&EPA
United States
Environmental Protection
Agency
SITE Technology Capsule
Evaluation of Soil Amendment
Technologies at the Crooksville/
Roseville Pottery Area of
Concern
STAR Organics Soil Rescue
Introduction
In 1980, the U.S. Congress passed the Comprehensive En-
vironmental Response, Compensation, and Liability Act
(CERCLA), also known as Superfund, which is committed
to protecting human health and the environment from uncon-
trolled hazardous waste sites. CERCLA was amended by the
Superfund Amendments and Reauthorization Act (SARA) in
1986. SARA mandates implementing permanent solutions
and using alternative, innovative treatment or resource re-
covery technologies to the maximum extent possible.
State and federal agencies and private organizations are
exploring a growing number of innovative technologies for
treating hazardous wastes. These new technologies are
needed to remediate the more than 1,200 sites on the Na-
tional Priorities List. The sites involve a broad spectrum of
physical, chemical, and environmental conditions requiring
diverse remedial approaches.
The U.S. Environmental Protection Agency (EPA) is engaged
in a number of activities that are focused on exploring and
applying innovative technologies to Superfund site
remediation. One EPA initiative to accelerate the develop-
ment, evaluation, and use of innovative site remediation tech-
nologies is the Superfund Innovative Technology Evaluation
(SITE) Program. One of the goals of the SITE Program is to
disseminate information about innovative technologies to the
user community. This Technology Capsule is one of the docu-
ments the SITE Program uses to meet this goal.
EPA SITETechnology Capsules summarize the latest infor-
mation available on innovative technologies.TheTechnology
Capsules assist EPA remedial project managers, EPA on-site
coordinators, contractors, and other remedial managers in
evaluating site-specific information to determine a
technology's applicability for site remediation.
This Technology Capsule provides information on the Star
Organics, L.L.C. (Star Organics), Soil Rescue remediation
fluid. Star Organics developed the technology to remediate
heavy metals in soil.The remediation fluid was evaluated in
September, 1998 at a site in southeastern Ohio. The Soil
Rescue remediation process was applied in s/futo residen-
tial and industrial soils contaminated with lead from pottery
factory waste.
This Technology Capsule describes the Soil Rescue
remediation process and summarizes results from the SITE
evaluation.The capsule includes the following information:
Abstract
Site Background
Technology Description
Evaluation Activities
Technology Applicability
Performance Data
Technology Status
Sources of Further Information
Abstract
Soil Rescue remediation fluid consists of organic phospho-
ryl compounds and weak organic acids that bind with heavy
metal contaminants in soils, sludges, and sediments. The
technology is based on a chelation process where a heavy
metal ion is attached to ligands in the remediation fluid to
form complex metallic compounds.
The EPA SITE Program evaluated a pilot-scale, in situ ap-
plication of the remediation fluid at two sites in September
1998. The fluid was sprayed onto the surface of the lead-
contaminated soil and then was injected to a depth of 2 feet.
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During the evaluation, SITE Program personnel collected
untreated and treated soil samples to evaluate the
technology's performance with respect to primary and sec-
ondary evaluation objectives.
The soil samples were analyzed for lead concentrations
using theToxicity Characteristic Leaching Procedure (TCLP)
and in-vitro method for bioavailable lead to support two pri-
mary objectives. 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 dis-
posal of soils contaminated with lead. The alternative UTS
for soil contaminated with lead is 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 milli-
grams per liter (mg/L), or (2) 10 percent of the lead concen-
tration 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 underTitle 40 of the Code of Federal Regu-
lations (CFR), Chapter I, part 268.49 (40 CFR 268.49). To
meet that objective, soil samples were collected before and
after the application of Soil Rescue. The untreated and
treated soil samples were analyzed forTCLP lead concen-
trations to evaluate whetherthe technology met objective P1.
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 per-
cent. 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 con-
centrations 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 Res-
cue could decrease the soil lead bioaccessibility by 25 per-
cent or more, as defined by the Solubility/Bioaccessibility
Research Consortium's (SBRC) Simplified In-VitroTest
Method for Determining Soil Lead and Arsenic Bioavailability
(simplified in vitro method [SIVM]). However, EPA Lead Sites
Workgroup (LSW) and Technical Review Workgroup for lead
(TRW) at this time, do not endorse an in-vitro test for deter-
mining 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 forsoil lead
bioaccessibility to evaluate whether the technology met ob-
jective P2. Analysis of the data demonstrates that Soil Res-
cue 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 dem-
onstration involves a highly acidic sample digestion process,
which may be revised in the future, because it may be ex-
ceeding the acid concentrations that would be expected in
human stomach fluids.
Using information obtained from the SITE evaluation, the
technology developer, and other sources, an economic
analysis examined 12 cost categories fora scenario in which
the Soil Rescue remediation fluid was applied at full scale to
treat lead-contaminated soil at a Superfund site. The cost
estimate assumed the site was 1 acre in size, and the treat-
ment was applied to a depth of 6 inches.These assumptions
result in a total treated volume of approximately 807 cubic
yards of soil. The estimate assumes that the site's soil char-
acteristics and lead concentrations were similar to those
encountered during the SITE evaluation. Based on these
assumptions, the total costs were estimated to be $32,500
per acre, or $40.27 per cubic yard of soil treated. Costs for
application of the Soil Rescue remediation fluid may vary
significantly from this estimate, depending on site-specific
factors.
The SITE Program evaluation of the Soil Rescue remediation
fluid, described in detail in an Innovative Technology Evalu-
ation Report, was based on the nine decision-making crite-
ria used in the Superfund feasibility study process. Results
of the evaluation are summarized in Table 1.
Site Background
The villages of Crooksville and Roseville, located along the
Muskingum/Perry County line in southeastern Ohio, are fa-
mous for a long history of pottery production. Lead com-
pounds were used in pottery glazes until they were replaced
during the last 20 years.
In 1996, the Ohio Environmental Protection Agency (OEPA)
entered into a cooperative agreement with the EPA to con-
duct a Geographic Initiative (Gl) of the Crooksville/Roseville
Pottery Area of Concern (CRPAC).The purpose of the inves-
tigation was to determine if the pottery operations in the
CRPAC resulted in heavy metal contamination of the soil,
groundwater, surface water, and ambient air.
Analytical results from samples collected for the Gl investi-
gation in mid-1997 identified 14 pottery waste disposal sites
with significant lead contamination in shallow soil. OEPA is
seeking innovative technologies that will remediate the lead
in the soil in the CRPAC.
SITE Program personnel collected soil samples from four
sites throughout the CRPAC in May, June, and August 1998.
These samples were analyzed forTCLP lead concentrations
and relative percent bioavailable lead concentrations. The
analytical results and visual observations were used to char-
acterize soil to enable selection of the evaluation sites.
The two locations selected forthe SITE demonstration were
an inactive pottery factory in Roseville, Ohio, and a residen-
tial 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 under consideration. The trailer
park was selected forthe SITE demonstration primarily be-
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Table 1. Evaluation of Soil Rescue Compared to the Nine Criteria forSuperfund Feasibility Studies
Criterion
1 . Overall Protection of Human Health and the Environment
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
3. Long-term Effectiveness and Permanence
4. Short-term Effectiveness
5. Reduction of Toxicity, Mobility, or Volume through Treatment
6. Implementability
7. Cost
8. Community Acceptance
9. 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.
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 MEP lead, pH, and 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; measures for dust control and
surface runoff controls may be required 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, the estimated
costs are $32,500, or $40.27 per yd3 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.
cause it was a residential setting. 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 (PRG) for lead established by EPA (EPA
2000). However, previous field sampling conducted by OEPA
with X-ray fluorescence (XRF) analyzers had indicated that
total concentrations of lead in the soil at the trailer park were
well above 400 mg/kg.
Technology Description
Soil Rescue remediation fluid consists of a mixture of weak
organic acids and phosphoryl esters that act as metal
complexing agents. In the complexation reaction, coordinate
covalent bonds are formed among the metal ions, the or-
ganic acids and esters, and the soil substrate. The
remediation fluid can be applied to the surface or pressure
injected to a depth of 15 feet into contaminated soil. The
application can be repeated until the metal concentrations
in the soil are reduced below applicable cleanup standards.
The Soil Rescue remediation fluid does not destroy or re-
move toxic concentrations of metals. Star Organics claims
that the metal complexes formed by Soil Rescue immobilize
the metal, which reduces the TCLP metal concentrations in
soils to less than regulated levels, subsequently reducing the
risks posed to human health and the environment.
Evaluation Activities
SITE Program personnel prepared the evaluation sites by
removing the sod, tilling the soil, and collecting samples of
untreated soil. Evaluation activities began on September 21,
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1998. SITE Program personnel located several experimen-
tal units in the trailer park and at the inactive pottery factory.
The sod was removed from the experimental units, and the
units in the trailer park were tilled to a depth of 6 inches us-
ing a garden tiller. The units at the inactive pottery factory
were tilled using a backhoe to a depth of 6 inches. SITE Pro-
gram personnel screened the experimental units with a field
XRF analyzer for total lead concentrations. The screening
results were used to select the units with high lead concen-
trations. The Soil Rescue remediation fluid was then applied
to 10 experimental units in the trailer park and one experi-
mental unit at the inactive pottery factory. The experimental
units at the trailer park measured 5 feet wide by 5 feet long,
and the unit at the inactive pottery factory measured 3 feet
wide by 6 feet long. Although Star Organics injected the
remediation fluid to a depth of 2 feet, the depth evaluated
during this evaluation was limited to 6 inches.
Sampling of untreated soil in the trailer park consisted of
collecting composite soil samples from each experimental
unit.The composite soil samples were formed by collecting
approximately 1900 cubic centimeters of soil from five loca-
tions (each corner and the middle) of the experimental unit.
The soil was collected using a stainless steel spoon ortrowel
and placed into a stainless steel bowl. The samples were
sieved through a brass, 0.375-inch sieve into a plastic, 5-
gallon bucket. All particles larger than 0.375 inch were re-
turned to the stainless steel bowl. The percentage of the
particles that did not pass through the sieve was estimated
and recorded in the logbook. The composite sample was
mixed in the bucket for 1 minute before the sample contain-
ers we re filled.
Sampling of untreated soil at the inactive pottery factory
consisted of collecting five grab samples from one experi-
mental unit. Approximately 1,900 cubic centimeters of soil
were collected for each grab sample (one sample was col-
lected from each corner and from the middle) within the unit.
The soil was collected using a stainless steel spoon ortrowel
and placed into a stainless steel bowl. The soil sample was
sieved through a 0.375-inch sieve into a plastic, 5-gallon
bucket. The percentage of the particles that did not pass
through the sieve was estimated and recorded in the log-
book. Each grab sample was mixed in the bucket for 1 minute
before the sample containers were filled.The individual grab
samples were not composited.
Star Organics applied the Soil Rescue remediation fluid af-
ter the sampling of untreated soil was completed at each
experimental unit. The Soil Rescue remediation fluid was
sprayed onto the surface and pressure injected into the soil.
The remediation fluid was injected to a depth of two feet.
SITE Program personnel collected samples of treated soil
from the experimental units a minimum of 72 hours after
treatment with Soil Rescue. Samples of treated soil were
collected from the trailer park using the same techniques as
the untreated soil samples; at the pottery factory, however,
four additional grab samples were collected from the mid-
points between the corners on each side.
Technology Applicability
According to Star Organics, the Soil Rescue remediation
fluid has been effective in reducing concentrations of barium,
cadmium, chromium, copper, lead, mercury, selenium, and
zinc. Star Organics indicated that the technology can be
applied using only surface spraying where contamination is
shallow (up to 6 inches) and the soil is moderately perme-
able.
Technology Limitations
In dense or heavily compacted soils, the remediation proce-
dure may require soil excavation and application of the Soil
Rescue remediation fluid to moisten the media, followed by
mixing in a rotating cylinder. For sites with high concentra-
tions of heavy metals, the application process may require
subsequent treatments until the concentrations of heavy
metals in the media are reduced to below the applicable
cleanup standards.
Site Requirements
Star Organics determines a site-specific concentration of the
Soil Rescue remediation fluid through bench-scale studies
on soil samples.The site must be evaluated to determine the
contaminant concentration throughout the site, and the con-
centration of other metals that may be present at the site.The
site conditions, such as soil type, depth of contamination, and
moisture content, must be evaluated to determine the appli-
cation procedure and equipment requirements.
The remediation fluid may be applied with equipment
mounted on a truck, orwith common farming equipment.The
site should be accessible to wheeled ortracked vehicles and
have sufficient storage space for the required volume of
remediation fluid. Potable water is required for equipment and
personnel decontamination.
Process Residuals
Based on existing data, it appears that application of the Soil
Rescue remediation fluid generates little residual wastes.The
chemicals in the remediation fluid bond with the lead to form
an insoluble complex. However, personal protective equip-
ment and the decontamination fluids that contact lead-con-
taminated soil may require management as potentially
hazardous waste.
Performance Data
Primary and secondary objectives were established for this
SITE evaluation to provide criteria for evaluating technology
performance. To achieve the evaluation objectives, SITE
Program personnel collected untreated and treated soil
samples from the experimental units.
Primary Objectives
Primary objective 1 (P1) was to evaluate whether Soil Res-
cue can treat soil contaminated with lead to meet the Re-
source Conservation and Recovery Act (RCRA)/Hazardous
and Solid Waste Amendments (HSWA) alternative universal
treatment standards (UTS) for land disposal of soils contami-
nated with lead. The alternative UTS for soil contaminated
with lead is determined from the results of the toxicity char-
acteristic leaching procedure (TCLP).The alternative UTS
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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 eli-
gible 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 (CRF), Chapter
I, part 268.49 (40 CFR 268.49).To meet that objective, soil
samples were collected before and after the application of
Soil Rescue. The untreated and treated soil samples were
analyzed forTCLP lead concentrations to evaluate whether
the technology met objective P1 .Analysis of the data dem-
onstrated Soil Rescue reduced the mean TCLP lead concen-
tration 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.
Primary objective 2 (P2) was to evaluate whether Soil Res-
cue could decrease the soil lead bioaccessibility by 25 per-
cent or more, as defined by the Solubility/Bioaccessibility
Research Consortium's (SBRC) Simplified In-VitroTest
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) at this 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
after the application of Soil Rescue. The soil samples were
analyzed for soil lead bioaccessibility to evaluate whetherthe
technology met objective P2. Analysis of the data demon-
strates 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 highly acidic
sample digestion process (pH = 1.5), which may be revised
in the future, because it may be exceeding the acid concen-
trations that would be expected in human stomach fluids.
Secondary Objectives
The secondary objectives of the demonstration were:
S1 Evaluate the long-term chemical stability of the treated
soil.
S2 Demonstrate that the application of Soil Rescue did
not increase the public health risk of exposure to lead.
S3 Document baseline geophysical and chemical condi-
tions in the soil before the application of Soil Rescue.
S4 Document the operating and design parameters of
Soil Rescue.
S1 was evaluated primarily by analyzing soil samples using
the following analytical procedures: the multiple extraction
procedure (MEP), lead speciation using a scanning electron
microscope (SEM), lead speciation with a sequential extrac-
tion procedure, oxidation-reduction potential (Eh), pH, cat-
ion exchange capacity (CEC), acid neutralization capacity,
total lead (as determined by two different methods), leach-
able lead by the synthetic precipitation leaching procedure
(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. Sec-
ondary objective S2 was evaluated by collecting air samples
during the sod removal, tilling, and soil sampling operations
and calculating exposure based on the total lead analysis of
the air sample filters. Air samples were collected during the
collection of untreated and treated soil samples. Secondary
objective S3 was evaluated by analyzing soil samples from
the experimental units at both demonstration sites for plas-
ticity, moisture content, predominant clay type of the soil, the
presence of volatile organic carbons (VOCs), semivolatile
organic compounds (SVOCs), oil and grease content, and
humic and fulvic acid concentrations. Secondary objective
S4 was established to provide data for estimating costs as-
sociated with use of the Soil Rescue remediation fluid and
was based on observations during the evaluation and data
to be provided by StarOrganics.
Site Evaluation Results
This section summarizes the results of the SITE evaluation
and includes an evaluation of the primary and secondary
objectives.
Evaluation of Objective P1
The TCLP lead concentrations from the inactive pottery fac-
tory were used to evaluate objective P1 .The TCLP extrac-
tion was performed according to SW846 Method 1311 .The
extracts were digested by SW846 Method 301OA, and the
lead concentration was determined using ICP-AES accord-
ing to SW-846 Method 601 OB. Soil samples from the inac-
tive pottery factory were collected before and after
application of the technology. The results from analyses of
the treated soil were evaluated to determine if the lead in the
soil was leaching at levels above the alternative UTS of 7.5
mg/L TCLP lead.
The data analysis shows that the Soil Rescue remediation
fluid reduced the TCLP lead concentration to below the al-
ternative UTS of 7.5 mg/L at the inactive pottery factory site.
The technology reduced the mean TCLP lead concentration
from 403 mg/L to 3.3 mg/L. Therefore, the TCLP lead con-
centrations were reduced by at least 90 percent. Table 2
summarizes the TCLP lead data from five sampling locations
within the experimental unit at the inactive pottery factory
site.
Evaluation of Objective P2
Objective P2 requires using an in-vitro test to evaluate the
relative percentages of bioavailable lead in untreated and
treated soils from the trailer park site. For this demonstration,
the simplified in vitro method (SIVM) developed by the Solu-
bility/Bioavailability Research Consortium (SBRC) was se-
lected to evaluate the relative percent bioavailability of lead
in soil. The SBRC consists of representatives from the fed-
eral and state regulatory agencies, academia and other re-
search organizations, and the regulated community. The
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Table 2. TCLP Lead Results from the Soil Rescue Evaluation
Experimental Unit
U
U
U
U
U
U
U
U
U
Sampling Location
1
2
3
4
5
6
7
8
9
Untreated Soil TCLP Lead
Concentration (mg/L)
453
376
411
364
411
ns
ns
ns
ns
Treated Soil TCLP Lead
Concentration (mg/L)
3.2
3.0
3.6
3.5
3.1
4.0
2.9
3.2
3.2
Note:
n/s = Statistical experimental design only required five pretreatment samples for TCLP analysis.
Nine grab post-treatment samples were collected instead of five to obtain a more precise estimate
of the post-treatment mean.
SIVM determines the relative percent of bioavailability of lead
in soil by calculating the ratio of the lead in the sample be-
fore extraction to the amount of lead that leached using an
extraction solution that simulates gastric fluid. However, the
EPA Lead Sites Workgroup (LSW) and the EPA Technical
Review Workgroup (TRW) for lead, at this time, do not en-
dorse an in-vitro test for determining lead bioavailability.
The relative percent bioavailable data is used to determine
if the technology would reduce the risk of exposure to the
bioavailable lead in the soil. The risk of exposure is deter-
mined by calculating the percent reduction in the relative
percent bioavailable lead, which is calculated by dividing the
relative percent bioavailable lead after the application of the
technology to the relative percent bioavailable lead before the
application of the technology and multiplying by 100.
The data are not intended to be used to support a risk-based
cleanup level forthe soil, such as a level that is determined
using the ERA'S Integrated Exposure Uptake Biokinetic
model (IEUBK). IEUBK is used to determine if the lead ex-
posure (from various sources) on a residential property has
no more than a 5 percent probability that a child's blood lead
level will exceed 10 micrograms per deciliter.
The technology decreased the relative percent bioavailable
lead by approximately 2.9 percent. Although the technology
did not achieve the goal of objective P2, which is reducing
the relative percent bioavailable lead by 25 percent, it was
recognized early on that meeting this goal would be difficult
because the SIVM test procedure used in the demonstration
involves a highly acidic sample digestion process. The SIVM
process may be revised in the future, because it may be
exceeding the acid concentrations that would be expected
in a human stomach. Table 3 summarizes the bioavailable
lead data. Figure 1 compares the relative percent
bioavailable lead in the residential soil before and after treat-
ment.
Evaluation of Objective S1
Objective S1 was evaluated using the results of 11 analyti-
cal procedures that were conducted to predict the long-term
chemical stability of the treated soil. Soil treated with Soil
Rescue appears to exhibit overall long-term chemical stabil-
ity. 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 forsoils
treated by Soil Rescue at both test locations, as indi-
cated by the analytical results of the multiple extrac-
tion 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 capac-
ity, and leachable lead by the simulated precipitation
leaching procedure (SPLP).The results from the pro-
cedure for evaluating lead speciation by sequential
extraction indicated chemical stability inconclusively at
one site, but not at all at the 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
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Table 3. Relative Percent Bioavailable Lead Results from the Soil Rescue
Evaluation
Experimental Unit
C
G
K
L
M
N
0
Q
R
T
Untreated Soil %
Bioavailable Lead
50.4
70.4
57.6
67.0
58.3
58.1
47.9
52.5
46.2
43.8
Treated Soil %
Bioavailable Lead
44.2
68.9
64.0
65.9
63.2
56.7
52.1
41.8
50.1
32.5
80.0
70.0
CD 60.0
_i
o
in
30.0
StarOrganics Relative % Bioavailable Lead
K L M N
Experimental Unit
Q
R
I Untreated DTreated
Figure 1. Relative percent bioavailable lead before and after treatment.
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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 (organi-
cally 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
fortotal phosphates; and analysis for leachable phos-
phates by the SPLP. (It should be noted that the tests
involving two types of total lead analysis were ex-
tremely aggressive tests, thus meeting the acceptance
criteria established for these tests; but they were not
as important as meeting the acceptance criteria of
other tests involving long-term chemical stability.)
Evaluation of Objective S2
SITE Program personnel collected air samples during pre-
demonstration operations (sod removal, tilling and soil sam-
pling) and calculated exposure based on the total lead
analysis of the air sampling filters. However, since the Soil
Rescue reagent is normally injected into the soil and does
not require sod removal and tilling, the data collected under
this objective may not be typical of the ambient air quality
during aplication of the Soil Rescue process. Ten out of 11
samples did not indicate the presence of lead above the
detection limit of 0.004 mg/m3.The result above the detec-
tion limit, 0.024 mg/m3, was found to be within applicable
exposure guidelines, which include the Occupational Health
and Safety Administration Permissible Exposure Limits
(OSHA PELs), the American Conference of Governmental
Industrial Hygiene Threshold Limit Values (ACGIHTLVs), the
National Institute for Occupational Safety and Health Rec-
ommended Exposure Limits (NIOSH RELs), and the Na-
tional Ambient Air Quality Standards Program (NAAQS)
limits. Based on these results, the risk to public health and
worker exposure was not increased due to the demonstra-
tion activities.
Evaluation of Objective S3
Soil samples from the experimental units at both demonstra-
tion sites were analyzed for plasticity, moisture content, pre-
dominant clay type of the soil, the presence of volatile organic
compounds (VOC), semivolatile organic compounds
(SVOC), oil and grease content, and humic and fulvic acid
concentrations.
Table 4 lists the plastic index, liquid limit, and soil type from
the analyses of the soil samples from both sites using the
American Society forTesting and Materials (ASTM) Method
D 2487-93, Standard Classification of Soils for Engineering
Purposes.
The VOC analytical results did not indicate the presence of
any volatile organics in the soils at either site. The SVOC
analysis indicated the presence of the following SVOCS in
the soils at the inactive pottery factory site:
benz(a)anthacene (0.82 mg/kg), benzo(b)fluoranthene (0.91
mg/kg), benzo(k)fluoranthene (0.77 mg/kg), benzo(a)pyrene
Table 4. Soil Classification Information
Site
Trailer Park
Inactive Pottery
Factory
Plastic
Index
8
11
Liquid
Limit
42
46
Soil
Type
Sandy
Silt
Sandy
Silt
(0.69 mg/kg), chrysene (1.0 mg/kg) fluoranthene (1.9 mg/
kg), and pyrene (1.9 mg/kg). These SVOCs are typically
found in crude oil, gasoline, or used motor oil.
The soil in this area did show signs of staining that may be
the result of the disposal of a small quantity of waste oil.
Based on these concentrations and the current state regu-
lations for petroleum releases, it does not appear that the
SVOCs present at the site require remediation. Also, the
technology developer indicated that these SVOCs will not
interfere with the Soil Rescue remediation fluid.The analyti-
cal results for the inactive pottery factory indicate the pres-
ence of oil and grease at a concentration of 3,680 mg/kg.The
analytical results for the trailer park site did not indicate the
presence of oil and grease.
The concentration of humic acid at the trailer park site was
2,400 mg/L, and the mean concentration of humic acid at the
inactive pottery factory site is 1,400 mg/L. The concentration
of fulvic acid at the trailer park site was 600 mg/L, and the
mean concentration of fulvic acid at the inactive pottery fac-
tory site is less than 500 mg/L.
Evaluation of Objective S4
An economic analysis used information obtained from the
SITE evaluation, Star Organics, and other sources. The
analysis examined 12 cost categories fora scenario in which
the Soil Rescue remediation fluid was applied at full scale to
treat lead-contaminated soil at the CRPAC site. The cost es-
timate assumed the site was 1 acre in size and that the treat-
ment was applied to a depth of 6 inches, which results in an
estimated treated volume of approximately 807 cubic yards.
Based on these assumptions, the total costs were estimated
to be $32,500 per acre, and an estimated cost of $40.27 per
yd3. Costs for application of the Soil Rescue remediation fluid
may vary significantly from this estimate, depending on site-
specific factors.
Technology Status
Star Organics is currently performing several bench-scale
studies and pilot-scale tests on soil and debris contaminated
with heavy metals and radionuclides.
References
Canadian Society of Soil Science. 1993. "Soil Sampling and
Methods of Analysis". Chapters 19 and 38. Lewis Publishers.
1993.
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Evans, G. 1990. "Estimating Innovative Treatment Technol-
ogy Costs for the SITE Program." Journal of Air and Waste
Management Association. Volume 40, Number?. July.
Environment Canada Method Number 7.
Interstate Technology and Regulatory Cooperation (ITRC)
Work Group. 1997. "Emerging Technologies for the
Remediation of Metals in Soils: Insitu Stabilization/lnplace
Inactivation." December.
R.S. Means, Company, Inc. 1998. Environmental Restoration
Assemblies Cost Book. R.S. Means Company, Inc., Kingston,
Massachusetts.
Northern Kentucky University (NKU). 1999. Letter Regard-
ing Technical Review of Soil Amendment Technologies, Cat-
ion Exchange Capacity Assessment. From Lee Otte, Senior
Consultant.To David Gilligan, Project Manger, Tetra Tech EM
Inc. (Tetra Tech) October 7.
Ohio Environmental Protection Agency. 1998. "Interim Re-
port and Proposal for Additional Work, Crooksville/Roseville
Pottery Area of Concern Geographic Initiative." March. Pre-
pared for Environmental Protection Agency.
Solubility/Bioavailability Research Consortium (SBRC).
1998. "Simplified In Vitro Method for Determination of Lead
and Arsenic Bioaccessibility" Unpublished.
Star Organics, L.L.C. (Star Organics) 2000. Facsimile Re-
garding Soil Rescue uses since SITE demonstration in Sep-
tember 1998. From Kevin Walsh, Star Organics. To David
Gilligan, Tetra Tech. August.
Tessier, A. 1979. "Sequential Extraction Procedure for the
Speciation of Particulate Trace Metals." Analytical Chem-
istry. Volume 51, Number 7. Pages 844-850.
Tetra Tech EM Inc. (Tetra Tech) 1998. "Evaluation of Soil
Amendment Technologies at the Crooksville/Roseville Pot-
tery 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 at the Crooksville/Roseville Pot-
tery Area of Concern: SITE Program Demonstration Tech-
nology 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) No-
vember http://www.epa.gov/region09/waste/sfund/prg/
index.htm
EPA. 1988. Protocol for a Chemical Treatment Demonstra-
tion Plan. Hazardous Waste Engineering Research Labora-
tory. Cincinnati, Ohio. April.
EPA. 1996.Test Methods for Evaluating Solid Waste, Volumes
IA-IC: Laboratory Manual, Physical/Chemical Methods; and
Volume II: Field Manual, Physical/Chemical Methods, SW-
846, Third Edition, Update III, 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.
Sources of Further Information
EPA SITE Program
Edwin Barth, EPA Project Manager
U.S. Environmental Protection Agency
Office of Research and Development
26 W Martin Luther King Drive
Cincinnati, Ohio 45268
(513)569-7669
(513) 569-7676 (fax)
E-mail: barth.ed@epa.gov
Technology Developer
Kevin Walsh
Star Organics
5 Mustang Circle
Forney, TX 75126
(972)552-1423
(972) 552-2531 (fax)
E-mail: remediate@starorganics.com
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