v>EPA
                         United States
                         Environmental Protection
                         Agency
EPA/540/S5-90/002
August 1990
                         SUPERFUND INNOVATIVE
                         TECHNOLOGY EVALUATION
                          Technology Demonstration
                          Summary

                          CF Systems  Organics Extraction
                          System,  New  Bedford Harbor,
                          Massachusetts
                           The Site Program demonstration of
                         CF Systems' organics extraction
                         technology was conducted to obtain
                         specific  operating  and  cost
                         information that could be used in
                         evaluating the potential  applicability
                         of the technology to Superfund sites.
                         The demonstration was conducted
                         concurrently with pilot dredging
                         studies managed by the U.S.  Army
                         Corps of Engineers at the New
                         Bedford Harbor Superfund site in
                         Massachuetts. Contaminated sed-
                         iments were treated by CF Systems'
                         Pit Cleanup Unit (PCU) that  used
                         liquified  propane/butane as the
                         extraction solvent. The  PCU was a
                         trailer-mounted system with a design
                         capacity of 1.5 gpm (20  bbl/day). CF
                         Systems claimed that the PCU would
                         extract organics from contaminated
                         soils based on solubility of organics
                         in liquified propane/butane.
                           The objectives included an
                         evaluation  of  (1)  the unit's
                         performance, (2) system operating
                         conditions, (3)  health  and safety
                         conditions, and  (4) equipment and
                         system materials handling problems.
                         Extensive sampling and  analyses
                         were performed showing  that
                         polychlorinated biphenyl (PCS)
                         extraction efficiencies of 90 percent
were  achieved  for  sediments
containing PCBs ranging from 350 to
2,575 ppm. In Test 2, sediments
containing 350 ppm were reduced to
40 ppm after 10 passes, or recycles,
through the PCU. In Test 3, a 288 ppm
feed was reduced to 82 ppm after 3
passes. In Test 4, a 2,575 ppm feed
was reduced to 200 ppm after 6
passes. Some operating problems
occurred, such as the intermittent
retention of solids  in system
hardware and foaming in the treated
sediment collection tanks.  These
problems did not  affect extraction
efficiency but could affect operation
of a full-scale  unit.  Corrective
measures will be addressed  by the
developer and EPA. A mass balance
established over  the  entire
demonstration showed excellent
accountability for 96 percent of the
total mass. Operation of the unit did
not present any threats to the health
and safety of the  operators  or the
local community.
  This Summary was developed by
EPA's Risk Reduction  Engineering
Laboratory, Cincinnati, OH, to
announce key findings  of the SITE
program demonstration  that is fully
documented in two separate reports
(see ordering information at back).

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Introduction

  CF Systems  Corp., developer of an
organlcs extraction technology,  was
selected to demonstrate their "system at
the New Bedford Harbor, Massachusetts,
Suporfund  site. The system demon-
strated was CF Systems' Pit Cleanup
Unit (PCU), a trailer-mounted system with
a  design  capacity of 1.5  gpm  (20
bbl/day).  Successful application  of  the
technology depends on  the ability of
organic  pollutants  to sclubilize  in  the
process  solvent, a  liquified gas. The
process used a mixture of liquified pro-
pane  and butane,  at 240 psi and 69
degrees F, as  a solvent for extracting
organics from  soils. As liquified  solvent
was mixed with the waste, organics were
extracted into  the solvent. The sblvent-
organics mixture was then decanted from
the separated  solids and  water. The
pressure  of the solvent-organics mixture
was reduced  slightly  to vaporize  the
solvent which allowed separation from the
organics. The  solvent was recovered by
the system and compressed to a liquid
for reuse.
  The site is  located on the Acushnet
River Estuary north  of Buzzard's  Bay in
the city of New Bedford, Massachusetts,
where sediments  contain  pollutants
discharged to the harbor from a variety of
industrial sources. The pollutants  include
polychlorinated biphenyls (RGBs), poly-
nuclear aromatic hydrocarbons,  copper,
chromium, zinc, and lead. PCBs present
the greatest toxic threat and  concentra-
tions range up to 30,000 ppm.
  The following  technical criteria were
used to evaluate the effectiveness of the
CF Systems process for extracting PCBs
from New Bedford Harbor sediments:
1. System Performance
  » Evaluate  PCB  concentration  in
    sediments  before and   after
    treatment.
  • Evaluate PCB  extraction efficiency
    with each  pass,  or recycle,  of
    sediments through the unit.
  * Evaluate mass balances  established
    for total mass, solids and  PCBs.
2. Operating Conditions
  • Compare  operating  conditions to
    operating  specifications for flow,
    temperature, pressure, and physical
    sediment  characteristics   of  the
    sediment and  assess the effect on
    extraction rate.
3. Health and Safety Considerations
  • Determine if significant  amounts of
    propane/butane or PCBs are  emitted
    to the air by the process.
  « Determine if staging" area  soils, are
    contaminated by, system  spills  or
    malfunctions.
  • Decontaminate the unit with toluene
    to  levels less  than  50  ppm  in
    decontamination residues.
4. Equipment anc( Material Handling"
  Problems     j
  • Observe  equipment and  material
    handling  problems that would affect
    the  performance of a  full-scale site
   ••cleanup.    ;      '     .      ;  '
          '   '  i
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Facility and Process
Description  |

  Contaminated j sediments from five
harbor locations jwere processed  by the
PCU; The U.S. Army Corps of Engineers
dredged sediments from the harbor and
stored  them  \n\ 55-gallon drums  for
processing by the PCU. The drummed
sediments were blended to provide
feedstocks for four tests. Each of the four
tests was run similarly  except that the
number   of  [passes   and   PCB
concentrations were varied for each test.
A pass was defined as one cycle of the
feed through  the PCU.  A pass of feed
results in a treated sediment product and
an  extract  product.  Collecting and
recycling  the treated  sediment through
the PCU constituted  an additional pass.
Recycling was cpnducted to simulate the
operation of a  full-scale  commercial
system.  The  PCU is only a  two-stage
system,  whereas  commercial designs
include  four  stages, longer extractor
residence times, and longer  phase
separation times:
  I.Test 1 was run as a shakedown test
    to set pressure and flowrates in the
    PCU.  The;  feed  had  a  PCB
    concentration  of 360  ppm.  Three
    passes were run to gain experience
    with materials handling.
  2.Ten  passes, were run in  Test 2 to
    simulate  a high-efficiency process
    and  to  achieve  treated  sediment
    levels less than  10 ppm.  The feed
    had  a PCB  concentration of 350
    ppm.  A 350  ppm concentration was
    chosen  forj this test since this
    represents an  average, or typical,
    PCB concentration in the harbor.
  3. Test 3 was a 3-pass test that used a
    288 ppm feed. The purpose  of Test
    3 was to  replroduce the results of the
    first three passes of Test 2.
  4. Test  4  was a  6-pass test. The
    purpose of this test was to reduce a
    high-level waste (2,575 ppm) to a
    lower level waste such as  that used
    in  Tests  1,' 2,  and  3. High-level
    wastes are found  at several  "hot
    spots" in the harbor.       ,
  Samples were taken of the feed at the
commencement of  each test.  Treated
sediment  products  and extracts were
planned  for, sampling  at  each pass.
Additional samples were taken of system
filters and strainers,  although the amount
of PCB contained  in these miscellaneous
samples, later, proved to be small.  PCU
operating pressures, temperatures, and
flow-rates were monitored throughout the
tests. Field tests were conducted for feed
viscosity,  pH,  and  temperature.
Decontamination of  the  system  involved
running  toluene through  the PCU as a
solvent wash.
  The PCU is a  continuous processing
unit that used a liquified propane/butane
mix as the extraction solvent. The solvent
mix  was 70-percent propane   and  30-
percent  butane. The PCU process flow
diagram is shown in  Figure 1. For each of
the 3 demonstration tests,  a  batch of
approximately 50  gallons of sediments
was  fed to the unit  at a  nominal rate of
0.9 gpm. Feed viscosity was maintained
below 1,000 cp, by adding water in order
to produce a pumpable slurry.  Particles
greater than  one-eighth   inch were
screened from  the  feed  to  prevent
damage to valves.  Sediments were
pumped to the extractors,  which were
typically operated at 240 psig  and  70
degrees F. Liquified solvent was  also
pumped to the extractors at a rate of 2.3
gpm  (10  Ib/min) and  mixed  with  the
sediments.
  The PCU was not designed for large-
scale remedial actions. Therefore, treated
sediments  were  recycled,  or  passed
through the unit to simulate operation of a
commercial-scale  unit. CF Systems'
commercial-scale  designs do not include
recycling. These designs feature 60 gpm
flowrates,  several  extraction stages,  and
longer processing  times.
  The process steps included extraction,
phase separation and solvent recovery. A
simplified flowchart is shown in Figure 1.
In step one, sediments were fed into the
top of an extractor at a rate of 0.9 gpm. In
step two,  solvent  was  compressed to a
liquid state and allowed  to  flow through
the same extractor. In  the extractor, the
solvent  was thoroughly mixed  with the
waste at a  pressure  of  240 psig.
Following  this extraction procedure, the
residual  mixture  of  water/solids  was
removed from the base  of  the  extractor
(step three). In step four, the mixture of
solvent and organics left the top of the
extractor and was  expanded  across a
valve prior to passing to a separator. The
reduction in pressure caused the solvent
                                                        i   2

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          Simplified Flow Chart

          Here is the CF Systems unit operating cycle, for extracting and separating organics
          from liquid or solid waste:
          1. Solid or liquid waste fed into
            top of extractor.
4. Mixture of solvent gas and
  organics leaves extractor,
  passes to separator through
  valve where pressure is
  partially reduced.
                                Extractor
                 Wastewater or Sludge
          2. Condensed by compression
            at 70°, solvent gas flows
            upwards through extractor,
            making non-reactive contact
            with waste. Solvent typically
            dissolves out up to 99 + % of
            organics.

          3. Clean water or water/solids
            mixture then removed from
            extractor.
     Figure 1. CF Systems organics extraction simplified flow chart.
                          Organics
                                                                                                  Compressor
                                            5. In separator, extraction gas
                                               vaporized and recycled as fresh
                                               solvent.

                                            6. Organics drawn off from
                                               separator, recovered for
                                               disposal or recycling as
                                               feedstocks or fuel.
to vaporize  through  the top  of the
separator.  It was then  collected  and
recycled through the compressor as fresh
solvent (step five). The liquid organics left
behind were drawn off the separator and
pumped to storage (step six).  About 1  to
2 hours were required to run a feedstock
through the PCU.


Results and  Discussion
  The program  obtained a  large  amount
of analytical and operating data for
evaluating the effectiveness of the PCU
for extracting PCBs  from New Bedford
Harbor sediments.  The  results  are
summarized beiow.
System Performance
  The performance of the treatment unit
was  evaluated in terms of extraction
efficiency and a mass balance. Extraction
efficiency per pass is defined as the input
  PCB concentration minus the output PCB
  concentration divided  by the input PCB
  concentration (multiplied by 100 percent).
  An  inventory of  system ..inputs  and
  outputs  was  established and  evaluated
  for total mass, total solids, and the total
  mass of PCBs.
    PCB analyses  for feed sediments and
  treated sediment, conducted for samples
  collected at each  pass, are  shown  in
  Figures  2, 3, and 4. The data show that
  treated sediment concentrations below 10
  ppm are achievable and that as much as
  84  percent of the PCB contained  .a
  sediment that can be removed in a single
  pass. In Test 2, feed containing 350 ppm
  of PCB  was reduced to 40 ppm after 10
  passes through the PCU. In Test 3, a 288
  ppm feed was reduced to 82 ppm after 3
  passes.  In Test 4, a 2,575  ppm feed was
  reduced to 200 ppm after 6 passes.
    The data  for each  test show general
  reduction trends based on  differences
  between initial feed  and final treated
sediment concentrations. However, these
trends are  not consistent on a pass-by-
pass  basis.   For  example,  PCB
concentrations  in treated  sediments
increase at Test  2, passes 4 and 10,  and
at Test  3, passes  2  and 3.  These
anomolies are not  related  to  the
extraction process. Instead, they reflect
cross->contamination  within  system
hardware.  Only 50 to 150 gallons  per
day were run through the unit, which  was
designed to handle up to 2,160 gallons
per day. Therefore, some  solids  may
have  been retained  in  equipment dead
spaces and intermittently discharged at
later passes.  Since the treated  sediment
collection tanks  were under pressure, it
was not possible to clean out collection
hardware and piping.
  Extraction efficiencies greater than 60
percent were achieved on the first pass
of each test. Later passes, or recycles, of
treated sediments through the  unit
resulted in  efficiencies that  ranged from

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zero to 84 percent. This wide range was
due  to solids retention in the system.
Solids retained  in the system cross-
contaminated treated sediments  that
were recycled. Recycling was necessary
to simulate the peformance of a full-scale
commercial system. CF Systems'  full-
scale designs do not include recycling
since more extraction stages and longer
processing times are involved.
  A good mass  balance was established
for  total mass and solids through the
system. A total of 3-1/2 tons of solids and
water were fed to the unit during Tests 2,
3, and 4.  Of  the  total, 96 percent was
accounted  for in effluent streams. A total
of 789 pounds of  solids were processed
during Tests 2, 3, and 4. Of the total, 93
percent was accounted  for  in  effluent
streams. The slight imbalances, 4 and 7
percent, are attributed to the inaccuracy
of the weighing  device (1  percent),
sample error,  and accumulation of  mass
in system hardware.
  A mass balance was not established for
RGBs. A total of 157  grams were fed  to
the unit during  system shakedown and
Tests 2, 3, and 4. Of the total, 80 grams
were  accounted for in system effluents.
Decontamination  washes produced an
additional  169  grams.  The  sum  of
effluents and decontamination  washes
was, therefore,  101 grams greater  than
that fed to the unit. This large difference
may be due, in part, to limitations of the
analytical method. PCB analytical Method
8080 precision criteria established for this
project were plus or  minus 20  percent
and accuracy  criteria were plus or minus
50 percent. In addition, the mass balance
calculation was dominated by the Test 4
feed  concentration.   Therefore,  error
associated with  the Test 4 feed sample
could also be a source of  the PCB  mass
imbalance. Another possibility  is
contamination of the PCU  from prior use
at other sites.
  Metals  were  not  expected to  be
removed from the sediments, and were
not removed  during the extraction.  EP
Tox test results indicate that metals did
not leach from either treated or untreated
sediments.  Characteristics  of  the
sediments,  with respect to  the  EP Tox
test, were  not changed by the treatment
process.
  The decontamination  procedure
showed that PCBs were  separated from
the sediment  during  the tests since
nearly all,  88 percent,  of the PCBs were
contained in extract subsystem hardware.
Of the 81  grams of PCB fed to  the unit
during Tests 2,  3, and 4, only 4 grams
remained in the final  treated sediments.
This indicated an overall PCB separation
efficiency  of 95 percent.   Subsequent
decontamination  of the  PCU  wjth a
toluene wash showed that some PCB had
accumulated   in  system hardware.
However, 91   percent  of the  PCBs
contained  in decontamination residues
were found  in  extract  subsystem
hardware.
Operating Conditions
  Operating  conditions  that  were
essential to the efficient performance of
the PCU were  manually  controlled and
monitored during  Tests  2, 3,  and  4.
These  included (1)  feed temperature,
particle  size,  flow  rate, pH, and solids
content, (2) solvent  flow  rate  and
solvent/feed mass ratio, and (3) extractor
pressure and  temperature.  The  unit
generally performed as  predicted by the
developer,  although some deviations
from the planned specifications occurred.
  During Test 2, feed  temperatures for
the last 4 passes were  10 degrees F
lower than the minimum specification, 60
degrees F. This may have contributed to
decreased extraction efficiency that was
apparent during this  test. Sustained  low
temperatures  could have the effect  of
seriously reducing extraction efficiency of
a full-scale commercial system.
  Solvent flow fluctuated as much.as 75
percent above  and below  the  nominal
flow rate, 12 Ib/min.  This may have
affected the solvent-to-feed ratio in Test 2
Pass 1. Low solvent-to-feed ratios could
directly  affect  extraction efficiency  in a
full-scale system, since less  solvent
would be available  to  extract  organic
pollutants from the feed soil.
  Specifications for  maximum  particle
size, one-eighth inch, were met by
sieving sediments through a screen. This
was  necessary to prevent damage  to
system valves. Less than 1 percent of the
sediment particles were greater than the
one-eighth inch.
  Specifications for maximum viscosity,
1,000 centipoise, were  met by adding
water to form a pumpable feed  mixture.
Feed viscosities ranged from  25 to 180
centipoise.   However,  added  water
increased the mass of waste by about 33
percent.
  Solids contents ranged from 6 to 23
percent and  fell below  the  minimum
specification, 10 percent, after the fourth
pass of Tests  2 and 4.  A 10-percent
minimum spec was set merely to ensure
that  the  technology  would  be
demonstrated  for  high  solids  content
feeds.
Health and Safety
Considerations

  The Health and Safety Plan established
procedures and policies  to  protect
workers and the  public from  potential
hazards during  the demonstration. Air
emissions from the unit did not affect
operating  personnel  or  the  local
community. Combustible  gas meters
indicated  that  the  unit  did  not  leak
significant amounts  of  propane.
Therefore, operation of the  unit does not
present  an explosion threat much
different  than  that associated  wfth
domestic propane usage. Background air
sampling and  personnel  monitoring
results indicate  that organic vapors and
PCB levels were present at levels below
the detection  limit for the analytical
methods.  The  unit  did  not  cause  a
sudden release of propane/butane or
liquids. Only minor  leaks occurred and
staging area soils were not affected. The
treated  sediment  subsystem  was
successfully decontaminated before
leaving the site. The extract subsystem
was decontaminated  with  toluene,
however,  the decontamination goal of 50
ppm was  not  achieved  since  the  final
wash contained 60 ppm of PCB.
Equipment and Material
Handling Problems
  Equipment  and  material  handling
problems occurred throughout the dem-
onstration. While these problems did not
impede  achievement of the developer's
treatment goals, they could  impact the
economic performance  of  a full-scale
commercial system.  Some problems
were  anticipated since relatively  small
volumes of sediments were  batch-fed to
a unit that  was designed  for continuous
operation. The  nominal capacity  of the
unit is 2,160 gallons per day, but only 50
to 100 gallons  per  day  were batch-fed
during shakedown and Tests 2, 3, and 4.
Consequently,  the  unit  intermittently
discharged  and  retained solids with each
pass.
  Previous  use of the  unit affected
interpretation  of  semivolatiles  data.
Internal  surfaces of extract collection
hardware collected PCBs as evidenced
by mass balances.  In addition,  Test 3
was interrupted and  viscous oils were
found  accumulating in extract subsystem
hardware. PCBs are soluble  in oil, which
coated the internal  surfaces of  system
hardware.  As  a  result  of  this
demonstration, CF Systems now requires

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more  rigorous  decontamination
procedures for the PCD.
  Solids were observed  in  extract
samples that were expected to be solids-
free. This indicates  poor performance or
failure of the  pleated paper  cartridge
filter. An alternative type of  filter should
be investigated by the developer.
  Low-pressure dissolved  propane
caused foaming to  occur  in the  treated
sediment product tanks. This  hindered
sample  collection and caused frequent
overflow of treated  sediment to  a
secondary treated sediment product tank.
CF Systems states  that design  of  a
commercial-scale unit will allow  release
of propane  entrained  in the treated
sediment and elimination of  the foaming
problem.
  Two analysis methods for PCBs were
used and results  were  compared.
Reviewers suggested  the use of EPA
Method 680,  since  the  CF  Systems
technology could  have  selectively
extracted higher molecular  weight PCB
congeners as  opposed to lower weight
PCB congeners.  Method  680 would
reveal  any  selective  extraction, since
Method  680 is  used to analyze individual
PCB congeners. Method 8080,  a less
expensive analysis method, would not
reveal selective extraction since it is used
to analyze  mixtures  of  PCBs called
Alaclors, instead  of individual congeners.
EPA Method  8080 was chosen  over
Method 680 since selective extraction
was minor and since it analyzes for the
classes  of congeners that compose the
majority of PCB contaminants (Aroclors
1242 and 1254) in the harbor sediments.
  Methods  680 and 8080 produced
similar relative results, but very different
absolute results. Use of Method 680  in
Test 4 showed  a  PCB  extraction
efficiency of 96 percent and Method 8080
showed a similar efficiency, 87 percent.
However,  Method  680 showed  an
untreated sediment PCB concentration of
8,700 ppm while Method 8080  showed
2,575 ppm.  Data quality objectives were
met for each measurement.
Conclusions and
Recommendations

   Based  on  'the  above data  and
discussions, the following  conclusions
and recommendations  can  be made
concerning   the  operation  and
performance of the CF Systems organics
extraction process.
   LEven though solids retention caused
     cross-contamination  of treated
     sediments, significant PCB  removal
     occurred.  For  example, in  Test  2
     after Pass  9, treated sediments
  contained 8 ppm of PCB.Compared
  with a Test 2 feed concentration  of
  350  ppm,  this  represents  an
  extraction efficiency of 98 percent.
2. System  decontaminated  procedures
  showed  that PCBs were  separated
  from the sediment since  nearly all,
  88  percent,  of the  PCBs  were
  contained 'in  extract  subsystem
  hardware. Of the 81 grams  of  PCB
  fed to the Unit duing Tests 2, 3, and
  4, only 4 grams remained in the final
  treated sediments. This indicates an
  overall PCB  separation efficiency  of
  95 percent. |
3. Bench-scale tests are  useful  for
  determining whether or not organics
  contained in a soil will be extracted
  by  a  liquified  solvent such  as a
  propane-butane mixture. Bench-scale
  tests may also be  used to determine
  if  a liquified   solvent selectively
  extracts specific classes  of organica
  such as  high or low molecular weight
  PCBs.  Bench-scale tests, however,
  do  not  yield information  relating  to
  operational and material handling
  issues such  a  pumpability, foaming,
  and temperature, for example.
4. Commercial-scale  designs for appli-
  cation  of |the  technology  should
  ensure  that  operating  specifications
  are maintained. Wide fluctuations in
  the feed-to-solvent ratio should be
  minimized,  since  extraction
  efficiency may be directly related to
  this parameter.
5. Feed materials  are likely  to be well
  below  60 [degrees  F throughout
  winter months and this could affect
  performance. Therefore, heat must
  be added; to  sediments fed  to a
  commercial-scale unit.
6. Pretreatment  technology  will be
  required to. condition feed materials.
  Coarse  splids removal will be
  required to maintain  feed sediment
  particle  sizes below one-eighth inch
  and water jnust be added to ensure
  pumpability.
7.Health and!safety  monitoring showed
  that OSHAj level B protection will  be
  necessary: for personnel that  will
  handle  input and output. However,
  only OSHA level C protection will be
  necessary for unit operators.
S.Regulatory   or  engineering
  interpretation of PGB analysis should
  include  consideration of the analysis
  methods used.
9. Operations,  materials  handling,  and
  safety issues  are addressed  in the
  Application Analysis  Report.  Costs
  are  estimated for several  cases
  involving the  New Bedford  Harbor
   Superfund  site.  A significant cost
   element for a full-scale system is
   extraction  process  equipment which
   must be  scaled to  handle  much
   higher throughputs (60 gpm) than the
   PCU  (0.9pgm). Full-scale extractors
   have 4 to 6 foot  diameters as
   compared with the 18 inch diameter
   of  the  PCU  extractors.  Recom-
   mended  treatment technology
   includes conveyors, screening, heat
   and  water addition, mixing and
   holding  tanks.  Post  treatment
   technology  includes  treated
   sediment  dewatering,  wastewater
   treatment  and reuse, holding tanks,
   conveyors  and disposal of  treated
   sediments  and extracted organics.
   Onsite analytical  capabilities and
   health  and  safety   program
   implementation are additional cost
   elements.
10. EPA  and the developer will address
   corrective  measures  for operational
   controls  and  material handling
   issues. However, these measures are
   not the subject of this report.

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  The EPA Project Manager, Richard Valentlnetti, was with' the Risk Reduction
        Engineering Laboratory, Cincinnati, OH 45268 (see\below).
  The complete report consists of two volumes, entitled "Technology Evaluation
        Report, SITE  Program  Demonstration Test,  OF  Systems Organics
        Extraction System, New Bedford Harbor, Massachusetts."
        "Volume I (Order No. PS 90-786 495/AS; Cost: $21.95, subject to change)
        discusses the results of the SITE demonstration    \
         "Volume II (Order No. PB 90-116 024/AS;Cost: $42.95, subject to change)
        contains the technical operating  data logs, the sampling  and analytical
        report, and the quality  assurance project plan/test plan
  These two reports will be available only from:            \
            National Technical Information Service        ;
            5285 Port Royal Road                       \
            Springfield, VA 22161                       <
            Telephone: 703-487-4650                    i
  A related report, entitled "Applications Analysis Report; CF Systems Organics
        Extraction System"  which discusses  application and costs,  is  under
        development.                                   \
  For further information, Laurel Staley can be contacted at: \
            Risk Reduction Engineering Laboratory
            U.S. Environmental Protection Agency         ;
            Cincinnati, OH 45268                       '
United States
Environmental Protection
Agency
Center for Environmental Research
Information              !
Cincinnati OH 45268     !
      BULK RATE
POSTAGE & FEES PAID
         EPA
   PERMIT No. G-35
Official Business
Penalty for Private Use $300
EPA/540/S5-90/002

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