple and treat the site will be the same as that required
for the SITE demonstration. Sampling of untreated and
treated soil, each activity lasting 1 day, was performed by
Tetra Tech and required a total of44 hours of labor. Labor
costs associated with the sampling activities for Case 1
were approximately $2,100. The treatment performed by
Star Organics required 24 hours and lasted three days, for
a total of 48 hours of labor. The total cost of labor for the
treatment activities associated with Case 1 was
approximately $2,600. The total per diem for two workers
over the five-day period was $800. Therefore, the total
costs of labor associated with Case 1, including per diem,
was $5,500.
For Case 2, sampling activities require a total of 64 hours
of labor, bringing the total labor costs for the sampling
activities for Case 2 to $3,000. It is assumed that treatment
activities for Case 2 require approximately 80 hours of
labor over a five-day period, bringing labor costs associated
with treatment activities for Case 2 to an estimated $4,320.
The total labor cost for Case 2 is estimated to be
approximately $7,320. The total per diem for two workers
over the five-day period is $800. Therefore, the total cost
of labor associated with Case 2, including per diem, is
estimated to be $8,120. Labor costs associated with
Table 4-4J Equipment Costs
Cost Category
Rental equipment
Purchased equipment
Total Capital Equipment Cost
Case 1
$100
$200
$300
Case 2
$700
—
$700
Note: 1998 dollars.
Table 4-5. Labor Costs
Cost Category
Sampling Labor
($47.40/hr x hours)
Treatment Labor
($54/hr x hours)
Per Diem
($80/worker/day x 5 days x 2
workers)
Total Labor Costs
Case 1
$2,100 (44
hours total)
$2,600 (48
hours total)
$800
$5,500
Case 2
$3,000 (64
hours total)
$4,320 (80
hours total)
$800
$8,120
Note: 1998 dollars.
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laboratory analysisareincludedin Section4.3.10, Analytical
Services.
4.3.5 Supplies and Materials Costs
The necessary supplies for the soil sampling activities and
theapplicationofSoilRescueincludeSoilRescue, sampling
supplies, Level D disposable PPE (latex rubber gloves),
decontamination supplies, and miscellaneous field supplies.
Table 4-6 presents the costs for supplies and materials.
The total cost of Soil Rescue reportedby Star Organics for
Case 1 was $75. Disposable PPE typically consists of
latexinner gloves and nitrile outer gloves. Decontamination
supplies consist of soap, deionized water, and Alconox.
PPE and decontamination supplies cost approximately
$500 for Case 1. Sampling supplies include sample bottles,
labels, a 5-gallon bucket with a lid, sieves, and shipping
containers. Sampling supplies cost approximately $200 for
Case 1. Field supplies include water for personnel, a
cooler, field notebooks, an outdoor canopy, and other
miscellaneous supplies. Field supplies cost an estimated
S200. Total costs for supplies and materials for Case 1
were approximately $ 1,000.
For Case 2, it is assumed that approximately 161 times as
much soil (by volume) will be treated with Soil Rescue.
Assuming a linear cost-to-volume ratio, the total cost of
Soil Rescue for Case 2 is estimated to be approximately
$12,100. Because Case 2 represents a more extensive
application of the technology, expenses for PPE,
decontamination supplies, sampling supplies, and field
supplies are expected to be higher than the costs associated
with Case 1. The costs of PPE and decontamination
supplies are estimated at approximately $800 for Case 2.
Sampling supplies are expected to cost approximately
$400 for Case 2. The cost of field supplies for Case 2 is
estimated to be $900. The total cost for supplies for Case
2 therefore is approximately $ 14,200.
Table 4-6. Supplies and Materials Costs
Cost Category
Soil Rescue fluid
Sampling supplies
PPE and decontamination
supplies
Miscellaneous field supplies
Total Supplies and Materials Costs
Case 1
$100
$200
$500
$200
$1,000
Case 2
$12,100
$400
$800
$900
$14,200
Note: 1998 dollars.
4.3.7 Utilities Costs
Electric utility connections arenotrequired for the application
of Soil Rescue. However, because of the manner in which
Soil Rescue is applied, a small amount of electricity is
needed to pump the solution from the storage tank. This
electricity can be provided by a portable generator, making
it unnecessary to incur electrical utility costs. The cost of
fuel to run the generator and other rental equipment is
negligible and is not included in the estimate. Water is
required for decontamination of personnel and equipment.
Water and other utility costs were insignificant and therefore
are not included in the estimate.
4.3.8 Effluent Treatment and Disposal
Costs
No effluent is produced during the application of Soil
Rescue.
4.3.9 Residual Waste Shipping and
Handling Costs
One of the key features of Soil Rescue is that it does not
produce significant amounts of residual waste. Residual
wastewater is generated during decontamination of
equipment and personnel. For Case 1, the amount of
residual wastewater was negligible. OEPA determined
that the residual wastewater would not have further effect
on the soil or groundwater at the site and allowed the
disposal of the wastewater, on site by pouring the
wastewater onto the soil in the demonstration area.
Therefore, no costs for disposal of wastewater are included
in the analysis for Case 1. It is assumed that the only solid
wastes generated from the application of Soil Rescue are
used disposable PPE and soil derived during the
decontamination of field equipment. For Case 1, the
amount of residual solid waste was negligible. The small
amountofresidualwasteproducedduringthe demonstration
was classified as nonhazardous. The waste was disposed
of as solid waste. The owner, of the property provided a
dumpster for the disposal of the waste. Therefore, no costs
for disposal of residual waste are included in the estimate
for Case 1.
i
For Case 2, it is assumed that one 5 5-gallon drum of
residual wastewater will be generated during
decontamination activities. For the cost estimate, it is
assumed that the disposal cost is $5 00 per 55-gallon drum.
It also is assumed that one 5 5 -gallon drum of nonhazardous
solid waste will be generated. The disposal cost for
nonhazardous solid waste is estimated at 35500 per 55-
gallon drum. Therefore, the total estimated cost for disposal
54
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of residual waste for Case 2 is $ 1,000. If the residual solid
waste were hazardous, disposal costs likely would be more
expensive.
4.3.10 Analytical Services Costs
Analytical services include costs for laboratory analyses,
data reduction, and QA/QC. Sampling frequencies and
number of samples are site-specific. Therefore, the costs
presented in this analysis may not be applicable to other
sites. In total, 292 samples were collected at the CRPAC
demonstration site, including 145 samples of untreated soil
and 147 samples of treated soil. The large number of
samples were taken to ensure that it would be possible the
to evaluate how well the stringent objectives of the
demonstration had been'met.
',
For Case 1', which is a demonstration-sized or pilot-scale
application of the technology, fewer samples are needed.
It is assumed that one composite sample will be taken from
each of the 11 plots during the sampling of both untreated
and treated soil, for a total of 22 samples for Case 1. It also
is assumed that, for both cases, the TCLP will be the only
parameter analyzed for, since thatparameter will determine
whether the treatment has reduced concentrations of
metals to levels lower than those established under
regulatory requirements levels. The average unit cost per
sample for the TCLP analyses performed for the SITE
demonstration is $73, including the costs of analytical
services for standard QA/QC samples. Since the site
characteristics for both cases are assumed to be identical
to those of the CRPAC demonstration site, it is assumed
that the average cost per sample will remain the same. For
Case 1, the total analytical costs for the TCLP analysis of
22 samples is approximately $1,600.
For Case 2, it is estimated that 5 8 composite samples must
be taken to obtain a statistically valid population. To
estimate the number of samples, treated TCLP data from
the SITE demonstration was used and assumed to be
representative of the variance [0.35 (mg/L)2] of
concentrations of lead in treated soil at the Case 2 site. It
was assumed that the data set couldbe described adequately
by anormal distribution. Ahypothesis test was established
to compare the treated concentration with 7.5 mg/L (the
alternative UTS for lead in soil and the regulatory action
level), with the null hypothesis stating that the average
concentration in treated soil is greater than 7.5 mg/L.
Calculations of sample are based on use of the one sample
t-test statistic. The following equation was used to determine
the appropriate number of samples.
where
Var (A)
6
Z
Variance of the data on treated soil from
the SITE demonstration
Minimum detectable difference from the
alternative UTS
Value from standard normal such that a is
the area under the curve to the right of this
value
Value from standard normal such that b is
the area under the curve to the left of this
value
The variables a and p are probabilities associated with
Type I and Type n errors, respectively. For the analysis,
an a level of 0.1 was defined as acceptable to meet the
goals of the study. A p level of 0.1 was used with a
minimum detectable difference (*) of 0.2 mg/L. Values
for Za and Zp were obtained from a table of standard
normal values.
To obtain the desired confidence levels (90 percent) and
minimum detection level (0.2 mg/L), atleast58 composite
samples must be analyzed at the site. The 5 8 samples to be
analyzed by the TCLP bring the total analytical costs for
Case 2 to an estimated $4,200.
4.3.11 Equipment Maintenance Costs
All equipment used in the application of Soil Rescue can be
rented. Thatoption, coupled with the factthatthe technology
can be applied in a short period of time, eliminates the need
for maintenance of equipment. Therefore, no maintenance
costs are included in the analysis. It may be necessary to
consider equipment maintenance costs for projects other
than the two cases considered in the analysis, depending
on the volume of soil to be treated, the soil conditions, and
the length of time necessary to treat the contaminated soil.
4.3.12 Site Demobilization Costs
Site demobilization costs consist of demobilizing personnel
and transporting materials from the site. Table 4-7 presents
the costs for site demobilization. For both cases, it is
assumed that some equipment and materials are
transported by a medium-duty truck from the CRPAC to
the office of Star Organics in Dallas, Texas. The distance
between the CRPAC site in Roseville, Ohio, and Dallas,
Texas, is approximately 1,100 miles. Star Organics
55
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Table 4-7. Site Demobilization Costs
Cost Category
Mileage
Labor (40 hours total)
($54/hr x 20 hrs x 2 workers)
Per diem
($80Avorker/day x 3 days x 2 workers)
Total Demobilization Costs
Casel
$300
$2,200
$480
$3,000
Case 2
$300
$2,200
$480
$3,000
Note: 1998 dollars.
demobilized two field personnel and one truck. It is
assumed that, for Case 2, two personnel and one truck also
will be demobilized. Assuming the standard government
mileage reimbursement rate of 31 cents per mile, mileage
costs from the CRPAC site to Dallas, Texas, are
approximately $300. The drive from the CRPAC site to
Dallas, Texas, requires approximately 20 hours of driving
time. Labor costs for demobilizing two personnel (for a
total of 40 hours of labor) earning an estimated labor rate
of $54 per hour are approximately $2,200. Assuming the
trip is completed in three days and a per diem of $80 per
worker per day, the total per diem charges for two
personnel is $480. The total demobilization cost for both
casesisapproximately$3,OOO.Demobilizationofpersonnel
and materials to other sites could be accomplished in a
number of ways. For example, materials could be shipped
by a carrier service, and personnel could be flown to the
next site. Such options should be explored to minimize the
costof demobilization.
4.4 SUMMARY OF THE ECONOMIC
ANALYSIS
Two cost estimates are presented for applying Soil Rescue
to remediate soil contaminated with lead in the CRPAC.
Both cases are based directly on the costs of the
demonstration. The first case (Case 1) involves a cost
estimate for a demonstration-scale application, and the
second case (Case 2) involves a larger one-acre site at
which conditions are identical to those encountered at the
Case 1 site. Table 4-1 shows the estimated costs and the
percent distributions associated with the 12 cost categories
presented in the analysis for both cases.
For Case 1, important cost categories include site
preparation (10.94 percent), mobilization (23.44 percent),
equipment (2.34 percent), labor (42.97 percent), supplies
and materials (7.81 percent), and analytical services
(12.50 percent). No costs were incurred in the other cost
categories (permitting and regulatory, utilities, effluent
treatmentanddisposal, residual waste shippingandhandling,
equipmentmaintenance, and site demobilization) forCase
1. For Case 2, important cost categories included labor
(21.54 percent), supplies and materials (41.85 percent),
and analytical services (12.92 percent). The costs for site
preparation (4.62 percent), mobilization (9.23 percent),
equipment (2.15 percent), residual waste shipping and
handling (3.08 percent), and site demobilization (9.23
percent) were also significant for Case 2. No costs were
incurred in the other cost categories (permitting and
regulatory, utilities, effluent! treatment and disposal, and
equipment maintenance) for Case 2.
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Section 5
Technology Status
Since the SITE demonstration projects, Star Organics has
conducted several bench-scale treatability studies of Soil
Rescue on a variety of soils and wastes contaminated with
antimony, arsenic, cadmium, chromium, lead, selenium,
and thallium. The studies have included testing of Soil
Rescue's ability to treat oil refinery wastes contaminated
with heavy metals, metal processing waste, soil at a
manufacturing facility that was contaminated with lead,
and mine tailings (Star Organics 2000).
Remediation of Refinery Waste
Testing was conducted to determine whether Soil Rescue
couldreduce the leachable concentrations ofheavy metals
in wastes from oil refining processes, including spent
catalyst, accumulations of tank bottom sludges,
contaminated soil from oil spills or releases, and
miscellaneous oil saturated waste. These wastes were
treated with thermal desorption, and the ash material was
treated with Soil Rescue to reduce concentrations of
leachable heavy metal concentrations to levels lower than
the UTS. Soil Rescue also was applied to the waste
streams before thermal processing. According to Star
Organics, Soil Rescue successfullyreduced concentrations
of leachable heavy metals in the waste streams to levels
lower than the UTS (Star Organics 2000).
Remediation of Metal Processor Waste
Star Organics conducted studies on a waste generated by
a metal processing firm that recovers metal from scrap.
The primary heavy metal of concern for the waste was
lead. Star Organics determined that Soil Rescue could
reduce the concentration of leachable lead to meet the
UTS.
In Situ Remediation of a Manufacturing Facility
Star Organics conducted several tests on soil contaminated
with lead at an abandoned manufacturing site. One test
included evaluation of Soil Rescue's ability to reduce the
concentration of leachable lead to less than 5.0 mg/L and
confirmation of the results through a third-party evaluation
of the samples of the soil treated with Soil Rescue. Star
Organics claims that Soil Rescue was successful in
meeting the project goal and that the results were confirmed
through third-party test results.
57
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Section 6
References
Canadian Society of Soil Science. 1993. "Soil Sampling
and Methods of Analysis." Chapters 19 and 38. Lewis
Publishers. 1993.
Evans, G. 1990. "Estimating Innovative Treatment
Technology Costs for the SITE Program." Journal of Air
and Waste Management Association. Volume 40,
Number 7. July.
Environment Canada Method Number 7.
Interstate Technology andRegulatory Cooperation (TTRC)
Work Group. 1997. "Emerging Technologies for the
RemediationofMetalsinSoils:/w5f/MStabilization/Inplace
Inactivation." December.
R.S. Means, Company, Inc. 1998. Environmental
Restoration Assemblies CostBook. R.S. Means Company,
Inc., Kingston, Massachusetts.
Northern Kentucky University (NKU). 1999. Letter
Regarding Technical Review of Soil Amendment
Technologies, Cation Exchange Capacity Assessment.
From Lee Otte, Senior Consultant. To David Gilligan,
ProjectManger, Tetra TechEM Inc. (TetraTech) October
7.
Ohio Environmental Protection Agency. 1998. "Interim
Report and Proposal for Additional Work, Crooksville/
RosevillePotteryAreaofConcemGeographicInitiative."
March. Prepared for Environmental Protection Agency.
Solubility/BioavailabilityResearchConsortium(SBRC).
1998. "Simplified In Vitro Method for Determination of
Lead and Arsenic Bioaccessibility." Unpublished.
Star Organics, L.L.C. (Star Organics) 2000. Facsimile
Regarding Soil Rescue uses since SITE demonstration in
September 1998. From Kevin Walsh, Star Organics. To
David Gilligan, Terra Tech. August.
Tessier, A. 1979. "Sequential Extraction I'rocedure for
the Speciatipn of Particulate Trace Metals." Analytical
Chemistry. Volume 51, Number 7. Pages 844-850.
Tetra Tech EM Inc. (Terra Tech) 1998. "Evaluation of
Soil Amendment Technologies atthe Crooksville/Roseville
Pottery Area of Concern: SITE Program Final Quality
Assurance Project Plan." Prepared for EPA under
Contract No. 68-35-0037. November.
Tetra Tech. 2001. "Star Organics, L.L.C. "Evaluation of
Soil Amendment Technologies attheCrooksville/Roseville
Pottery Area of Concern: SITE Program Demonstration
Technology Evaluation Report." Prepared for EPA under
Contract No. 68-35-0037. December.
U.S. Environmental Protection Agency (EPA). 2000.
EPA Region 9 Preliminary Remediation Goals (PRG
2000) November http://www.epa.gov/region09/waste/
sfund/prg/index.htm
EPA. 1988. Protocol for a Chemical Treatment
Demonstration Plan. Hazardous Waste Engineering
Research Laboratory. Cincinnati, Ohio. April.
EPA. 1996. Test Methods for Evaluating Solid Waste,
Volumes IA-IC: Laboratory Manual, Physical/Chemical
Methods; and Volume H: FieldManual, Physical/Chemical
Methods, SW-846, Third Edition, Update HI, Office of
Solid Waste and Emergency Response, Washington D.C.
December.
EPA. 1983. Methods for Chemical Analysis of Water and
Wastes EPA/600/4-79-020, Environmental Monitoring
and Support Laboratory, Cincinnati, Ohio, and subsequent
EPA/600/4 technical additions.
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Appendix A
Vendor Claims
A.1 Introduction
Star Organics L.L.C.'sSoilRescue technology is designed
to stabilize toxic metals in soils, sludges, and other waste
streams, permanently binding the metals and rendering
them inactive or unleachable. The technology is applied as
a fluid and utilizes one or more techniques depending on the
medium being treated and the conditions required to
achieve intimate contact of the fluid with the medium of
concern.
A.2 Technology Overview
The technology utilized by Star Organics is chemical
complexation, whereby unstabilized metals are bound in a
multidentate coordination bond with phosphoryl organic
compounds, thereby stabilizing the metal. The technology
isnot limited to RCRA metals, nor is it limited to soils as the
current name of the product implies. It has been tested and
found to be effective on metals of concern in the oil field,
such as barium, and possibly sodium (more testing is being
done as this is written). It has also been tested on antimony,
thallium, selenium, arsenic (limitedresults to date), copper,
zinc, and cadmium. The efficiency of the treatment varies
depending oh the target metal, competing metals, and pH
of the medium to be treated. The technology can be applied
to media such as wastewater treatment sludges, flyash,
mine tailings, andmunicipal landfill leachatesinaddition to
soils. The Company has also tested the technology on non-
toxic metals related to agriculture, turf farms, and golf
courses, utilizing the metal stabilization properties of the
technology to reduce soil hardness and alkalinity which are
known to retard the growth of crops, commercial turf,
putting greens, and other vegetation.
A.3 Theory of Metals Complexation
The theory behind the Star Organics technology.
demonstrated in this SITE program evaluation pertains to
the bonding relationships in metal complexes. Chemical
elements interact to achieve low (stable) energy conditions
when the physical and chemical environments (available
complexing agents, pH, intimate contact) permit it.
A metal complex consists of a central ion and ligands. The
central ion is a metallic cation (such as lead) about.which
a definite number of ions or molecules are attached in a
preferred geometric arrangement. The molecules or ions
attached to the central ion are called ligands. The ligands
are classified as monodentate or polydentate, depending
on the number of atoms in the ligand which are attached
directly to the central atom.
Metal complexes can be formedby anions, some molecules,
and very few cations. Star Organics manufactures an
organic-based solution containing carboxylic acids and
phosphoryl esters, among other compounds, which are
known to have properties suitable for the formation of
coordinationcovalentbondscharacteristicofthose formed
in metal complexes.
A.4 Advantages of Star Organics'
Remediation Technology
• In-situ application
• Low labor cost
• No concrete cost
• No incineration cost
• No offsite disposal cost
• No toxic reaction products
• No air pollution issues
• No volume increase when treating wastes
• Limited disposal concerns; disposable coveralls and
shoe coverings of application personnel
• No special handling requirements; fluid is non-toxic
and non-hazardous
• Few access limitations to the potential site since
large dirt handling equipment is not required
59
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S-/EPA
United States
Environmental Protection
Agency
National Risk Management
Research Laboratory
Cincinnati, OH 45268
Official Business
Penalty for Private Use
$300
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detach or copy, and return to the address in the upper
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detach, or copy this cover, and return to the address in the
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March 2003
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