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

Treatment  Process:


Document Reference:
Document Type:

Site Name:

Location of Test:
Biological - Aerobic


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

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.


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.

 Division of General Motors Corporation

 Massena Plant

 Post Office Box 460

 Massena, New York 13662
                                               October 7, 1986
       Cert i fied MaiI
       Return Receipt
       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
          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 .

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

                WORK    PLAN
Biodegradation of Polychlorinated Biphcnyls (PCBs)
                 a Superfund Site
                Hassena, New York

                12919 Dairy Ashford
              Sugar Land, TX   77478
                  (713) 240-0892


                             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


 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


 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.

      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.


                               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.




                             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.


                            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.

                        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.


                               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-


      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.


                                 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


                                TRAINING PLAN
Detox personnel previously  trained in handling  parameters  of Detox process.

All training performed in Detox's Houston facilities.


                            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



PCB analysis.  (See next page for  flowchart.)

                        THIRD  PARTY
        Proj.  Mgr.
     o  Preventative  Maint.
     o  Corrective  Action
     o  Increased Productivity
       of  Process
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
       Onsite  Coord.
     o   Audit  procedure  - Optional
   Using  all  EPA  standard  operating  procedures  and analytical
                              - 13  -

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+ **"** '"
.«—•*•,*,.'.<*  ^
      •  '  *   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
    We rec
    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

                              -  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"
     -      •
   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 ..


    1th fNtoM.offic»«ym6o/.i
                            For Oofwction
                       For Your Information
Wti«U   Date
                                            Not* and ftotum
         far-  /noire  OA


                                                                J. |
DO NOT uw IMS form tt
                            •  RECORD of •pprovaH, eoncunwwm.
                                 and »iinllw aetlofM
     FROM: (Num. 
                          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
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
107  ppa
 63  ppa
6.5  ppm
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

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
Enclo sure

Division of General Motors Corporation
Massena Plant
Post Office Box 460
Massena, New York 13662
                                           October  31,  1986
       Certified Mai I-
       Return  Receipt
       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.

                                      David P. Fayette
                                      C.M.  Facility Coordinator
       cc:  Joseph P. Chu,  PhD,  P.E.

                            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
SWL  Lab No.
DDT,  ppm
PCB,  ppm
as 1248
as 1248
as 1248
as 1248
as 1248
as 1248
as 1242
as 1242
                                                                   •Ol/rHWBSTBRN LABORATORIES
3 - DeTox Industries,  Inc.
                          Enris Barry
. 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.

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


              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.

                  (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

                  (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.
                  (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

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).

 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.



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.


 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.


 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.

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.

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.

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.
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.