United States
          Environmental Protection
          Agency
           Office of Research and
           Development
           Washington DC 20460
EPA/540/R-99/503
June 1999
vxEPA
ELI/SBP's UVB (Vacuum
Vaporization Well)
System for Treatment of
VOC-Contaminated Soils

Innovative Technology
Evaluation Report
               SUPERFUND INNOVATIVE
               TECHNOLOGY EVALUATION

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                                  EPA/540/R-99/503
                                  June 1999
    ELI/SBP's UVB (Vacuum
Vaporization Well) System for
       Treatment of VOC-
                        Soils
Innovative Technology Evaluation Report
         National Risk Management Research Laboratory
            Office of Research and Development
            U.S. Environmental Protection Agency
              Cincinnati, Ohio 45268
                               Printed on Recycled Paper

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                                      Notice
The information in this document has been funded by the U.S. Environmental Protection Agency
(EPA) under Contract Nos. 68-CO-0048 and 68-C5-0001  to Science Applications  International
Corporation (SAIC). 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 is charged by Congress with protecting the Nation's land,
air, and water resources.  Under a mandate of national environmental laws, the Agency strives to
formulate and implement actions leading to a compatible balance between human activities and the
ability of natural systems to support and nurture life. To meet this mandate, EPA's research program
is providing data and technical support for solving environmental problems today and building a
science knowledge base necessary to manage our ecological resources wisely, understand how
pollutants affect our health, and prevent or reduce environmental risks in the future.

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

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

                                    E. Timothy Oppelt, Director
                                    National Risk Management Research Laboratory
                                           in

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                                     Abstract
This report summarizes the findings of an evaluation of the Unterdruck-Verclampfer-Brunnen (DVB)
technology developed by IEG Technologies (IEG) and licensed in the eastern U.S. by Environmental
Laboratories Inc. (ELI) and SBP Technologies (SBP). This evaluation was conducted under the U.S.
Environmental  Protection  Agency (EPA)  Superfund  Innovative  Technology Evaluation (SITE)
Program. The UVB technology was demonstrated over a period of 14 months from July 1994 through
October 1995 at the Sweden-3 Chapman Landfill in Sweden, NY.  A modified microbial system
employing an in-well biofilterwas demonstrated, along with the ENSR/Larsen Biovault technology and
the R.E. Wright Environmental, Inc. In Situ Bioventing System, as part of a multivendor bioremediation
demonstration. The primary objective of the demonstration was to determine the effectiveness of the
UVB process in reducing the concentrations of six target VOCs in the vadose zone to below New
York State Department of Environmental Conservation Soil Cleanup Criteria (NYSDEC). The VOCs
and criteria are: acetone 0.2 ppm; methyl ethyl ketone 0.6 ppm; 4-methyl-2-pentanone 2 ppm; cis-
1,2-dichloroethene 0.6  ppm; trichloroethene  1.5 ppm; and tetrachloroethene 2.5  ppm.  After 5.5
months, 65% of the approximately 50 soil samples from both the vadose zone and saturated zones
met the NYSDEC criteria.  Seventy percent met the criteria after 14 months.
                                          iv

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                                     Contents
Notice	  ii
Foreword  	Hi
Abstract  	  jv
Tables	vii
Figures	viii
Abbreviations and Acronyms	  ix
Acknowledgments  	  xi
Executive Summary	ES-1

1.0    Introduction 	 1-1
       1.1     Background  	 1-1
       1.2    Brief Description of Program	 1-3
       1.3    The SITE Demonstration Program and Reports  	 1-3
       1.4    Purpose of the Innovative Technology Evaluation Report (ITER)	 1-4
       1.5    Technology Description	 1-4
       1.6    Key Contacts  	 1-5

2.0    Technology Applications Analysis	2-1
       2.1     Key Features of the UVB Treatment System	 2-1
       2.2    Operability of the Technology	2-1
       2.3    Applicable Wastes  	2-2
       2.4    Availability and Transportability of Equipment	2-2
       2.5    Materials Handling Requirements	2-2
       2.6    Site Support Requirements  	2-3
       2.7    Range of Suitable Site Characteristics	2-3
       2.8    Limitations of the Technology	2-3
       2.9    ARARS for the ELI/SBP UVB Treatment Process		2-3
              2.9.1   Comprehensive  Environmental Response, Compensation, and
                      Liability Act (CERCLA) 	2-4
              2.9.2   Resource Conservation and Recovery Act (RCRA)	2-4
              2.9.3   Clean Air Act (CAA)	2-7
              2.9.4   Clean Water Act (CWA)  	2-7
              2.9.5   Safe Drinking Water Act (SDWA)	2-7
              2.9.6   Occupational  Safety   and   Health   Administration   (OSHA)
                      Requirements	 2-8

3.0    Economics	 3-1
       3.1     Introduction	 3-1
       3.2    Conclusions  	•.	 3-1
       3.3    Issues and Assumptions 	 3-4
       3.4    Basis for Economic Analysis  	3-5

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                                Contents  (Cont'd)
              3.4.1    Site and Facility Preparation Costs	  3-5
              3.4.2   Permitting and Regulatory Costs	  3-7
              3.4.3   Equipment Costs	  3-7
              3.4.4   Startup and Fixed Costs	  3-8
              3.4.5   Labor Costs	  3-8
              3.4.6   Supplies and Consumables Costs 	  3-8
              3.4.7   Utilities Costs	3-8
              3.4.8   Effluent Treatment and Disposal Costs	  3-8
              3.4.9   Residuals and Waste Shipping, Handling and Transport Costs	3-8
              3.4.10  Analytical Costs	'.	  3-9
              3.4.11  Facility Modification, Repair and Replacement Costs	  3-9
              3.4.12  Site Restoration Costs	  3-9

4.0    Treatment Effectiveness During the Site Demonstration  	4-1
       4.1    Background	4-1
       4.2    Detailed Process Description	4-2
       4.3    Methodology	4-2
       4.4    Performance Data	4-6
              4.4.1   VOC Concentrations in Soil Initially and at Completion   	4-6
              4.4.2   Change in Mass of VOCs in Soil with Time	4-7
              4.4.3   VOCs in Air Samples	4-15
              4.4.4   Mass Removal of VOCs - Biodegradation Contribution  	4-15
              4.4.5   Other Supporting Evidence for Biodegradation	4-18
              4.4.6   UVB Well Characteristics/In Situ Biofilter Behavior	4-19
              4.4.7   Groundwater	4-19
              4.4.8   Distinctions between Vadose and Saturated Zones	4-20
              4.4.9   Process Residuals	4-20

5.0    Other Technology Requirements	 5-1
       5.1     Environmental  Regulation Requirements	 5-1
       5.2     Personnel Issues	 5-1
       5.3     Community Acceptance	 5-2
                                                                     ]
6.0    Technology Status	 6-1
       6.1     Previous Experience  	 6-1
       6.2     Scaling Capabilities 	 6-1
                                                                     ii
                                                                     i
Bibliography	 7'1

Appendix-Vendors' Comments	A'1
                                           VI

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                                      Tables
Table

ES-1   Evaluation Criteria for the ELI/SBP UVB Treatment System  	ES-4
2-1     Federal and State Applicable and Relevant and Appropriate Requirements
              (ARARs) for the ELI/SBP UVB Treatment Process	2-5
3-1     Estimated Costs for Pilot-Scale Treatment Using the
              ELI/SBP Treatment System	,,	 3-2
3-2     Estimated Costs in $/m3 for Treatment Using the ELI/SBP
              Treatment System  to Remediate 10,092 m3 (Full-Scale)	 3-4
4-1     NYSDEC Soil Cleanup Criteria for Demonstration	4-1
4-2     ELI/SBP Achievement of New York State Cleanup Criteria 	4-6
4-3     Masses of Contaminants (gm)  in Plot at Various Times	4-7
4-4     Mass of VOCs Removed in Air Stream by ELI/SBP Technology 	4-16
4-5     Removal of Critical VOCs from Air Stream by Ex Situ Biofilters	4-16
4-6     Removals after 14 Months  Using PQL for ND	4-17
4-7     Average Microbial Counts in ELI/SBP Demonstration
              Soil and Groundwatec	4-19
4-8     Percent Removals Based in the In Situ Biofilter on VOC Concentrations	4-20
4-9     Vadose/Saturated Zones Approximate % Removals  	4-21
                                         VII

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                                     Figures
Figure

1-1     Northern area of site	 1-2
3-1     Cost distribution	 3-6
4-1     UVB System schematic	4-3
4-2     ELI/SBP treatment plot showing soil boring locations	4-5
4-3     Acetone masses at three times	4-8
4-4     MEK masses at three times	4-9
4-5     MIBK masses at three times	4-10
4-6     Cis-DCE masses at three times	4-11
4-7     TCE masses at three times	4-12
4-8     PCE masses at three times	4-13
4-9     Toluene masses at three times	4-14
                                         viii

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                       Abbreviations and Acronyms
AQCR         Air Quality Control Regions
ATTIC         Alternative Treatment Technology Information Center
CAA          Clean Air Act
CERI          Center for Environmental Research Information
CFR          Code of Federal Regulations
cfm           Cubic feet per minute
Cis-DCE       Cis-1,2-dichloroethene
CWA          Clean Water Act
dscfm         dry standard cubic feet per minute
ELI/SBP       Environmental Laboratories, Inc. and SBP Technologies, Inc.
gm/cm3        Gram per cubic centimeter
FS            Feasibility Study
ITER          Innovative Technology Evaluation Report
GAG          Granular Activated Carbon
HSWA        Hazardous and Solid Waste Amendments
LDR          Land Disposal Restriction
MDL          Method Detection Limit
MEK          2-Butanone (methyl ethyl ketone)
MIBK          4-Methyl-2-pentanone (methyl isobutyl ketone)
OSHA         Occupational Safety and Health Administration
ND           Non-Detectable, not detected, less than detection limit
NRMRL       National Risk Management Research Laboratory (EPA)
NYSCHWM    New York State Center for Hazardous Waste Management
NYSDEC      New York State Department of Environmental Conservation
ORD          Office of Research and Development (EPA)
OSWER       Office of Solid Waste and Emergency Response (EPA)
PCE          Tetrachloroethene
PID           Photoionization Detector
POTW        Publicly Owned Treatment Works
PPE          Personal Protective Equipment
PQL          Practical Quantitation Limit
PVC          Polyvinyl Chloride
POTW        Publicly Owned Treatment Works
QAPP         Quality Assurance Project Plan
SAIC          Science Applications International Corporation
SARA         Superfund Amendments and Reauthorization Act
SDWA        Safe Drinking Water Amendments
SWDA        Solid Waste Disposal Act
SITE          Superfund Innovative Technology Evaluation
S.U.          Standard Units
                                         IX

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              Abbreviations and Acronyms (continued)
SUNY       State University of New York
TER         Technology Evaluation Report
TCE         Trichloroethene
VOC         Volatile Organic Compound
jug/Kg       Micrograms per kilogram
USEPA      United States Environmental Protection Agency

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                              Acknowledgments
This report was prepared under the direction of Ms. Annette Gatchett and Ms. Michelle Simon, the
EPA Technical Project Managers for this SITE demonstration at the National Risk Management
Research Laboratory (formerly the Risk Reduction Engineering Laboratory) in Cincinnati, Ohio. The
demonstration required the services of numerous personnel from the New York State Department of
Environmental  Conservation (NYSDEC),  the New York State  Center for Hazardous  Waste
Management (NYSCHWM), Environmental Laboratories, Inc., SBP Technologies, Inc., and Science
Applications International  Corporation.  The cooperation and efforts of these organizations and
personnel are gratefully acknowledged.
                                         XI

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                                       Executive Summary
This report summarizes the findings of an evaluation of the
Environmental   Laboratories,   Inc.   (ELI)   and  SBP
Technologies, Inc. (SBP) UVB Treatment System (Vacuum
Vaporization Well).   The  system was tested  for the
remediation  of soil  contaminated with volatile  organic
compounds (VOCs) at the inactive Sweden-3 Chapman
landfill  in  Sweden,  New York.  This evaluation  was
conducted  under the  U.S. Environmental  Protection
Agency  (EPA)   Superfund   Innovative   Technology
Evaluation (SITE) Program and with the participation of the
New   York  State  Department  of  Environmental
Conservation (NYSDEC) and the New York State Center
for  Hazardous Waste Management (NYSCHWM).  Two
other technologies also were evaluated at the same time
and the same site: The ENSR/Larsen Biovault Treatment
Process and the  R. E. Wright Environmental, Inc. In Situ
Bioventing Technology.  The results of those evaluations
are described in separate reports.

Overview of Site Demonstration

According to the developers, the ELI/SBP UVB Treatment
Process  is an  in  situ  bioremediation  technology  that
combines   air   stripping,   extraction,   sparging,   and
bioremediation   to  remove  VOCs  from  soil   and
groundwater.  The  process  was  developed  by  1EG
Technologie GmbH  of Germany and is licensed in the
eastern U.S. by Environmental Laboratories, Inc. (ELI) and
SBP Technologies, Inc.  (SBP).   It is based  on the
circulation of groundwater  through a  centrally-located
"Vacuum Vaporization"  well and the  surrounding soil
formation. In addition to a pump, the well contains an in
situ biofilter where microbial growth can be accelerated by
organic contaminant biodegradation. The microbial growth
is circulated via the groundwater to the saturated zone for
in situ biodegradation of organic contaminants. Air drawn
through the system to assist water circulation and  to
provide oxygen for biological activity also strips volatiles
from the vadose zone. These volatiles may be removed by
an  aboveground  carbon  cartridge   or,  as  in  the
demonstration, by an aboveground vapor-phase biofilter.
The UVB System consists of a submersible pump and an
in-ground biofilter cartridge containing a special  carbon-
based support. The system is installed in a large diameter
well drilled to the bedrock.  Air is pumped through the
biofilter and, together with the submersible pump, causes
groundwater to circulate through  the system  and back
through the formation.

The demonstration was conducted in a 50 x 50 ft plot at the
Sweden-3 Chapman landfill site in Sweden, New York
under EPA's SITE program from the middle of July 1994 to
early December 1994.  Based on preliminary assessment
of the results to that time, the evaluation was continued to
the following  October.   At the outset and during the
demonstration, soil and groundwater were found to be very
non-uniformly contaminated with trichloroethene (TCE),
tetrachloroethene (PCE), cis-1,2-dichloroethene (cis-DCE),
acetone, 2-butanone (MEK), 4-methyl-2-pentanone (MIBK),
toluene,  and  other  aromatic  compounds.     These
characteristics were considerably different from those
anticipated based on available characterization data for the
site.

A primary objective of the demonstration was to determine
the effectiveness of the UVB System in reducing the target
VOC contaminants in the vadose zone soil to  below the
New  York   State  Department  of  Environmental
Conservation (NYSDEC) Soil Cleanup Criteria which are:
acetone: 0.2 mg/Kg, MEK: 0.6 mg/Kg, MIBK:  2 mg/Kg,
DCE: 0.6 mg/Kg, TCE: 1.5 mg/Kg, and PCE: 2.5 mg/Kg.
(The criteria do not differentiate between cis- and trans-
dichloroethene.) Specifically, the developers expected that
90% of the soil samples collected from the plotwould meet
the NYSDEC  Soil Cleanup Criteria for  the six target
contaminants after six months (one season) of treatment.
A second primary objective was to attempt to evaluate the
developers' assertion that biodegradation would be the
dominant mechanism for contaminant removal. Evaluation
of this objective was qualitative  in nature because the
sampling procedures were not designed  specifically for
representative mass balances or to quantify the extent of
biodegradation. Other, circumstantial evidence collected
during the project was used to aid in assessing the role of
biodegradation.  As the result of a  late start for the
demonstration, unforeseen site and operational  problems,
and the unique nature of the process, the investigation was
                                                  ES-1

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extended from  one season  (~6 months) through the
following warm season, a total of about fourteen months.

Conclusions from this SITE Demonstration
Based on this SITE pilot-scale Demonstration, the following
primary conclusion may be drawn about the applicability of
the ELI/SBP UVB Treatment Process:
•      The technology was not able to  reduce VOC
       contamination of the vadose and saturated zone
       soil in the targeted depth interval  to levels that
       satisfy NYSDEC Soil Cleanup Criteria within 6
       months.  The technology did not meet the 90%
       objective after 14 months of essentially continuous
       operation. Compliance with the NYSDEC Cleanup
       Criteria for all six contaminants after 5.5 and 14
       months were 65% and 70%, respectively.
The  discussions  presented  below  are  possible  and
reasonable explanations as to the mechanism responsible
for VOC removal.  It should be noted that at the outset of
the project, due to limited funding, soil samples were not
collected to represent statistically valid average VOC
concentrations for  the site.   These conclusions  are,
therefore,  limited  and qualitative  because  of the soil
sampling procedures.
The soil samples collected do not represent a site average
because the soil core sections were scanned for specific
VOC "hot spots" and sampled in those areas, which may
have  created a known bias when the soil data were
analyzed.   This was  done to  minimize the chance of
collecting "non-detect" VOC samples.  Mass balances for
soil  data   are  therefore  uncertain;  however,  some
circumstantial evidence exists to suggest the following:
•      The UVB Treatment  Technology did achieve
       removals between 54% and 73% for the three
       ketones (acetone, MEK, and MIBK) from the soil
       over 14 months by a combination of stripping and
       other mechanisms. Stripping accounted for only a
       small portion  of the  apparent removal,  and
       biodegradation potentially accounted for all or part
       of the remaining removal.
•       Removal of the chlorinated volatile hydrocarbons
       (cis-DCE, TCE and PCE), appeared to be much
       lower (<40%) over the 14-month demonstration.
       The role of biodegradation could not be estimated.
•      The accumulated results and observations (e.g.,
       mass  removal accounting,  high  cis-1,2-DCE
       concentrations,  changes  in  CO2  and  O2
       concentration  in air  samples, and  changes  in
        microbial populations), did not provide  strong
        evidence  for  biodegradation  as  a  viable
        mechanism,  particularly for  the removal of
        chlorinated VOCs. The detection of vinyl chloride
       in the air stream and in groundwater suggests that
       anaerobic degradation  may also have been
       underway.

•      Although not a critical VOC for this demonstration,
       removal of toluene was effective, with calculated
       removal of 4% by all mechanisms after about 5.5
       months and 87% after 14 months. Since stripping
       appeared to account for only a small portion of the
       toluene removal, biodegradation may account for
       a large portion of this removal.

«      In the absence of controls, it cannot be stated with
       certainty that the  UVB  Treatment  Process
       enhanced the natural VOC removal or accelerated
       bioremediation.

Other observations, which were  not  based upon the
primary data collection procedures, include:

•      The cost associated with applying this  technology
       to the treatment of an assumed vadose zone of
       480 m3  (628 yd3) was $453/m3  ($347/yd3).   If
       treatment is assumed to  occur throughout the
       vadose and saturated zones, a depth of 3.3 m (11
       ft),  then the treatment cost would decrease to
       $247/m3   ($189/yd3)  for  the   14-month
       demonstration.
       The cost associated with applying this  technology
       to the treatment of 10,092  m3 (13,200 yd3) of
       vadose zone contaminated with VOCs as in the
       demonstration   is   approximately  $195/m3
       ($149/yd3) for a 14-month  remediation period.
       Extending the duration  of the remediation to  3
       years or 5 years, as suggested by the developers,
       increases total cost to $339/m3 ($259/yd3) and
       $491/m3   ($375/yd3),   respectively.  Soil
       characteristics and VOC types and concentrations
       may make it necessary to extend the treatment
       period or increase the addition of amendments,
       which would increase the cost accordingly.

•      Measurements of  VOC concentrations in the
       circulating groundwater entering and leaving the in
       situ biofilter indicate that some removal  is taking
       place. It was not determined whether this is due to
       adsorption  on the  carbonaceous  substrate,
       biodegradation,   other  mechanisms,   or  a
       combination of mechanisms.

•      In general terms, the concentrations of the critical
       VOCs in the groundwater samples obtained from
       monitoring wells appear to decrease with both time
       and distance from the central UVB well.
•      The redesigned ex  situ gas  phase  biofilters
       operated successfully for the last eight months of
       the project. While concentrations in the air stream
       were low, some removal (50% to 75%) appears to
                                                  ES-2

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have been achieved for all of the VOCs. Again,
the removal mechanisms  cannot be stated with
certainty.
The ELI/SBP UVB Treatment System was evaluated based
on the  nine  criteria  used for decision-making in the
Superfund Feasibility Study (FS) process.  Table  ES-1
presents this evaluation.
                                           ES-3

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           Table ES-1. Evaluation Criteria for the ELI/SBP UVB Treatment System (page 1 of 2)
              Overall Protection of
              Human Health & the
                 Environment
                          Compliance with Federal
                                  ARARs
                              Long-term Effectiveness
                                 and Permanence
    Reduction of Toxicity,
 Mobility, or Volume Through
        Treatment
 Short-term Effectiveness
m
CO
Provides long-term
protection by eliminating
organic contaminants
from soil and
groundwater.

Minimizes further
groundwater
contamination and off-
site migration.

May require measures
to protect workers and
community during drilling
and treatment.
May require compliance
with RCRA treatment,
storage, and land disposal
regulations (of a hazardous
waste).

Construction, well drilling
and operation of on-site
treatment unit may require
compliance with location-
specific ARARs.

Emission controls may be
needed to ensure
compliance with air quality
standards for volatile
compounds.

Wastewater discharge to
POTW or surface bodies
requires compliance with
Clean Water Act
regulations.
                                                                Potentially removes
                                                                contamination source
                                                                effectively.

                                                                Treats contaminated
                                                                vadose and saturated soil
                                                                and groundwater.

                                                                Involves some residuals
                                                                treatment and disposal,
                                                                e.g., extracted air, well
                                                                cuttings, well development
                                                                water.
Potentially reduces toxicity
and mobility of soil
contaminants through
destructive treatment.

Does not produce any known
toxic intermediates  as a
result of biodegradation
when properly conducted;
vinyl chloride production
must be
controlled/minimized.

May initially distribute
contaminants throughout
zone of influence.
May present short-term
risks to workers and
community, including
noise exposure and
exposure to airborne
contaminants (e.g., dust,
volatile organic
compounds, etc.)
released into the air
during drilling and
operation. These can be
minimized with correct
handling procedures.

Potentially provides
reduction in
contamination levels;
duration of treatment
determines final
contaminant levels.

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                  Table ES-1. Evaluation Criteria for the ELI/SBP UVB Treatment System (page 2 of 2)
                           Implementability
                                                   Cost
                                         Community Acceptance
                                      State Acceptance
m
Y»
01
Major equipment is limited to blower
system, control panel, and in situ and
ex situ biofilters.

Support equipment includes drill rigs
for wells and monitoring equipment
(e.g., for airflow, pH, and
temperature).

UVB wells can be constructed in <2
weeks. Requires heavy equipment,
e.g., crane, to install and position
system.

Once on-site, the blower and control
system can be assembled and ready
within 3 days after the central well and
casing are installed.

After treatment is complete, the
system can be demobilized in three
days.  The biofilter and piping can be
cleaned and reused or discarded.
Granular carbon can be returned to
suppliers for regeneration.	
Demonstration cost was $453/m3
($347/yd3) for treatment of 50 x 50 ft
of vadose zone to a depth of about 6
ft, remediating a total of 480 m3 (628
yd3) of soil.

Actual cost is site-specific and
dependent upon the volume of soil,
soil characteristics, contaminants
present, and original and target
cleanup levels. Cost data in this table
are for treating VOC-contaminated soil
similar to the SITE demonstration soil.

Remediation of 10,092 m3 (13,200
yd3) of a site similar to that of the
demonstration, using 22 wells and
treatment duration of 14 months, 3
years, and 5 years, was estimated to
cost $195/m3 ($149/yd3), $339/m3
($259/yd3), and $491/m3 ($375/yd3),
respectively.
Minimal short-term risks
presented to the community make
this technology favorable to the
public.

Public knowledge of common
bioremediation application (e.g.,
wastewater treatment) eases
community acceptance for
hazardous waste treatment using
this technology.

Use of naturally-occurring
microorganisms makes treatment
by this technology a favorable
option to the community.

Noise from blower operation may
impact community in the
immediate vicinity, but is readily
minimized.
                                                                                                                            If remediation is conducted
                                                                                                                            as part of a RCRA
                                                                                                                            corrective action, state
                                                                                                                            regulatory agencies may
                                                                                                                            require permits to be
                                                                                                                            obtained before
                                                                                                                           . implementing the system.
                                                                                                                            These may include a permit
                                                                                                                            to operate the treatment
                                                                                                                            system, an air emissions
                                                                                                                            permit (if volatile
                                                                                                                            compounds are present), a
                                                                                                                            permit to store
                                                                                                                            contaminated soil for more
                                                                                                                            than 90 days, and a
                                                                                                                            wastewater discharge
                                                                                                                            permit.

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                                             Section 1.0
                                             Introduction
This section provides background information about the
Superfund  Innovative  Technology  Evaluation  (SITE)
Program,  discusses  the  purpose  of this  Innovative
Technology Evaluation Report (ITER), and describes the
I EG Technologic GmbH "Unterdruck-Verdampfer-Brunnen
(UVB)" Technology (Vacuum Vaporization) licensed to the
team of Environmental  Laboratories, Inc.  and  SBP
Technologies,  Inc.  For additional information about the
SITE Program, this technology, and the demonstration site,
key contacts are listed at the end of this section.

1.1     Background
Preliminary discussions  between the  New York State
Department of Environmental Conservation (NYSDEC) and
the U.S. Environmental Protection Agency (EPA) in  1992
led to an agreement to evaluate  several bioremediation
technologies at one site.  The New York State Center for
Hazardous Waste Management (NYSCHWM), under the
leadership of  the  former  Director,  Dr. Ralph  Rumer,
brought together a panel of interested experts in 1993 to
develop  a  suitable  protocol  for  such  a  group  of
demonstrations and to identify  potentially suitable sites.
The original plan was for the NYSDEC to issue a Request
for Proposal for four different types of technologies: ex situ
bioremediation  alone; ex  situ  coupled with additional
technology (e.g., physical/chemical); in situ bioremediation
alone; and in situ  bioremediation  coupled with additional
technology.  It was agreed that NYSDEC would provide
funding to the selected developers for site preparation and
installation and operation of their systems while EPA would
provide  the  funds to develop  an independent Quality
Assurance Project  Plan (QAPP) and  to carry out an
independent  evaluation  of  the results  from  each
developer's demonstration.

The Sweden-3 Chapman Site,  located  in Sweden,  New
York, near Rochester, was selected for the demonstration
after considering others. It is an inactive  2-acre landfill that
was used to dispose of construction and demolition debris
and hazardous wastes between 1970 and 1978.  Studies
conducted in  1992, after 2,300 buried  drums  were
removed, identified three areas of heavily contaminated
soil. The focus of the demonstration was on the largest of
these, referred to as the "northwestern source area"
(Figure 1-1) which had  been  found in earlier soil and
groundwater  examinations  to  be  contaminated  with
trichloroethene (TCE), tetrachloroethene (PCE), acetone,
2-butanone (MEK), 4-methyl-2-pentanone (MIBK), toluene,
xylenes and various other substituted hydrocarbons.

The ELI/SBP UVB Treatment Process  was one of three
technologies   selected  through   New  York  State's
competitive bidding process.  The others were an ex situ
biovault technology developed  by ENSR Consulting and
Engineering and Larsen  Engineers  and  an  in situ
bioventing  technology  offered   by  R.E.   Wright
Environmental, Inc.

Although originally expected to provide oversight services
only, it was quickly apparent that  EPA's evaluation
contractor, Science Applications International Corporation
(SAIC), would  need to play a larger role to assure the
validity and uniformity of the data that would be generated
by the three simultaneous pilot-scale demonstrations. To
limit costs, SAIC was supported  in the expanded sampling
and analysis effort by faculty and graduate students of the
State University of New York (SUNY) at Buffalo who were
funded by the NYSCHWM. The added personnel provided
much needed manpower and they gained valuable actual
experience in field activities under the guidance  of vendor
and contractor personnel.

Because of time and financial constraints, it was necessary
to rely on existing site characterization data, some of which
were several years old, in  selecting the areas to be used by
each of the three developers and in planning the objectives
and process design for the technologies.  Combined with
the large tracts that  were necessary to evaluate three
distinct technologies,  this proved to  be unfortunate when
soil geology and chemical contamination observed during
the demonstration (for any of the developers) proved to be
significantly different from the historical  data, primarily in
the  relative concentrations  of the VOCs and their
distribution over the tract  - both laterally and vertically.
                                                   1-1

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                                                        NORTH EAST P?X
                                                         SOURCE  ft
                                                          AREAS//
                                 APPROXIMATE
                              LANDFILL BOUNDARY
             APPROXIMATE LOCATION OF
             CONTAMINANT SOURCE AREAS
        MW-5D
         SMW-SI
                                                                       ALL CONCENTRATIONS IN ppD
                                                                       TOT
                                                                        TAL VOLATILE ORGANIC
                                                                       CONCENTRATIONS DO NOT INCLUDE
                                                                       CONCENTRATIONS DETECTED IN
                                                                       METHOD BLANKS.
                                                             	1CO—   LINE OF EQUAL CONCENTRATION

                                                             	100±—   ESTIMATED LINE OF EQUAL CONC.
                DUNN GEOSCIENCE ENGINEERING Co.
                12  Metro  Park Road
                Albany,  NY 12205
NYS DEPT.  OF ENVIRONMENTAL CONSERVATION
    WORK ASSIGNMENT No. D-2520-1 +
   SOURCE AREAS  AND  INTERFACE
   ZONE GROUNDWATER PLUMES
     SWEDEN-3  CHAPMAN  SITE
    PROJECT NO.  40296-150
                             DATE   June. 1893    DWG. NO. 4A0022MR   SCALE  T-tSO'
                                                                               FIGURE NO. 2.1
Figure 1 -1. Northern area of site.
                                                  1-2

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The ELI/SBP UVB SITE Demonstration was conducted to
evaluate the developers' treatment process for vadose
zone soil contaminated with volatile organic compounds
(VOCs). A single UVB Well System was utilized for this
demonstration.  The system (shown later in Figure 4-1)
consists of a submersible pump and an in-ground biofilter
cartridge containing a special carbon-based support, which
are installed in a wide bore well drilled to the bedrock. Air
is  pumped  to  the  biofilter  and, together with the
submersible pump,  causes  groundwater  to  circulate
through the system and  back into the  formation  thus
contributing to stripping volatiles from the water.
One  primary objective of the  Demonstration  was  to
determine the effectiveness of the technology in reducing
VOC contamination in the vadose zone sufficiently to meet
NY State  Department of  Environmental Conservation
(NYSDEC) Cleanup Criteria.  As a remediation goal  to
evaluate this objective, the developers expected that 90%
of the soil  samples collected from the anticipated vadose
zone in the plot after 6 months of operation would be below
NYSDEC Cleanup Criteria for six target VOCs (acetone,
MEK, MIBK, TCE, PCE and DCE), as shown later in Table
4-1.   In addition, as  a second  primary objective, the
developers asserted  that biodegradation would be the
dominant  mechanism of contaminant removal from the
formation.   As  a secondary objective, ELI/SBP  also
expected  that  groundwater would  exhibit significant
reductions in VOC concentrations as a result of circulation
through the in situ biofilter. Finally, as an adjunct to the
project,  the developers also sought to evaluate the
effectiveness of ex situ biofilters in removing VOCs  from
the air extracted from the formation.

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

The SITE  Program's primary purpose is to maximize the
use of alternatives in cleaning hazardous waste sites by
encouraging the development and demonstration of  new,
innovative treatment and monitoring technologies.  It
consists of three major elements:
•      the Demonstration Program,
•      the  Consortium   for   Site   Characterization
       Technologies, and

•      the Technology Transfer Program.
The objective of the Demonstration Program is to develop
reliable  performance  and  cost  data on  innovative
technologies so  that  potential  users  can assess  the
technology's site-specific applicability.    Technologies
evaluated  are either available commercially  or close to
being available for full-scale remediation  of Superfund
sites.  SITE demonstrations usually are  conducted at
hazardous  waste sites  under  conditions that closely
simulate full-scale remediation conditions, thus assuring
the usefulness and reliability of the information collected.
Data collected are used to assess: (1) the performance of
the technology; (2) the potential  need for pre- and post-
treatment of wastes; (3) potential  operating problems; and
(4) the  approximate costs.   The  demonstration also
provides opportunities to evaluate the long term risks and
limitations of a technology.

Existing and new technologies and test procedures that
improve field monitoring and site characterizations  are
explored  in the  Consortium for Site  Characterization
Technologies  (CSCT)  Program.    New  monitoring
technologies, or  analytical methods that provide faster,
more cost-effective contamination and  site assessment
data are supported by this program.  The CSCT Program
also  formulates  the protocols and standard operating
procedures for demonstration methods and equipment.

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

1.3    The SITE Demonstration  Program and
       Reports
Technologies are selected for the SITE Demonstration
Program  through annual  requests  for proposals. This
solicitation  ended in  1995.   ORD staff reviews  the
proposals to determine which technologies show the most
promise for use at Superfund sites. Technologies chosen
must be at the pilot- or full-scale stage, must be innovative,
and must have some technological and/or cost advantage
over existing technologies.  Mobile technologies are of
particular interest.
Once the  EPA has accepted a proposal, cooperative
agreements between the EPA and the developer establish
responsibilities for conducting  the demonstration  and
evaluating the technology. The developer is responsible
for demonstrating the technology at the selected site and
is expected to pay any costs for transport, operation, and
removal of the equipment.  The EPA is responsible for
                                                   1-3

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project planning, sampling and analysis, quality assurance
and  quality control,  preparing  reports,  disseminating
Information, and transporting and  disposing of treated
waste materials.
The results of Demonstration Programs are published in
three documents: the SITE  Demonstration  Bulletin,  the
Technology Capsule, and the Innovative  Technology
Evaluation   Report   (ITER).    The  Bulletin   provides
preliminary results of the field demonstration and  the
Technology Capsule provides relevant information on the
technology, emphasizing key features of the results of the
SITE field  demonstration.  The ITER provides detailed
information on the technology investigated and the results
of the SITE field demonstration.  An additional report, the
Technology Evaluation Report (TER), which is not formally
published,  contains the raw data  collected during  the
demonstration and provides a quality assurance review of
Ihe data. Both the SITE Technology Capsule and the ITER
are intended for use by remedial  managers  making a
detailed evaluation of the technology for a specific site and
waste.

1.4     Purpose of the Innovative Technology
        Evaluation Report (ITER)
This ITER provides information on  the  ELI/SBP UVB
Treatment  Process  for treatment of VOCs in soils and
includes a comprehensive description of this demonstration
and  its  results.  The ITER is intended for  use by EPA
remedial project managers, EPA on-scene coordinators,
contractors,  and other  decision-makers  carrying  out
specific remedial actions. The ITER is designed to aid
decision-makers in  evaluating specific technologies for
further consideration as applicable options in a particular
cleanup operation. This report represents a critical step in
the development and commercialization of a treatment
technology.
To  encourage the  general  use  of  demonstrated
technologies, the EPA provides information regarding the
applicability of each technology to specific  sites  and
wastes.  The  ITER includes  information on cost  and
desirable site-specific characteristics. It also discusses
advantages,   disadvantages,  and   limitations   of  the
technology.
Each SITE demonstration evaluates the performance of a
technology in  treating a specific  waste  matrix.  The
characteristics of other wastes and other sites may differ
from the characteristics of the treated waste. Therefore, a
successful field demonstration of a technology at one site
does not necessarily ensure that it will be  applicable at
other sites. Data from the field demonstration may require
extrapolation for estimating the operating ranges in which
the  technology will perform satisfactorily.  Only limited
conclusions   can  be   drawn  from   a  single  field
demonstration.

1.5    Technology Description

The UVB Treatment Process combines in situ air stripping
with  bioremediation to  remove VOCs  from soils.  The
system used by the developers (see Figure 4-1) at the site
consisted of an aboveground blower  connected  to  a
specially adapted groundwater well. The upper portion of
the well  contained a negative-pressure in  situ stripping
reactor and an integrated bioreactor (fixed film activated
carbon bioreactor with slow-release inorganic nutrients),
both  located  above the expected seasonal high water
table.  The  lower  portion  of the well, below a  packer,
contained buoyancy chambers and a submersible pump to
allow for fluctuations in the water table and to insure  a
constant supply of groundwater to the bioreactor.

In operation, the aboveground blower induces a suction in
the stripper, drawing in ambient  air through a centrally
located pipe as well as from the surrounding vadose zone
soil formation, while raising the  level  of water  already
present in the bioreactor. The ambient air infiltrating the
surrounding soil  formation contains any VOCs that may
have volatilized.    It  also  increases  the   oxygen
concentration of the groundwater/soil matrix and stimulates
indigenous microbes to enhance the biodegradation of
contaminants. The ambient air bubbles through the raised
groundwater, stripping VOCs in the  process. The VOC
laden air is then exhausted by the aboveground blower
through a combination of vapor-phase bioreactors and an
activated carbon filter on the positive pressure side of the
blower.
After treatment  in the stripper  reactor,  the elevated
groundwater is discharged back into the upper soil stratum
and  percolates through the vadose zone  back to the
natural  level of the groundwater, again picking  up any
contaminants that are adsorbed onto the soil matrix. This
sets  up  a  groundwater circulation loop that eventually
returns the re-contaminated groundwater to the bottom of
the  UVB treatment system  for  another  pass.  This
circulation   cell   constantly  transports  contaminants,
nutrients, oxygen  and  indigenous bacteria through the
affected soil profile.  The relative  contributions of the
physical "stripping" effect  and  the biological effect vary
according to site specific conditions.
Dewatering is  not considered  essential  for  efficient
operation of this system. Treatment of the phreatic and
capillary fringe zones occur simultaneously. The system
can  be  operated  in either  a  standard flow  mode, as
described above,  or in a  reverse-flow  circulation  mode
through the addition of a support pump.  Flow modes can
be  readily  converted  in  the field, according  to the
developers.
                                                    1-4

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The in situ bioreactor utilizes indigenous microflora on a
fixed-film which can be augmented with other types of
contaminant-degrading  microbes,  depending  on  site
conditions.  The biodegradation of contaminants can be
further stimulated  by the  addition of either liquid or
gaseous-phase inorganic  nutrients  and/or  alternative
electron acceptors. Injection of heated air increases the
biodegradation rate as well as the rate of VOC desorption
and movement and can enhance the biodegradation of
organic contaminants in regions normally subject to cold
winter climates.

1.6   Key Contacts
Additional information on the  ELI/SBP UVB Treatment
System and the SITE Program can  be obtained from the
following sources:

Technology Developers

James G. Mueller, Ph.D.
Dames & Moore
One Continental Towers
1701 Golf Road, Suite 1000
Rolling Meadows, IL 60008
(847)  228-0707 Ex 131
Fax:(847)228-1328

Richard Desrosiers
Mactec, Inc.
1819 Denver West Drive, Suite 400
Golden, CO 80401
(303)278-3100
Fax: (303) 278-5000


The SITE Program
U.S. EPA SITE Project Manager
Ms. Michelle Simon
U.S. EPA NRMRL
26 W. Martin Luther King, Jr. Dr.
Cincinnati, OH 45268
(513)569-7469
Fax (513) 569-7676
Email: simon.michelle@epamail.epa.gov
Mr. Robert A. Olexsey, Director
Land Remediation and Pollution Control Division
U.S. Environmental Protection Agency
26 W. Martin Luther King, Jr. Drive
Cincinnati, Ohio 45268
(513)569-7861

Information on the role of the New York State in this project
may be obtained from the following sources:

NYSDEC Program Manager
Mr. James Harrington, P.E.
New York State Dept. of Environmental Conservation
50 Wolf Road
Albany, New York 12233
(518)485-8792
Fax:(518)457-7743

NYSCHWM Program Director
Prof. Scott Weber
Jarvis Hall
SUNY at Buffalo
Buffalo, New York 14260
(716)645-2114
Fax:(716)-645-3667

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

•      The  SITE  Home page  (www.epa.gov/ord/site)
       provides  general  program information, current
       project status, technology documents, and access
       to other remediation home pages.

       The  OSWER CLU-ln  electronic bulletin  board
       (http://www.clu-in.com) contains information on the
       status of SITE technology demonstrations. The
       system operator  can be  reached at (301) 585-
       8368.

Technical  reports  may   be obtained  by writing  to
USEPA/NSCEP, P.O. Box 42419, Cincinnati, OH 45242-
2419, or by calling 800-490-9198.
                                                  1-5

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                                             Section 2.0
                              Technology Applications Analysis
This  section  of  the  report  addresses  the  general
applicability   of  the  ELI/SBP  UV8  Technology  to
contaminated waste sites. The analysis is based primarily
on  the  results of this  pilot-scale SITE  demonstration;
information on other similar applications of the technology
was not available.   SITE  demonstration  results  are
presented in Section 4 of this report. The vendors' had the
opportunity to discuss the applicability and performance of
the technology (and alternate interpretations of the data) in
Appendix A.

2.1     Key Features  of the UVB Treatment
        System

The ELI/SBP UVB  Treatment System is designed to
remove volatile organic compounds (VOCs) and, to some
extent, semi-volatile organics (SVOCs) from the saturated
zone and from groundwater by a combination of stripping,
sparging,  extraction, and biodegradation.   Biological
degradation   by  naturally-occurring   microorganisms
reportedly takes place on the in situ biofilter (carbonaceous
matrix)  and  also throughout the saturated  zone when
microorganisms from the biofilter are dispersed throughout
the zone of influence  (up to -40 ft radius) with  the
circulating groundwater. Biological activity is enhanced by
introducing nutrients as needed and supplying oxygen via
the air management system. The developers believe that
the technology is capable of effectively removing both
halogenated and nonhalogenated VOCs by the combined
mechanisms.
The developers also claim that the technology can remove
VOCs from the vadose zone and the capillary fringe by
stripping and/or extraction into the groundwater, where
biodegradation may  also  occur.  This aspect was of
primary interest for this demonstration.

2.2    Operability of the Technology
The effectiveness of the ELI/SBP UVB Treatment System
is  dependent  on the  stimulated  growth of naturally-
occurring microorganisms on  the  in  situ  biofilter and
subsequent transfer of these VOC-degrading bacteria to
the water table in the zone of influence by the circulating
groundwater. Microbial activity may be influenced by soil
and groundwater pH and temperature, oxygen availability,
water table depth,  and available nutrients,  all of which,
except for water table depth and temperature, can be
controlled by the air and water management systems.

The air transfer system consists  of  an aboveground
vacuum blower by which ambient air is  drawn  into the
groundwater as it  leaves the in situ  biofilter.  For the
demonstration, air  flow was initially maintained at ~50
dscfm on the basis  of available soil characterization data,
but was later increased to about 180 dscfm. In addition,
some air also may be drawn into the formation from the
surface. The combined air intake increases the dissolved
oxygen  concentration  before  the   groundwater  is
recirculated to the formation. After leaving the blower, the
extracted air passes through a water separator.  For the
demonstration, two ex situ  gas phase  biofilters were
installed in parallel on the exhaust line.  During the first ten
months of the  demonstration, these biofilters created a
back pressure and little air appeared to pass through them.
The design was modified during the winter  of 1994 to a
spiral wound biofilter which was successful in allowing
approximately  equal  flows of air through each of two
parallel legs. At the same time, the water separator was
also modified to provide spray humidification for the air
entering the biofilters. Finally, for additional security, each
leg of the exhaust line after the biofilter was also equipped
with an adsorbent carbon drum to assure that no VOCs
escaped to the atmosphere.

Water circulation was accomplished by  a  submersible
pump located at the base of the central UVB  well (16 inch
diameter),  which forced water  up  through the in situ
biofilter. Because of unexpected large fluctuations in the
height of the water table, an expandable packer was added
between the pump and the in situ biofilter to assure that the
water entering the biofilter was  groundwater drawn in
through  the lower screen  of the  well  casing.   This
modification also simplified the effort involved in manually
raising or  lowering  the  in  situ treatment system  to
                                                   2-1

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accommodate the water table, which fluctuated as much as
4 ft. If necessary, nutrients and pH-adjusting chemicals
could be injected into the water in the DVB well through a
narrow tube.
For the demonstration, the drain on the water separator
was equipped with a sampling tap and with a totalizer water
meter so that the volume of water lost from the system
could be documented. The discharged water was stored
on-site in a 500-gal storage tank.
Typical  soil and  contaminant characteristics must  be
established at the outset  of  the  project, including soil
porosity and  permeability for air and  water,  moisture
content, nutrient availability, pH, metals content, etc. The
depth of the water table is particularly important because it
determines the relative importance of the saturated and
vadose zones in treatment, the estimated zone of influence
for  groundwater  circulation,  and,  presumably,  the
mechanisms  that  predominate.   The water table also
determines the positioning of the in situ system, which has
a limited adjustment range, as noted.
Once the air flow and groundwater circulation rates had
been established (and airflow through the ex situ biofilters
had been  adjusted), the system  operated relatively
automatically and unattended  for the major portion of the
demonstration.    Local  weather-related power failures
occasionally did result in system shutdowns until the next
weekly visit.   The major  operational difficulty  was the
unexpected fluctuations in the water table, which resulted
fn the need to reposition the in situ system more frequently
than anticipated during the course of the demonstration.

During the demonstration, the in situ system was operated
fn the upward mode, i.e., with water drawn  in to the UVB
well at the  base and discharged to the soil via the upper
screen which is intended to be at the water table,  but the
developers advise that operation can be reversed if desired
based on geological conditions. In addition, the developers
suggest that heated air could  be introduced to overcome
cold weather; this was not evaluated.

2.3    Applicable Wastes
According to the developers, the UVB Treatment System
Is  primarily applicable  to the  saturated  zone  and  to
groundwater contaminated with VOCs and semivolatile
organic compounds, including fuels, solvents, etc.  The
developers also claim that contaminated vadose zone and
the capillary fringe can be remediated by a combination of
soil vapor extraction, stripping, and flushing/extraction into
the groundwater. Contaminant volatility and water solubility
may affect the mechanism of contaminant removal from
each zone.
2.4    Availability  and  Transportability  of
       Equipment

The ELI/SBP Treatment System requires the use of a drill
rig with large auger flights to install the UVB well, which
was  16 inches in diameter for the demonstration.  The
same drill rig or a crane is also needed  to install and
position the in situ system, consisting of the air sparger, the
in situ biofilter, the expandable packer, and the submersible
pump. In addition, smaller wells may need  to be installed
for groundwater monitoring purposes.
The  aboveground system, consisting of the air blower,
water separator, ex situ biofilters, and carbon adsorption
drums, requires a level pad area, ideally concrete, of about
50 ft x 50 ft.  (It is assumed that a trailer also  would be
placed near the system for an extended site remediation.)
All pipe connections were made from locally-available 2
inch  PVC piping.

All equipment was transported to the demonstration site by
truck for which access must be available. For remediation
of a larger  site, multiple systems would probably be
necessary and could require multiple vehicles.
Demobilization required the removal and decontamination
of the in situ system before it could be returned  to the ELI
facility.  This was accomplished for the demonstration
using steam and water on an available decontamination
pad.  The biofilter support material (carbonaceous) was
removed by ELI/SBP at the conclusion of field activities. All
PVC piping  was disposed  of as non-hazardous.  The
adsorbent carbon drums were returned to the vendor and
regenerated after testing confirmed the carbon was not
hazardous.
According to NYSDEC requirements, monitoring well
casings  were  removed and the wells  filled with  a
bentonite/cement mixture. Attempts to remove the casing
from the 16-inch diameter UVB well were not successful,
even using a large crane, and only a portion of the casing
could be removed.    The  aboveground portion was
decontaminated with water, cut into sections and left on
site for disposal during site remediation.

Water from  the water separator was treated  by the
NYSDEC with an available adsorbent carbon system and
discharged on-site after testing for residual contaminants.

2.5    Materials Handling Requirements

The major materials handling requirement for the UVB
technology was construction  of the large  diameter UVB
well. Well cuttings from this well and from the twelve
monitoring wells that were installed were placed in 55
gallon drums, labeled,  and stored on-site for disposal
during site remediation in accordance with instructions from
the NYSDEC. Purge water removed from the monitoring
                                                    2-2

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wells before sampling was also stored in labelled 55 gallon
drums in accordance with NYSDEC instructions.

Depending on the contaminants present, the excavation of
the soil from the UVB well may require special precautions
to protect the site  and/or operating personnel.  For the
demonstration, the removed soil was placed on a plastic
sheet until it could be containerized.   A PID was  used
frequently  to  monitor  the  concentration of  volatile
hydrocarbons in the vicinity of the drill rig during operation.
Under warm, dry conditions, local  air  concentrations  of
VOCs or dust may require additional precautions, such as
spraying with water.

As noted in the previous section, the only two waste
streams generated during operation are the extracted air
stream and any water removed from the water separator.
Both of these streams were treated with activated carbon.


2.6     Site Support Requirements

Locations suitable  for on-site treatment  using the UVB
Treatment System  must be able  to provide relatively
uninterrupted electrical power for operation of the blower
and the submersible pump. The UVB system used in the
demonstration   employed  3-phase 460  Volts,  which
required  installation  of  a three-phase converter  by  a
contractor. It does not appear that sufficient power could
be readily provided by diesel generators.  In addition, a
limited amount of distilled water was needed to maintain
the moisture level in the ex situ and in situ biofilters until the
circulation pattern was created.

2.7     Range of Suitable Site Characteristics

In addition to having roads adequate for heavy equipment
(trucks,  drill rigs and crane), the site should be free  of
overhead lines and underground pipes or tanks that could
interfere with drill rig or crane operation.

The saturated zone should consist of permeable soil that
will enable a reasonable circulation of air  and water. For
the demonstration, the soil character was such that the
radius of influence achieved probably was somewhat less
than the  anticipated 40 ft. Ideally,  the water table above
the bedrock should be thick enough to allow the in situ
system to float in the well (this was not  possible at the
Sweden-3 Chapman site). In addition, large fluctuations of
the water table require more frequent repositioning of the
in situ system and may even exceed the adjustment range
of the system, which was about 4 ft for the demonstration.

For successful treatment, the  vadose  zone must  have
sufficient thickness  and contain minimal fracturing and
man-made conduits such as underground utilities so that
"short circuiting" by air from the surface is minimized. Air
permeability should be in the range customarily used for
soil vapor extraction, i.e., greater than 10~7.
Although the in situ system should be minimally impacted
by changes in ambient weather since groundwater usually
remains at a relatively constant temperature, the intake of
ambient air can affect the groundwater temperature and
the operating  temperature  of the  in  situ biofilter.  In
addition,  if the  site (vadose and saturated) is shallow,
ambient temperatures may  have an impact on soil and
groundwater temperature, which can affect the rates of
both  biodegradation and soil vapor  extraction.   The
developers claim that cold temperatures can be overcome
by injecting heated air if necessary.

As with most biological processes, the  pH of the soil and
groundwater should be in the range of 7 to 9 standard units
and  the   concentrations of  heavy metals  and  other
potentially toxic constituents  should not  be  excessive;
these levels would need to  be established by laboratory
testing and/or acclimation of the microbial population.

2.8    Limitations of the Technology
The technology is intended primarily for groundwater and
the saturated zone; any treatment of the vadose zone is
almost incidental and  probably occurs  by  soil  vapor
extraction. A very  high (i.e., near the ground surface)
water table can adversely affect treatment efficiency by
allowing contaminated air to escape rather than enter the
UVB well  system.  A narrow saturated zone interval will
make it difficult to maintain the in situ UVB system since
little buoyancy would be provided by the column of water.
In addition, excessive fluctuation in the water table also can
make frequent repositioning of the in  situ UVB system
necessary or even exceed the range of the unit.
For the technology to be effective, the saturated zone must
have the porosity for a reasonable radius of circulation to
develop for the aerated and bacteria-laden water.  While
some groundwater flow  probably helps to establish the
circulation cell, excessive flow could remove contaminants
from the radius of influence before degradation can occur.

As  with  all   biodegradation  treatments,  excessive
concentrations of certain heavy metals or even  of the
VOCs being treated could result in toxicity to the biological
system in the soil formation or on the in  situ biofilter. Very
low ambient temperatures may also slow biodegradation,
particularly if the water table is relatively shallow; the
developers claim that heated  air  can  be injected to
overcome this potential problem.

2.9    ARARS for the ELI/SBP UVB Treatment
       Process
This subsection discusses specific federal environmental
regulations pertinent to the operation of the ELI/SBP UVB
Treatment Process including the transport,  treatment,
storage, and disposal of wastes and treatment residuals.
                                                   2-3

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These  regulations  are  reviewed with  respect  to  the
demonstration  results%   State   and   local   regulatory
requirements, which may be more stringent, must also be
addressed by remedial managers. Applicable or relevant
and  appropriate requirements  (ARARs)  include  the
following:  (1)  the  Comprehensive   Environmental
Response,  Compensation, and Liability Act;  (2)  the
Resource Conservation and Recovery Act; (3) the Clean
Air Act; (4) the Clean Water Act; (5) the Safe Drinking
Water Act, and (6)  the Occupational Safety and Health
Administration regulations; These six general ARARs are
discussed below; specific ARARs that may be applicable
to the UVB Treatment Process are identified in Table 2-1.

2.9.1   Comprehensive    Environmental
        Response,    Compensation,   and
        Liability Act (CERCLA)
The  CERCLA of 1980 as amended  by the  Superfund
Amendments and  Reauthorization Act (SARA) of 1986
provides for federal funding to respond to releases or
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.
As part of the requirements of CERCLA, the EPA  has
prepared the National Oil and Hazardous Substances
Pollution Contingency  Plan    (NCP)  for  hazardous
substance response. The NCP is codified in Title 40 Code
of Federal Regulations (CFR) Part 300, and delineates the
methods and criteria used to determine the appropriate
extent  of removal  and  cleanup for hazardous waste
contamination.
SARA states a strong statutory preference for remedies
that are highly reliable and provide long-term protection. It
directs EPA to do the following:
•       use remedial alternatives that permanently  and
        significantly reduce the  volume, toxicity, or the
        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; and
•       avoid off-site transport and disposal of untreated
        hazardous  substances or contaminated materials
        when practicable treatment  technologies  exist
        [Section 121(b)].

The UVB Treatment Process can meet each of these
requirements.    Volume,  toxicity,   and  mobility  of
contaminants In the waste matrix are reduced as a result
of treatment. Volatile organic compounds are biodegraded
or removed by  other mechanisms.   The principal by-
products of these reactions are innocuous and generally
consist of carbon dioxide, water, and inorganic salts. The
need for off-site transportation and disposal of solid waste
is eliminated by on-site treatment of the soils.
In general, two  types of responses are possible under
CERCLA:  removal and remedial  action.   Superfund
removal  actions are  conducted  in  response  to  an
immediate threat caused by a release of a hazardous
substance.  Many removals involve small quantities of
waste of immediate threat requiring quick action to alleviate
the hazard. Remedial actions are governed by the SARA
amendments  to CERCLA^   As  stated  above, these
amendments promote remedies that permanently reduce
the volume, toxicity, and mobility of hazardous substances
or pollutants. The UVB Technology is likely to be part of a
CERCLA remedial action. Remedial actions are governed
by the SARA amendments to CERCLA.

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

2.9.2  Resource Conservation and Recovery
       Act(RCRA)
RCRA, an amendment  to the Solid Waste Disposal Act
(SWDA),  is the primary  federal legislation  governing
hazardous waste activities.   It was passed in  1976 to
address  the  problem of how to  safely  dispose of the
enormous volume of municipal and industrial solid waste
generated  annually.    Subtitle C of RCRA  contains
requirements for generation, transport, treatment, storage,
and  disposal of hazardous waste,  most of which are also
applicable to CERCLA activities. The Hazardous and Solid
Waste Amendments (HSWA) of 1984 greatly expanded the
scope  and requirements of RCRA.
RCRA regulations define hazardous wastes and regulate
their transport, treatment,  storage, and disposal. These
regulations are only applicable to the UVB  Treatment
Process  if RCRA-defined hazardous wastes are present.
                                                  2-4

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          Table 2-1. Federal and State Applicable and Relevant and Appropriate Requirements (ARARs) for the ELI/SBP DVB Treatment Process

               Process Activity             ARAR           Description of Regulation      Specific Applicability to the UVB         General Applicability
                                                                                                 Treatment Process
            Waste characterization
            of untreated wastes
RCRA: 40 CFR Part
261 (or state
equivalent)
Standards that apply to
identification and
characterization of wastes.
Chemical and physical properties of
waste determine its suitability for
treatment by the UVB Treatment
Process.
Chemical and physical
analyses must be
performed to determine if
waste is a hazardous
waste.
            Well installation
CAA: 40 CFR Part 50
(or state equivalent)
Regulations govern toxic
pollutants, visible emissions
and particulates.
Applies to well installation and
construction activities.
Emission of volatile
compounds or dusts may
occur.
            Waste processing
RCRA: 40 CFR Part
264 (or state
equivalent)
Standards apply to treatment
of wastes in a treatment
facility.
Applicable or appropriate for UVB
Treatment Process.
When hazardous wastes
are treated, there are
requirements for
operations, recordkeeping,
and contingency planning.
en
CAA: 40 CFR Part 50
(or state equivalent)
Regulations govern toxic
pollutants, visible emissions
and particulates.
During UVB operations, off-gases must
not exceed limits set for the air district of
operation. Standards for monitoring and
recordkeeping apply.
Off-gases may contain
volatile organic compounds
or other regulated
substances.
            Storage of auxiliary
            wastes
RCRA: 40 CFR Part
264 Subpart J (or
state equivalent)
Regulation governs standards
for tanks at treatment facilities.
Storage tanks for liquid wastes (e.g.,
decontamination waste) must be
placarded appropriately, have
secondary containment and be
inspected daily.
If storing non-RCRA
wastes, RCRA
requirements may still be
relevant and appropriate.
                                    RCRA: 40 CFR Part
                                    264 Subpart I (or
                                    state equivalent)
                      Regulation covers storage of
                      waste materials generated.
                              Potential hazardous wastes remaining
                              after treatment, spent carbon, drilling
                              wastes (e.g., soil cuttings), purge water,
                              and decontamination wastes must be
                              labeled as hazardous waste and stored
                              in containers in good condition.
                              Containers should be stored in a
                              designated storage area and storage
                              should not exceed 90 days unless a
                              storage permit is obtained.
                                        Applicable for RCRA
                                        wastes; relevant and
                                        appropriate for non-RCRA
                                        wastes.

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Table 2-1 (Cont'd). Federal and State Applicable and Relevant and Appropriate Requirements (ARARs) for the ELI/SBP UVB Treatment Process

     Process Activity             ARAR          Description of Regulation      Specific Applicability to the UVB       General Applicability
                                                                                     Treatment Process
   Determination of
   cleanup standards
SARA: Section
121(d)(2)(ii);SDWA:
40 CFR Part 141
Standards that apply to
surface and groundwater
sources that may be used as
drinking water.
Applicable and appropriate for UVB
Treatment Process in projects that
require groundwater to be treated.
Remedial actions of
surface and groundwater
are required to meet
Maximum Contaminant
Level Goals (MCLGs) or
Maximum Contaminant
Levels (MCLs)
established under
SDWA.
   Waste disposal
RCRA: 40 CFR Part
262
Standards that pertain to
generators of hazardous
waste.
Waste generated by the UVB Treatment
Process which may be hazardous is
limited to spent carbon, drilling wastes
(e.g., soil cuttings), purge water and
decontamination wastes.
Generators must dispose
of wastes at facilities that
are permitted to handle
the waste. Generators
must obtain an EPA ID
number prior to waste
disposal.
                          CWA: 40 CFR Parts
                          403 and/or 122 and
                          125
                       Standards for discharge of
                       wastewater to a POTW or to
                       a navigable waterway.
                            Applicable and appropriate for
                            decontamination wastewaters.
                                       Discharge of
                                       wastewaters to a POTW
                                       must meet pre-treatment
                                       standards; discharges to
                                       a navigable waterway
                                       must be permitted under
                                       NPDES.
                           RCRA: 40 CFR Part
                           268
                       Standards regarding land
                       disposal of hazardous
                       wastes
                            Applicable for off-site disposal of
                            auxiliary waste (e.g., PVC piping).
                                       Hazardous wastes must
                                       meet specific treatment
                                       standards prior to land
                                       disposal, or must be
                                       treated using specific
                                       technologies.

-------
 If soils are determined to be hazardous according to RCRA
 (either because of a characteristic or a listing carried by the
 waste), essentially all RCRA requirements regarding the
 management and disposal  of this hazardous waste will
 need to be addressed by the remedial managers.  Wastes
 defined as hazardous under RCRA include characteristic
 and listed wastes.  Criteria for identifying characteristic
 hazardous wastes  are included in 40  CFR  Part 261
 Subpart C.  Listed wastes from specific and nonspecific
 industrial sources, off-specification products, spill cleanups,
 and other industrial sources are itemized in 40 CFR Part
 261 Subpart D.  RCRA regulations do not apply  to sites
 where RCRA-defined wastes are not present.
 Unless they are specifically  delisted through delisting
 procedures, hazardous wastes listed in 40 CFR Part 261
 Subpart D currently remain listed wastes regardless of the
 treatment they may undergo and regardless of the final
 contamination levels in  the resulting effluent streams and
 residues. This implies that even after remediation, treated
 wastes are still  classified as hazardous wastes because
 the pre-treatment material was a listed waste.

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

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

 2.9.3   Clean  Air Act (CAA)

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

 The CAA requires that treatment, storage, and disposal
 facilities comply with primary and secondary ambient air
 quality  standards.  Fugitive  emissions  from  the UVB
 Treatment Process may come from (1) well installation and
 construction  activities  (VOCs and  dust), (2) periodic
 sampling  activities,  and  (3) off-gas  during system
 operation. The off-gas treatment system must be designed
 to meet the current air quality standards.  State air quality
 standards may require  additional measures to prevent
 emissions, including requirements to  obtain permits to
 install and operate the UVB treatment system and off-gas
 treatment.

 2.9.4  Clean Water Act(CWA)

 The objective of the Clean Water Act is to restore and
 maintain the chemical, physical and biological integrity of
 the nation's waters by establishing federal, state, and local
 discharge standards.  If treated water is discharged to
 surface water bodies or Publicly Owned Treatment Works
 (POTW), CWA regulations will apply.  A facility desiring to
 discharge water to a navigable waterway must apply for a
 permit under the National Pollutant Discharge Elimination
 System (NPDES). When  a NPDES permit is  issued, it
 includes waste  discharge  requirements.  Discharges to
 POTWs also must comply  with  general  pretreatment
 regulations outlined in 40CFR Part 403, as well as other
 applicable state and local administrative and substantive
 requirements.

 Wastewater generated from the UVB process  that may
 need to be  managed  includes  that generated  from
 equipment decontamination and from well purging and the
 water separator.  This water can be discharged to a local
 POTW or into surface waters. Depending on the levels of
 contaminants and permit limitations, treatment may be
 required prior to discharge.

 2.9.5  Safe Drinking Water Act (SDWA)
 The SDWA of 1974, as most recently amended by the Safe
 Drinking Water Amendments of 1986, requires the EPA to
 establish regulations  to  protect  human  health   from
 contaminants in drinking water. The legislation authorized
 national drinking water standards and a joint federal-state
 system for ensuring compliance with these standards.
The National Primary Drinking Water Standards are found
in 40 CFR Parts 141 through 149. Parts 144 and 145
discuss requirements associated with  the  underground
injection of contaminated water. If underground injection of
wastewater is  selected as a disposal means, approval from
EPA for constructing and operating a new  underground
injection well is required.
                                                   2-7

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2.9.6  Occupational   Safety   and   Health
       Administration (OSHA) Requirements

CERCLA remedial actions and RCRA corrective actions
must  be  performed in accordance with the  OSHA
requirements detailed in 20 CFR Parts 1900 through 1926,
especially Part 1910.120, which provides for the health and
safety  of workers at hazardous waste sites.   On-site
construction activities at Superfund or RCRA corrective
action sites must be performed in accordance  with Part
1926  of OSHA,  which describes  safety and  health
regulations  for  construction  sites.    State  OSHA
requirements, which  may  be significantly  stricter than
federal standards, must also be met.
All technicians involved with the construction and operation
of the UVB Treatment  Process are required to  have
completed an OSHA training course and must be familiar
with all OSHA requirements relevant to hazardous waste
sites.  Workers on hazardous waste sites must also be
enrolled in a medical monitoring program. The elements of
any acceptable program must include: (1) a health history,
(2) an initial exam before hazardous waste work starts to
establish fitness for duty and as a medical baseline, (3)
periodic  examinations  (usually annual) to determine
whether changes due to exposure may have occurred and
to ensure continued fitness for the job, (4) appropriate
medical  examinations  after  a suspected  or known
overexposure, and (5) an examination at termination.

For most sites, minimum PPE for workers will include
gloves, hard hats, steel-toe boots, and Tyvek® coveralls.
Depending on contaminant  types and concentrations,
additional PPE may  be required, including the use of air
purifying respirators or supplied air. Noise levels are not
expected to be high, except during well installation which
will involve the operation of  drilling equipment. During
these activities, noise levels should be monitored to ensure
that workers are not exposed to noise levels above a time-
weighted average of 85 decibels over an eight-hour day.
If noise levels increase above this limit, then workers will
be required to wear hearing protection. The levels of noise
anticipated are not expected to  adversely  affect  the
community, but  this will  depend on  proximity  to  the
treatment site.
                                                    2-8

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                                             Section 3.0
                                             Economics
3.1    Introduction

The primary purpose of this economic analysis is to provide
a  cost estimate  (not including profit)  for commercial
remediation of soil  contaminated  by  volatile  organic
compounds  (VOCs)  utilizing   the  Environmental
Laboratories, Inc. (ELI) and SBP Technologies, Inc. (SBP)
UVB Treatment System (Vacuum Vaporization Well). This
analysis is based on the assumptions and costs provided
by ELI/SBP, and on the results and experiences gained
from the SITE demonstration that was conducted over a
14-month period at the Sweden-3 Chapman site. The SITE
demonstration evaluated one UVB well. Based on the site
characteristics such  as  the soil  type  and depth  to
groundwater, the treatment area for this one UVB well was
approximately 263 m2 or 2,827 ft2 (9.14 meter or 30 foot
radius),  which  enclosed most of  the  demonstration
treatment area of 50 feet by  50 feet (15.2 meters by 15.2
meters).  The ELI/SBP Vacuum Vaporization Process is
applicable   principally  to   soils   and  groundwater
contaminated with VOCs. Based on the demonstration
site, this is assumed  to be  1.83 meters  (6 feet) for this
economic analysis.

Economic calculations were  done for  both the  SITE
demonstration treatment area/volume, as  well as for a full-
scale remediation of the Sweden-3 Chapman site using this
technology.  A number of  factors  affect  the cost  of
treatment. These include, but are not limited to: soil type,
contaminant type and concentration, depth to groundwater,
soil moisture, air permeability of the soil, and site geology.
This economic analysis assumes that the ELI/SBP System
will remediate saturated and vadose soil with the same
characteristics  as the SITE demonstration soil at the
Sweden-3 Chapman site.
The SITE demonstration treated a volume of approximately
480 m3 (628 yd3) of soil contaminated with VOCs. This is
assuming that the vadose zone is on average 1.83 meters
(6 feet) deep. The SITE demonstration soil was classified
as a glacial till with a permeability of 1 x 10"4 cm/sec. The
SITE demonstration treated the soil for 14 months. Results
of the demonstration are presented in Section 4 of this
report.

For the full-scale remediation, it was assumed that 22 UVB
wells would be needed to treat an area  of 5,518  m2
(59,400 ft2). Assuming a vadose zone of 1.83 meters (6
feet), the treatment volume is 10,092 m3 (13,200 yd3). It is
assumed that all  of the wells will operate at once.  If
ELI/SBP decide to use an alternate approach, such as
staggered treatment, the costs may be  different. ELI/SBP
estimate that typical site treatment times will be 3 to 5
years. Treatment times will depend on site characteristics,
as well as on-line factors. For the SITE demonstration the
on-line factor was approximately 60%.  Full-scale costs
are given for treatment times of 14 months (the SITE
demonstration treatment time), for 3  years, and for 5
years.

3.2     Conclusions

Estimated costs for one UVB well treating a total volume of
480 m3 (628 yd3) of vadose zone soils, assuming a 1.83
meter or 6 foot vadose zone, are approximately $453/m3
($347/yd3)  for  a  14-month  period  at the Sweden-3
Chapman site in Sweden, NY. Estimated costs for treating
a total volume of 10,092 m3 (13,200 yd3) of vadose zone
soils utilizing 22 UVB wells at the Sweden-3 Chapman site
in Sweden, NY are approximately $195/m3 ($149/yd3) for
a 14-month period, $339/m3 ($259/yd3) fora 3-year period,
and $491/m3 ($375/yd3) for a 5-year period.  Tables 3-1
and 3-2 summarize these costs by categories and list each
category's cost as a percent of the total cost for the 480-m3
and 10,092-m3 cases, respectively.  Those costs that are
assumed to be the obligation of the responsible party or
site owner have been omitted from this cost estimate and
are indicated  by  a line  (-)  in Tables 3-1  and  3-2.
Categories with no costs associated with this technology
are indicated by a zero (0) in Tables 3-1 and 3-2.  The
categories and their contents are discussed at length  in
Section 3.4.

A large percentage of the 10,092-m314-month, 3-year, and
5-year treatment cost  is for labor  (16.7%, 27.8%, and
                                                  3-1

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Table 3-1. Estimated Costs for Pilot-scale Treatment Using the ELI/SBP Treatment System
Total Treatment Area: 263 m2 (2,827 ft2)
Treatment Depth: 1.83 meters (6 feet)
Total Treatment Volume: 480 m3 (628 yd3)
Treatment Time:  14 months
$/m3
$/yd3
Site and Facility Preparation Costs
        Site design and layout
        Survey and site investigations
        Legal searches
        Access rights and roads
        Preparations for support facilities
        Auxiliary buildings
        Technology-specific requirements
        Transportation of waste feed
Total Site and Facility Preparation Costs

Permitting and Regulatory Costs
        Permits
        System monitoring requirements
        Development of monitoring and protocols
Total Permitting and Regulatory Costs

Equipment Costs
        Annualized equipment cost
        Monitoring equipment
        Support equipment cost
        Equipment rental/lease
Total Equipment Costs

Startup and Fixed Costs
        Working capital
        Shakedown testing
        Insurance and taxes
        Initiation of monitoring programs
        Contingency
Total Startup and Fixed Costs

Labor Costs
        Senior scientist
        Engineer
        Project manager
        On-site technician
        Rental car
        Travel
Total Labor Costs
 140.00  107.69

 140.00  107.69
  20.83
   6.25
  64.85
  91.93
   4.83
   3.48
   8.31
  24.99
  28.33
  32.57
  27.99
 15.92
  4.78
 49.58
 70.29
  3.69
  2.66
  6.35
 19.11
 21.66
 24.90
 21.40
 113.88   87.07
           31.1%
20.3%
 1.8%
           25.1%
Supplies and Consumables Costs
PPE
Health and safety plan
Small hand tools
Consumables (plumbing, site maintenance, etc.)
Blowers and groundwater pumps
Total SuDDlies and Consumables Costs
10.41
10.40
0.42
10.41
6.46
38.11
7.96
7.96
0.32
7.96
4.94
29.14
8.4%
                                              3-2

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Table 3-1 (Cont'd).  Estimated Costs for Pilot-scale Treatment Using the ELI/SBP Treatment System
Total Treatment Area: 263 m2 (2,827 ft2)
Treatment Depth:  1.83 meters (6 feet)
Total Treatment Volume: 480 m3 (628 yd3)
Treatment Time: 14 months
$/m3
$/yd3
Utilities Costs
Sanitary
Electricity
Water
Total Utilities Costs

2.19
15.87
0.47
18.53

1.67
12.13
0.36
14.16




4.1%
Effluent Treatment and Disposal Costs
        On-site facility costs
        Off-site facility costs
                -wastewater disposal
                -monitoring activities
Total Effluent Treatment and Disposal Costs

Residuals & Waste Shipping, Handling & Transport Costs
        Preparation
        PPE
        Well cuttings
        Development water
        Carbon
Total Residuals & Waste Shipping, Handling and
Transport Costs

Analytical Costs
   1.04
   1.04
   0.80
   0.80
0.2%
Operations (for developer's purposes, not regulatory)
Environmental monitoring (regulatory)
Total Analytical Costs
Facility Modification, Repair, & Replacement Costs
Design adjustments
Routine maintenance (materials & labor)
Equipment replacement
Total Facility Modification, Repair, & Replacement Cost
Site Restoration Costs
Site cleanup and restoration
- Technology specific
Permanent storage
Total Site Restoration Costs
TOTAL OPERATING COSTS
19.99
—
19.99

0
Oa
0
oa

	
20.77
—
20.77
$453
15.29
—
15.29

0
Oa
0
oa

...
15.88
	
15.88
$347


4.4%




Oa




4.6%

      Maintenance materials are listed as spare parts under "Spare Parts and Consumables".

      Maintenance labor is included in the on-site labor under "Labor".
                                             3-3

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Table 3-2. Estimated Costs in $/m3 for Treatment Using the ELI/SBP Treatment System to Remediate 10,092/m3 (Full-scale)
Treatment Area =
Treatment Depth =
Total Treatment Volume =
Treatment Time =
Approximate Total Project Period =

Site Facility Preparation Costs
Permitting & Regulatory Costs
Equipment Costs
Startup & Fixed Costs
Labor Costs
Supplies & Consumables Costs
Utilities Costs
Effluent Treatment & Disposal Costs
Residuals Shipping, Handling, & Transport Costs
Analytical Costs
Facility Modifications, Repair, & Replacement Costs
Site Restoration Costs
Total Costs (S/m3 )
Total Costs (S/yd3 )
5,518m2
1.83m2
10,092 m3
14 months
16 months
$/m3
78.88
—
43.96
4.26
32.51
15.13
7.88
-
0.20
1.31
0'
10.57
195
149
%
40.5
—
22.5
2.2
16.7
7.7
4.1
-
0.2
0.7
0'
5.4


5,518 m2
1.83m2
10,092m3
3 Years
3.1 7 Years
$/m3
78.88
—
101.41
9.78
94.10
19.99
20.25
—
0.55
3.05
0'
10.57
339
259
%
23.3
—
29.9
2.9
27.8
5.9
6.0
—
0.2
0.9
0'
3.1


5,518m2
1 .83 m2
10,092m3
5 Years
5.1 7 Years
$/m3
78.88
"
164.08
15.81
156.84
25.30
33.73
—
0.89
4.80
0"
10.57
491
375
%
16.1
•~
33.3
3.2
32.0
5.2
6.9
—
0.2
0.9
0"
2.2


  Maintenance labor is included under "Labor Costs". Maintenance Materials are included under "Supplies and Consumables Costs".
32.0%, respectively). As experience at a site is gained
over the first few years, it may be possible that labor
intensive activities can be done more efficiently.  Thus,
fewer man-hours may  be required in later years  for
operating the system and reviewing field data (i.e., in years
3,4, and 5).
If the ELI/SBP System actually remediates to the bedrock
at the demonstration site, then the treatment depth would
Increase to 11 feet.  This would increase the treatment
volume of the SITE demonstration to 880 m3, and the full-
scale treatment volume to 18,500 m3. Based on an 11 foot
treatment depth, this would make the SITE demonstration
14-month treatment costs 247/m3 ($189/yd3), and the full-
scale 14-month,  3-year,  and  5-year  treatment  costs
$106/m3, $185/m3, and $268/m3, respectively.
Costs presented  in this report are order-of-magnitude
estimates as defined by the American Association of Cost
 Engineers, with an expected accuracy within +50% and
-30%; however, because this is a  new technology,  the
 range may actually be wider.

 3.3   Issues and Assumptions
 The cost estimates  presented in  this  analysis  are
 representative of charges typically assessed to the client
 by  the vendor, but do  not include profit.   In general,
assumptions are based on information provided by the
developer and observations made during this and  other
SITE demonstration projects.

Many actual or potential costs that exist were not included
as part of this estimate. They were omitted because site-
specific engineering designs that are beyond the scope of
this SITE project would be required. Also, certain functions
were assumed to be the obligation of the responsible party
or site owner  and were not included in  the estimates.
These costs are site-specific. Thus, calculations are left to
the reader so that relevant information may be obtained for
specific cases. Whenever possible, applicable information
is provided on these topics  so that the reader can
independently perform the calculations required to acquire
relevant economic data.

Other  important   assumptions   regarding  operating
conditions and task responsibilities that could significantly
impact the cost estimate results are presented below:

       The cost estimate assumes that the site has been
       characterized during previous investigations.

       This  cost  estimate  assumes  that treatability
       studies  or  pilot  studies  have  already  been
       performed.
                                                     3-4

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        It is assumed that the site has suitable access
        roads.

•       It is assumed that the  site  has electrical  and
        telephone supply lines.

        This cost estimate assumes  that the soil being
        remediated is similar to the VOC-contaminated soil
        treated during the SITE demonstration.

        It is assumed, based on the SITE demonstration,
        that each UVB well can treat a 9.14-meter radius.

•       This cost estimate assumes that operating labor
        time on-site during treatment is 4 hrs/week and 24
        hrs/week for the 480-m3 and 10,092-m3 cases,
        respectively.     This   labor   time  includes
        maintenance labor.

        It is assumed that the 480-m3  case will require
        11.5 pre-treatment days  for site preparation  and
        shakedown testing, and  it will  require 3.5 post-
        treatment days for site demobilization.

 •       It is assumed that the 10,092-m3 case will require
        42 pre-treatment days for site  preparation  and
        shakedown testing, and it will  require 19 post-
        treatment days for site demobilization.

•       This cost estimate assumes that the pre-treatment
        and post-treatment working days are 8-hour days
        for both cases.

•       It is assumed that drilling costs do not include
        disposal costs for well cuttings and development
        water.


3.4     Basis for Economic Analysis

In order to compare the cost-effectiveness of technologies
in the SITE Program, EPA breaks down costs into twelve
categories:
       Site and facility preparation costs,
       Permitting and regulatory costs,
       Equipment costs,
       Startup and fixed costs,
       Labor costs,
       Consumables and Supplies costs,
       Utilities costs,
       Effluent treatment and disposal costs,
       Residuals  and  waste snipping,  handling, and
       transport costs,
       Analytical costs,
       Facility modification, repair, and  replacement
       costs, and
       Site restoration costs.
These 12 cost categories reflect typical cleanup activities
encountered on Superfund sites. Each of these cleanup
activities is defined and discussed, forming the basis for
the detailed estimated costs presented in Tables 3-1  and
3-2. The estimated costs for the 480-m3 case are shown
graphically in Figure 3-1.  The 12 cost factors examined
and assumptions made are described in detail below.

3.4.1  Site and Facility Preparation  Costs

For the purposes of these cost calculations, "site" refers to
the location of the contaminated waste. 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, preparations for support  and
decontamination facilities, utility connections (except for a
phase converter for the 480-m3 case), and fixed auxiliary
buildings. Since these costs are site-specific, they are not
included as part of the site preparation costs in this cost
estimate.

For  the purposes  of  these cost calculations,  only
technology-specific site preparation costs are included.
These are limited to: UVB well installation, monitoring well
installation, UVB internal  components installation, in situ
bioreactor installation, ex situ  bioreactor  installation,
installation of an electrical phase converter (for the 480-m3
case only), and installation of a fence (for the 10,092-m3
case only). The developers' estimates of these costs are
presented below:

        UVB Well Installation. A total of $11,000/UVB well
        for drilling. This includes drilling a 0.76-meter (30-
        inch) hole 8.22-meter (27-feet) deep via a bucket
        rig, and a borehole with 0.41-meter (16-inch) mild
        black  steel  casing,  sand  pack,  concrete/grout
        seals, and development.  Labor requirements are
        2 workers for 20 hours  each per UVB well, in
        addition to the labor included in well drilling cost.
        Labor  rates are  $60/hr  and $85/hr for a  field
        technician and an engineer, respectively.
•       Monitoring Wells.  A total of $21,086  for 15
        monitoring wells.   This includes drilling/installing
        5.08-cm (2-inch) PVC wells as shallow/deep well
        clusters, development, screens, riser pipe, sand,
        grout, protective casing, locks, and seals. Labor
        requirements for installing the 15 monitoring wells
        are 2 workers for  16 hours each.  Labor rates are
        $60/hr and $85/hr for  a  field technician and an
        engineer, respectively. (Note: this cost is directly
        scaled-up for 22 monitoring wells for the full-scale
        cost calculations.)
                                                    3-5

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                                                                                  (A) 31.1%
                           (8)20.3%
                                  (0)25.1%
                                                                                                   (1)4.6%


                                                                                                    (H)4.4%
                                                                                                   (0)0.2%
                                                                               (E)8.4%
                                                      Unit Cost = $347/yeP
            £g  (A) Sii and Facity Preparation
            Q|  (OStartup&RxadCo«ii
            0  (E)SuppiM&Contumablaa
            Q  (G)Radduato&WMteShlpping,HaiKlng&Tranipoit
            0§  0) SSaRartoraflon
            Q  (IQEffiuantTnMtmant&DtopoiaKD
(B) Equipment
(D) Labor
(F)UtUHIas
(H) Analytical Sanicaa
(J) Permitting & Regulatory 0)
(L) Fae«y Modification, Repair & Raptacament ®
              0) TbaMcoattaranotlndudadlntttlaaconomlcanalyaia.
Figure 3-1. Cost Distribution
                                                             3-6

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 •       DVB Internal Components. UVB equipment costs
        are  included  Under equipment costs.   Labor
        requirements  for  UVB  internal  components
        installation are 2 workers for 24 hours each per
        UVB well. Labor rates are $60/hr and $85/hr for a
        field technician and an engineer, respectively.
 •       In Situ Bioreactor.  This includes the in  situ
        bioreactor ($1,700/UVB well), carbon as support
        media (S945/UVB well), crane service to install the
        in situ bioreactor ($1,000/UVB well), and labor (2
        workers for 16 hours each per UVB well).  Labor
        rates are $60/hr and $85/hr for a field technician
        and  an engineer, respectively.  ELI/SBP claims
        that  newer designs will not require a crane or as
        many labor hours.

 •       Ex  Situ Bioreactor.   Labor requirements for
        installing the ex situ bioreactor are  2 workers for
        16 hours each per UVB well.  Labor rates are
        $60/hr and $85/hr for a field  technician and an
        engineer, respectively.
 •       Phase Converter. The UVB System requires three
        phase power.  For  the SITE demonstration  a
        licensed electrician (at a labor  cost  of $1,040)
        installed a phase converter ($2,405). This cost is
        very site-specific, and is not included for the full-
        scale costs. For the full-scale costs, it is assumed
        that all electrical connections and conversions are
        the site owner's responsibility.

 In addition, the cost of a fence is included for the full-scale
 case only. The fence to enclose the treatment area (1,500
 linear feet or  457 linear meters) is  estimated to cost
 $5/linear ft ($16.40/linear  meter),  based on  past SITE
 project experience, for a total of $7,500.

 3.4.2   Permitting and Regulatory Costs
 Permitting and regulatory costs are generally the obligation
of the responsible  party  (or site owner), not that of the
vendor. These  costs may include actual permit costs,
system  monitoring requirements, the development of
monitoring and analytical protocols, and health and safety
monitoring.  Permitting and  regulatory  costs can vary
greatly because they are site- and waste-specific. Permits
that may need to be considered for this technology include
drilling  permits, building permits, and water and/or air
discharge permits. No permitting costs are included in this
analysis; however,  depending on the treatment site,  this
may be a significant factor since permitting activities can be
very expensive and time-consuming.

3.4.3   Equipment Costs

Equipment costs include purchased equipment, purchased
support equipment, and rental/lease equipment. Support
equipment refers to pieces of purchased equipment and/or
sub-contracted items that will only be'used for one project.
Purchased Equipment Costs

The  purchased equipment  costs  are presented  as
annualized equipment costs, prorated  based on the
amount of time the equipment is used for the project. The
annualized equipment cost is  calculated using a 10-year
equipment life and a 10% annual interest rate. The
annualized equipment cost is based upon the writeoff of the
total  initial capital  equipment  cost and  scrap  value
(assumed to be zero) using the following equation:

        Capital recovery = (V - Vs)  1(1 +0"
where
V
Vs
n
I
                                 (1 + l)n -1
is the cost of the original equipment,
is the salvage value of the equipment,
is the equipment life (10 years), and
is the annual interest rate (10%).
For the 480-m3 case there are no purchased equipment
costs.  Instead, ELI/SBP provide a lease cost for the UVB
well internal components.  ELI/SBP approximate this cost
at $27,311 for 14  months for one UVB well.  For the
10,092-m3 case, ELI/SBP estimate the capital cost for one
UVB system to be $82,600. This cost is used to calculate
the prorated annualized purchased equipment cost for the
10,092-m3 case.
Support Equipment Costs

For  this cost  estimate,  support  equipment includes
monitoring equipment and a crane rental to raise/lower the
bioreactor due to groundwater level changes.  ELI/SBP
estimate   the   monitoring  equipment  costs  to  be:
groundwater flow meter ($1,200); air flow meter ($1,647);
field  HACH testing kits ($600 for the 480-m3 case and
$13,200 for the 10,092-m3 case); dissolved oxygen  meter
($619); magnetic gauges ($150); oxygen, carbon dioxide,
and   lower  explosive  level  meter  ($2,241)   and
miscellaneous  equipment including water level meter and
PID/OVA  meter ($3,543).    The  support monitoring
equipment  will not be used  on subsequent projects,
therefore these costs are not prorated.
A crane is required  to adjust the location of the UVB well.
ELI/SBP estimate the  crane costs  at $750/adjustment.
Based on the SITE  demonstration, it is approximated that
this crane will be required once per quarter for the 480-m3
case and once per month for the 10,092-m3 case.
Rental Equipment Costs
For the 480-m3 cost  estimate, rental/lease equipment
includes:  a UVB  well for $27,311 for 14 months  (as
                                                   3-7

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mentioned above), an office trailer at $225/month for 15
months, and a telephone at $30/month for 15 months.

For the 10,092-m3 cost estimate, rental/lease equipment
includes: an office trailer at $225/month and a telephone
at $30/month. It is assumed that these will be rented for 16
months, 38 months, or 62 months for the 14-month, 3-
year, and 5-year treatment times, respectively.

3,4.4   Startup and Fixed Costs
Working capital is based on the amount of money currently
invested in supplies and consumables. The working capital
cost of supplies and consumables is not expected to be a
significant cost, and is not included here. ELI/SBP include
transportation costs for the UVB internal components and
btoreactors in their equipment costs that are listed above
in the "Site Preparation" and "Equipment" costs sections.

Based on their SITE demonstration experience, ELI/SBP
have estimated that startup and shakedown testing will
require 2 workers for 16 hours each per UVB well. Labor
rates are $85/hr for  an engineer and $60/hr for a field
technician. This is in addition to the installation and set-up
labor listed above under the "Site and Facility Preparation"
section.
Insurance  and taxes  together are  assumed for the
purposes of this estimate to be  10%  of the total annual
capital equipment costs.  The cost for the initiation of
monitoring  programs has  not  been included  in  this
estimate. Depending on the site and  the location of the
system, however, local authorities may impose specific
guidelines for monitoring programs. The stringency and
frequency of monitoring  required may have significant
impact on the project costs.  No contingency costs are
included.   Often these costs will equal  the costs of
insurance and  taxes.  Contingency costs allow for any
unforeseen  or  unpredictable cost conditions, such as
strikes, storms, floods, and price variations.

3.4.5  Labor Costs
Hourly labor rates for operation include  base salary,
benefits,  overhead,  and  general  and  administrative
expenses, but no travel, per diem, or car rental costs, since
these costs are site specific. ELI/SBP estimate that for the
480-m3 case quarterly visits to the site and/or field data
evaluation would  require: a senior scientist for 24 hrs/qtr
at a rate of $125/hr, a field technician, an engineer or a
geologist for a total of 40 hrs/qtr at a rate of $85/qtr,  and a
project manager for 24 hrs/qtr at a rate of $115/hr. For the
 10,092-m3 case these labor requirements were projected
to be: a senior scientist for 144 hrs/qtr at a rate of $125/hr,
a field technician, an engineer or a geologist for a total of
240 hrs/qtr at a rate of $85/qtr, and a project manager for
204 hrs/qtr at a rate of $115/hr.
For this cost estimate, operating labor time on-site is
assumed to be 4 hrs/week for the 480-m3 case, and 24
hrs/week for the 10,092-m3 case.  This is assumed to be a
field technician at a labor rate of $60/hr. This labor time
includes routine maintenance labor.

3.4.6  Supplies and Consumables Costs

Supplies cost for this cost estimate is limited to  personal
protective equipment (PPE), a health and safety plan, small
hand   tools,  blowers,  groundwater  pumps,   and
consumables related to plumbing, site maintenance, and
miscellaneous items. ELI/SBP estimate these costs to be:
PPE at $5,000 for the 480-m3  case and $31,250 for the
10,092-m3 case; preparation of a health and safety plan at
$5,000 for both cases; small hand tools at $200 for both
cases; replacement blowers at $2,500 each (one for the
480-m3 case,  and  two  for  the  10,092-m3  case);
replacement groundwater pumps at $600 each (one for the
480-m3 case, and  two for the 10,092-m3  case) and
consumables at $5,000 for the 480-m3 case and $110,000
for the 10,092-m3 case. ELI/SBP do not expect any costs
for amendments or microbes, therefore these costs are not
included.

3.4.7 Utilities Costs
Utilities required are  limited  to electricity, water, and
sanitary. ELI/SBP estimate the electricity required for each
UVB well to  be 1,058 kWhrs/wk.  If a phase converter is
required (as  was for the  SITE demonstration) ELI/SBP
estimates  its electrical  usage at  1,210  kWhrs/wk.
Electricity rate is assumed  to  be $0.06/kWhr.  ELI/SBP
estimate the water and sanitary costs for both cases to be
$15/month and $70/month, respectively.

3.4.8 Effluent Treatment and Disposal Costs

ELI/SBP claim that this system does not generate waste
once installed, except for off-gas treatment.  They claim
that all groundwater is treated in situ. During the  14-month
SITE  demonstration,  no water was collected in  the
knockout tank.  No effluent treatment and disposal costs
are included.

3.4.9  Residuals   and    Waste   Shipping,
        Handling and Transport Costs
It is assumed that the only  residuals or solid wastes
generated from this  process  will  be used PPE, well
cuttings, and development water. The disposal cost for
208-L (55-gal) drums of  used PPE is estimated  at
$500/208-L   drum   based  on  SITE  demonstration
experience.  For this cost estimate, it is assumed that one
208-L drum  of used PPE will be generated per 14 months
for the 480-m3 case and that four 208-L drums of used PPE
                                                    3-8

-------
will be generated per 14 months for the 10,092-m3 case.
Waste disposal costs (including storage, transportation and
treatment costs) for all other residuals are assumed to be
the obligation of the responsible party (or site owner). The
SITE demonstration generated approximately 10.4 m2 (112
ft2) of well cuttings and 2,271  liters  (600 gallons) of
development water. No costs are included for regenerating
the carbon beds, replacing the carbon, or disposing used
carbon.  During the SITE demonstration the carbon did not
require regeneration  or replacement.

3.4.70 Analytical Costs

Only spot checks executed at ELI/SBP's discretion  (to
verify that equipment is performing properly and that
cleanup criteria are  being met) are included in this cost
estimate. The client may elect, or may be required by local
authorities, to initiate a planned sampling and analytical
program at their own  expense. The cost for ELI/SBP's spot
checks is estimated at $100 per sample. For the purposes
of this cost estimate, it is assumed that there will be 16
samples/qtr  analyzed  for  the  480-m3  case  and  22
samples/qtr analyzed for the 10,092 m3case. Labor costs
for evaluating field data are included under the "Labor" cost
section.

The analytical  costs  associated  with  environmental
monitoring have not been included in this estimate due to
the fact that monitoring programs are not typically initiated
by  ELl/SBP.  Local  authorities may, however, impose
specific  sampling and monitoring criteria whose analytical
requirements could contribute significantly to the cost of the
project.
3.4.11  Facility  Modification,  Repair  and
         Replacement Costs
Maintenance costs are assumed to consist of maintenance
labor and maintenance materials. Maintenance labor and
materials costs vary with the nature of the waste and the
performance of the equipment. The labor cost component
for this effort has already been accounted for in the "Labor"
cost category as weekly on-site labor. ELl/SBP estimate
the repair and maintenance labor requirements to  be 32
hours per quarter for the 480-m3 case.

Maintenance materials  include  blowers, groundwater
pumps, and consumables related to plumbing, site
maintenance and miscellaneous items. These costs are
already  accounted  for  under  the  "Supplies  and
Consumables" cost category.

3.4.12  Site Restoration Costs
Site restoration requirements will vary depending on the
future use of the site and are assumed to be the obligation
of the responsible party. Therefore, the only site restoration
costs included are: the cost for drillers to decommission the
wells  ($5,490 for the 480-m3  case and projected  to be
$8,050 for the 10,092-m3 case); the cost for a crane to
remove the wells ($770 for the 480-m3 case and projected
to be $16,980 for the 10,092-m3 case); and the cost for a
dumpster ($350 for the 480-m3 case and projected to be
$7,700 for the 10,092-m3 case). ELl/SBP estimate labor
requirements for these activities to be 2 workers for 28
hours each for the 480-m3 case, and this is projected to 8
workers for 19 days (8 hrs/day) each for the  10,092-m3
case.  Labor rates are $60/hr.
                                                   3-9

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                                            Section 4.0
               Treatment Effectiveness During the SITE Demonstration
This section presents the results of the SITE demonstration
of the ELI/SBP DVB in situ bioremediation technology at
the Sweden-3 Chapman landfill during the period from July
1994 through October 1995.

4.1    Background

The Sweden-3 Chapman landfill site was a privately owned
facility used  for the disposal  of construction debris and
industrial hazardous wastes  between about 1970 and
1978. Sampling indicated that the soil and groundwater at
the site were seriously contaminated with volatile organic
compounds (VOCs) and innumerable drums. As part of an
interim cleanup started in 1989, approximately 2300 drums
in various conditions and  with various contents  were
removed from the site.  The  site was then capped with
several feet of fill. Subsequent soil analyses indicated that
considerable concentrations of various VOCs were still
present in various portions of the site and were migrating
with the groundwater.  After  considering desirable site
characteristics and alternate sites for the cooperative Multi-
Vendor  Bioremediation Demonstration,  the  Sweden-3
Chapman site was selected for use.
The  primary objectives for  the demonstration  were
designed in  collaboration with  ELI/SBP and the  other
developers and were used  to examine claims that  were
agreed to by all participants.  Based on the  NYSDEC
desire to clean up the soil at the site, it was agreed that one
primary .objective would be evidence of cleanup of the
vadose zone soil to predefined NYSDEC Cleanup Criteria.
The agreed-to  goal then was  that  90% of  the  VOC
analyses of soil samples from the test plot after 5.5 months
of remediation would meet the  specified NYSDEC Soil
Cleanup  Criteria shown in  Table 4-1 for the six critical
VOCs.
To evaluate this claim, it was planned to obtain soil cores
of the expected  vadose zone below the overburden (9 to
15 ft below ground surface, bgs) at 25 points non-uniformly
distributed across the ELi/SBP plot  at the  end of the
anticipated six months of treatment.  In fact, it was found
that vadose and saturated zones both were present in most
   Table 4-1.  NYSDEC Soil Cleanup Criteria for
             Demonstration
             Compound
Criterion
    (ppb)
     acetone

     2-butanone (MEK)

     4-methyl-2-pentanone (MIBK)

     1,2-dichloroethene (DCE)

     trichloroethene (TCE)

     tetrachloroethene (PCE)
  200

  600

 2000

  600

 1500

 2500
borings of the 9 to 15 ft zone and varied in depth in every
sampling event.  Consequently, separate samples were
obtained of each zone for VOCs and other analyses on the
basis of observation. Asubsample of each boring interval,
selected  from the area  indicating the highest VOC
concentration by immediately passing  a field PID probe
over the core, was sent for VOC analysis by EPA Method
8260. This field sub-sampling selection  procedure was
implemented to minimize the possibility  of "non-detect"
samples and, therefore, is not necessarily representative
of average  site contaminant concentrations.   The
laboratory composited subsamples from each portion of the
sub-element in methanol.  The  results for the six noted
VOCs in the samples were then compared to the NYSDEC
Cleanup Criteria and achievement of the claim measured
in terms of total samples.  In addition to the sampling in
December  1994, after approximately six  months  of
treatment, sampling also was carried out  initially (July
1994), after  about  3 months (October 1994), after 10
months  (May  1995),  and  at  the actual  end  of  the
demonstration  (September 1995),  after 14 months  to
document the progress of the treatment.

The  NYSDEC Soil  Cleanup Criteria used for this study
refer only to "1,2-dichloroethene," which is presumably the
                                                  4-1

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sum of the cis- and the trans- isomers. The trans- isomer
(s rarely found as an industrial waste or a biodegradation
product while the cis- isomer is known to be a degradation
product of other chlorinated ethenes.  Therefore, although
analyses included both isomers, only the cis- isomer was
evaluated as one of the critical VOCs and the 600 pg/Kg
criterion was used.
The second primary objective of the project was to attempt
to demonstrate whether bioremediation was,  in fact, a
major mechanism by  which  the  critical  VOCs  were
removed from the site.   Because of the anticipated
uncertainties (1) in converting soil VOC concentrations to
masses  because  of the  known  bias  created  by the
sampling procedures; (2) in measuring VOC masses
stripped  and/or sparged  by the air used by the UVB
technology; (3) In assessing changes attributable to rainfall
and groundwater migration onto and  off the test plot over
the course of the demonstration, and (4) other, unknown
factors,  it was agreed that this objective would only be
evaluated in a  qualitative sense.   To  assist in this
evaluation, supportive evidence such as the production of
cis-1,2-d!chloroethene, vinyl chloride, and carbon dioxide;
the consumption of oxygen; and increases  in microbial
colonies would be used to support any conclusion.

4.2    Detailed Process Description
The ELI/SBP  UVB (Vacuum Vaporization)  Technology
uses  a combination  of  air  extraction/injection  and
groundwater pumping through one or more central wells to
create a circulation loop between the upper and the lower
limbs of the saturated zone. Indigenous bacteria can then
proliferate on the biofilter in the central well, with some of
the bacteria being transferred back throughout the radius
of influence with the returning water. The lithology of the
formation is a major factor in determining the uniformity and
radius of the  circulation loop around the central well.
Movement of air and water are induced by a submersible
pump and an air lift pump. The air lift pump also disperses
air into the water as it exits the biofilter, which contributes
to  additional removal of VOCs by  air stripping  and/or
sparging. Removal of VOCs from the vadose zone occurs
primarily as a result of this air movement.  Figure  4-1
provides a  schematic of one  configuration of the UVB
system, essentially as used in the demonstration.
For the demonstration, a single central well was installed
using a truck-mounted auger.   A 16-inch  casing was
grouted into the bedrock (approximately 20 feet bgs), and
was equipped with screening for introduction and removal
of  groundwater  at the base and in the vicinity of  the
expected water table, approximately 9-15 feet bgs. The
UVB unit includes an air lift pump and flotation chambers
which are intended to facilitate repositioning of the biofilter
as the water table fluctuates. The biofilter consists of an
activated carbon  substrate so that adsorption can assist
biodegradation. An inflatable packer separates the lower
limb and the upper limb of the well so that the water must
pass through the in  situ biofilter.   Other wells are not
required for the UVB Technology  to be operated, but
monitoring wells are desirable to estimate the distance and
uniformity of the zone being treated.

An aboveground vacuum blower is used to draw ambient
air  into the biofilter  to  provide aerobic conditions for
biodegradation. A portion of the air also escapes into the
formation with the recirculating groundwater and serves to
strip and sparge VOCs  from the formation.  The air is
withdrawn through the vacuum blower, which is equipped
with a water separator tank.  For the demonstration, two
small capacity biofilters were installed  in parallel on the
exhaust  air  line to  enable  ELI/SBP  to   evaluate
biodegradation of the  extracted VOC vapors.  Finally, a
carbon adsorption drum was added after each of the
biofilters to assure that no VOC vapors  escaped to the
environment.

Operational difficulties were  encountered with the initial
design because of a high and fluctuating water table and
excessive back pressure in the gas-phase biofilters. As a
result,  design  changes were made after the December
1994 sampling event to simplify positioning of the in-well
biofilter in  response to water  table fluctuations. The gas-
phase  biofilter system was also  totally  redesigned to
minimize back pressure.
Auxiliary equipment included the water separator  tank,
aboveground gas-phase biofilters, and carbon adsorption
drums  on the exhaust side of the blower.  The blower and
pump operated automatically and unattended. An operator
was required to make intermittent measurements of the
water table level and, when necessary, to oversee the
repositioning of the  in-well biofilter system.   Initially,
repositioning of the well system required a crane or drill rig;
the design  changes made  in December 1994 allowed
repositioning to be done with a block and tackle.

4.3    Methodology

The protocol devised to evaluate the ELI/SBP technology
included sampling of the soil in the expected vadose zone
of the test plot at the beginning of the demonstration (Event
0),  after about three months  (Event 1) to provide data for
an  intermediate stage, and after about six months (Event
2).   When the  project  was extended, two  additional
sampling events were added: after 10 months (Event 3)
and at the new end of the demonstration (Event 4), after a
total of approximately 14 months.   At the outset of the
project in July 1994,  the  50 ft x 50 ft plot surface was
divided into a 3 by 3 grid (-16 ft by -16 ft) and 2 inch
diameter soil borings from the expected vadose zone were
removed  and  immediately  screened  with  a field PID
instrument.   On the  basis  of   volatile hydrocarbon
                                                    4-2

-------

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Figure 4-1. DVB System schematic.
                                                    4-3

-------
distribution indicated by the PID readings, an additional 16
soil sampling points were selected in what appeared to be
the more contaminated portion of the plot.  Figure 4-2
provides a schematic of the resulting 25 sampling points.
(The sampling point locations were also used later to define
the surface areas when calculating volume elements for
VOC  mass calculations.)    All soil  borings  for all
subsequent events were obtained as close as possible to
these 25 locations using  2-ft split spoons and a truck-
mounted drill rig.
A number of four inch diameter groundwater wells were
also  installed  with the same truck-mounted  drill  rig;
screened casings were installed so that shallow and deep
wells were paired at radii of about 20 ft, 30 ft, and 40 feet
in the northeastern direction and 20 ft in the southwestern
direction from the UVB well. These wells were screened at
~7 to 10 ft and at -16 to 20 ft (bgs), respectively. Plans to
Install a third well at each groundwater well location so that
gaseous contaminants could be captured were abandoned
because of the very shallow vadose zone.
Further, although soil cores were obtained in each of the
25 locations, visual observation indicated that some of the
2-ft split spoon cores were vadose zone while others were
saturated zone. Consequently, a field decision was made
to sample each zone separately;  each  2-ft  core  was
scanned with a PID and a subsample was then removed
from the segment of the core with the highest PID reading
for VOC analyses.   Where more than  one 2-ft  core
represented the vadose or saturated zone, the laboratory
was instructed to composite these cores in methanol (1:1)
before completing the analysis by SW 846 Method 8260.
After  the rapid transfer of VOC samples  had  been
completed, the  remaining soil (vadose or saturated) was
composited in the field for various other parameters  (e.g.,
phosphorus, nitrogen, metals, microbial populations, etc.)
requested by the developers.
The -5 '/a month (Event 2) samples were used to evaluate
ELI/SBP's ability to achieve the NYSDEC Cleanup Criteria,
and  the final (14 month) samples were also  evaluated
against the same objectives. The change in concentration
of each VOC  from the beginning  to  the end of the
demonstration also was used to calculate an estimated
value  for  the  mass of each  VOC removed by all
mechanisms.  The volume of each sub-plot element was
calculated on the basis of the core length and the surface
area assigned to that sub-element. Density of the soil in
the plot was determined twice over the course of the
project so that the vadose or saturated zone soil volumes
could be converted to mass when calculating the mass of
VOCs  in  each sub-element and then in the total  plot.
Masses rather than concentrations were used  in all
calculations to  account for the different vadose and
saturated zone depths; in effect this provided weighted
concentrations.  Ail summarized results are reported on a
dry weight basis.
To account for any stripping and sparging of VOCs by the
air extracted from the system by the vacuum blower, and
also to evaluate the effectiveness of the ex situ biofilter(s)
on the exhaust line, the agreed-to plan also called for VOC
analyses of the air before and after the ex situ biofilter(s)
and before the carbon adsorption drums at several times
over the course of the demonstration (initially, 3,13,20,36,
and 64  weeks).  SUMMA canisters  (6L) were used to
collect these samples, which were then analyzed by EPA
Method  TO-14 for VOCs.  Combined with temperature,
barometric pressure,  differential  pressure    for the
sampling, and airflow data for the system provided by the
developer from  operating logs, these concentration data
allowed  calculation of the average mass removal of each
VOC in  the extracted air stream over the course of the
demonstration and the  portion removed  by  the ex situ
biofilters. Because of previous SITE program experience,
a water impinger was included in the sampling train before
the SUMMA  canister.   However,  very little water  was
collected in these impingers and the removal of VOC mass
in this water was consistently negligible.  The SUMMA
canister air samples were also analyzed for oxygen, carbon
dioxide, and  total non-methane hydrocarbons by EPA
Method  TO-13 during each sampling event.
VOCs could  also leave the ELI/SBP plot in the water
separator on the blower. The volume of water discharged
automatically from the separator was documented during
each sampling event using a totalizing meter and the water
was analyzed for VOCs  (SW-846 Method 8260)  at the end
of the demonstration. Using the total volume of water, the
mass of VOCs  lost in the water was then estimated; the
mass lost in this water was small.
All participants recognized at the outset of the project that
transfer of VOCs  into the groundwater could be another
significant route for loss of VOCs  from the vadose and,
particularly, the saturated soil. However, the intent of this
project  was to evaluate the effectiveness of the  UVB
system  in removing VOCs (including chlorinated VOCs)
from the vadose zone.  Consequently, although no effort
was made to measure  the flow of groundwater over the
duration of the  project or the mass of VOCs leaving - or
entering - the test plot by groundwater migration, each pair
of shallow and deep groundwater wells was sampled to
determine if there was evidence of a  circulation loop both
in the lateral and the vertical direction.  The unexpected
influx of surface water  and the unexpectedly high water
table encountered during portions of the project make
interpretation of these results even more tenuous.
ELI/SBP  was  responsible  for  operating  its system,
obtaining monitoring data and making any adjustments
necessary for optimization. Soil and groundwater samples
obtained by EPA's contractor were used to provide soil and
                                                    4-4

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                     0
                     SB1

                     SB7
                                           SB17            SB15       SB16
                                                                                         N
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 •     •
SB24   SB20
©
§83
                                      •
                                     SB25
                                                SB10
                                              ©
           ^
           •      •
         SB23   SB14

               •
              SB19
                                                                               SB22
                                                                       SB21
                                            *
                                           SB11
                SB13
                                                ©
                                                 • SB12
                                              50'
                                   •   UVB System Well

                                  (•)  Initial Borings No. 1-9

                                   •   Borings No. 10-25
                           ®

                            SB9
Figure 4-2. ELI/SBP treatment plot showing soil boring locations.
                                               4-5

-------
groundwater characteristics (pH, metals, nitrogen forms,
phosphorus, microbial counts, etc.) that aided in making
these decisions.

 4.4   Performance Data

This section presents the performance data gathered by
the  testing  methods  described  above.   Results are
presented and interpreted in the following paragraphs.

4.4.1 VOC Concentrations in Soil  Initially
       and at Completion

Using the 25 sampling locations identified in the  initial
sampling, approximately  50 soil  samples  of the zones
designated visually as vadose and as  saturated  were
collected  initially  and during each of the succeeding
sampling  events  over  approximately  14 months  of
operation of the ELI/SBP  UVB System. Each soil boring
was taken as close as possible to the approximate center
of each sub-element on the grid, considering the limitations
of the available drilling equipment and the proximity  of the
grouted holes from earlier borings.   Core sections for
analysis were selected by scanning the core for the highest
reading using a field PID. Each core was then analyzed for
a full suite of VOCs according to SW-846 Method 8260 but
only the  critical VOCs for this study (and toluene  as an
indicator of other aromatic VOCs) are presented and
discussed in detail in this Innovative Technology Evaluation
Report. The complete VOC summaries are available in the
Technology Evaluation Report (TER). High concentrations
of  toluene and other alkyl benzenes, including  ethyl
benzene, xylenes, and various trimethylbenzenes, suggest
that the  contamination is indicative of past disposal  of
waste hydrocarbon solvents on the site. Also, because the
concentrations of non-critical VOCs (e.g., toluene) often
were  very  much  higher  (-10X)   than  the critical
contaminants, rather high detection limits were reported for
some of the samples.  This had a major impact on the
ability to evaluate and interpret the results of the pilot-scale
 demonstration.
 Because of the interference by the aromatic VOCs and the
 resulting high detection limits, a non-statistical approach
 has been taken to the interpretation of the results. All data
 are presented in two forms, first using the  Practical
 Quantitation  Limit (PQL) and then using a hypothetical
 value of "0" where a value of "ND" had been reported for
 that critical VOC. Considering the sources of error in the
 sampling, transfer (into jars, during shipping and then
 during subsampling into methanol), and analysis of the soil
 samples, it is believed that this approach provides the
 reader with a range of maximum  and minimum values
 which are more  useful than a statistical approach that
 would Impart some quantified confidence level to the data.
 Where  the two  approaches yield large  differences in
masses, it indicates that many of the concentrations were
reported as "ND".

For  purposes  of  determining  whether  the  VOC
concentration for a particular sub-element core sample
satisfied the NYSDEC Soil Cleanup Criteria (first primary
objective) at Event 2 and then at Event 4, the end of the
demonstration,  only the  higher  value, based on  the
Practical  Quantitation Limit (PQL), was used. However,
because  the high detection limits (PQLs)  reported for
acetone  and 2-butanone (MEK) usually exceeded  the
NYSDEC Soil Cleanup Criteria, these values could not be
used in assessing the success of the treatment.   The
detection limits for 4-methyl-2-pentanone (MIBK) and for all
of the chlorinated ethenes were usually below the NYSDEC
Cleanup  Criteria and allowed the results to be used in
assessing whether the sample met each of the NYSDEC
Cleanup  Criteria.  Table 4-2 provides a summary of the
results for the  six critical contaminants relative to the
Cleanup  Criteria.  Using the measurable values and PQL
values that were less than the  Criteria, the ELI/SBP

   Table 4-2.  ELI/SBP Achievement of New York
              State Cleanup Criteria

                Results after 5 Months
Compound
Acetone
MEK
MIBK
DCE
TCE
PCE
Total
#Met
Criteria
0
0
21
14
27
29
91
# Usable
Points (*)
11
12
23
32
31
31
140
% Met
Criteria
0
0
91
44
87
94
65
                Results after 14 Months
Acetone
MEK
MIBK
DCE
TCE
PCE
Total
0
4
45
22
45
44
160
19
25
46
46
46
46
229
0
16
98
48
98
96
70
    Note: (*) Data for samples reported as non-detectable
    were not used in the evaluation if the detection limit was
    above the NYSDEC criterion.
    Developer is intentionally "credited" with any samples
    that were uncontaminated initially.
                                                    4-6

-------
technology achieved a 65% compliance with the NYSDEC
Soil  Cleanup Criteria, after  5.5 months.   Although
contaminant concentrations did continue to decrease over
the remainder of the project, even after 14 months of
treatment only a 70% compliance was achieved.  In each
case, these  values are well below the 90% claim.  For
comparison, it may be noted that the concentration data at
the outset of the project indicate a 67% compliance before
the  technology  was  undertaken.    Although  these
compliance  results appear to  imply little improvement,
significant removal of at least some of the contaminants
was achieved over 14 months, even if the residual levels
still exceeded the NYSDEC Cleanup Criteria.  Changes in
VOC masses (discussed later), probably are a more useful
indicator of treatment effectiveness.

4.4.2   Change in Mass of VOCs in  Soil with
        Time

The mass of a VOC in the vadose or saturated zone of a
particular sub-element was calculated by multiplying the
concentration found in that sub-element, the volume of the
sub-element based on the surface area and the length of
the zone, the experimentally determined  density, and the
moisture content (to correct to dry weight), as shown in the
following equation:
   Massv = concv x volume x density x (% solids/100)

with units of:

            mg = ug/Kg x cm3 x gm/cm3 x 10"6

where massv and  concv refer to an individual VOC. The
total mass of a particular VOC in the entire test plot, initially
and at any later time in the demonstration, needed  to
                        estimate mass changes over time, is then obtained by
                        adding the masses in  all vadose and saturated zones.
                        Although  sampling procedures  may  be biased when
                        calculating total  mass  in  soil,  the  use of the same
                        procedure  at the beginning and at the end of the
                        demonstration should allow for comparable data when
                        calculating overall percent removal efficiencies.

                        A summary  of the masses calculated  at the  various
                        sampling times is given in Table 4-3. All calculated VOC
                        masses were highest during the 3-month sampling event
                        (Event 1)  and then  appeared  to decrease  over the
                        remaining  11  months of the  investigation.    This
                        phenomenon has been observed in another study of the
                        UVB Technology, but the non-representative "hot  spot"
                        sampling  must be considered  to be another  possible
                        explanation (although it was not observed in the other two
                        technologies). Toluene, included as an indicator of other
                        aromatic VOCs found to be prominent in the test plot,
                        exhibited similar behavior.

                        Graphical presentation of the initial and final mass results
                        for each critical VOC, calculated from the experimental
                        concentrations and the PQLs for ND determinations, as
                        shown in Figures 4-3 to 4-9, clearly shows the very non-
                        uniform distribution, as well as the decrease in  specific
                        VOCs  over  the course  of the  14  months  of the
                        demonstration.   The   non-uniformity   may   reflect
                        heterogeneities in site geology and hydrogeology, local
                        residues of VOCs from drums of chemicals that  were
                        removed, movement with groundwater, or sampling and
                        analytical problems.  For each sample point, the mass
                        value represents  the sum of the masses calculated  as
                        present in the vadose and the saturated  zone using the
                        PQL value for all "ND" results.
 Table 4-3. Masses of Contaminants (gm)* in Plot at Various Times

  Compound                                            Time (months)

                                   0               3             5.5
                                                   10
                                                                                                14
Acetone
MEK
MIBK
3,700
6,300
2,200
4,200
8,800
3,500
2,700
5,300
2,300
1,900
4,400
970
960
2,100
440
  DCE

  TCE

  PCE
 1,900

 1,500

   380
  3,900

  8,200

  3,500
1,500

4,500

  680
1,400

 660

 890
1,200

3,200
  350
  Toluene
58,000
100,000
                                                              55,000
               20,000
               7,400
 * Masses calculated from concentrations and volume elements.  For non-detect values, the Practical Quantitation Limits were
  used.
                                                  4-7

-------
Figure 4-3. Acetone masses at three times.
                                                     4-8

-------
Figure 4-4.  MEK masses at three times.
                                                     4-9

-------
                               1000





                                800






                                eoo





                                400
Figure 4-5.  MIBK masses at three times.
                                                    4-10

-------
Figure 4-6.  Cis-DCE masses at three times.
                                                     4-11

-------
Figure 4-7. TCE masses at three times.
                                                    4-12

-------
       gOO
        180
        100
                                                              300
                                                              ISO
                                                              ioo
                                   8OO
                                   160
                                   100
Figure 4-8. PCE masses at three times.
                                                     4-13

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Figure 4-9. Toluene masses at three times.
                                                      4-14

-------
The Technology Evaluation Report (TER) contains tables
which, in  addition  to a  summary  of the achievement
of the NYSDEC Cleanup Criteria, present the concentration
and mass data for all soil samples initially, after 3 months,
51/2  months, 10  months,  and  at  the end  of  the
demonstration (14  months).  Tables are provided using
both the PQL values and "0" for "ND" values to provide the
reader with the high and low masses that could be present.
In addition to the six critical VOCs, concentration and mass
data are also provided for toluene.  Since toluene was
found  at  significant  concentrations  in  essentially  all
samples, the masses calculated using  PQL  or "0" are
approximately the same.

4.4.3  VOCs in  Air Samples

Samples of the air exhausted from the ELI/SBP extraction
manifold were collected in 6L SUMMA canisters (1) after
the water separation tank and before the ex situ biofilters
and (2) after the ex situ biofilter(s) and before the carbon
adsorption drums so that the effectiveness of  the ex situ
treatment  could  also be evaluated.  This procedure was
carried out in duplicate at the start of the project, after ~3
weeks, ~13 weeks, -20 weeks, -36 weeks, and finally at
the end of the demonstration (-64 weeks).  Air samples
were analyzed for VOCs by Method TO-14 and for oxygen,
carbon dioxide,  and non-methane hydrocarbons by EPA
Method TO-13.

The VOC concentrations leaving the in situ system were
then converted to instantaneous mass flow (mg/min) at the
time  of sampling  using temperature  and   differential
pressure to calculate flow during sampling.   These
instantaneous  mass flows were  then plotted  using
ELI/SBP's records for air flow through the system over the
course of the demonstration (taking  into consideration
inoperative time due  to power failures, maintenance
shutdowns, etc.) to estimate the  total mass of  each VOC
removed  in  the air  stream  over the course  of  the
demonstration (Table 4-4) using a bar graph approach. In
addition to the critical VOCs  and  toluene, the air samples
(and groundwater samples but not the soil samples) also
did  contain significant concentrations of vinyl chloride,
suggestive of anaerobic biodegradation of  chlorinated
ethenes.

The air results provide the basis for several  interesting
observations. First, the presence of acetone  and MEK,
even if at relatively low concentrations, makes it difficult to
accept the "0" values for "ND" in  the soil samples; clearly
some concentrations of these VOCs must have been
present.  Second, there  was a significant and relatively
rapid  decrease in the concentration  of  all  VOCs,
particularly early in the demonstration. This suggests that
pre-existing VOCs were being removed during the early air
sampling  and/or  that  volatilization  becomes a  less
important removal mechanism as other mechanisms, e.g.,
biodegradation, accelerate.  Third, while no vinyl chloride
was detected in the soil, even when low detection limits
were ultimately attained,  the detection  of  significant
concentrations of vinyl chloride in the  air  suggests that
anaerobic biodegradation of chlorinated ethenes is taking
place,  due to (1) incomplete success in  achieving an
aerobic environment throughout the soil, or (2) anaerobic
degradation  before   the  ELI/SBP  process   became
operative. Transfer from outside the test area could also
be an explanation for vinyl chloride and other VOCs in the
air stream.

From a comparison of VOC concentrations or masses in
the air before and after the ex situ biofilters, it is clear that
little if any VOC-contaminated air was passing through the
biofilters during the first six months of operation of the DVB
Treatment  Process.   Very low  air flows through  the
biofilters  also supported  this  conclusion.  When  the
biofilters  were redesigned and installed before the April
1995 sampling event to minimize  back-pressure, air flow
data confirmed that improved passage of air was occurring,
with airflows of-95 dry standard cubic feet/minute (dscfm)
now being achieved through each of the two parallel
biofilters. Comparison of VOC concentrations before and
after the  parallel biofilters now indicated removals in the
range of  50% to 80%, as shown in Table  4-5.  It is not
possible to state whether the observed removals were due
to adsorption, biodegradation, other mechanisms, or a
combination.

Only very low concentrations of the critical VOCs were
found in  the water collected in the impingers in  the
sampling  train  before   the  SUMMA  canisters.
Consequently, the contribution of this water to VOC mass
removed  by stripping was insignificant (<1 % of the mass in
the air). Similarly, when the combined water from the water
separation tank was analyzed at  the end of the project,
very low concentrations of VOCs were found  and the
calculated masses were, again, insignificant.

4.4.4  Mass    Removal    of     VOCs-
       Biodegradation Contribution
Removal  of an individual VOC, v, over the course of the
project BY ALL MECHANISMS is calculated by comparing
the initial  mass to the final mass of that VOC in the soil:

     % Removal,, = 100 x (MassVi, - Massvf)/Massvi.
These  results are summarized in  Table  4-6 and  are
presented for the two scenarios described earlier, with ND
= PQL and with ND = 0, to provide the range of high and
low masses  that might be present in the formation.
Because  only a very shallow vadose zone was found to be
present, the weighted masses for vadose and saturated
zones between 9 and 15 ft bgs have been combined.
                                                  4-15

-------
Table 4-4. Mass of VOCs Removed in Air Stream by ELI/SBP Technology*
  Type of Analysis                  Compound
                                    Mass (g) Removed
                                      Over 14 Months
  Critical
  Non-Critical
  Acetone
    MEK
    MIBK
  cis-DCE
    TCE
    PCE
  Toluene
Vinyl Chloride
 120
 58
 69
2,200
 510
 120
1,900
 260
* Elapsed operating days: 425;  blower operation: 24 hours/day.
Table 4-5. Removal of Critical VOCs from Air Stream by Ex Situ Biofilters
                      5/95 Inlet               Biofilter A Outlet
                                              Biofilter B Outlet
Compound

Acetone
MEK
MIBK
cis-DCE
TCE
PCE
Toluene
VC

Compound
Acetone
MEK
MIBK
ds-OCE
TCE
PCE
Toluene
VC
Mass Flow
(mq/min)
.24
<.02
<.005
.40
.11
.10
.26
.006
10/95 Inlet
Mass Flow
(ma/min)
.26
.32
.38
12.55
2.16
.89
17.83
2.43
Mass flow
(ma/mm)
.08
.15
<.02
.07
<.02
.04
.05
<.002
% Removal

65
—
-
82
77
53
81
54
Biofilter A Outlet
Mass flow
(mo/min)
.09
.10
.18
5.61
.95
.37
.23
1.20
% Removal
65
68
54
55
56
58
54
51
Mass flow
(ma/mm)
.07
.12
<.003
.22
.04
<.02
.07
<.02
Biofilter B
Mass flow
(ma/min)
.06
.06
.10
4.86
.80
.35
7.54
1.06
% Removal

70
—
52
46
61
74
73
~—
Outlet
% Removal
78
81
73
61
63
60
58
56
                                                  4-16

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    Table 4-6. Removals after 14 Months Using PQL for ND
Compound
Acetone
MEK
MIBK
DCE
TCE
PCE
Toluene
Compound
Acetone
MEK
MIBK
DCE
TCE
PCE
Toluene
Mass in Soil
(gm)
Initial Final
3,700
6,300
2,200
1,900
1,500
380
58,000
960
2,100
440
1,200
3,200
350
7.400
Using "0" for ND
Mass in Soil
(gm)
Initial Final
2,000
4,500
280
1,800
1,500
350
58,000
610
1,600
130
1,200
3,100
320
7,400
Overall
Percent
Removal
74
67
80
37
8
87
Overall
Percent
Removal
70
64
54
33
9
87
Mass (gm)
Removed in
Air and
Water
120
58
69
2,200
510
120
1,900
Mass (gm)
Removed in
Air and
Water
120
58
69
2,200
510
120
1,900
Contribution
(%) to Removal
Attributable to
Bioremediation
96
99
96


96
Contribution
(%) to Removal
Attributable to
Bioremediation
92
98
54


96
Removal by
Bioremediation (%)
71
66
77


84
Removal by
Bioremediation (%)
64
63
29


84
Subtracting the total mass  of  a  VOC removed by air
stripping over the course of the demonstration (Massva), as
determined by the SUMMA  canister sampling of the air
stream leaving the UVB well,  from the total mass removed
(Massv j - Massvf), and, noting that removal in the impinger
and separator water was  insignificant, the resulting value
is an estimate of the removal by bioremediation.

  % Bioremovalv = 100x(Massvi-Massvf-Massva)/Massvi

Although it is recognized that  considerable masses of
VOCs may be present in  the groundwater and may have
been  removed  from the vadose zone and from  the
saturated zone both  by the natural water flow and by the
water circulation induced by  the UVB system, that route
has not been included in the  analysis.  (Changes in VOC
concentrations  in  the  several pairs  of  groundwater
monitoring wells are discussed, albeit briefly, in Section
4.4.7.)

This estimate of VOC mass  removal from the soil also is
limited by the sampling procedures.  Sample cores were
sectioned  for  analysis  by   selecting  "hot  spots"  as
determined by a field PID.  Hot spots in the soil were
potentially  recognized  with  the PID by  the  high
concentration of TCE or other VOCs such as toluene.
There were  possibly hot spots containing even  higher
concentrations of cis-DCE in the collected soil cores, but
these may not have been sampled due to  the  higher
concentrations  of  TCE   or  toluene  detected  and
subsequently selected for sampling and analysis. (The PID
will not distinguish between cis-DCE and TCE and the
relative  response factor for  these two compounds  is
unknown.  It may be that one compound will respond much
better than the other, meaning concentrations cannot be
compared  based on PID response. The response factor
for toluene is  known to be considerably higher than that for
chlorinated hydrocarbons.)

It  could,  consequently, be argued that the sampling
procedures missed the cis-DCE "hot spots" because of the
higher concentration of or better response to TCE or
toluene "hot spots". The true average soil concentrations
for these compounds may be  more than detected for the
cis-DCE and less for the TCE or toluene.  This could
explain why cis-DCE concentrations in the air samples are
so much greater than  concentrations in  the soil samples.
This same argument would suggest that average TCE (or
toluene) soil  concentrations may be lower.  Higher soil
                                                  4-17

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concentrations of cis-DCE and lower TCE concentrations
would mean that the biodegradation mechanism is actually
less significant than noted by the collected data. For this
reason,  comparing total mass data is inadequate  to
establish the role of biodegradation.
For the ELI/SBP technology, the mass balance approach
does indicate that extensive removal from the plot is only
achieved for the ketones, even  after  14 months  of
treatment,  using the initial (Event  0) samples as the
baseline. Of the calculated removal, at least for acetone
and MEK, bioremediation potentially accounts for the major
portion (between 96% and 99%), based on the low removal
by stripping. Because of a high frequency of "ND" values
for MIBK, both the removal efficiency (between 80% and
54%) and any estimate of biodegradation (96% to 54%)
should be  considered very skeptically.  After only 5.5
months, at the originally planned completion of the project,
residual  masses  of acetone, MEK,  and  cis-1,2-DCE
Indicated removal, while  the  calculated masses of the
critical VOCs found in the soil were higher than the original
masses for the remaining three of the six critical VOC
contaminants: MIBK, TCE and PCE (see Table 4-3). As
noted  earlier,  this  could  be  the  result  of  the
nonrepresentative sampling approach  or  inexperience
during the first sampling and analysis effort that allowed
VOCs to escape at some  point during the procedure.
However, this behavior was not observed in the other two
vendors' tests. The unique characteristics of the UVB
treatment  process   also   may   have   redistributed
contaminants, as has been observed in other evaluations
of the technology.  This  was, in fact, one of the major
reasons for continuing the test for a longer time period.

Even using the results after 14 months of total treatment,
it is not possible to reach conclusions concerning the role
of biodegradation for the chlorinated VOCs  based on the
mass balance calculations. The large mass of DCE found
fn the air stream exceeded the removal (between 37% and
33%) from the soil, making it impossible  to make any
statement concerning biodegradation. Some portion of the
DCE mass found in the soil and in the air may be the result
of accelerated biodegradation of TCE and PCE due to the
UVB process, but this cannot be  confirmed.  Another
contributing factor to these anomalous results may be that
a portion of the cis-DCE found in the air samples may
reflect cis-DCE in the pore spaces from pre-demonstration
natural biodegradation of various chlorinated VOCs. Cis-
DCE is an initial biodegradation product of TCE and PCE.
Since cis-DCE  is not widely used  as a commercial
chemical, it is unlikely that the observed cis-DCE in the soil
or the air was the result of disposal at the site in earlier
years. A mass balance calculation also cannot be carried
out for TCE since the total mass found in the final samples
after 14  or 5.5 months exceeded the  initial mass without
even considering the calculated mass removed in the air
stream.  For PCE, concentrations were low at all sampling
times and the total removal from the soil is small (7% to
9%) and far exceeded by the calculated mass (118 gm) in
the air stream.  The vinyl chloride observed  in the air
samples may be the result of further biodegradation of the
cis-DCE, but vinyl chloride is usually considered to be the
result of anaerobic, but not aerobic, biodegradation.

The results for toluene provide a less ambiguous data base
from  which to reach some conclusions, particularly since
essentially  all  soil  samples   contained  measurable
concentrations. The comparable calculations indicate that
approximately 4% of the toluene is removed from the soil
by all mechanisms over 5.5 months and 87% is removed
after 14 months. Of the 87% removed after 14 months,
only  4% is  accountable  by stripping based  on mass
balance comparisons; consequently, it may be concluded
that as much as 96% of the 87%, or 84%, is removed by
other mechanisms  such  as biodegradation.  As noted
earlier, losses to groundwater, to surface water flushing,
and by surface vaporization could not be measured and
are not included in this analysis.  And, as  noted earlier,
sampling bias also may be a factor contributing to the
assumption that the removal mechanism is biodegradation.


4.4.5  Other   Supporting    Evidence   for
        Biodegradation

Several factors were identified at the outset of the project
to provide at least circumstantial supporting evidence that
biodegradation was  or was not a  major mechanism for
removal  of the critical VOCs.   These  included the
production  of cis-DCE and/or vinyl chloride, changes in
oxygen and carbon dioxide concentrations, and changes in
microbial counts.
As discussed in the previous section, the cis-DCE results
are not clear, but biodegradation of TCE and PCE to cis-
DCE could be a contributing explanation. The vinyl chloride
results also would be useful except that (a) the ELI/SBP
system  is   intended  to  be operating under aerobic
conditions where vinyl chloride should not be the expected
product, and (b) vinyl chloride concentration in the air was
high at the beginning of the demonstration when vinyl
chloride would be easily stripped from the pores in the soil,
but also was measured as high at the end of the 14- month
study.
Observed  decreases  in  oxygen  concentrations  and
increases in carbon dioxide in the extracted  air would
normally be used  to suggest that biodegradation  is
occurring.    However, over the  course of  the  UVB
demonstration, oxygen concentrations in the extracted air
remained fairly consistent at -21%  and carbon  dioxide
concentrations were usually quite low.  These results do
not  provide  support  for the  presence of accelerated
biodegradation by the ELI/SBP technology; however, since
the UVB process continually introduces air, large changes
                                                   4-18

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in oxygen and carbon dioxide probably should not have
been expected. Shutdo.wn tests may have provided more
valuable  evidence of changes  in  oxygen and  carbon
dioxide. In addition, considering the high concentrations of
toluene and other aromatic hydrocarbons, it would not be
necessary to  attribute  any changes preferentially to
biodegradation of the six critical VOC contaminants.
Similarly, neither high levels nor large increases were
observed in the counts of total heterotrophs found in soil
samples over the course of the demonstration.  This is
somewhat surprising when one  considers  the  high
concentration of other VOCs present in the soil. TCE-
degrader counts also were low, and appeared to decrease
over the course of the demonstration  (Table 4-7). Total
heterotrophs and TCE-degraders in groundwater from the
monitoring wells both decreased over the course of the
project and, consequently, also do not provide evidence for
biodegradation. There were wide variations in all microbial
counts for different soil and groundwater samples, making
interpretation even more unreliable.
4.4.6 UVB   Well   Characteristics/In
       Biofilter Behavior
Situ
The biofilter in the central UVB well contained 200 Ibs of a
carbon-based medium through which groundwater flowed
at ~8  gpm  as part of the circulation  loop.   This is
considered by the developers to be the  main source of
biodegradation of VOCs in the groundwater. Samples of
the water entering and leaving the biofilter were tested for
VOCs during each sampling event. The results indicate (a)
a decrease  in VOC concentrations by passage through
the biofilter and (b) a decrease in the concentrations of the
VOCs  entering the biofilter over the   course of the
demonstration. The highest VOC concentration, observed
for cis-DCE during the initial sampling time, was still less
than 500 ug/L; over the course of the demonstration the
concentrations decreased until they were all essentially
below  the PQLs during the final  sampling event in
September  1995.   ELI/SBP planned  to  carry  out  a
supplemental study to determine the portion of the removal
that can be attributed to adsorption and that portion that
might be assumed to be the result of biodegradation on the
biofilter; however,  the  results  of that study  are  not
available.  The results for the estimated percent removals
for each VOC  over time are shown in Table 4-8; actual
VOC concentrations decreased from several hundred ppb
initially to 100 ppb or less by Event 4 (14 months) when
removals could no longer be calculated for the critical
VOCs.

4.4.7  Groundwater
At the  outset of  the  demonstration,  four  pairs  of
groundwater monitoring wells were installed in an effort to
observe changes in  VOC concentrations at  different
distances  and times as the demonstration progressed.
Each pair consisted of a shallow well with screening above
the expected water table (~7 -10 ft bgs) and the second
one with screening near the bedrock (20 ft bgs). Shallow
and deep  wells were  chosen because of  the different
solubilities and densities of the ketones and the chlorinated
VOCs. One set of wells was installed 20 ft  southwest of
the central UVB well, in what was believed to be the up-
gradient direction. The other three pairs were installed in
the northeast or down gradient direction at distances of 20
ft, 30 ft and 40 ft (see Figure 4-2). Only wells at 20 ft and
30 ft were  expected to be within the radius of influence of
the treatment process.  In addition, a pair of shallow and
deep wells was also installed close to the large UVB well to
serve as the "0" distance well pair. All wells were sampled
approximately  coincident with the removal  of soil cores
throughout the demonstration.  Plans to  install vapor
sampling wells at each location were abandoned because
of the shallow vadose zone.
The VOC concentration results obtained over the course of
the demonstration  were very variable.  Coupled with
changes in the water table, any attempt at assessment of
the changes would be very uncertain.  Qualitatively, while
some contaminants actually increased in some wells during
    Table 4-7. Average Microbial Counts in ELI/SBP Demonstration Soil and Groundwater
Soil
Total Heterotrophs
TCE-Degraders
Total Heterotrophs
TCE-Degraders
Initial cfu/qm
580,000
160,000
Groundwater
2,700,000
56,000
6 Month cfu/am
1,300,000
100,000
cfu/ml
470,000
13,000
14 Month cfu/am
3,900,000
11,000
550,000
1,000
                  cfu = colony forming units
                                                   4-19

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   Tablo 4-8. Percent Removals for the In Situ Biofilter Based on VOC Concentrations

             Event:        Initial             "1"              "2"              "3"
Compound
Acetone
MEK
MIBK
ds-DCE
TCE
PCE
Toluene
VC
0 Months
16
_
—
38
33
-
33
13
3 Months
—
—
—
0
41
—
71
-
5.5 Months
-
—
—
14
33
—
45
-
10 Months
--•
—
—
92
92
—
97
~
14 Months
ND
ND
ND
ND
ND
ND
0
ND
                  ND = reflects influent and effluent values below PQL
some of the samplings, there were also indications of
decreases  in  others.  Any definitive observations or
conclusions concerning the  groundwater are  left to
ELI/SBP, who sampled more frequently.  It is important to
note that vinyl  chloride was present in concentrations as
high as 37,000 ug/L in some of the groundwater samples
and seemed to increase during the demonstration.  The
potential production  of vinyl  chloride will need  to be
examined carefully in other installations.

4.4.8  Distinctions  between   Vadose   and
        Saturated Zones
Because of the unexpectedly high water table, the soil
samples that were obtained from the  ELI/SBP plot often
were not from only  the vadose  zone.   A rapid, visual
determination  was made  by the field  geologist as to
whether a  particular 2-ft split spoon  core  was vadose,
saturated or a  mixture.  Vadose and saturated soils were
then submitted for separate VOC analyses.   Since the
vadose zone was often small, the data and comparisons
presented earlier in this report re-combine the masses for
saturated and vadose  zone samples to  evaluate the
effect of the technology on both zones within the 9-15 ft
bgs  zone originally expected  to represent vadose zone
only.
It is, however, interesting to consider the possible different
effects that might be observed on the two separate zones.
For example, the water-soluble ketones might be expected
to concentrate in the saturated zone where biodegradation
is apt to occur while the less water soluble chlorinated
ethenes might be expected to concentrate  in the vadose
zone where soil vapor extraction and stripping would be
expected to play a larger role.  When the masses for each
VOC in  the soil samples for each sampling event were
assigned to vadose or saturated zones on the basis of the
visual designation, it appears, as shown in Table 4-9, that
the  initial  removal or  loss occurs preferentially in the
vadose zone while the longer term (14 month) removal
appears to be more uniform in the two zones. Clearly other
factors, such as the high-biased sampling noted earlier and
the  inclusion  of PQL  values  for  "ND"  results,  the
temperature, the remaining concentration of each VOC in
each zone, the water table, the modifications to the system,
etc. all could be influencing the results.
In addition, the impact of these designations as vadose or
saturated  zones on the  apparent  achievement  of the
NYSDEC Soil Cleanup Criteria was also assessed but
found  to  be  negligible.    Thus,  where  the  overall
achievement after the second  event (5.5 months) was
65%, the vadose zone compliance was 63%; after 14
months the values were 70% and 67%, respectively. Once
again, however, the limitations of this analysis must be kept
in mind.

4.4.9 Process Residuals
Since the ELI/SBP process is primarily an in situ process
(excluding the ex situ gas phase biofilter), there should be
no actual residuals during treatment. However, because
extracted   air  could   have  contained  unacceptable
concentrations or total masses of VOCs, ELI/SBP agreed
that it would be prudent to install adsorbent carbon on the
exhaust line after the ex situ biofilter(s). Monitoring by PID
demonstrated that the carbon was effective  in removing
any VOCs over the course of the demonstration, with no
VOCs detected in the final exhaust gas. At the end of the
demonstration, the carbon was tested and, on the basis of
results that showed it to be non-hazardous, it was returned
to the supplier for steam  regeneration.
Similarly, the water accumulated in the water separator
tank and automatically transferred to an on-site storage
tank probably would require some treatment before it was
discharged, even though it was pretreated  by passage
through two drums (600 Ib/drum) of granular activated
carbon. Several options were considered by NYSDEC for
                                                   4-20

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    Table 4-9. Vadose/Saturated Zones Approximate % Removals
      Toluene
                                                  % Removal
voc
acetone
MEK
MIBK
c-DCE
TCE
PCE
tot.
-13
-40
-56
-107
-431
-826
Event 1
vad.
0
-39
-27
-33
-
-819
sat.
-34
-41
-103
-347
-288
-834
Event 2
tot. vad.
28
15
-4
22
-192
-81
69
69
26
80
74
69
sat.
-36
-77
-55
-168
-247
-250
Event 3
tot. vad.
48
29
57
28
57
-135
34
19
53
54
32
-91
sat.
69
45
63
-58
62
-185
tot.
74
66
80
36
-104
-7
Event 4
vad.
72
71
84
71
-164
33
sat.
77
59
73
-79
-92
-21
-73
-38  -194
                                             78   -252
                                         66
                                         75
36
                                                                              87
                                                                   93
                                                                   66
           Note: negative data given only to emphasize variability.
this waste stream and the decision was made by NYSDEC
to treat it again with activated carbon before it was dis-
charged to the site. The carbon used for pretreatment was
returned to  the supplier for steam regeneration  after
testing.

Another waste that was generated by the ELI/SBP process
was well cuttings generated during installation of the large
(16-inch) well and the additional monitoring wells. These
wastes  were placed in  55 gallon drums  and will  be
disposed of as part of the final site remediation. Personal
protective equipment used by ELI/SBP personnel, by the
driller, and by the sampling teams was also containerized
for eventual disposal.
                                     When the demonstration was completed, the NYSDEC
                                     required that the DVB well casing be removed. This was
                                     undertaken using  a drill rig and  a crane but was only
                                     partially successful and the effort was abandoned, with the
                                     concurrence of the NYSDEC.  The portion that could be
                                     removed was cut  into sections and stored  in 55 gallon
                                     drums  for disposal during  site  remediation.    The
                                     aboveground PVC  manifold  and  other  piping  were
                                     disposed through a local salvage firm. The vacuum blower
                                     system  was  steam-cleaned on-site  and  retained by
                                     ELI/SBP for reuse at another installation. Casings were
                                     also removed from some of the monitoring wells, cut into
                                     sections and stored in 55  gallon drums  for disposal.
                                     Several wells were left operational for future sampling by
                                     the NYSDEC.
                                                  4-21

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                                             Section 5.0
                              Other Technology Requirements
This section discusses potential permitting requirements for
operation of the UVB treatment system.  It also presents
health and safety requirements and potential hazards to be
addressed to  assure  the safety  of  workers and  the
community during operation of the technology.

5.1 Environmental Regulation  Requirements
Before implementing the ELI/SBP UVB  treatment process
as part of a remediation at another site, it usually will be
necessary to obtain a number of permits from state, federal
or local regulatory agencies.  A permit may be required to
operate the system and, in many states, a separate permit
will  be required to exhaust air with or  without treatment.
Similarly, depending on how the separator (knockout) and
monitoring  well development and   purge  water  are
managed, permits may also be required  for those activities.
Permits usually will be required for installation and closure
of the large UVB well and groundwater monitoring wells.
Permits also may be needed for storage and disposal of
any well cuttings;  if these wastes are determined to be
hazardous, on-site  storage  limitations  may  also  be
imposed.

Section  2 of this  report discusses the environmental
regulations that apply to this technology.  Table  2-1
presents a summary of the Federal and state ARARs for
the  UVB technology.

5.2    Personnel Issues
The number of ELI/SBP personnel required is  largely
determined by the extent of a planned remediation.  During
the  demonstration, two to four workers were required for
about 1 week to install the wells and the manifold and to
make the aboveground blower system  operational.  Once
the system is operational, and the flow of air adjusted, only
minimal labor is necessary for routine field monitoring and
minor system  adjustments.    This   can  probably  be
accomplished in about  1 day/week by a single technician
trained to operate and adjust the system under supervision
by telephone.  Major changes, such as those created by
power failures or significant changes in the water table are
something  of  a problem, as experienced  during the
demonstration,  and  may   require  more  extensive
readjustment of the system to restore optimum conditions.
Such efforts will require more manpower.
The health and safety issues for personnel operating the
ELI/SBP technology are generally the same as those that
apply to any hazardous waste treatment facility and are
most important during installation  of the system.  The
regulations  covering these issues are documented in 40
CFR 264 Subparts B through G and Subpart X.

Emergency response training for operation of the ELI/SBP
treatment system  is the  same as the general training
required  for operation of any treatment, storage and
disposal (TSD) facility as detailed in  40 CFR 264, Subpart
D.  Training must address  fire-related issues such as
extinguisher operation, hoses, sprinklers, hydrants, smoke
detectors, and alarm systems, as appropriate, although
these issues should  be of little risk since the system will
usually  be  outside.   Training   must  also address
contaminant-specific issues  such as  hazardous material
spill control and the  use of decontamination equipment.
Other issues include self-contained breathing apparatus
use, evacuation and emergency response planning, and
coordination with  outside emergency  personnel (e.g.,
fire/ambulance).
For most sites, personal protective equipment (PPE) for
workers will include gloves, hard hats, steel-toed boots and
Tyvek® suits.   Depending on  contaminant types and
concentrations, additional PPE may be required, such as
during the purging and sampling of groundwater monitoring
wells. Noise levels should be monitored, particularly in the
vicinity of the  blower,  to  ensure  that workers are not
exposed to noise levels above a time weighted average of
85 decibels over an 8-hour day. If this level is exceeded
and cannot be reduced, workers would be required to wear
additional hearing protection.
                                                   5-1

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5.3    Community Acceptance
Potential hazards related  to the  community  include
exposure to volatile organic pollutants that could be emitted
by the venting of exhaust air if VOCs are still present and
exposure to particulate matter that might be released to the
air during site preparation and/or well  installation.   Air
emissions of VOCs can be controlled by the ex situ biofilter
and/or activated carbon or other post-treatment systems.
Particulate matter can be controlled by wetting down the
area before and while it is being disturbed; this latter
problem would be of short duration.

Noise from the blower may be a factor to neighbors since
the blower  operates around the clock.  Berming or an
enclosure may be necessary to assure that the community
is not disturbed.
                                                     5-2

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                                            Section 6.0
                                      Technology Status
This section discusses the experience of the developers in
performing treatment using the UVB treatment process. It
also examines the capability of the developers in using the
technology at sites with contaminant mixtures.

6.1    Previous Experience

In addition to the demonstration performed on oxygenated
and chlorinated VOCs at the Sweden-3 Chapman  site,
ELI/SBP have also carried out several site remediations
where the principal VOC contaminants were hydrocarbons,
particularly gasoline from leaking storage tanks.  Other
licensees also  have implemented remediation of other
configurations of the UVB treatment system.

6.2    Scaling Capabilities
ELI/SBP have installed and operated the UVB treatment
system on a scale larger than that of the demonstration at
several  sites where  hydrocarbons  were the primary
contaminants. The system has not previously been tested
at either the pilot-scale or full-scale on soils contaminated
with chlorinated VOCs.
                                                 6-1

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  Analysis  Report  -  Accutech  Pneumatic  Fracturing
  Extraction and Hot Gas Injection, Phase I," EPA/540/AR-
  93/509 July 1993.

Vogel, T.M.  and P.L. McCarty, "Biotransformation  of
  Tetrachloroethylene   to  Trichloroethylene,
  Dichloroethylene, Vinyl  Chloride, and Carbon Dioxide
  under Methanotrophic Conditions," Applied and Enviro.
  Microbiol., 49, 1080 (1985).

Wackett,  L.P.   and  D.T.   Gibson,   "Degradation  of
  Trichloroethylene by Toluene Dioxygenase in Whole-Cell
  Studies  with Pseudomonas  putida  F1,"  Applied and
  Enviro. Microbiol., 54, 1703 (1988).

Wilson,  J.T.  and  B.H.  Wilson, "Biotransformation  of
  Trichloroethylene in Soil," Applied and Enviro. Microbiol.,
  49,242(1985).
                                                   7-1

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                                    Appendix
                              Vendors' Comments
Vendors did not provide input for this section.
                                       A-1

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