EPA/540/2-89/046
SUPERFUND TREATABILITY
CLEARINGHOUSE
Document Reference:
Detox Industries, Inc. "Work Plan for Biodegradation of Poly-Chlorinated Biphenyls
(PCBs) at a Superfund Site." Technical report of three volumes with a total of about 20
pages and related correspondence. Work plan prepared for General Motors
Corporation, Massena, New York. September 1986.
EPA LIBRARY NUMBER:
Superfund Treatabllity Clearinghouse - FCQP
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SUPERFUND TREATABILITY CLEARINGHOUSE ABSTRACT
Treatment Process:
Media:
Document Reference:
Document Type:
Contact:
Site Name:
Location of Test:
Biological - Aerobic
Sludge/Generic
Detox Industries, Inc. "Work Plan for Biodegrada-
tion of Poly-Chlorinated Biphenyls (PCBs) at a
Superfund Site." Technical report of three volumes
with a total of about 20 pages and related corres-
pondence. Work plan prepared for General Motors
Corporation, Massena, New York. September 1986.
Contractor/Vendor Treatability Study
Melvin Hauptman
U.S. EPA - Region II
Emergency & Remedial Response Division
26 Federal Plaza
Nev York, NY 10278
212-264-7681
Massena, NY (NPL)
Hearne Utilities, Hearne, TX
BACKGROUND: This document is composed of a work plan and additional
technical information which demonstrates the qualifications of Detox
Industries, Inc. to conduct remediation of a PCB contaminated sludge at
General Motors (GM) plant in New York. Provided are the results of a field
demonstration conducted on sludge containing PCB at Hearne Utilities in
Hearne, TX. Bench-scale biodegradation studies were also conducted by
Detox Inc. on samples of sludge provided by GM from their Massena, NY
site. Significant reductions in PCB levels were noted in the tests.
OPERATIONAL INFORMATION: The technical summary provided by Detox
Industries, Inc. provides a description of a field test conducted on
approximately 500 Ibs. of a PCB contaminated sludge at the Hearne Utility
site in Hearne, Texas. The sludge was placed into a non-leaking bioreactor
open to ambient air. PCB transformer oil was added to the sludge to bring
the total PCB concentration to approximately 2000 ppm. The mixture was
stirred constantly to ensure aerobic conditions and microbes and nutrients
were added to the reactor. Testing time was approximately two -months
(September 83 - December 83). Samples were provided to NUS Laboratories in
Houston, Texas for PCB analysis.
Bench tests were conducted by Detox Industries, Inc. on PCB
contaminated sludge samples provided by General Motors from their site in
Massena, New York. Samples were inoculated with microorganisms and
agitated in a water bath for 16 days. Aliquots were taken and sent to
Southwestern Laboratories for PCB analysis.
The technical summaries provided very few details on the microbes that
Detox Industries, Inc. has developed for the biodegradation of PCB other
than generic statements indicating that oxygen, moisture and nutrients must
3/89-24 Document Number: FCQP
NOTE: Quality assurance of data may not be appropriate for all uses.
-------
be present for the process to occur and that Detox Industries microbes are
not affected by PCB. The work plan refers to QA/QC procedures, but they
are not included in the plan.
PERFORMANCE; The field test at Hearne, Texas showed a significant
reduction of PCB from the initial concentration at 2000 ppm. Final
concentrations were as low as 0.12 ppm PCB. Results of bench scale tests
of samples of PCB contaminated sludge taken from the GM site in New York
also showed reductions in PCB levels. Table 1 shows the results after 16
days of treatment.
Results of the various studies revealed that the Detox Industries, Inc.
biodegradation process reduced PCB levels in contaminated materials. The
U.S. EPA approved the GM request to conduct a full-scale pilot study of
this process at the GM site in Massena, New York.
CONTAMINANTS:
Analytical data is provided in the treatability study report. The
breakdown of the contaminants by treatability group is:
Treatability Group CAS Number Contaminants
W02-Dioxins/Furans/PCBs 1336-36-3 Total PCBs
TABLE 1
PCB (1248) BIODEGRADATION
Untreated Soil Treated Soil % Reduction
GM Lagoon #1 338 ppm 107 ppm 68.3
GM Digester 110 ppm 63 ppm 42.7
GM Activated Sludge 63 ppm 6.5 ppm 89.6
Notes: a) Treatment time - 16 days
b) This is a partial listing of data. Refer to the document for
more information.
3/89-24 Document Number: FCQP
NOTE: Quality assurance of data Bay not be appropriate for all uses.
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Tc
M
a
Division of General Motors Corporation
Massena Plant
Post Office Box 460
Massena, New York 13662
October 7, 1986
Cert i fied MaiI
Return Receipt
Requested
Chief, Site Investigation S Compliance Branch
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, N.Y. 10278
Attn: CM Foundry Project Coordinator
Mr. Melvin Hauptman, P.E.
Dear Mr. Hauptman:
This is a request for EPA's approval of CM's conducting a
Biological Degradation of PCBs at this Superfund Site.
CM plans to have Detox Industries, Inc. conduct the
biodegradat ion of PCBs in accordance with the attached Work
Plan. The first phase will be the treatment of
approximately 300,000 gallons of sludge and soil as
described in the Work Plan. This request for approval
concerns this first phase only. When the first phase is
compl eted, CM will determine whether additional phases are
appropriate and, if so, we will make a separate request for
EPA1 s approva
CM
soon
and Detox are in the position to initiate this project as
n as EPA's approval is received.
Should you or your staff have any questions regarding this
matter, please contact me at (315) 764-2233.
S incere ly ,
D. P. Fayette
C. M. Facility Coordinator
Encl .
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xc: Chiefi Waste and Toxic Substances Branch
" Office of Regional Counsel
U. S. Environmental Protection Agency
Room 437 - 26 Federal Plaza
New York, New York 10273
Att: G. M. Foundry Attorney
Director, Division of Solid and Hazardous Waste
New York State Dept. of Environmental Conservation
Room 207 - 50 Wolf Road
Albany, N. Y. 12233
•
Mr. Randy Hart
St. Regis Mohawk Health Service
Community Building
St. Regis Mohawk Reservation
Hogansburg, N.Y. 13655
U. S. Environmental Protection Agency
Region II
Woodbrldge Avenue
Building 209
Edison, New Jersey 08817
Att: Ms. Diana Messina '
Mr. Dan-ell Sweredoskl
Sr. Sanitary Engineer
Division of Solid and Hazardous Waste
New York State Department of
Environmental Conservation
Region 6
317 Washington St.
Watertown, N. Y. -13601
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WORK PLAN
FOR
Biodegradation of Polychlorinated Biphcnyls (PCBs)
at
a Superfund Site
GENERAL MOTORS CORPORATION
Hassena, New York
DETOX INDUSTRIES, INC.
12919 Dairy Ashford
Sugar Land, TX 77478
(713) 240-0892
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9/30/86
X.
OPERATIONAL PLAN TO BIOLOGICALLY
TREAT PCBS ON SITE
1. Project Objectives
DETOX INDUSTRIES, INC. ("Detox") proposes to construct a 24' high and
/
56* diameter open steel* tank to vhich 300,000 gallons, more or less,
of PCS contaminated sludges and/or soils vill be gathered from an
existing 350,000 gallon capacity lagoon located on property owned by
General Motors Corporation located in Massena, New Tork. Such sludges
and/or soils shall be treated in phases of 300,000 gallons minimum at
the site in the tank. Its purpose is to reduce the PCB contamination
level of the above material to less than 2 ppm to be reported on an
•as received" basis or any higher level concentration agreed to by EPA
Region II. Said tank will be the property of Detox and will be
removed at the expense of Detox within one (1) year of completior. of
the project.
2. Scope of Work;
The work to be performed consists of the following tasks:
2.1 Detox will place into the tank (bioreactor) approximately 300,000
gallons of contaminated sludge from the CM lagoon. A minimum of
a two-foot freeboard will be maintained to prevent any
overflowing.
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2.2 A mixing (i.e., diffusion) device will be placed into the tank to
ensure mixing of the sludge.
2.3 After twenty-four hours of mixing, two one-quart camples will be
taken, coded, sealed and properly stored with chain-of-cuttody
forms for transmittal to a third party laboratory for PCB
analysis to be reported on an "as received" basis. These samples
will represent the background "untreated* samples.
2.4 Detox's proprietary nutrients will be added to start the PCB
biodegradation process. Detox's microorganisms will then be
innoculated into the mixture. (Timely addition of nutrients and
microorganisms will be made by Detox to ensure the rate of
degradation.)
2.5 Two one-quart samples will be removed from the tank for total PCB
analysis each Monday during the biodegradation process. These
samples will be treated exactly as in Task 2.3. Al1 samples will
be sent to a third party laboratory for total PCB analysis to be
reported on an "as received" basis.
2.6 All samples will be secured in the presence of a GM
representative designated in writing by GM.
2.7 All samples shall be treated by Detox with a biocide designated
in writing to GM for the purpose of destroying Detox's
proprietary microorganisms. The quantity of said biocide added
to each sample shall be prescribed in such writing.
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2.8 Tasks 2.4 through 2.7 will be repeated until the PCB
contamination level of the samples has been reduced to the
greater amount of 2 ppm or such higher concentration level as may
be acceptable to EPA Region XI.
«
2.9 After the PCB contamination level has been reduced in accordance
with Task 2.8 above, the tank contents will be removed to a
location on the GM property as designated by GM not further than
500 feet from the 'original lagoon.
3. Performance Schedule;
Based on past projects conducted by Detox involving similar
contaminated sludges, the project is estimated to be completed within
a six-month period.
4. Volumetric Determination
Materials (sludges and/or soils) to be treated shall be measured on
the basis of input as follows:
(a) Sludges - volume shall be measured with a flow-meter designed
to quantify the amount of through-put.
(b) Soils - volume shall be measured from an elevation benchmark
through each phase of excavation.
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XI.
WASTE DESCRIPTION
DESCRIPTION »
300,000 gallons, more or less, of sludge contaminated with polychlocinated
biphenyls (PCBs) in excess of 2 ppm to a depth of approximately six (6) feet
-(plus an undetermined amount of similarly contaminated soil beneath the
sludge to a depth of approximately forty (40) feet) contained in and under a v "y
— ~ t
350fOOO gallon capacity lagoon located at the General Motors Corporation,
Central Foundry Division, Massena Plant in Massena, Mew York as indicated in
the attached site plan. Said Material shall not include any object
exceeding one (1) inch in diameter.
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INDUSTRIAL
LANDFILL
NOMTH DISPOSAL
AMEA
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III.
SAMPLING PROCEDURES
PROPOSED PROTOCOL »
Sampling Initial Stage
1. From the bioreactor and under the proper chain-of-custody, two
one-quart split samples of contaminated material will be taken
randomly after twenty-four hours of mixing. These samples will
be analyzed by a third party laboratory for total PCBs by Gas
Chromatograph (GC) to establish an analytical benchmark for
performance evaluation. The concentration levels of PCBs in
samples are to be reported on an "as received" basis.
Subsequent Sampling Stages
2. Two one-quart samples will be taken under chain-of-custody
procedures at 12 o'clock noon each Monday on a weekly basis for
duration of the project and shipped to a third party independent
test laboratory for GC analysis in the same manner as that for
all previous samples.
All Sampling
3. All samples taken in step* 1 and 2 above shall be taken in the
presence of a GM representative designated in writing to Detox
and shall be transmitted to the laboratory pursuant to chain of
custody procedures designated by EPA Region ZZ.
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IV.
ANALYTICAL PROCEDURES
Staples will be analyzed in accordance with EPA Method 8080, "Organochlorine
*
Pesticides and PCBs, in Test Methods for Evaluating Solid Haste , SW 846, 2d
Edition, July 1982".
Analytical results will be reported on an "as received" basis. CM shall pay
the cost of analysis. The third party laboratory hired by CM nust be
acceptable to Detox and EPA. All laboratory reports shall be delivered to
CM and Detox separately by the laboratory. In addition, the laboratory
shall deliver all gas chromate grains to Detox.
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V.
DATA REPORTIHG/RrfCORDKEEPIHG
Detox Industries plans to keep records of the following:
*
1. Daily* - Records of bioreactor temperature
• Log of activities
— Operational parameters
— Visitors
— Weather
— Shutdownsf spills, accidents
— Notifications
2. Weekly* - Sample description, location, chain-of-custody
- Third party laboratory results (notification)
All records/books (on site) open to GM and EPA inspection.
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VI.
SPILL PREVENTION
Spill prevention is directly addressed by the following considerations:
1. The process vill be applied in a manufactured open steel tank.
Rupture of these standard tanks is considered relatively non-
existent.
2. A containment bern is to be constructed completely around the
process facility to act as an impediment to any extraneous flow
of material created in an emergency situation.
3. Should an emergency occur, spilled material will be placed back
into the tank along with any extra material which becomes
contaminated through a spill or rupture.
4. Any spill will be reported to CM immediately. CM is responsible
for reporting to the government, as necessary.
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VII.
SAFETY PLAN
Detox Industries, Inc.'s safety plan insures that each employee has been
properly instructed in the use of a wide variety of safety equipment
including, but not limited to, the following:
• Protective Clothing
• Face Shields, Protective Gloves
• Respirators
• Emergency Personnel Wash
• First Aid
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VIII.
TRAINING PLAN
Detox personnel previously trained in handling parameters of Detox process.
All training performed in Detox's Houston facilities.
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IX.
QUALITY ASSURANCE PLAN
Detox's biodegradation is a new alternate destruction technology for PCBs.
Quality assurance for analytical work is the responsibility of the third
party laboratory as such laboratory will be doing all cample monitoring and
analysis.
MEASUREMENT VERIFICATION
PCB analysis. (See next page for flowchart.)
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MEASUREMENT VERIFICATION (Cont.)
PROCESS
THIRD PARTY
LAB*
DETOX
Proj. Mgr.
copy
o Preventative Maint.
o Corrective Action
Procedures
o Increased Productivity
of Process
CM
copy
o Frequency - once per week
o Calibration Proccedures
o Quality Control Checks
o Data Reduction
o Valuation Reporting
o Distribution
o Responsible for Accuracy,
Precision & Completeness
copy
EPA
Onsite Coord.
o Audit procedure - Optional
Using all EPA standard operating procedures and analytical
calculations.
- 13 -
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RETURN RECEIPT REQUESTED
Mr. David P. Fayette
G.M. Facility Coordinator
Central Foundry Division
General Motors Corporation
P.O. Box 460 .•...
Massena, New York 13662
Re: G.M. Central Foundry*
**
* ; _' •«.
Dear Mr. Fayette:
.?'•> .
-' -V-'" ' v
':• * f t+ **"** '"
.«—•*•,*,.'.<* ^
U-
• ' * ji . • .-
, ;* r--^"'"^-" ^•;i;">""r?
''5" '" """•* ""-.',- i "* ••
,*-:!
This is in response to your letter of October 7T 1986 request inqr
the Environmental Protection Aqency (BPA) approval for <5.M,
to treat some of the wastes at the above- capt
throuqh biological degradation using the Detox Indus trie
(Detox), Inc. process. EPA has reviewed^'jthis request
work plan for this undertaking in greatrdeta.il. -The treat^ient
you have proposed appears to have the pojbenti&l for being'
effective and economic means for dealing with, the S>CB materials. '
at the site. We have determined that, subject; to the
set forth below, G.M*'s proposal should , be carried out
field-scale pilot study examining the effectiveness ..of the J 'i;
process. -• ,. «..* " - .; .- '•;, /. &
EPA will consider the Detox process under the Treatability-study."
task in the Remedial Investiqation/Feasibility study; (RI/FS)' .*
currently being conducted by G.M. under'the^EPA Administrative
Order, Task 11 was ^an optional task in the 'September' 1984 BJPA'
Work Plan for this .RI/FS and .it called for *i
treatability studies" ,to evaluate remedigi^actions; applicable'
We do not understand the reason for
of the lagoon down to "approximately ,1
described
this
We rec
basis
industrial' . . . . ,
We require /pomplete hazardous substance/jaa^ardou's warste^^v,
characteris^icsVfpriority oollutjint and non-hajtardous T'gV ;/
industrial waste) analyses of the'liguid ^n^jk>lids *ijp^;^*?>^ v^;.^
the conclusion 6t the six month 9tt^i^f:i^^^^'ir^^,fr'-.f^^
Because the lagoon contains volatile:vOr. ->' ^;>,
along with the PCBs,' we require inonthlf ilr wnltorinq >>"^ - 3>.
for volatile organic priority obi*tfr»*t»t*»«#fiat*!TA ^~y * '57"-^
;^febe i^a«t»ii^e««9i.-^o--as«i»«^-*ii»%--««i
EtJ
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- 2 -
5. The water supernatant remaining in the 300 f 000 gallon
treat ment tank after the 6 month treatment period nay be
allowed to be passed through the existing G«M^ba*tewater
treatment facility. This decision will be ma^£j$o'ihtly
by New York. State and EPA after reviewing thV analytical
results of the supernatant. , 'i^^'ffe '-.
6. The solids remaining in the treatment tank after the 6
month time period may have to be handled as hazardous
waste or non-hazardous industrial wastes under New York
State regulations. A decision as to the ultimate disposition
of these solids will also be made jointly by New York
State and EPA a t. -that time. ': ,*. ; , \ -V. . .' >
7. At the -conclusion of the six month treatment period, G.M. ;
shall submit £o fPA * Final Report containing descriptions^ ' •' -4,
of the activities which have taken place, the sampling and .*"£>%-.
ana ly s is -.data , v<}uaZ tty assurance/qual ity control^ reports £. * ^t^-'
for the data* 'volumetric information on *he starting v*nd .M ."'""V' .
remaining materials, and a discussion on ; the .performance ., • ir'S
ability of the process to detoxify P^Bs*^ , ^.^ w ? r-^-',^\'
6. G»M.' is to supply in the final Report, capita} investmentr^'V^'i '
and operational costs associated with this process. Th is >-,,-% ^~
information way subsequently be used in the PeasibilitJ1 '_.-"£ "% -^ \
Study for the entire G.M. site. The parameters necessary' ' ^ Vr
• for the cost-effectiveness analysis reguired by J300.68 ',: "v"'5* •
of the National Contingency plan are to be included "in ."> V- ' "*M-i
the final Report . '-^ . V,-> .^r: ;.-: » ^ -f; - '':.; *' '- -W"
- •
-,
We
time
look forward• toVthis undertaking- and apologize for the" extended v= • c
ie necessary for our decision. <:' -r-i, ^;.-- = ^ra/- -w^-: /^" ^4-;£'•'•• • .'- :;«.,-^i#
S incerely'yours.
Site compliance
cc: Leonard "fT. Charla,. G.H. :>
; joe Chu, G.M<* 'f- "V. 7
Randy Hart, St. Regis Mohawk Health Services
Norman N. Nosenchuck, NYSDEC •*' '.
ward Stone, NYSDEC
Darrell Sweredoski, NYSDEC . -.
Gary Litwin, NYSDOH ./>. .
bcc: Carol Casazza, ORC ' *v^J*.1^*
V ..
.^
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if
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Not* and ftotum
REMARKS
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and »iinllw aetlofM
FROM: (Num.
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DETOX INDUSTRIES, INC,
4800 SUGAR GROVE BLVD.
SUITE 210
STAFFORD. TEXAS 77477
(713) 240-0892
January 7, 1986
Mr. David P. Fayette
Sr. Plant Engineer
Central Foundry Division
GENERAL MOTORS CORPORATION
P.O. Box 460
Massena, New York 13662
Dear Mr. Fayette:
This letter is to confirm
whereby we discussed our
on PCB samples sent to
our telephone conversation of last week
successful feasibility study conducted
us by you from the Massena Plant.
Enclosed for your review is a laboratory report from Southwestern
Laboratories of Houston, Texas. This report is dated January 6,
1986 reporting analyses of three (3) samples provided by you.
Each of the three samples received from you was separated into a
control and a sample to be treated. The treated samples were
inoculated with our naturally occurlng microorganisms on November
27, 1985 and placed on a water bath shaker to cause agitation.
Aliquots of each control and treated sample were removed for
laboratory analysis of PCBs on December 11, 1985. The following
is a recapitulation of that analysis:
GM Lagoon 11
GM Digester
GM Activated Sludge
Control (untreated) Treated Z Reduction
338 ppm
110 ppm
63 ppm
(1248)
107 ppa
63 ppa
6.5 ppm
68.3Z
42.7Z
89.6Z
The above analyses represent comparisons of the contaminated
samples sent to us before and after treatment with our p»oo«is&.
They demonstrate a significant reduction in PCB contamination
after only sixteen (16) days of treatment by our biological
process. Consequently, we are confident that our process may be
successfully applied to the sites from which each sample was
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Mr. David P. Fayette
January 7, 1986
Page Two
provided to reduce the contamination level to a very low concen-
tration. As discussed, application of our process to the conta-
minated sludge may be expected to ultimately result in water and
sediment relatively uncontaminated for all practical purposes.
We hope you are as excited about the above results as we are. We
look forward to the possibility of using our technology to solve
your disposal dilemma and hope to hear from you soon.
Thank you for giving us the opportunity to demonstrate the effec-
tiveness of our preferred disposal alternative.
Sincerely yours,
' /'. ''^ ',*^^— /< f~ -"
Tnomas A. Dardas
cc : Dr. J. Chu
Mr. J. Medved
TAD/mec
Enclo sure
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ihrjl
•
Division of General Motors Corporation
Massena Plant
Post Office Box 460
Massena, New York 13662
October 31, 1986
Certified Mai I-
Return Receipt
Requested
Chief, Site Investigation & Compliance Branch
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, N.Y. 10278
Attn: C.M. Foundry Project Coordinator
Mr. Me Ivin Hauptman, P.E.
Dear Mel:
Enclosed you will find a copy of the letter and Laboratory
Report from Detox Industries, Inc. dated January 7, 1986.
As we discussed during last Wednesday's meeting, the test
run times were limited to 16 days duration. It should also
be noted that the report details samples taken from three
(3) areas of the Plant, the 350,000 gallon lagoon is listed
as CM Lagoon II, the remaining two samples were selected as
areas that might be beneficial to the plant operation
should the process prove viable.
If there are any questions concerning this matter, please
contact me at 315-764-2233.
Sincerely,
David P. Fayette
C.M. Facility Coordinator
cc: Joseph P. Chu, PhD, P.E.
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SOUTHWESTERN LABORATORIES
Materials, environmental and geolechnical engineering, nondestructive, metallurgical and analytical services
222 Cavalcade St. • PO Box B7SB. Houston. Texas 77243 • 713/B92-9151
File No. 2-1787-00
Report No. 7344-7355
Report Date —1/6/B6—
DeTox Industries, Inc.
Gene Liner
4 Sugar Grove, Suite 210
4800 Sugar Grove Boulevard
Stafford. Texas 77477
Analysis of samples submitted 12/12/85 by Gene Liner.
Sample I.D.
Baker 58055, Control
Baker 58196, Control
Baker 58055, Treated
Baker 58196, Treated
GM-Lagoon #1, Control
GM-Digester, Control
GM-Activated Sludge, Control
GM-Lagoon #1, Treated
GM-Digester, Treated
GM-Activated Sludge. Treated
GM-(IND)-E-3, Treated 8/27
GM-(IND), Treated 8/18
RESULTS
SWL Lab No.
7344
7345
7346
7347
7348
7349
7350
7351
7352
7353
7354
7355
DDT, ppm
3965
117
2391
110
PCB, ppm
338
no
63
107
63
6.5
8253
4107
as 1248
as 1248
as 1248
as 1248
as 1248
as 1248
as 1242
as 1242
•Ol/rHWBSTBRN LABORATORIES
n:
3 - DeTox Industries, Inc.
pm
Enris Barry
Chemist
. and report* are for the exclusive ute of ttie client to whom they are addressed. The ute of our name must receive our prior written approval. Our letters
i apply only to the sample tmted and/or inspected, and are not necessarily indicative of the quentities of apparently identical or timiur oroducn.
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I UNITED STATES ENVIRONMENTAL PROTECTION ACENCN
uf^/ REGION VI
1tiT iNTEWFmsT TWO BUILDING. 12O1 ELM STREET
DALLAS. TEXAS 7S27O
J »££-
\ *&&.
August 15. 1984
Mr. Thomas A. Dardas, President
Detox Industries, Inc.
Four Sugar Grove, Suite 210
4800 Sugar Grove Blvd.
Stafford, Texas 77477
Dear Mr. Dardas:
This letter responds /to the application submitted by Detox Industries.
requesting approval by the Regional Administrator of the U.S. Environmental
Protection Agency, Region VI for the use of Its biological disposal method
for the destruction of polychlorlnated biphenyls (PCBs) 1n Region VI States.
EPA hereby grants the requested approval subject to the enclosed conditions
and based upon the results of a demonstration Detox conducted on PCB
contaminated wastes. Split samples were collected by EPA before and after
the test period.
Section (6)(e) of the Toxic Substances Control Act (TSCA) requires EPA to
control the disposal of PCBs. EPA promulgated regulations In Title 40 Code
of Federal Regulations, Part 761 to Implement Section (6)(e). These regula-
tions provide that disposal of PCBs In concentrations of 50 parts per million
or greater shall be by methods approved by the Regional Administrator of
the EPA Region 1n which the method 1s to be used. Detox has requested by
Its application of 12/17/82, that Its PCB biological disposal method be
approved In accordance with EPA PCB disposal regulations.
Violation of 40 CFR Part 761 or any condition Included as part of this
approval may subject Detox to enforcement action under the appropriate
statute and/or termination, revocation or modification of the approval.
Furthermore, receipt of evidence that (1) a misrepresentation of any material
fact has been made In any Detox submlttal; (2) all relevant facts have not
been disclosed; (3) the nature of the disposal process has substantially
changed from the effective date of this approval; or, (4) Detox Is found to
be In non-compliance with Its approval conditions shall constitute sufficient
cause for revocation or modification of this approval.
This approval shall be effective upon receipt of this letter.
Sincerely yours,
Dick whlttington, P.E.
Regional Administrator
Enclosure
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Conditions for PCB Disposal by the Detox Industries
Biological Degradation Technology
1. Before disposal of any PCBs by the Detox biological disposal Method,
except for up to a 3 gallon sample for testing or demonstrating the
process, Detox end the owner of the PCB waste material (applicant) shall
make written request to the EPA Region VI Regional Administrator for
approval to dispose of PCBs. A copy of the notification shall be sent tc
the appropriate State and local officials. PCBs 1n concentrations at or
over 500 parts per million (ppm) are required to be Incinerated by the PCB
regulations. For sites with PCB concentrations of 500 ppm or greater, Detox
and the applicant shall request from the Regional Administrator an exemption
from the Incineration requirements of 40 CFR 761.70.
Detox May test or demonstrate the ability of Us process to degrade an ap-
plicant's PCB waste without EPA approval on one sample not to exceed
three gallons. Disposal of the sample after testing 1s completed shall
be according to applicable federal and/or State regulations. EPA may
request additional Information or add additional requirements to complete
Its evaluation of the disposal project. Detox and the applicant must
receive written approval from the Regional Administrator before disposal
can begin. The Regional Administrator may add other conditions to the
approval that are not 1n this general approval.
Detox and the applicant shall attach to the written request a report which
shall contain the following Information:
(a). A report detailing the extent of surface and sub-surface
PCB contamination 1n soil and/or presence or movement In the
groundwater, and Identification of hazardous wastes which
may be present as defined by 40 CFR Part 261 of the Resource
Conservation and Recovery Act (RCRA). This report shall
Include a "Background" section describing how the PCB
contamination occured and showing the range 1n concentration
of PCBs (and hazardous wastes If present), and the total
contaminated waste volume. This report shall be compiled
from representative samples from the waste material and
analyzed according to methods acceptable to EPA.
*
(b). A waste disposal plan showing the following:
(1). How access shall be controlled during the disposal period.
(2). A runoff/run-on control plan showing how potential losses
of PCBs from the contaminated area shall be controlled.
(3). If groundwater contamination exists, what are the plans
for groundwater decontamination, groundwater monitoring,
and/or remedial action for groundwater decontamination/
control after disposal 1s completed. If groundwater
1s not contaminated, how the groundwater will be protected
from PCB contamination.
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(4). The approximate length of time required for PCB disposal.
and the expected level of treatment the biological
process 1s expected to achieve. Included 1n this
part shall be a discussion of the number of expected
•Icroblal applications; types of organisms to be used;
nutrient applications; type and amount of emulslfler to
be applied, 1f any; soil type and conditions such as pH;
and what factors are expected to Influence the disposal
process, either positively or negatively, to achieve final
treatment.
(5). A proposal for monitoring and reporting the progress
during the PCB disposal. Periodic reporting shall be
required based upon the length of time projected for
PCB disposal. Monitoring of the project shall be
required to ensure that the waste materials are properly
handled during the disposal process.
j
(6). A Quality Assurance (QA) Plan shall be submitted
detailing the sampling plan, sampling protocols,
and the Analytical Quality Assurance/Quality Control
(QA/QC) during the disposal period. The name, address.
and contact person for the analytical laboratory shall
be submitted. EPA nay disapprove the proposed laboratory.
(7). A contingency plan showing where the PCB contaminated
waste will be taken for proper final disposal If the
PCB concentration Is not reduced to below 2 ppm.
(c). A plan for final disposition of the waste material. This
plan shall show where the treated waste shall be sent 1f moved
from the original site of contamination. Whether or not the
waste material 1s planned to be moved, a closure plan and
post closure plan shall be submitted for the site of
contamination.
2. PCBs shall be treated to a concentration less than 2 parts per million
(ppm). Detox or the applicant may request a different final level of
treatment by providing justification to the Regional Administrator.
Failure to meet the 2 ppm PCB concentration may require removal to a
hazardous waste landfill approved to receive such wastes 1n accordance
with RCRA, Subtitle C; a landfill approved pursuant to TSCA Section 6(e)
to receive PCB wastes: or, an Incinerator approved to receive PCB wastes
pursuant to TSCA Section 6(e).
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3. Detox and the applicant shall Identify and obtain all required state,
local, and federal permits, approvals, and/or authorizations before
disposal can begin.
4. Records and data shall be Maintained on the proceedings at each disposal
site. Data shall Include: (a), the name and address of the company or
Individual for whom the service was performed; (b), name and telephone
number of contact person for the company; (c), the location and dates
service was performed; (d), the amount of PCB waste treated; (e), a copy
of the gas chromatograph and/or data record from analysis of representative
samples taken before, during, and after PCB disposal.
EPA may require additional samples and analyses for PCBs or for the
presence of other chemical compounds to ensure that the required level
of disposal has been achieved or that the site does not pose a threat
to human health or the environment. The documents must be compiled
within 60 days of the completion of the project, and copies kept at one
central location where the data shall be available for Inspection by
authorized representatives of the Environmental Protection Agency and
State regulatory agencies. Such documents shall be maintained and
accessible to EPA for at least 10 years (one copy to be kept by Detox,
and one copy by the applicant).
5. Detox and the applicant shall notify State and local officials 1n
writing of the proposed PCB disposal project. If the project 1s
approved by the Regional Administrator, Detox and the applicant
shall notify State and local officials In advance of starting
the disposal project.
6. Any PCB container used for PCB transport, storage, or disposal shall
not be used for any other purpose unless decontamination of the con-
tainer complies with 40 CFR 761.79.
7. All PCB articles, equipment, and containers shall be properly marked
according to 40 CFR 761.45.
8. Detox and the Applicant's personnel safety requirements and procedures
for onslte PCB handling, storage, transport, and disposal shall comply
with OSHA requirements.
9. The conditions of this authorization are not severable, and 1f any
provisions of this authorization, or any applications of any provision,
1s held Invalid, the remainder of this authorization shall be held to be
entirely Invalid.
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TECHNICAL SUMMARY OF THE DETOX, INC.
BIOLOGICAL PCB DISPOSAL PROCESS
BACKGROUND
On December 17, 1982, Detox, Inc. (formerly "Biotechnology") reouested
approval fron EPA Region VI to dispose of PCBs usinq its biological degradation
process. The process was used in 1981 to treat pentachlorophenol (PCP)
contaminated wastes in soil to less than 1 ppm at a site located at Conroe,
Texas. The process utilizes a method for acclimating a naturally occuring
species of microbes that have a natural tendency for degrading small amounts
of PCBs to metabolize PCBs in wastes containing relatively higher PCB
concentrations. The microbes metabolize PCBs by attacking the chlorine
atoms and ultimately reducing the molecule to cell protoplasm, water,
carbon dioxide (aerobic degradation) or methane (anaerobic degradation),
and salts. Enzymes are added when necessary to ensure contact between non-
soluble PCBs and the microbe. Also, a catalyst is added to increase the
rate of the degradation process.
Detox claims PCBs are not toxic to these microbes. It is expected that the
higher chlorinated PCBs take longer to degrade than the less chlorinated
iscmers. Seme heavy metals, such as hexavalent chromium, are toxic to the
microbes. Each waste material must be examined to determine if the process
may be applied. The process cannot be used on wastes containing material
toxic to the microbes unless the toxic material is removed. Higher PCB
concentrations reportedly require longer time periods than lower concentrations
with the same number of microbes because the rate of degradation is constant.
The higher the PCB concentration in a waste, the greater the time reguired
to degrade the waste with the same amount of microbes. The time period for
PCB degradation can be shortened by introducing more microbes into the waste.
Once the microbes are applied to a PCB waste, continuation of the process
is ensured by the presence of sufficient oxygen, moisture, nutrients, and
proper pH. Adjustment of pH or the addition of moisture, oxygen or
nutrients may be reguired durinq the degradation period.
For sludges, aeration may be all that is reguired depending on the condition
of the lagoon (eg., oxygen levels may differ depending on light penetration,
depth of the lagoon, temperature, presence of other bacteria, or wind
turbulance). For dry waste materials, the surface may reguire the addition
of moisture, or soil may need to be further aerated by loosening the soil
surface. ^- -
After the source of PCBs is depleted, the microbial population dies out
and becomes an energy source for naturally occuring organisms. The process
is essentially the same as that used in municipal treatment plants except
this process uses microbes that can survive in an otherwise toxic environment.
A proposed decision to approve the Detox process was made on June 1, 1984.
A press release was issued opening a 30-day comment period. No comments
were received during the comment period.
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DEMONSTRATION PROTOCOL FOR ALTERNATE TECHNOLOGIES UNDER 40 CFR 761.60(e)
The PCB regulations require that alternative methods for PCB disposal must
be shown capable of achieving a level of performance equivalent to PCB
incineration or high efficiency boilers, and that the method does not present
an unreasonable risk to human health or the environment. The "level of
performance11 for alternate technologies has been established as reducing
the PCB concentration to below 2 parts per million (ppm). This concentration
is generally the state-of-the-art for a quantitative measurement by standard
GC-MS analytical techniques. PCB samples containing less than 2 ppm PCBs
would be regarded as'containing non-detectable PCB concentrations, and the
method used to achieve this result would therefore be judged equivalent to
the performance of an incinerator. The rationale is discussed in more
detail in the October 21, 1983, Federal Register (page 48988) on the Vulcanus
I and II draft ocean incineration permit (copy attached).
Alternate technology demonstrations are required to show the ability of the
process to reduce the PCB concentration below 2 ppm and to be commerically
applicable without risk of injury to human health in the environment. To
meet these demonstration requirements, Detox performed a bench scale test
and then a field demonstration of its process using PCB contaminated wastes.
DETOX BENCH SCALE DEMONSTRATION
To demonstrate the process, EPA required a bench scale test using a PCB con-
taminated sludge. The bench test consisted of placing one kilogram samples
of PCB contaminated sludge into three, two-liter erlenmeyer flasks. Each
flask was sampled for PCB concentration before the addition of microbes and
nutrients. The PCB concentration before the introduction of microbes was
approximately 150 ppm. Air was bubbled through the samples to maintain
aerobic conditions. A florisil trap was placed on the air exhaust line to
absorb any PCBs released into the air.
The bench scale test was approved by EPA on February 4, 1983. The test began
in March 1983 and was concluded in July 1983. Samples of 100 ml. volume were
withdrawn throughout the test period and sent to NUS laboratory located at
Houston, Texas for analysis of total PCBs in samples containing sediment and
water. The test set-up was inspected by EPA during the test period. Between
the period of March 30, 1983 and July 13, 1983, the PCB concentration dropped
to less than 1 ppm. Analysis of the florisil trap showed less than 0.5 ug PCBs.
Samples of flask 12 were analyzed on 3/30/83, 5/3/83, 5/20/83, 6/3/83, and
7/13/83. Based on the analytical results, the bench scale test demonstrated
that the biological process is capable of destroying PCBs to less than 2
pp^i without detectable PCB air emissions fron the sludge. Also, the qas
chromatograms showed no new chlorinated organic compounds formed during
the degradation process.
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The next phase was to conduct a field test which would demonstrate that
the process will work under ambient conditions. On August 8, 1983, Detox
submitted a request to conduct a field demonstration. Included was a
field demonstration plan that outlined project objectives, scope of work
and schedule of performance. The field demonstration was approved by EPA
on September 13, 1983, and begun September 22, 1983. The demonstration
was concluded in December 1983. It was conducted on the Hearne Utilities
property located at Hearne, Texas. The project consisted of placing less
than 500 Ibs. of PCB contaminated sludge into a non-leaking "bio-reactor"
open to ambient air. PCB transformer oil was added to the PCB sludge to
raise the total PCB concentration to approximately 2000 ppm. An impellar
drive device in the bio-reactor ensured mixing of the sample and that
aerobic conditions would be maintained. Microbes and nutrients were
added to the reactor after a sample was taken of the material.
EPA was present at the beginning and the end of the test to collect split
samples of the sludge before the microbes were introduced into the PCB
sludge. EPA observed the test set up to ensure it was in accordance with
the test plan, and observed the sample collection by Detox. Samples taken
be Detox throughout the test period were hand delivered to NUS laboratories
located at Houston, Texas. Detox claimed that chain of custody was maintained
in collection and delivery of the samples from Detox to NUS laboratories.
The analytical results showed a significant reduction in PCB concentration
with final sample results as low as 0.12 ppm.
DISCUSSION OF RESULTS
The Detox demonstration projects showed that the biological PCB disposal
method is capable of destroying PCBs to below 2 ppm, and has a practical
field application potential without harm to human health or the environment.
Some of the duplicate sample analytical results show a range in PCB
concentration. A range in results would be expected when dealing with
sediment samples due to non-homogeneous samples, and because of the
difficulties inherent in sediment extraction. However, the total picture
of the results of the bench and field demonstrations showed a definite
trend in the reduction of PCB concentrations in the sludge samples.
The air exhaust sample results in the bench scale test showed no detectable
PCBs. This ensured that the reduction in the PCB concentration was not due
to air dispersion, and that use of this technology in the field would not
result in harm to health or the environment by air dispersion. Ambient
air sampling was not conducted at the field demonstration because of the
results of the bench scale test, and because the field demonstration did
not utilize a heat source which could volatalize the PCBs, or use an air
dispersion device for aeration of the sample material which could result
in asperation of PCBs.
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Copies of the final report were sent to the state agencies for comment on
February 27, 1984. The Arkansas Department of Pollution Control and Ecology
(ADPC&E) commented that the approval should require site-specific evaluation
before granting permission to proceed with PCB disposal. The proposed PCB
approval requires a complete report evaluating the site including waste
analyses for EPA review. Each potential PCB disposal site would require
written approval by the Region VT Regional Administrator before disposal
could begin. Due to the wide variety and characteristics of contaminated
PCB wastes, it was felt necessary to require site specific approvals to
continue to collect more data on the performance of this relatively new
technology under different conditions.
CONCLUSION
The bench scale and field tests demonstrated the ability of the Detox
biological PCB disposal process to degrade PCBs to below 2 ppn without
endangering human health or the environment due to air dispersion, and
that the process is adaptable for commercial use.
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