United States
           Environmental Protection
           Agency
            Office of Research and
            Development
            Washington DC 20460
EPA/540/R-94/522
June 1995
&EPA
Dynaphore, Inc.
Forager™ Sponge
Technology

Innovative Technology
Evaluation Report
                 SUPERFUND INNOVATIVE
                 TECHNOLOGY EVALUATION

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                                               EPA/540/R-94/522
                                                      June 1995
              DYNAPHORE, INC.
       FORAGER™ SPONGE TECHNOLOGY
INNOVATIVE TECHNOLOGY EVALUATION REPORT
                   U S Environmental Protection Agency
                   Region 5, Library JPL-12J)
                   77 West Jackson Boulevard, IZln
                   Chicago, IL 60604-3590
  RISK REDUCTION ENGINEERING LABORATORY
   OFFICE OF RESEARCH AND DEVELOPMENT
   U.S. ENVIRONMENTAL PROTECTION AGENCY
           CINCINNATI, OHIO 45268
                                              Printed on Recycled Paper

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                                           NOTICE

       The information in this document has been prepared for the U.S. Environmental Protection Agency's
(EPA's) Superfund Innovative Technology Evaluation (SITE) Program under Contract No. 68-CO-0048. This
document has been subjected to the EPA's peer and administrative reviews and has been approved for publication
as an EPA document.  Mention of trade names of commercial products does not constitute an endorsement or
recommendation for use.

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                                                      FOREWORD

                   The Superfund Innovative Technology Evaluation (SITE) Program was authorized by the Superfund
            Amendments and Reauthorization Act (SARA) of 1986. The Program is administered by the EPA Office of
            Research and Development (ORD). The purpose of the SITE Program is to accelerate the development and use
            of innovative cleanup technologies applicable to Superfund and other hazardous waste sites. This purpose is
!            accomplished through technology demonstrations designed to provide performance and cost data on selected
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}            technologies.
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                   This project consisted of a demonstration conducted under the SITE Program to evaluate the Dynaphore,
x            Inc. Forager™ Sponge Technology for the treatment of heavy metal contaminated groundwater. The technology
            demonstration was conducted at the NL Industries, Inc. Superfund site located in Pedricktown, New Jersey. The
            demonstration provided information on the performance and cost of the technology. This Innovative Technology
            Evaluation Report presents an interpretation  of the data and discusses the potential applicability of the
            technology.

                   A limited number of copies of this report will be available at no charge from the EPA's Center for
            Environmental Research Information, 26 West Martin Luther King Drive, Cincinnati, Ohio, 45268. Requests
            should include the EPA document number found on the report's cover. When the limited supply is  exhausted,
            additional copies  can be purchased from the National Technical Information Service (NTIS), Ravensworth
            Building, Springfield, Virginia 22161, (703) 487-4600. Reference copies will be available at EPA  libraries in
            the Hazardous Waste Collection. You can also call the SITE Clearinghouse Hotline at (800) 424-9346 or (202)
            382-3000 in Washington, D.C. to  inquire about the availability of other reports.
            E. Timothy Oppelt, Director
            Risk Reduction Engineering Laboratory
                                                           111

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                                   TABLE OF CONTENTS
Section
Page
NOTICE	ii
FOREWORD	iii
ABSTRACT  	iv
LIST OF TABLES  	vii
LIST OF FIGURES	vii
ACKNOWLEDGEMENTS 	viii

Executive Summary	 1

Section 1       Introduction 	 6

        1.1     Background	 6
        1.2     Brief Description of Program and Reports 	 7
        1.3     The SITE Demonstration Program	 8
        1.4     Purpose of the Innovative Technology Evaluation Report (ITER)	 9
        1.5     Technology Description	 9
        1.6     Key Contacts	  11

Section 2       Technology Applications Analysis  	  12

       2.1     Key Features of the Dynaphore, Inc. Forager™ Sponge Technology	  12
       2.2     Operability of the Technology	  13
       2.3     Applicable Wastes  	  15
       2.4     Availability and Transportability of Equipment 	  16
       2.5     Materials Handling Requirements	  17
       2.6     Range of Suitable Site Characteristics	  18
       2.7     Limitations of the Technology	  19
       2.8     ARARs for the Dynaphore, Inc. Forager™ Sponge Technology	20
               2.8.1    Comprehensive Environmental Response, Compensation, and Liability Act
                      (CERCLA) 	21
               2.8.2    Resources Conservation and Recovery Act (RCRA)	25
               2.8.3    Clean Water Act (CWA)  	26
               2.8.4    Safe Drinking Water Act (SDWA)	27
               2.8.5    Occupational Safety and Health Administration (OSHA) Requirements	27
               2.8.6    Radioactive Waste Regulations  	28
               2.8.7   Mixed Waste Regulations	  29

Section 3       Economic Analysis	  30

       3.1      Conclusions of Economic Analysis  	  30
       3.2      Basis for Economic Analysis	  35
       3.3      Issues and Assumptions	  36
       3.4      Results of the Economic Analysis  	  37
               3.4.1   Site Preparation	  37

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                               TABLE OF CONTENTS (continued)
               3.4.2   Permitting and Regulatory Requirements	 38
               3.4.3   Capital Equipment 	 39
               3.4.4   Startup	 39
               3.4.5   Consumable and Supplies	40
               3.4.6   Labor	42
               3.4.7   Utilities	 43
               3.4.8   Effluent Treatment and Disposal	44
               3.4.9   Residuals and Waste Shipping and Handling Costs  	44
               3.4.10  Analytical Services	45
               3.4.11  Maintenance and Modifications	 46
               3.4.12  Demobilization	 46

Section 4       Treatment Effectiveness During the SITE Demonstration  	47

       4.1     Background	47
       4.2     Detailed Process Description	48
       4.3     Methodology	49
       4.4     Performance Data	 50

               4.4.1   Summary of Results for Critical Parameters 	 50
               4.4.2   Summary of Results for Non-Critical Parameters	 59

       4.4     Process Residuals	 63

Section 5       Other Technology Requirements	 65

       5.1     Environmental Regulation Requirements  	65
       5.2     Personnel Issues	 65
       5.3     Community Acceptance	 66

Section 6       Technology Status 	 67

       6.1     Previous Experience	 67
       6.2     Scaling Capabilities  	 67

Appendix A    Vendor Claims 	 68
                                               VI

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                                      LIST OF TABLES

Table                                                                                    Page
Table ES-1     Evaluation Criteria for the Dynaphore, Inc. Forager™ Sponge Technology	  4
Table 2-1       Federal and State ARARs for the Dynaphore, Inc. Forager™ Sponge Technology	22
Table 3-1       Estimated Costs for Treatment Using the Dynaphore, Inc. Forager™ Sponge
               Technology	31
Table 4-1       Treatment Performance for Critical Metals	  51
Table 4-2       Cadmium Column Data  	  53
Table 4-3       Chromium Column Data  	  54
Table 4-4       Copper Column Data	  55
Table 4-5       Lead Column Data	  56
Table 4-6       Summary of Data for Non-Critical Heavy Metals	  60
Table 4-7       Data Summary of Conventional Parameters  	  62


                                     LIST OF FIGURES

Figure                                                                                   Page
Figure 3-1       Percentage Breakdown by Cost Category 	  34
Figure 4-1       Process Flow Diagram of Dynaphore Inc. Forager™ Sponge Technology	49
Figure 4-2       Final Effluent Concentration of Critical Metals vs. Time	 51
Figure 4-3       Cadmium Concentration vs. Time	 57
Figure 4-4       Chromium Concentration vs. Time  	 57
Figure 4-5       Copper Concentration vs. Time	 58
Figure 4-6       Lead Concentration vs. Time 	 58
Figure 4-7       pH vs.  Time  	 64
                                             vn

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                                   ACKNOWLEDGEMENTS

       This report was prepared under the direction and coordination of Ms. Carolyn Esposito, the EPA SITE
Technical Project Manager at the Risk Reduction Engineering Laboratory (RREL) in Edison, New Jersey.

       This report was prepared for EPA's Superfund Innovative Technology Evaluation (SITE) Program by
Gary F. Vaccaro and Omer Kitaplioglu of Science Applications International Corporation (SAIC) for the U.S.
Environmental Protection Agency under Contract No. 68-CO-0048.  Major SAIC contributors to the successful
completion of this project were Paul Feinberg, Andy Matuson, Rita Schmon-Stasik, Herbert S. Skovronek, and
Joanne Torchia.

       The cooperation and participation of Dr.  Norman Rainer and Michael Rainer of Dynaphore, Inc.
throughout the course of this project and in review of this report are gratefully acknowledged. Special thanks are
noted to Mick Gilbert of EPA Region II, Steve Holt and Oris Ewing of NL Industries, Inc., and Lou Reynolds
of Adtechs Corp.

       Joyce Perdek and Uwe Frank of US EPA's Risk Reduction Engineering Laboratory provided technical
reviews of the draft report.
                                               Vlll

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                                  EXECUTIVE SUMMARY

       This report summarizes the findings of an evaluation of the Dynaphore, Inc. Forager™ Sponge
Technology  on the remediation of heavy metal  contaminated  groundwater at the NL Industries, Inc.
Superfund Site in Pedricktown, N.J.  This evaluation was conducted under the U.S. Environmental
Protection Agency's (EPA) Superfund Innovative Technology Evaluation (SITE) Program.

Technology Description

       The  Forager™  Sponge is an open-celled cellulose sponge incorporating an amine-containing
chelating polymer that selectively absorbs dissolved heavy metals from  aqueous waste streams.  The
Developer states that the technology can be utilized to remove and concentrate heavy metals from a wide
variety of contaminated aqueous media such as groundwater, surface  water, landfill leachate, and industrial
effluents.  The selective affinity of the polymer employed allows the Sponge to preferentially bind toxic
heavy metals over common innocuous cations such as Ca44, Mg"1"1", K+, and Na+.   The Sponge can be
regenerated with chemical solutions or  directly disposed; its matrix allows for compaction to a small
disposal volume. The Sponge could also be incorporated into varied treatment configurations.   For this
demonstration the Sponge was utilized in a pump-and-treat mode as a series of  four columns,  mounted
on a mobile  trailer unit. Each column contained  a removable fishnet bag of approximately 24,000 half-
inch sponge cubes.  The  Developer also reports  that the Sponge may have potential  in-situ treatment
applications; however, there is insufficient data currently available which demonstrates the viability of this
treatment option.

       The  Forager™ Sponge Technology  was  demonstrated at the  NL Industries,  Inc.  site  in
Pedricktown, N.J. from April 5 to 8, 1994.   This mobile pump-and-treat  system treated heavy-metal
contaminated groundwater over a continuous 72-hr operational period.  Based on field and laboratory
treatability tests, the Developer claimed that the technology would achieve at least  a 90% reduction of lead
and copper, an 80% reduction of cadmium and  a 50% reduction of chromium (as  trivalent chrome) in the
groundwater. Raw influent concentrations for  these metals ranged  from 426 ug/L for chromium to 917
ug/L for copper.

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Conclusions from this SITE Demonstration


       Based  on this SITE Demonstration,  the following conclusions  may be  drawn about  the
applicability of the Forager™ Sponge Technology:
              The technology was successful in meeting treatment claims for cadmium, copper and lead.
              Treatment claims for chromium, however, were not achieved. Specifically,  based on a
              90% confidence interval, cadmium was reduced by 89% + 2.4%, lead was reduced by
              96% + .40%,  and chromium was reduced by 32%  + 8.4%.  Reduction in copper was
              determined to  be >94%.  A confidence interval for percent reduction of copper was not
              calculated as all final effluent concentrations were non-detectable.

              Effective removal of cadmium,  copper, and  lead was  achieved in the presence of a
              groundwater pH ranging from 3.1 to 3.8, a sulfate concentration of approximately 20,000
              mg/L,  a TDS concentration of approximately 23,000  mg/L, and disproportionately higher
              concentrations of other cations such as calcium, magnesium, sodium,  and potassium.
              Concentrations for these cations ranged from 70 mg/L for magnesium to 6,000 mg/L for
              sodium.  The  technology's low affinity  for these cations was supported by their low
              removal rates.

              Although treatment claims for cadmium and lead were met, some of the Sponge columns
              became saturated with these metals during the demonstration.   Specifically, the first
              column became saturated with both cadmium and lead, while the second column became
              saturated with only cadmium. The capacity for copper was much greater, as none of the
              columns were  saturated with copper during the demonstration. The observed absorption
              capacity for these metals was significantly lower than the Developer's estimates which
              were based on saturation levels of laboratory metal standard solutions. These results show
              the need to conduct treatability tests on each waste stream proposed for treatment to
              determine the true absorption capacity of the system prior to implementing the technology.

              The Forager™ Sponge Technology was easy to  operate and exhibited  no operational
              problems over the course of the demonstration.  The system is trailer-mounted,  easily
              transportable, and can be operational within a day of arrival at a site.  The spent Sponges
              can be compacted into a  small volume for easy disposal. Four fishnet bags of Sponges
              were hand  compacted into one 55-gallon drum.  Compactor tests done off-site utilizing
              an industrial waste compactor revealed that 16 to 40 bags of Sponges could be compacted
              into one 55-gallon drum.

              The technology's usefulness may be limited by its overall absorption capacity for the
              heavy  metals  of concern.  If frequent changeout  or regeneration  of the columns  is
              required,  it could make this  technology  cost  prohibitive.   In these applications,
              pretreatment may be necessary in order to reduce  the concentration of specific
              contaminants to technically and/or economically optimal levels.

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               The cost to treat heavy metal contaminated groundwater over a one year period with the
               Dynaphore,  Inc. Forager™  Sponge  Technology  is estimated  at $340/1,000 gallons,
               assuming the Sponges are not regenerated and are replaced upon saturation, or $238/1,000
               gallons, assuming the Sponges are regenerated twice providing for three useful treatment
               cycles.  These cost  estimates assume groundwater characteristics are similar  to  the
               demonstration groundwater,  and  that  cadmium, lead,  and  copper  are  treated  to
               demonstration performance claims utilizing a four-column, pump-and-treat unit similar to
               the demonstration unit.

               A significant portion of the cost is attributable to the frequent replacement or regeneration
               of the Sponges due to the limited absorption capacity for cadmium in this groundwater.
               The Developer believes that a modification of the polymer may improve its overall
               absorption capacity for the critical metals which would greatly aid in lowering treatment
               costs.  Additionally,  further cost reduction may be achieved through  the use of larger
               scale units which could handle higher flow rates, and the use of an industrial compactor
               to compact Sponges which could lower disposal costs.
       The Dynaphore, Inc. Forager™ Sponge Technology was evaluated based on the nine criteria used

for decision-making in the Superfund Feasibility Study (FS) process. Table ES-1 presents the evaluation.

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             TABLE ES-1.  EVALUATION CRITERIA FOR THE DYNAPHORE, INC. FORAGER™ SPONGE TECHNOLOGY
OVERALL PROTECTION OF
HUMAN HEALTH AND THE
ENVIRONMENT
  COMPLIANCE WITH
  FEDERAL ARARs
LONG TERM EFFECTIVENESS
AND PERMANENCE
  REDUCTION OF TOXICITY,
  MOBILITY, OR VOLUME
  THROUGH TREATMENT
 Protects human health and the
 environment by removing
 contaminants from groundwater
 or surface water.
Requires compliance with RCRA
treatment, storage, and disposal
regulations for hazardous waste &
pertinent AEA, DOE, & NRC
requirements for radioactive or
mixed waste.
 Permanently removes contamination
 from affected matrix.
Volume reduction technology which
transfers contaminants from aqueous
media to a smaller concentrated
volume.
 Minimizes or eliminates the
 further spread of contaminants
 within the aquifer.
Well construction activities may
require permits.
 Residuals from the process must be
 disposed of in an appropriate
 manner.
Ability to compact Sponges to small
volumes may be advantageous for
radioactive or mixed waste.
                                  Wastewater discharges to POTWs
                                  or surface water bodies or
                                  underground injection wells may
                                  require compliance with the Clean
                                  Water Act or Safe Drinking Water
                                  Act.

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SHORT TERM
EFFECTIVENESS
  IMPLEMENT ABILITY
     COST
COMMUNITY ACCEPTANCE  STATE ACCEPTANCE
 Presents minimal risk to
 workers and the community.
Easily implementable and
transportable.
$340 per 1,000 gallons with
no regeneration.'*'
Minimal short term risks to
the community make this
technology attractive to the
public.
If remediation is conducted
as part of a RCRA
corrective action, state
regulatory agencies may
require permits to be
obtained before
implementing the system.
These may include a permit
to operate the treatment
system, a permit to store
contaminated residuals (i.e.,
Sponges, regenerant
solutions) for more than 90
days, and a wastewater
discharge permit.
                              Requires minimal site
                              preparation and utilities
                              (water & electricity).
                             $ 238 per 1,000 gallons
                             with Sponges regenerated
                             twice providing for 3 useful
                             cycles/*'
                                                           Significant portion of cost
                                                           attributable to frequent
                                                           replacement and
                                                           regeneration due to limited
                                                           absorption capacity for
                                                           cadmium in this
                                                           groundwater. Treatment
                                                           costs can be seriously
                                                           impacted by absorption
                                                           capacity for the metals of
                                                           concern.
                Actual cost of a remedial technology is site-specific and is dependent on factors such as the cleanup level, contaminant concentrations and types, waste
                characteristics, and volume necessary for treatment. Cost data presented in this table are for treating 525,000 gallons of heavy metal contaminated over a one
                year period. The groundwater is assumed to have similar waste characteristics to the demonstration groundwater with cadmium, copper, and lead treated to
                Developer claims utilizing a four column pump and treat unit similar to the demonstration, mobile trailer unit.

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                                         SECTION 1
                                      INTRODUCTION

       This  section provides  background information about the Superfund Innovative Technology
Evaluation (SITE) Program, discusses the purpose of this Innovative Technology Evaluation Report
(ITER), and describes the Dynaphore, Inc. Forager™ Sponge Technology. For additional information
about the  SITE Program, this technology, and the demonstration site, key contacts are listed at the end
of this section.

1.1    Background

       The Forager™ Sponge Technology was demonstrated under the SITE  Program  at the NL
Industries, Inc. Superfund site in Pedricktown, New Jersey in April, 1994. The mobile, pump-and-treat
system treated groundwater contaminated with heavy metals. The demonstration focused on the system's
ability to  remove cadmium, chromium, copper, and lead from the contaminated  groundwater over a
continuous 72-hour test. Based on field and laboratory  treatability tests, the Developer claimed that the
technology would achieve at least a 90% reduction of lead and copper, an 80% reduction of cadmium and
a 50% reduction of chromium (as trivalent  chrome) in the groundwater.   This evaluation of the
Dynaphore, Inc. Forager™  Technology is  based primarily on the results of the SITE demonstration
conducted at the NL Industries, Inc. site.

       The Forager™  Sponge is an  open-celled cellulose sponge incorporating  an amine-containing
chelating polymer that selectively absorbs dissolved heavy metals in both cationic and anionic states. This
technology is a volume reduction technology in which heavy metal contaminants from an aqueous medium
are concentrated into a smaller volume for facilitated disposal. The Developer states that the technology
can be used to  remove and concentrate heavy metals from a wide variety of aqueous media, such as
groundwater,  surface waters, and process waters.  The  sponge matrix  can be directly disposed, or
regenerated with chemical solutions.

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1.2    Brief Description of Program and Reports

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

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

       •       the Demonstration Program,
       •       the Emerging Technologies Program,
       •       the Monitoring and Measurement Technologies Program, and
       •       the Technology Transfer Program.

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

       The Emerging Technologies Program focuses on conceptually proven bench-scale technologies
that are in an early stage of development involving pilot or laboratory testing. Successful technologies are
encouraged to advance to the Demonstration Program.

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       Existing technologies that improve field monitoring and site characterizations are identified in the
Monitoring and Measurement Technologies Program. New technologies that provide faster, more cost-
effective  contamination and site assessment data are supported by this program.  The Monitoring and
Measurement Technologies Program also formulates the protocols and standard operating procedures for
demonstration methods and equipment.

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

1.3    The SITE Demonstration  Program

       Technologies are selected for the  SITE Demonstration Program through annual  requests for
proposals. ORD staff reviews  the proposals to  determine which technologies show the most promise for
use at Superfund sites. Technologies chosen must be at the pilot- or full-scale stage, must be innovative,
and must have some advantage over existing technologies. Mobile technologies are  of particular interest.

       Once the EPA has accepted a proposal,  cooperative agreements  between the EPA and the
Developer establish responsibilities  for conducting the demonstration and evaluating the technology. The
Developer is responsible for demonstrating the technology at the selected site and is expected to pay any
costs for transport, operation, and removal of the equipment. The EPA is responsible for project planning,
sampling and analysis, quality assurance and quality control, preparing reports, disseminating information,
and transporting and disposing of treated waste materials.

       The results of this evaluation of the Dynaphore, Inc. Forager™ Technology for treatment of heavy
metal contaminated aqueous waste are published in two basic documents: the SITE Technology Capsule
and  this  Innovative Technology Evaluation Report. The SITE Technology Capsule  provides relevant
information on the technology, emphasizing key features of the results of the SITE field demonstration.
Both the SITE Technology Capsule and the ITER are intended for use by remedial managers making a
detailed evaluation of the technology for a specific site and waste.

                                               8

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1.4    Purpose of the Innovative Technology Evaluation Report (ITER)

       This  ITER provides  information on  the Dynaphore, Inc.  Forager™  Sponge Technology  and
includes a comprehensive description of this demonstration and its results. The ITER is intended for use
by EPA remedial project managers, EPA on-scene coordinators, contractors, and other decision-makers
carrying out specific remedial actions. The ITER is designed to aid decision-makers in further evaluating
specific technologies for further consideration as applicable options in a particular cleanup operation. This
report represents a critical step in the development and commercialization of a treatment technology.

       To encourage  the general use of  demonstrated  technologies,  the  EPA provides information
regarding the applicability of each technology to specific sites and wastes. The ITER includes information
on cost and site-specific characteristics. It also discusses advantages, disadvantages, and limitations of the
technology.

       Each SITE demonstration evaluates  the performance of a technology in treating a specific waste.
The waste characteristics of other sites may differ from the characteristics of the treated waste. Therefore,
a successful field demonstration of a technology at one site does not necessarily ensure that it will be
applicable at other sites. Data from the field demonstration may require extrapolation for estimating the
operating ranges in which the technology will perform satisfactorily. Only limited conclusions can be
drawn from  a single field demonstration.

1.5    Technology Description

       The  Forager™  Sponge is an open-celled  cellulose sponge which contains  a water-insoluble
polyamide chelating polymer for the selective removal of heavy metals. The polymer is intimately bonded
to the cellulose so as to minimize physical separation from the supporting matrix.  The functional groups
in the polymer (i.e., amine groups in the  polymer backbone,  and pendent carboxyl groups) provide
selective affinity for heavy metals in both cationic and anionic states, preferentially forming coordination
complexes with transition-group heavy metals (groups IB through VIIIB of the Periodic Table). The order
of affinity of the polymer for metals is influenced by solution parameters such as pH, temperature,  and

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total ionic content.  The following affinity sequence for several representative ions is generally expected
by Dynaphore:

Cd^ > Cu++ > Fe^ > AU+++ > Mn++ > Zn~ > Ni^ > CG++ > Pb^ > Au(CN)2" > SeO4'2 > AsO4'3 > Hg^
CrO4-2 > UO4-2> Ag+ > Alw > K> Ca^ > Mg++ > > Na+

        The high selectivity for heavy metals, and the low selectivity for alkali and alkaline earth metals
(Na+, K+, Mg^, and Ca^), is especially useful for the treatment of contaminated natural waters which may
contain high concentrations of these innocuous chemical species. These monovalent and divalent cations
do not  interfere with or compete with absorption of heavy metals, therefore  allowing for  maximum
removal of heavy metals from  contaminated waters.

        The Sponge is highly porous thereby promoting high rates of ion absorption.  Absorbed ions can
be eluted from  the Sponge by techniques typically employed for regeneration  of ion exchange resins.
Following elution and washing, the Sponge is ready for the next absorption cycle. The useful life of the
Sponge depends on the operating environment and the elution techniques used. Where regeneration is not
desirable or economical, the Sponge can be compacted to a small volume to facilitate disposal. The metal-
saturated Sponge can also be incinerated with careful attention given to the handling of resultant vapors.

        The Sponge can be used in columns, fishnet-type enclosures, or rotating  drums.   For this
demonstration, the Sponge was utilized in a series of four columns. Each column was comprised of a 1.7
cubic foot,  pressurized acrylic tube containing about 24,000 half-inch Sponge cubes packaged within a
removable fishnet bag. The columns were mounted on a mobile trailer unit.

        Section 4.2 provides the specific details of the process design used during the Demonstration Test.
Section 4.3  discusses the  methodology behind the treatment and testing  performed.   Specific details
regarding the polymer's configuration and removal chemistry are presented by the Developer in Appendix
A.
                                              10

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1.6    Key Contacts


       Additional information on the Dynaphore,  Inc. Forager™  Sponge Technology and the SITE

Program can be obtained from the following sources:
       The Dynaphore, Inc. Forager™ Sponge Technology

       Dr. Norman Rainer
       Dynaphore, Inc.
       2709 Willard Road
       Richmond, VA 23294
       Phone: 804/288-7109
       Fax:   804/282-1325

       The SITE Program

       Robert A. Olexsey, Director                        Carolyn Esposito
       Superfund Technology Demonstration Division       EPA SITE Technical Project Manager
       U.S. Environmental Protection Agency               U.S. Environmental Protection Agency
       26 West Martin Luther King Drive                  2890 Woodbridge Avenue (MS-106)
       Cincinnati, Ohio 45268                            Edison, New Jersey 08837-3679
       Phone: 513/569-7861                              Phone: 908/906-6895
       Fax:   513/569-7620                              Fax:   908/906-6990

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

clearinghouses:
              The Alternative Treatment Technology Information Center (ATTIC) System (operator:
              703/908-2137) is a comprehensive, automated information retrieval system that integrates
              data on hazardous waste treatment technologies into a centralized, searchable source. This
              data base provides summarized information on innovative treatment technologies.

       •      The Vendor  Information  System for Innovative  Treatment  Technologies (VISITT)
              (hotline: 800/245-4505) data base currently contains information on approximately 231
              technologies offered by 141 Developers.

       •      The OSWER CLU-In electronic bulletin board contains information on the status of SITE
              technology demonstrations. The system operator can be reached at 301/585-8368.


       Technical reports may be  obtained by  contacting  the Center for  Environmental  Research

Information (CERI), 26 West Martin Luther King Drive in Cincinnati, Ohio, 45268 at 513/569-7562.
                                             11

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                                         SECTION 2
                         TECHNOLOGY APPLICATIONS ANALYSIS

       This section of the report addresses the general applicability of the Dynaphore, Inc.  Forager™
Sponge Technology to contaminated waste sites.  The analysis is based primarily on the results of this
SITE demonstration since limited information is available on other applications of the technology. SITE
demonstration results are presented in Section 4.   The vendor's claims regarding the applicability and
performance of the Forager™ Sponge technology are presented in Appendix A.

2.1    Key Features of the Dynaphore, Inc. Forager™ Sponge Technology

       The Forager™ Sponge Technology incorporates a specialty chelating polymer that has  a selective
affinity for removing heavy metals from aqueous media. The polymer preferentially binds toxic heavy
metals over common aqueous constituents such as Ca^, Mg""", K+, and Na+.  The Sponge's low affinity
for these monovalent and divalent cations  allows these ions,  for the most part, to pass through the
treatment system, enabling maximum absorption of the toxic heavy metals even in the presence of higher
concentrations of these innocuous species. The selective affinity of the polymer  is similar to commercially
available chelating resins; however, the Sponge's unique supporting cellulosic matrix may provide the
technology with distinct advantages under certain processing conditions.

       The Forager™ Sponge could potentially be incorporated into varied treatment configurations. The
technology can be utilized in a conventional pump-and-treat remedial process, as was performed during
the SITE  Demonstration.  According to the Developer, the Sponge also can be used in applications
requiring in-situ treatment. In-situ applications, however, were not evaluated for this demonstration nor
has the Developer commercially utilized the technology in such applications. For in-situ applications, the
Developer reports that the Sponge, contained within fishnet bags, could be placed within trenches or wells
to intercept an existing flow of water (e.g., groundwater or  acid mine drainage). The Sponge reportedly
could also be used to treat surface waters by placing the Sponge in a fishnet configuration across channels
or within other surface water bodies.

       In addition to potential different treatment applications, the Sponge's matrix provides  advantages
in terms of disposal and operating conditions. The high porosity of the Sponge enables a low pressure

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system to be used.  For this demonstration, the four column unit operated under an inlet pressure as low
as 4.4 psig.  With sufficient  head the system could have operated  by gravity flow,  but this was not
demonstrated.  The metal-laden Sponge can also be compacted into small disposal volumes, which could
aid in lowering disposal costs; this is particularly beneficial when minimal residual waste is required due
to the properties of the contaminants being absorbed.  For example, this may be advantageous  in the
treatment of radiologically contaminated waters, where the need to minimize the volume of residual waste
is a critical disposal issue.

2.2    Operability of the  Technology

       The Forager™ Sponge Technology was utilized in a pump-and-treat mode. The treatment system
employed consisted of a series of four 1.7 cubic foot columns situated on a mobile, open trailer-mounted
unit measuring approximately 50 square  feet.  Each column measures 5 feet in height with an 8 inch
inside diameter.  The columns are connected for upward series flow.  Each column contains a removable
fishnet bag which is filled with approximately 24,000 half-inch Sponge cubes.  The trailer  is equipped
with a wastewater pump, water heater, and both a rotameter and positive displacement type flow totalizer.
These flow meters are installed on the outlet line of the unit. The system is operated by trained personnel
and may be operated unattended until replacement and/or regeneration of the Sponges is required. The
Forager™  Sponge unit appeared to be  free of operational problems during the  demonstration in
Pedricktown, NJ.

       Since reaction kinetics are an important factor in the metal removal efficiency of the Sponge, both
flow and temperature are key operating parameters  which influence the performance  of the Forager™
Sponge Technology.  Based on treatability tests conducted on the groundwater the Developer determined
that optimum removal efficiency, utilizing the system employed, would be achieved at a flow rate of 1
gpm or .08 bed volumes per minute. Additionally, to  ensure optimum conditions, the Developer increased
the groundwater temperature approximately 14° C from 17° C to 31° C.  The optimum flow rate and the
need to increase water temperature  is dependent upon the waste treated and  the removal  efficiencies
required, as well as the number of Sponge columns employed.

       Both flow and temperature were continually monitored during the demonstration. Temperature
gauges were installed on the inlet and outlet of the water heater. As stated earlier, a rotameter and volume

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totalizer were situated on the trailer.  However, due to the physical location of the meters, air bubbles in
the treated groundwater passing through the meters influenced the reliability of the measurements.  A
digital flowmeter provided by the EPA for the demonstration was substituted and installed on the outlet
line to the treated storage tank where its physical location was not influenced by air bubbles. Based on
experience from the  SITE demonstration, the Developer may need to relocate his flow meters and/or
utilize a meter(s) less influenced by air bubbles.

       Replacement and/or regeneration of the Sponges within the columns is necessary when Sponges
become saturated and/or operate below a desired removal efficiency.  According to  the Developer,
replacement and/or regeneration was not required for the demonstration, since none of the columns of
Sponges  were anticipated to be  saturated.  However, as to  be discussed in Section 4,  although  the
Developer was able to meet his treatment claims, some of the Sponge columns became saturated during
the demonstration. For the four column system utilized, the  system would be shut down to allow for
replacement or regeneration of the Sponges. Once put back on line, a regenerated or new Sponge column
would then become the last column, with all remaining columns moving up the treatment line. This is
easily accomplished through the wastewater piping design which provides for manifolding of the columns.
Raw influent flow can be redirected by valving to any of the columns.

       Replacement of the Sponges can be easily performed within a one hour period. Each column has
a lid secured with eight bolts and contains a removable fishnet container (bag) filled with Sponge cubes.
Following removal of the lid, the fishnet container is removed from the column via an overhead pulley
system mounted on the trailer.  The containers of Sponges are  lifted out and suspended over the columns
to allow any residual water to drain  back into the  columns.  Once sufficiently drained, plastic sleeves
(bags) are  placed over the fishnet bags of Sponges.  The Sponges are then  ready for disposal.  The
Developer reports that he will be replacing the bolted lid design with a quick-release, bayonet-type fitting,
which will allow for  easier and faster removal of the column lids.  The Sponges can be hand compacted
into 55-gallon drums, as was performed for the demonstration.  By laying the Sponges horizontally and
bending into a horseshoe shape within the drum, four fishnet bags of Sponges could be laid on top of each
other.  Additional compaction could be achieved through the  use of a waste compactor.  However,  if a
waste compactor is used, provisions may have to be  in place to collect any residual water which would
be squeezed from the Sponges during compaction. Any water collected could be recycled to the treatment
system.

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       As stated, regeneration of the Sponges was not conducted for the demonstration. Regeneration
of small test columns with standard solutions of critical metals was performed to evaluate the Sponge's
regenerative capabilities (see Section 4). After the demonstration, the Developer conducted regeneration
tests on Sponge cubes taken from the columns.  These tests showed regeneration of the Sponge is feasible.
For the 1.7 cubic foot columns used, the Developer reports that regeneration can be accomplished by
slowly running 34 quarts of 10% industrial grade hydrochloric acid (HC1) at  1 quart/minute through a
column Sponge followed by a water wash with 34 quarts of potable water  at 1 quart/minute. The acid
and water wash is pumped through the top of the column from a 30 gallon tank located on the trailer.
The trailer unit is also equipped with a pump to feed regenerant chemicals automatically to the columns.
The Developer also noted that heating of the HC1 to  40° C may be desirable to improve metals recovery
or to permit the use of less concentrated acid.  If heating is not feasible, the Developer suggests retaining
the HC1 in the column for a two to four hour period.

2.3    Applicable Wastes

       The Forager™ Sponge Technology is  suitable for dissolved heavy metals  in both cationic and
anionic states.    The Developer reports that the Forager™ Sponge  can be utilized to remove and
concentrate heavy metals in the parts per billion (ppb) and  parts  per million (ppm) range from a wide
variety of contaminated aqueous media such as groundwater, surface water, landfill leachate, industrial
effluent,  and acid mine drainage.   For this demonstration the  technology was successful in  treating
groundwater with heavy metals in  the ppb range.  The technology was able to achieve >89% reduction
of lead, cadmium, and copper in concentrations ranging from 500 to 900 ppb.  The Sponge  may also be
effective for radioactive or mixed waste (radioactive and hazardous waste) since it reportedly  has a strong
affinity for radioactive isotopes such as uranium. This, however, was not evaluated for the demonstration.
Although  present in  the  groundwater,  the  levels of alpha and beta  radioactivity were  too  low to
conclusively determine the technology's effectiveness.  As stated in  Section 2.2, the ability to compact
the Sponge to  small volumes is particularly advantageous for radiologically contaminated waters.

       The Sponge's high selectivity for toxic heavy metals and the low selectivity for monovalent and
other divalent cations (i.e., Na+, K+, Mg++, and Ca^) is especially useful for the treatment of contaminated
natural waters which may contain high concentrations of these innocuous chemical species. These cations
do not interfere with or compete with absorption of the toxic heavy metals. This was supported by the

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demonstration results which showed effective removal of the lead, cadmium, and copper in the presence
of disproportionately higher concentrations of calcium, magnesium, aluminum, sodium and potassium.
Concentrations of these cations ranged from  70  mg/L for magnesium to 6000 mg/L for sodium with
virtually no removal occurring.

        The Forager™ Sponge can be utilized in a conventional pump-and-treat remedial process as either
the primary or secondary removal mechanism, depending upon the type and concentration of contaminants
as well as the properties of the wastewater.  For example, the  Sponge may be used as a polishing step in
conjunction with a  technology that can reduce high concentrations of metals to moderate  levels (e.g.,
chemical precipitation). As discussed in Section 2.1, the Sponge could also potentially be used for in-situ
applications.  However,  there is insufficient information  to  properly evaluate the viability of in-situ
applications.

        The Developer reports that the Sponge is effective over a wide pH range of 2 to 11. The pH of
the groundwater treated in the demonstration ranged from 3.1 to 3.8.  The Developer reports little or no
pretreatment is required for the technology. TSS levels as  high as 100 mg/L do not impact the Sponge
performance as shown by the demonstration. TSS levels for the demonstration ranged  from 85 mg/L to
107 mg/L.  Also, according to the Developer, oil and grease also do not impact the Sponge unless the
water contains a significant oily layer. Organics also reportedly do not foul the system.

2.4     Availability and Transportability of Equipment

        The Forager™  Sponge treatment unit is mounted on a flat-bed trailer and is easily transported.
Once on site, the treatment system can be in operation within a day if all necessary facilities, utilities, and
supplies are available. On site assembly and maintenance requirements are minimal.

        Demobilization activities include decontaminating on-site equipment (if necessary), disconnecting
utilities, disassembling equipment,  and  transporting  equipment  off-site.  Demobilization  requires
approximately one day for the Forager™ Sponge unit.
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2.5    Materials Handling Requirements

       If the Forager™ Sponge Technology is utilized to treat groundwater in a pump and treat approach,
a groundwater recovery well(s) will need to be installed. Boreholes for wells are installed using a drill
rig.  Drilling services are generally subcontracted to a company which has both the required equipment
(drill rigs, augers, samplers) and personnel trained in drilling operations  and well construction.  Drilling
personnel must  have OSHA-required 40-hour health and  safety training,  if work is performed at a
hazardous waste site. Once all of the well(s) are drilled and developed, each must be equipped with a
pump to supply the feed water to the system.  An equalization tank may be required to store the feed
water rather than pumping directly to the unit. Additionally, if the treated water is temporarily stored
prior to disposal (e.g., for testing), a suitably sized storage tank will be needed, including an effluent pump
to transport treated water from the unit to the tank.  All pumps chosen must be able to perform under
harsh conditions, high solids  content (both total  and dissolved), corrosive pH, and variable chemical
composition and concentrations.  These factors should be taken into account during the selection of pumps
and ancillary equipment such as hoses and fittings.

       As stated in  Section 2.3, the Developer reports little  or no pretreatment is required for the
technology unless appreciable amounts of solids or oils are present. Waters containing a visible oily layer
will  require pretreatment to remove the oil. An oil/water separator should be sufficient to reduce the oil
content to  an acceptable level.   Pretreatment for removal of  suspended solids may be required if a
significant concentration of suspended matter  is present which could plug the Sponge pores.  Depending
on the concentration,  a simple bag filter or cartridge filter may be sufficient.

       The residuals generated from the Sponge technology consist of solid sponge material and liquid
(acid) regenerant solution, if regeneration is performed.   These residuals will be concentrated with heavy
metals, and depending on contaminant levels,  may be subject to RCRA regulations as a hazardous waste.
These waste  materials can be easily stored in appropriate  55-gallon drums for off-site transport and
disposal. For the demonstration, four fishnet bags of Sponges were  hand compacted into one 55-gallon
drum.  Further  compaction is possible  utilizing a  waste  compactor.  Following  completion  of the
demonstration, the Developer  sent four  fishnet bags of  virgin Sponges  to a waste compacting firm to
determine maximum compaction achievable. Tests performed revealed compaction ratios of 4:1  and 10:1
utilizing  compaction forces of 20,000  pounds  and 85,000 pounds,  respectively.   Based on these

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compaction ratios, using 20,000 pounds of compaction force, approximately 16 bags of Sponges could be
disposed within a 55-gallon drum, and at 85,000 pounds of force approximately 40 bags of Sponges could
be disposed in one 55-gallon drum.

       Depending on discharge limitations, treated water may be discharged into a POTW or  surface
water body, or may be reinjected into the ground.  For the demonstration, the treated water was collected
in a storage tank for transport to a local POTW for treatment.

2.6    Range of Suitable Site Characteristics

       Locations suitable for on-site treatment using the Forager™ Sponge Technology trailer unit must
be  able to accommodate and/or  provide  utilities, support facilities,  and support  equipment. These
requirements are discussed below.

       Utilities required for the Forager™ Sponge unit are limited to water and electricity.  Electricity
requirements for  the trailer unit  are dependent  upon the need to pump, rather than gravity feed the
wastewater through the columns; and the need to heat the wastewater  to improve absorption of heavy
metals and/or the HC1 for regeneration, if necessary (see Section 2.2).  The water heater utilized in the
system requires a single phase 220-volt electrical circuit.  If gravity feed is not feasible, the water can be
pumped with a 12-volt pump installed on the trailer.  This pump can also run off a car battery, as was
done  for the demonstration. Other than the trailer unit, electricity may be  required for running any
ancillary pump,  building and  outdoor lights, and  on-site office  trailers.  Water will be required
occasionally for regeneration of the Sponges, cleanup, and decontamination.

        Support facilities include an area for untreated and treated groundwater storage tanks (if used),
a chemical storage area for regenerant chemicals (i.e., acids) and any other process chemicals, and a waste
drum storage area for spent Sponges, spent regenerant solutions, and  other wastes requiring disposal.
These support areas must be constructed with a secondary containment system  (e.g., concrete berm) to
control runon and runoff.  Additionally,  an  enclosed  building or shed may be necessary to protect
equipment and personnel from weather extremes. This  shed should be  heated  and used to house the
Sponge technology.  Also, if below-freezing temperatures are anticipated for extended periods  of time,
influent and  effluent storage tanks and transfer lines may need to be insulated or also kept in the shed.

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During the demonstration, the treatment unit was housed in a tent measuring approximately 400 square
feet.  Mobile trailers may be used as office space on site.  These office trailers must be located outside
the treatment/contaminated area.

       Support equipment  for the Forager™ Sponge Technology may include  a drill  rig for well
installation, containers for waste storage, a forklift for moving waste drums, and a  waste compactor for
compaction of Sponges. In addition to an influent equalization tank, a treated effluent storage tank may
be needed if the water cannot be directly discharged to a POTW or surface water body or reinjected into
the ground.

2.7    Limitations of the Technology

       The technology is considered a volume reduction technology since the contaminants are removed
from  the waste stream and concentrated into a smaller volume which  can be more easily handled and
disposed.  The reduced volume, either  Sponge material or acid regenerant solution, must be immobilized
by  other means on-site or off-site.   A Toxicity  Characteristic Leaching Procedure  (TCLP) was not
performed  on metal-saturated Sponges for the demonstration. Although the Sponge is regenerated with
hydrochloric acid (which is stronger than acetic acid used in the TCLP test), it is not anticipated that the
Sponge would pass a  TCLP test for disposal as non-hazardous waste, assuming sufficient  quantities of
RCRA-regulated heavy metals are absorbed on the Sponge.  The Developer, however, does report that
bench-scale laboratory tests have shown that the metal-saturated Sponge cubes, when treated with certain
fixatives, such as  a phenol-formaldehyde resin, will pass the TCLP test for metals.

       According to the Developer, the scope of contaminants suitable for treatment using the Forager™
Sponge Technology is limited to certain heavy metals. This SITE demonstration was conducted to evaluate
the performance of the technology with respect to cadmium, chromium, copper and lead.  The behavior
of other heavy metals present was  noted during the demonstration and therefore, data regarding the
removal (or lack of removal) of these  species are also presented in this report.

       The technology's affinity and  absorption capacity for given metals can vary and appears to be
dependent on a number of waste characteristics including pH, concentrations and types of cations and
anions present, and  the presence of complexing agents. As an example, the technology had a unusually

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poor affinity for iron.  The Developer believes that this may have been caused by organosulfur compounds
which strongly complexed  with the iron and thus interfered with the Sponge's removal ability.  The
Developer  has also  theorized that the lower-than-expected saturation  levels for the critical  metals
(cadmium,  chromium, copper, and lead) may have been caused by the presence of anion species such as
sulfate,  phosphate, silicate, and vanadate. These anion species are  believed to  have reacted with the
calcium present in the starting Sponge, thereby binding the calcium on the Sponge  in a chemical form that
prevented its effective exchange for the metals of concern.  The Developer believes that a modified
polymer or a preactivation step with hydrochloric acid might have improved the polymer's capacity (see
Appendix A - Vendor's Claims).  It should be  noted  that an adverse  behavior due to commonly
encountered anions, such as sulfate and phosphate, could have a serious impact on the Sponge's absorption
capacity.

        Regardless of the reasons for the decreased capacity, the technology's usefulness may be severely
limited  by  its overall absorption capacity for the heavy  metals of concern.  If frequent changeout or
regeneration  of the  Sponges  is required, it could make this technology cost  prohibitive.   In these
applications, pretreatment may be necessary in order to reduce the concentration of specific contaminants
to technically and/or economically optimal levels. The results of the demonstration have shown that future
use of the  technology would require the Developer to conduct treatability tests on each waste stream
proposed for treatment to determine the true absorption capacity of the system.  The Developer's estimates
on absorption capacity  were  based on laboratory absorption tests performed on heavy metal standard
solutions rather than the groundwater.  As stated, the demonstration results revealed that  the actual
absorption  capacity for the critical metals was significantly  lower than the Developer's estimates.

2.8     ARARS for the Dynaphore, Inc. Forager™ Sponge Technology

        This subsection discusses specific federal environmental regulations pertinent to the operation of
the Forager™ Sponge Technology including the transport, treatment, storage,  and disposal of wastes and
treatment residuals. These regulations are reviewed with  respect to the demonstration results. State and
local regulatory requirements, which may be more stringent, must also be addressed by remedial managers.
Applicable  or  relevant and  appropriate   requirements  (ARARs) include the  following:  (1)  the
Comprehensive Environmental Response, Compensation, and Liability Act; (2) the Resource Conservation
and Recovery Act; (3) the Clean Water Act; (4) the Safe Drinking Water Act; (5) the Occupational Safety

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and Health Administration regulations; (6) radioactive waste regulations; and (7) mixed waste regulations.
These  seven general ARARs  are discussed below; specific ARARs that may be applicable to the
Dynaphore Inc. Forager™ Sponge Technology are identified in Table 2-1.

2.8.1   Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

       The CERCLA of 1980 as amended by the Superfund Amendments and Reauthorization Act
(SARA) of 1986 provides for federal funding to respond to releases or potential releases of any hazardous
substance into the environment, as well as to releases of pollutants or contaminants that may present an
imminent or significant danger to public health and welfare or to the environment.

       As part of the requirements of CERCLA, the EPA has prepared the National Oil  and Hazardous
Substances Pollution Contingency Plan (NCP) for hazardous substance response. The NCP is codified in
Title 40 Code of Federal Regulations (CFR) Part 300, and delineates the methods and criteria used to
determine the appropriate extent of removal and cleanup for hazardous waste  contamination.

       SARA states a strong statutory preference for remedies that are highly  reliable and provide long-
term protection and directs EPA to do the  following:
              use remedial alternatives that permanently and significantly reduce the volume, toxicity,
              or mobility of hazardous substances, pollutants, or contaminants;
              select remedial actions that protect human health and the environment, are cost-effective,
              and  involve permanent  solutions  and alternative treatment or  resource  recovery
              technologies to the maximum extent possible; and
              avoid off-site transport and disposal of untreated hazardous substances or contaminated
              materials when practicable treatment technologies exist [Section 121(b)].
       In general, two types of responses are possible under CERCLA: removal and remedial action. The
Dynaphore Inc. Forager™ Sponge Technology is likely to be part of a CERCLA remedial action.
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              TABLE  2-1.  FEDERAL AND STATE ARARs FOR THE DYNAPHORE, INC. FORAGER™ SPONGE TECHNOLOGY
          PROCESS ACTIVITY
         ARAR
     DESCRIPTION
        BASIS
                                                                                                                     RESPONSE
    Waste Characterization
    (untreated waste)
RCRA40CFRPart261 or
state equivalent'*'
Standards that apply to
identification and
characterization of waste to
be treated
A requirement of RCRA
prior to managing and
handling the waste
Chemical analyses must be
performed
    Waste processing
RCRA 40 CFR Part 264
and 265 or state
equivalent^'
Standards applicable to
the treatment of hazardous
waste at permitted and
interim status facilities
Treatment of hazardous
waste must be conducted in
a manner that meets the
operating and monitoring
requirements
Equipment must be
maintained daily.  Integrity
of treatment unit and
influent and  effluent storage
tanks, if used, must be
monitored and maintained
to prevent leakage or failure
to
    Storage after processing
RCRA 40 CFR Part 264
and 265 subpart I or state
equivalent^'
Standards that apply to the
storage of hazardous waste
in containers
The process residuals,
including spent Sponges and
regenerant solution may be
deemed hazardous
Process residuals must be
stored in appropriate
containers in good
condition. Containers
should be stored in
designated hazardous waste
storage area with proper
secondary containment.
    Waste characterization
    (process residuals)
RCRA 40 CFR Part 261, or
state equivalent'*'
Standards that apply to
waste characteristics
A requirement of RCRA
prior to managing and
handling the waste; it must
be determined if treated
material is RCRA  hazardous
waste and/or mixed waste
Chemical and physical
analyses must be performed
on process residual wastes
prior to disposal

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           TABLE  2-1 FEDERAL AND STATE ARARs FOR THE DYNAPHORE, INC. FORAGER™ SPONGE TECHNOLOGY
      PROCESS ACTIVITY
         ARAR
     DESCRIPTION
        BASIS
   RESPONSE
On-site/off-site disposal
RCRA 40 CFR Part 268 or
state equivalent^
Standards that apply to the
disposal of hazardous waste
The nature of the waste may
be subject to disposal
restrictions.
                           SARA Section 121 (d)(3)
                           Requirements for the off-
                           site disposal of wastes from
                           a Superfund site
                           The waste is being
                           generated from a response
                           action authorized under
                           SARA
Treated process residuals
defined as hazardous must
be disposed of at a
permitted hazardous waste
facility, or approval must be
obtained from the lead
regulatory agency to dispose
of the wastes on site.

Wastes must be disposed of
at a RCRA permitted
hazardous waste facility
Transportation for off-site
disposal
RCRA 40 Part 262 or state
equivalent^'
                           RCRA 40 CFR Part 263 or
                           state equivalent^
Manifest requirements and
packaging and labeling
requirements prior to
transporting

Transportation standards
Process residuals may need
to be manifested and
managed as a hazardous
waste

Treated wastes and/or
oversize material may need
to be transported as
hazardous waste
An identification (ID)
number must be obtained
from EPA


A transporter licensed by
EPA must be used to
transport the hazardous
waste according to EAP
regulations

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           TABLE 2-1 FEDERAL AND STATE ARARs FOR THE DYNAPHORE, INC. FORAGER™ SPONGE TECHNOLOGY
      PROCESS ACTIVITY
         ARAR
     DESCRIPTION
        BASIS
    RESPONSE
Wastewater discharge
Clean Water Act 40 CFR
Parts 301, 304, 306, 307,
308, 402, and 403
                           Safe Drinking Water Act 40
                           CFR Parts 144 and 145
Standards that apply to
discharge of wastewater into
POTWs or surface water
bodies
The wastewater may be
hazardous waste
                           Standards that apply to the
                           disposal of contaminated
                           water in underground
                           injection wells
                           Wastewater may require
                           disposal in underground
                           injection wells
Determine if wastewater
could be directly discharged
into a POTW or surface
water body.  If not, the
wastewater may need to be
further treated to meet
discharge requirements by
conventional processes.
An NPDES permit may be
required for discharge to
surface waters

If underground injection is
selected as a disposal means
for contaminated
wastewater, permission must
be obtained from EPA to
use existing permitted
underground injection wells
or to construct and operate
new wells
      Notes:   (+) = Activities may also be subject to DOE, NRC, and AEA regulations or directives for treatment, storage and disposal of radioactive or
              mixed wastes, if these wastes are treated

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       Remedial actions are governed by the SARA amendments to CERCLA. As stated above, these
amendments promote remedies that permanently reduce the volume, toxicity, and mobility of hazardous
substances, pollutants, or contaminants. The  Dynaphore Forager™ Sponge  Technology is a volume
reduction technology as it transfers aqueous heavy  metal contaminants from one media to a smaller
concentrated contaminant volume.

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

2.8.2   Resource Conservation and Recovery Act  (RCRA)

       RCRA, an amendment to the Solid Waste Disposal Act (SWDA), is the primary federal legislation
governing hazardous waste activities and was passed in 1976 to address the problem of how to  safely
dispose of the enormous volume of municipal and industrial solid waste generated annually.  Subtitle C
of RCRA  contains requirements for generation, transport, treatment, storage, and disposal of hazardous
waste,  most of which  are  also applicable to CERCLA  activities. The Hazardous and Solid Waste
Amendments (HSWA) of 1984 greatly expanded the scope and requirements of RCRA.

       RCRA regulations define hazardous wastes and regulate their transport, treatment, storage, and
disposal. These regulations are only applicable to the  Dynaphore Forager™ Sponge Technology if RCRA
defined hazardous wastes are present. Potential hazardous wastes include the aqueous waste to be treated,
spent Sponges, and eluted solutions from regeneration.  If these wastes are determined to be hazardous
according  to RCRA (primarily due to heavy metal content), all RCRA requirements  regarding the
management and disposal of this hazardous waste will need to be addressed by the remedial managers.
Wastes defined as hazardous under RCRA include characteristic and listed wastes. Criteria for identifying

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characteristic hazardous wastes are included in 40 CFR Part 261 Subpart C. Listed wastes from specific
and nonspecific industrial sources, off-specification products, spill cleanups, and other industrial sources
are itemized  in 40 CFR Part 261 Subpart D.  For this demonstration, the groundwater to be treated,
although not hazardous, did contain lead, cadmium, and chromium which, depending on concentrations,
could be D-listed RCRA wastes.  Since the technology would be transferring and concentrating these
metals to the  Sponge matrix, the spent Sponges were handled as a hazardous waste, under a conservative
approach.    Contaminated personal protective equipment (PPE) is  subject to  land disposal restriction
(LDR) under  both RCRA and CERCLA only if it contains more than 5% contamination per square inch.

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

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

2.8.3  Clean Water Act (CWA)

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

                                              26

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        Treated effluent from the SITE demonstration was considered acceptable for treatment at a local
POTW.  Since the technology is only effective for selected heavy metals, additional treatment methods
would probably be necessary for discharge to a surface water body.  Depending on the NPDES permit
limits and the influent quality of the water treated, further treatment could include pH adjustment, solids
reduction (i.e., TSS  and TDS),  reducing  temperature  (especially  if a water heater  is used),  and
detoxification of organic compounds, if present.

2.8.4   Safe Drinking Water Act (SDWA)

        The SDWA of 1974, as most recently amended by the Safe Drinking Water Amendments of 1986,
requires the EPA to establish regulations to protect human health from contaminants in drinking water.
The legislation authorized national drinking water standards and a joint federal-state system for ensuring
compliance with these standards.

        The National Primary Drinking Water Standards are found in 40 CFR Parts 141 through 149. Parts
144 and 145 discuss requirements associated with the underground injection of contaminated water.  If
underground injection  of wastewater is selected as a disposal means, approval from EPA for constructing
and operating a new underground injection well is required.

2.8.5   Occupational Safety and Health Administration (OSHA) Requirements

        CERCLA remedial actions and RCRA corrective actions must be performed in accordance with
the OSHA requirements detailed in 20 CFR Parts 1900 through  1926, especially Part 1910.120 which
provides for the health and  safety of workers at hazardous waste sites. On-site construction activities  at
Superfund or RCRA corrective action sites must be performed  in accordance with Part 1926 of OSHA,
which describes safety and health regulations for construction sites. State OSHA requirements, which may
be significantly stricter than federal standards, must also be met.

       All technicians operating the Forager™ Sponge Technology and all workers performing on-site
construction are required to have completed an OSHA training course and must be familiar with all OSHA
requirements relevant to hazardous waste sites. For most  sites, minimum PPE for workers will include
gloves, steel-toe boots, and Tyvek® coveralls.  Depending on contaminant types and concentrations,

                                              27

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additional PPE may be required. Noise levels are not expected to be high, however noise from the pumps
driving the system will be constant, so noise levels should be monitored to ensure that workers are not
exposed to noise levels above a time-weighted  average of 85 decibels over an eight-hour day. If noise
levels increase above this limit, then workers will be required to wear hearing protection. The levels of
noise anticipated are not  expected to adversely affect the community.

2.8.6   Radioactive Waste Regulations

        The Forager™ Sponge Technology reportedly has the ability to treat water contaminated with
radioactive materials. The primary agencies that regulate the cleanup of radioactively contaminated sites
are EPA, Nuclear Regulatory Commission (NRC),  the Department of Energy (DOE), and the states. In
addition, nongovernmental agencies may issue advisories or guidance, which should also be considered
in developing protective  remedy.

        The SDWA  has  established maximum contaminant levels (MCLs) for alpha and beta-emitting
radionuclides which  would be appropriate in setting cleanup standards for radioactively contaminated
water.   Discharge of treated effluent  from  the  Forager™  Sponge technology could  be subject to
radionuclide concentration limits established in 40 CFR Part 440 (Effluent Guidelines for Ore Mining and
Dressing). These regulations include effluent limits for facilities that extract and process uranium, radium,
and vanadium ores.

        NRC regulations  cover the possession and use of source, by-product, and special nuclear materials
by NRC licenses. These regulations  apply to sites where radioactive contamination exists, and  cover
protection of workers and public from radiation, discharges of radionuclides in air and water,  and  waste
treatment  and disposal requirements  for radioactive waste.  In evaluating requirements  for treating
radiologically contaminated waters, consideration must not only be given to the quality of the raw  water
and final effluent, but any process residuals, specifically spent Sponges. If the technology is effective for
radionuclides, these radioactive contaminants will be concentrated on the Sponge matrix.  This could have
an impact on disposal requirements, as well as health and safety considerations.
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       DOE requirements are included in a series of internal DOE orders that have the same force as
regulations at DOE facilities. DOE orders address exposure limits for the public, concentration or residual
radioactivity in soil and water, and management of radioactive wastes.

2.8.7   Mixed Waste Regulations

       Use of the Forager™ Sponge Technology at sites with radioactive contamination may involve the
treatment or generation of mixed waste. As defined by Atomic Energy  Act (AEA) and RCRA, mixed
waste contains  both  radioactive  and hazardous components  and is  subject to  both acts.  When the
application of both regulations results in a situation inconsistent with the AEA (for example, an increased
likelihood of radioactive exposure), AEA requirements supersede RCRA requirements.

       EPA's Office of Solid Waste and Emergency Response (OSWER), in conjunction with the NRC,
issued several directives to assist in the identification, treatment, and disposal of low-level radioactive
mixed waste. If high-level mixed waste or transuranic mixed waste is treated, DOE internal orders should
be considered when developing a protective remedy.
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                                         SECTION 3
                                   ECONOMIC ANALYSIS

       This  section presents  cost  estimates for operating the Dynaphore,  Inc.  Forager™ Sponge
Technology in the remediation of heavy metal contaminated groundwater.  With realistic costs and a
knowledge of the bases for their determination, it should be possible to estimate the  economics for
operating similar-sized units as well  as larger systems at other sites utilizing various scale-up approaches
and cleanup scenarios.

       This economic analysis is based on assumptions and costs provided by Dynaphore, Inc. and on
results and experiences from this SITE demonstration  developed over a 72-hr period of operation at 1
gallon per minute (gpm). The costs associated with treatment by the Forager™ Sponge treatment system,
as presented  in this economic analysis, are defined by 12 cost  categories that reflect typical cleanup
activities encountered on  Superfund sites. Each of these cleanup activities is defined  and discussed,
forming the basis for the estimated cost analysis presented. Certain actual or potential costs were omitted
because site-specific engineering aspects beyond the scope of this SITE project would be required. Certain
other functions were assumed to be the obligation of the responsible parties and/or site owners and also
were not  included in the estimates. Cost figures provided here are  "order-of-magnitude" estimates,
generally +50%/-30%.

3.1     Conclusions of Economic Analysis

        The estimated cost for the treatment of heavy metal contaminated groundwater for a  one year
period is presented in Table 3.1. This estimate assumes cadmium, lead, and copper are the contaminants
of concern and that they are treated to demonstration performance claims utilizing a four column pump-
and-treat unit similar to the demonstration trailer unit.

        The economic analysis evaluated two different operating scenarios.  The first scenario assumes
that the Sponges can only be used once and are replaced upon saturation, while the  second assumes the
Sponges can be regenerated twice providing for a useful life of three treatment cycles. The frequency of
regeneration  and replacement was based on the saturation rate of cadmium,  since demonstration results
revealed that cadmium saturated the Sponge the quickest compared to lead and copper.  A graphical

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TABLE 3-1 ESTIMATED COST FOR TREATMENT USING THE
     DYNAPHORE, INC. FORAGER™ TECHNOLOGY"

COST CATEGORY
1. Site Preparation
Well drilling & preparation
Enclosure & pad
Groundwater pump & piping
6,500 gal tank
Total Costs
2. Permitting & Regulatory Requirements
3. Capital Equipment ( 1 gpm
unit amortized over 10 yr )
4. Startup
6. Consumables & Supplies
Sponges
HCL (regeneration)
H & S gear
Maintenance supplies
Waste storage drums
Plastic sleeves
Total Costs
6. Labor
Operator
Jr. Operator
Total Costs
ESTIMATED COST ($)
REPLACEMENT"

2,000
10,000
3,000
11,000
26,000
N/A
2,500

250

101,910
0
500
50
5250
240
107,950

14,910
3318
18,228
REGENERATION'

2,000
10,000
3,000
11,000
26,000
N/A
2,500

250

33,970
2022
500
50
5250
80
41,872

24,390
7742
32,132
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COST CATEGORY
7. Utilities
Electricity (water heater)
Enclosure (heat/lights)
Total Costs
8. Effluent Treatment &
Disposal Costs
9. Residuals & Waste Shipping & Handling,
Sponge
Liquid (regeneration)
Total Costs
10. Analytical Services
11. Maintenance & Modifications
12. Demobilization
TOTAL COST
TOTAL COST PER 1,000 GALLONS
ESTIMATED COST ($)
REPLACEMENT"

1,730
1,000
2,730
N/A


20,825
0
20,825
N/A
N/A
N/A
178,483
340
REGENERATION0

1,730
1,000
2,730
N/A


7,000
12,209
19,209
N/A
N/A
N/A
124,693
238
Notes:
a.      Costs are  based  on one year remediation of 525,000 gallons of heavy metal contaminated
       groundwater.
b.      Assumes 474 bags of Sponges used with no regeneration.
c.      Assumes 158 bags of Sponges used and regenerated twice.
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percentage breakdown of each operating scenario is presented in Figure 3-1. Conclusions drawn from the
economic analysis are discussed below.

        For this groundwater scenario, it is more cost effective to regenerate the Sponge twice rather than
replacing it when it is saturated.  The groundwater treatment cost with replacement  was estimated at
$340/1,000 gallons compared to $238/1,000 gallons for regeneration. Obviously, the more  times the
Sponge can be regenerated, the greater  the cost  savings.  Analyzing the pertinent cost factors for both
scenarios (i.e., consumable/supplies, labor, residuals and waste shipping and handling) it is estimated that
for each regeneration cycle approximately $170 in cost savings is realized. However,  it  is important to
note that regeneration may not be feasible or practical (e.g., radioactive  waste) for all contaminated liquid
waste streams, including groundwater.

        For both replacement and regeneration, Consumables & Supplies accounted for most of the total
costs. However, on a percentage basis there was a two-to-one difference  between the two cases considered.
For replacement,  Consumables & Supplies accounted for approximately 61% of total costs, whereas for
regeneration, it accounted for only 34% of total costs.  The next largest categories, not necessarily in
order, were Site Preparation, Labor, and Residuals and Waste Shipping and Handling. The relative order
and percentage of each cost category differed for each case considered. For example, Labor, at 26%, is
the second largest cost category for regeneration due to the decreased cost for  Consumables and Supplies
and the additional time spent regenerating the Sponge and disposing of the resulting liquid waste. For
replacement,  Labor was the  fourth largest category at 10%.  Although the order is  a  little  different,
Consumables and Supplies; Site Preparation; Residuals and Waste Shipping and  Handling; and Labor
accounted for over 95% of costs in either case. This indicates that Capital Equipment,  Startup, and Utility
costs are relatively unimportant in terms of overall treatment cost.

        The effective absorption capacity of the Sponge for the metals of concern has the most significant
impact on costs as it determines the frequency of replacement or  regeneration. To  illustrate this point a
cost estimate was developed for utilizing the technology solely for the remediation of copper.  Based on
demonstration results the Sponge had a much greater capacity for copper than for cadmium.  Although
the SITE demonstration was not conducted long enough for the column to be saturated  with  copper,  a
non-linear extrapolation of the data determined the estimated absorption capacity for  copper.   Based on
the estimated absorption capacity, the influent mass loading of copper, and assumed  removal efficiency

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                         Figure 3-1
           Replacement Cost Breakdown
Consumables & Supplies 60.5'
                                         Capital Equipment 1.4%
                                       Startup 0.1%
                                              Site Preparation 14.6%
                                                Residuals/Waste Shipping 11.7%
                                           Utilities 1.5%
                                      Labor 10.2%
        Regeneration Cost Breakdown
 Consumables & Supplies 33.5%
                                 Capital Equipment 2.0%

                                 rtup 0.2%
Site Preparation 20.8%
                                             Residuals/Waste Shipping 15.5%
                 Labor 25.7%
                                      Utilities 2.2%
                               34

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for copper, it was determined that regeneration and/or replacement of the Sponge due to copper saturation
would be required every  100 hours, as opposed to every 18 hours due to cadmium saturation.  The
resultant estimated cost for treating the groundwater for copper is $124/1,000 gallons for replacement and
$104/1,000 gallons for regeneration.  This translates to an approximate 56% to 64% reduction in cost on
a $/l,000 gallon basis for  both scenarios.

        Increasing treatment volume (without sacrificing treatment performance) by utilizing larger scale
units that can handle more throughput,  or similar sized units connected in parallel, can reduce unit costs
for treatment. The Developer provided costs for a trailer unit incorporating larger diameter columns which
could operate at twice the flow rate of  the demonstration  unit.  Although there would be a cost increase
in the Consumables &  Supplies and Residuals/Waste categories, scale-up would reduce the unit cost for
treatment because larger bags of Sponges are utilized. Assuming similar treatment performance, the larger
scale unit would reduce the treatment cost, in terms of $/1000 gallons, by approximately  18% to 27% for
the replacement or regeneration scenarios. This demonstrates that a combination of design and operating
parameters could be adjusted to treat water at a particular  site in the most cost-effective manner possible.
Additionally, use of an industrial waste  compactor to compact Sponges could also aid in lowering disposal
costs.

3.2     Basis for Economic Analysis

        Dynaphore, Inc. claims that the Forager™ Sponge Technology can treat a wide variety of heavy
metal  contaminated  aqueous  waste  such  as  groundwater,  landfill  leachate, and  industrial  effluent.
Contaminated groundwater was selected as the basis of the economic analysis because it was the aqueous
waste treated for the demonstration. Additionally, it represents a waste commonly found at Superfund and
RCRA corrective action sites, and covers several cost categories.

        A number of factors affect the estimated costs of treating groundwater with the Forager™ Sponge
technology. These factors include type and concentration of contaminants, flow rate, number, type, and
depth of groundwater extraction  wells required, physical site conditions, geographical site  location,
required support facilities, site accessibility, availability of utilities,  and treatment goals.   Type and
concentration of contaminants potentially have the greatest impact, as they will determine the effective
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absorption capacity of the Sponge which ultimately affects consumable and supply costs (i.e., Sponges
and acid for regeneration) and disposal costs.

       Cost data associated with the Forager™ Sponge Technology has been assigned to the following
12 categories: (1) site preparation; (2) permitting and regulatory requirements; (3) capital equipment; (4)
startup; (5) consumables and supplies; (6)  labor; (7) utilities; (8) effluent treatment and disposal; (9)
residuals and waste shipping and handling; (10) analytical services; (11) maintenance and modifications;
and (12) demobilization.

3.3    Issues and Assumptions

       This section  summarizes the major issues and assumptions used to evaluate  the cost of the
Forager™ Sponge Technology.  In  general,  assumptions are based on information provided  by the
Developer and observations made during the demonstration project. Certain assumptions were made to
account for  variable site  and waste parameters and would,  undoubtedly, have to be modified to reflect
specific conditions at other sites.

       This economic  analysis assumes  that  the  Dynaphore,  Inc. system  will treat groundwater
contaminated with cadmium,  copper, and lead to demonstration performance claims.  The groundwater
is assumed to have similar waste characteristics to the groundwater treated for the demonstration, in terms
of types and concentrations of heavy metals,  TDS, TSS, sulfate,  and pH.  The groundwater would be
treated with a putnp-and-treat  system similar to that utilized for the  SITE demonstration.  Specifically, the
groundwater is pumped through a series of four upflow columns  at a flow rate of 1 gpm.  The  system
would be operated 24 hours per day, 7 days per week  for 1  year, resulting in a total volume of
approximately 525,000 gallons. The only modification to the trailer-mounted system used for the SITE
demonstration is that the trailer would  include two  additional standby columns. This will allow for
continuous operation of the system, with no shutdown required for regeneration and/or  replacement.

       Although the bags of Sponges were not replaced during the SITE demonstration, it was clear that
some of them had become saturated and had begun to show performance deterioration by the end of the
72 hour period.  The frequency of replacement and/or regeneration is site- and waste-specific.  Different
metals will  saturate a Sponge at different rates.  In addition, the  higher the  concentration of a specific

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metal, the faster a Sponge will be saturated.  For purposes of this analysis, the SITE demonstration test
results were used to predict the saturation rate of the Sponge to identify the frequency of replacement or
regeneration.  Costs for both  cases were  investigated; however, regeneration of the Sponges contained
within the four column unit was not evaluated for the demonstration. Therefore, the ability to regenerate
the Sponges was based on the Developer's laboratory tests and the assumption that the Sponge for the
demonstration groundwater could be regenerated twice providing for three useful cycles.

        The following is a list of further assumptions used for this analysis:
        •       The site is a Superfund site located in the Northeast.
        •       Suitable site access roads exist.
        •       No pretreatment of the groundwater is required.
        •       Treated effluent will be suitable for indirect discharge to a POTW.
        •       Utilities such as water and electricity are available on site.
        •       Storage facilities for chemicals and residual waste are available on site.
        •       Construction of a suitable building enclosure will be required to house the equipment.
        •       One lead operator would be required  to monitor  the  system and perform  routine
               maintenance.  A junior operator would be required to assist him/her when replacement or
               regeneration of the Sponge is required.

3.4 Results of the Economic Analysis

        Costs associated with the hypothetical remediation  of groundwater are presented below for each
of the 12 cost categories.

3.4.1    Site Preparation

        It was assumed that preliminary site preparation would be performed by the responsible party (or
site owner), and should be minimal as  compared  to other remediation approaches. Site preparation
responsibilities include site design and layout; surveys and site logistics; legal searches; access rights and
roads; and preparations for support facilities, decontamination facilities, utility connections, and auxiliary
buildings. None of these costs has been included here.
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       Instead,  for purposes of this cost estimate, installation costs have been limited to technology-
specific site preparation requirements. These costs are generally one-time charges. Drilling and preparation
(purging,  casings, caps,  etc.)  of groundwater wells were  assumed to be performed by  a  contractor.
Although these costs are highly site specific, they were included here at a rate of $2,000/well. Since only
one well is assumed to be necessary, this cost would total $2,000.  Additional well costs would include
purchase of a 2 inch submersible groundwater pump and associated discharge piping. The estimated cost
for these items is $3,000.

       An enclosure to house the trailer unit and protect equipment and personnel from weather extremes
is  recommended. The cost of constructing alOftxl5ftxl5ft high structure with a six-inch high
bermed concrete pad was estimated at $10,000.

       Based on experience from the SITE demonstration, a 6,500 gallon influent equalization tank would
be needed. The total cost for this system, including a recirculation pump and ancillary piping, is estimated
at  $11,000.

       Water may be necessary occasionally for regeneration of Sponges, cleanup, and decontamination.
It was assumed that a readily accessible supply of water is nearby. Hence, no cost or provision for a water
supply was included.

       The total site preparation cost is estimated at $26,000 or $50/1,000 gal for a 1  year remediation.

3.4.2  Permitting and  Regulatory Requirements

       Permitting and regulatory costs  are generally the  obligation of the responsible party (or  site
owner). These costs may include actual permit costs, system  health/safety  monitoring, and analytical
protocols. Permitting and regulatory costs can vary greatly because they are very site- and waste-specific.
No permits were required for this SITE demonstration; therefore, no permitting costs have been included
in this analysis.  Depending  on the treatment site, however, this may  be a significant factor since
permitting can be a very expensive and time-consuming activity.  Nevertheless, any such cost should be
very similar for both the replacement and the regeneration  scenario.
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3.4.3   Capital Equipment

        Capital equipment costs were provided by Dynaphore,  Inc. They included a six column (four
columns for treatment and two stand-by columns) trailer-mounted system with associated plumbing (pipes,
valves,  and fittings) and pumps, process control and monitoring equipment, and water heater.    The
columns do not include the Sponges in the fishnet bags. The cost for the 1  gpm system tested here is
approximately $25,000. If this is amortized over 10 years, then the annualized equipment costs are $2,500
or $5/1,000 gallons.

        The Developer also quoted a price for a slightly larger system than that utilized here. This larger
system would utilize 12 inch diameter columns instead of 8 inch diameter columns, and would cost about
$30,000. It would be just as effective,  but at a flow rate  of 2.3 gpm instead of 1  gpm  it could treat 1.21
million  gallons of water per year. Each column would  contain two  slightly larger fishnets  of Sponge
stacked  one on top of the other.  Each fishnet bag of Sponge would cost about $240 or $480/column.

3.4.4   Startup

        Transportation costs for the mobile unit are only charged to the client for one direction of travel
and are  usually included with mobilization rather than demobilization. They are  variable and dependent
on site  location.  Transportation costs are  not expected to be a major  factor. For purchased units,
transportation costs are borne by the buyer.

        The amount of on-site  assembly required for the mobile unit (or a permanent  installation) is
minimal, consisting of unloading equipment, connecting plumbing, and assuring that all joints are leak-
free. Mobilization and training were estimated to take one person about 2 days. This relatively short setup
time was included in the total time on site (1 yr).

        It was anticipated that installation of wells would be done before mobilization of the Forager™
system,  based on careful review of existing site characterization  data.  Well installation would be carried
out by a drilling contractor, but it would presumably require oversight by one person. Assuming one well
could be drilled and cased per day, this would add only an additional day to the schedule. The cost of this
has already been accounted for under Site Preparation Costs.

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        Depending on the site and the contaminants, local authorities may impose specific guidelines for
health and safety monitoring programs. The stringency and frequency of monitoring required may have
a significant impact on project costs.

        Fixed costs such as insurance and taxes were also included here.  The total of all startup costs was
assumed to be 10%  of the annual capital  equipment costs, or $250.

3.4.5   Consumables and Supplies

        The major consumable items used by the Dynaphore process are  Sponges. Two scenarios were
considered in estimating the cost.  The first scenario was the replacement of a bag of saturated Sponge
with a bag of virgin  Sponge, while the other case involved the regeneration of the Sponge and subsequent
reuse.
       For each of the two cases mentioned above, the frequency of replacement or regeneration was
based on the saturation rate of cadmium.  SITE demonstration results revealed that for this groundwater
cadmium saturated a Sponge at a higher rate than lead or copper.

       The average influent concentration of cadmium was measured to be 537 ug/L, corresponding to
a mass flow rate of 0.122 gm Cd/hr (1 gpm x 537 ug/L x 3.785 L/gal x lxlO'6g/ug x 60 min/hr). The
SITE demonstration test results showed that a bag of virgin Sponge becomes saturated and is no longer
effective  in removing  cadmium  after approximately 49 hrs (see Table  4.3, Section 4).   Based on the
demonstration data, after 49 hours the Sponge in the first column had absorbed 2.14 grams of cadmium
and had achieved an average removal efficiency for cadmium  of 95%.  Therefore,  treating an average
mass flow rate of 0.122 gm Cd/hour over a one year period (8760 hours) at a removal efficiency of 95%
removal,  the total mass absorbed by the four column system is 1015 grams.  Dividing the total  mass
absorbed (1015 grams) by the absorption capacity of each Sponge column (2.14 grams) provides the total
number of bags of Sponges needed  over a one year period.  This calculates to  474 bags of Sponges
needed with a bag requiring replacement or regeneration approximately every  18 hours based on  8760
hours per year.  The following provides  cost for replacement and regeneration.
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Replacement

       The Developer has quoted the cost of each new fishnet bag of Sponge at $215. Therefore, the
cost of utilizing 474 bags of Sponges is $101,910. The additional cost of disposing of the spent Sponge
is discussed under Residuals and Waste Handling and Shipping.

Regeneration

       Replacement costs may be reduced by  regenerating each Sponge rather than replacing it. The
Developer has indicated that a spent Sponge can be regenerated by very slowly running 34 quarts of 10%
industrial grade HC1 at one quart/minute.  This estimate assumes the HC1 is not heated to 40°C and the
HC1 is retained  in the columns for approximately 2 hours  (see  Section 2.2).   Following  the acid
regeneration, the Sponge would be washed with an additional 34 quarts of fresh water before being placed
back on  stream.  The disposal of the resulting 68 quarts of effluent  liquid with 5% HC1 concentration
containing dissolved heavy metals is discussed under Residuals and Waste Shipping and Handling.

       The Developer claims that regeneration  will remove about 80% of the absorbed Cu, 70  % of the
Pb, and  95% of the  Cd (based  on  their laboratory experiments with  Sponge retrieved from the
demonstration treatment unit). The Developer did not perform any test on the number of times the Sponge
can be effectively regenerated; however, the Developer has assumed that each  Sponge can be regenerated
two times after which it must be disposed of. Although the effectiveness of the regenerated  Sponge in
subsequent absorption cycles is unknown, it was assumed here, for simplicity, that it would still be capable
of absorbing enough of the dissolved heavy metals to meet the minimum project objectives.

       For the regeneration  scenario, the 474 bags of virgin  Sponges required for replacement is now
reduced to 158 (474/3), since each Sponge bag can be regenerated twice providing for three useful cycles.
The cost  of the 158 bags of Sponges is $33,970.

       The Developer has given the cost of 34 quarts of 10% industrial grade HC1 as $6.40. The cost to
regenerate the  158 bags of Sponges twice will be $2,022 (316 x $6.40).
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Other Supplies

        Four other items included are 55-gallon waste disposal drums, plastic disposal sleeve bags, health
and safety gear, and maintenance supplies (spare parts, oils, grease and other lubricants, etc.). Based on
the estimated amount of residual generated, (see  Section 3.4.9)  approximately 150 drums should be
sufficient for both scenarios. At $35/drum the estimated cost is $5250.  The cost for health and safety gear
should be approximately $500. The cost of maintenance supplies was assumed not to exceed 2% of the
capital costs on a yearly basis, or about $50.  Spent fishnet bags of Sponges are  placed in plastic sleeve
bags prior to disposal in a 55-gallon drum.  Each sleeve bag provided by the Developer cost $0.50.  Based
on the amount of Sponges used,  the cost for  sleeve bags is $240 and  $80 for the replacement and
regeneration scenarios, respectively.

3.4.6   Labor

        Once the system is operating at steady-state, very little additional labor is required. The majority
of the work involves the replacement or regeneration of the Sponges. It was estimated that an Operator
at $15/hr would  spend  approximately  10 hours per week primarily  monitoring system operation and
performing routine maintenance duties.  When replacement or regeneration is required,  a Junior Operator
at $7/hr would assist with these activities.  Replacement of the Sponges is estimated to take both operators
approximately one hour, while regeneration is estimated to take approximately three hours of their time,
including  containerization   of   wastes  generated  (i.e.,   Sponges  and   regenerant   solution).
Replacement/regeneration will be required once every  18 hour period.  Hourly rates are  straight salaries
and do  not include benefits, administration/overhead costs, and profit. Travel,  per diem, or car rental
expenses were not included here but can have a major cost impact if these duties cannot be assumed by
an on-site employee.

Replacement

        The total labor  cost for a 1-year remediation  assuming 474 bags of Sponges are used without
regeneration is estimated as follows:
                                               42

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Operator:       $15/hr x [(474 bags of Sponges x Ihr/bag) + 520 hrs of
               monitoring/maintenance] =                                                  $14,910

Jr. Operator:    $ 7/hr x 474 bags of Sponges x Ihr/bag =                                    $ 3,318

                                                                                         $18,228

Regeneration

       The total labor cost for a 1-year period assuming 158 bags of Sponges are used and regenerated
twice is estimated as follows:

Operator:       $15/hr x [(158 bags of Sponges x Ihr/bag) + (316 regenerations x 3hrs/regeneration)
               + 520hrs of monitoring and maintenance] =                                 $24,390

Jr. Operator:    $ 7/hr x [(158 bags of Sponges x Ihr/bag) + (316 regeneration x
               3hrs/regeneration)] =                                                      $ 7,742

                                                                                        $32,132

3.4.7  Utilities

       The electric water heater used to heat the groundwater consumed the largest amount of power by
far. Measurements during operation indicated that it used 3.3 kW of power. At $0.06/kW-hr, the cost of
running the heater for a year would be: 3.3 kW-hr x 24 hr/day x 7 days/wk x 52 wk/yr x $0.06/kW-hr
= $1,730

       An additional utility cost was included for heating the building enclosure  during cold weather
months and lighting. This cost is estimated at $1,000.
                                               43

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       Water was assumed to be readily available and relatively inexpensive. Since the amount of water
necessary for decontamination and flushing during the demonstration was small, no costs for water usage
were included.

3.4.8   Effluent Treatment and Disposal

       As stated earlier, this process is designed to treat the heavy metal constituents of wastes. As such,
it would  most likely be used in conjunction with other methods that can treat other waste constituents
before  discharge.  Hence, the effluent  from the Dynaphore Inc., process may serve as the influent for
another downstream treatment technology. In that case, the inclusion of an effluent treatment and disposal
cost would not be appropriate. Conversely, the Dynaphore Inc.,  process may be the last step in a total
treatment train.

       Based on  experience from this SITE demonstration, the resulting effluent was sent to a POTW
for disposal.  Hence,  for purposes of this economic analysis, it was assumed that the effluent from the
Dynaphore Inc., treatment technology  would meet the regulatory standards appropriate for discharge to
a POTW and therefore, no costs associated with effluent treatment and  disposal were assigned.

3.4.9   Residuals and Waste Shipping and Handling

       As discussed under Consumables and Supplies, two basic scenarios were considered - replacement
and regeneration. Here, the cost of disposal of residuals generated from each of these cases is considered.

Replacement

       474 bags of Sponges per year will be generated as solid waste requiring disposal off-site. Based
on experience from this SITE demonstration, four Sponge bags can be hand-compacted into a regular 55-
gal drum.   At a reported  cost of about $175/drum for  disposal as a hazardous waste,  including
transportation, the total cost of  disposal was calculated as:

(474 bags of Sponges/4 bags/drum) x  $175/drum =   $20,825
                                              44

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       Further compaction of the Sponges could be achieved utilizing a waste compactor, which could
reduce the number of drums needed.  This  was not evaluated in this estimate; however, as stated in
Section 2.5, following the demonstration four  fishnet bags of virgin  Sponges were  sent to a waste
compacting firm. Their compaction test showed that compaction ratios of approximately 4:1 and 10:1
could be achieved at 20,000 pounds (Ibs.) and 85,000 pounds (Ibs.) of compaction force,  respectively.
Based on these compaction ratios, at 20,000 Ibs. of force approximately 16 bags of Sponges could be
disposed in a 55-gallon drum, and at 85,000 Ibs. of force approximately 40 Sponges could be disposed
in a 55-gallon drum.  According to the vendor, the costs of these compactors range from $9000 for the
20,000 Ib. unit to $15,000 for the 85,000 Ib. unit.

Regeneration

        158 Sponges, as well as approximately 5,372 gallons of liquid waste (68 quarts x 316 regeneration
cycles) will be generated per year. The cost of disposing of the heavy metal contaminated liquid waste
is approximately $125/drum. The total cost of disposal for this option is:

(158 Sponges / 4 Sponges/drum) x $175/drum =      $ 7,000
(5,372 gal / 55 gal/drum) x $125/drum        =      $ 12,209
                                                   $ 19,209

3.4.10 Analytical Services

       No analytical costs during operation were included in this cost estimate.  Standard operating
procedures for Dynaphore, Inc. do not require planned sampling and analytical activities. Periodic spot
checks may be executed at Dynaphore's discretion to verify that equipment is performing  properly and
that cleanup criteria are being met, but costs incurred from these actions are not assessed to the client. The
client may elect, or may be required by  local authorities, to initiate a sampling and analysis program at
their own expense. No costs have been included for pre-disposal testing of wastes.
                                               45

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3.4.11 Maintenance and Modifications

       As stated earlier, site preparation activities for the demonstration were carried out by EPA under
the SITE Program. Any modification to the site for a more extensive remediation was assumed to be done
by the responsible party (or site owner), but such activities might be carried out by a contractor and some
of these have already been included under Site Preparation Costs.

3.4.12 Demobilization

       It was estimated that demobilization would take about 2 days and would be included in the total
time on-site. Site cleanup and restoration was limited to the removal of all equipment, facilities, and
wastes from the site. Any additional work will vary depending on the future use of the site, and was
assumed to be the obligation of the responsible party or site owner.
                                               46

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                                         SECTION 4
          TREATMENT EFFECTIVENESS DURING THE SITE DEMONSTRATION

       This section presents the results of the SITE demonstration at the NL Industries, Inc. site in
Pedricktown N.J. and discusses the effectiveness of the Dynaphore, Inc. Forager™ Sponge Technology
on heavy metal contaminated groundwater.

4.1    Background

       The NL Industries, Inc. site is located in Pedricktown, N.J. and encompasses approximately 44
acres. The site was originally a lead smelting facility.  Smelting operations at the site terminated in 1981
and the site was placed on the National Priorities List in September 1983. A Remedial Investigation report
on the site was approved by EPA in 1991.  Groundwater sampling results from the remedial investigation
indicated concentrations of lead, cadmium, and chromium in excess of New Jersey groundwater standards.

       The Forager™  Sponge Technology was evaluated for  its ability to remove heavy metals from
groundwater.  Percent removals of lead, cadmium, and chromium, the contaminants of concern at the NL
site, are the critical parameters for this study.  Copper was also considered a critical parameter because
of the high removal efficiency  observed in predemonstration treatability tests.

       The only critical objective for the Demonstration Test was based on the Developer's  claim.
Based on the results of field and laboratory treatability tests on the groundwater, the Developer claimed
that the technology would achieve at least a 90% reduction of lead and copper, an 80% reduction in
cadmium, and  a 50% reduction of chromium (as trivalent chrome) in the groundwater.

       In addition to the critical objective, there were a number of non-critical objectives, which provided
additional background data on  the technology's operating characteristics, capabilities, and costs. Non-
critical project objectives for the demonstration included:

       develop a temporal study of the treated effluent and individual column effluent concentrations for
       the critical parameters;
                                              47

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        determine selectivity of the Forager™ Sponge for heavy metal ions present in the groundwater by
        evaluating heavy metal removal efficiencies for both critical and non-critical heavy metals;

        determine the  removal efficiencies for radioactive contaminants in terms of alpha and  beta
        radioactivity (low  levels of  alpha  and beta radioactivity were  previously  detected  in  the
        groundwater);

•       evaluate the absorption capacity and regenerative  capabilities  of  the  Sponge for the critical
        parameters;

        characterize the quality of the raw influent and final  effluent in terms of heavy metals, alpha and
        beta radioactivity, COD, TSS, IDS, sulfate, pH, and conductivity; and

•       gather information to estimate operating costs, (e.g., utility and labor requirements, waste disposal
        costs, treatment capacity, etc..).

4.2     Detailed Process Description

        The technology was evaluated as a pump-and-treat system over a continuous 72-hour operational
period using a reservoir  of groundwater.  A flow schematic of the system is shown in  Figure 4-1.
Groundwater was pumped from the influent storage tank through a four column system connected in series
for upward flow.  The  flow rate was 1 gpm or 0.08 bed volumes per minute, resulting in a total volume
of approximately 4,300 gallons. The columns were situated  on a trailer-mounted unit, which included a
water heater to raise influent temperature approximately 15° C to increase reaction rates (i.e., improve rate
of absorption of metals).  The treated effluent was initially discharged to  a 250 gallon portable tank from
which it was subsequently pumped to a 20,000 gallon final effluent storage tank.

        The Sponge in the first three columns was in a calcium presaturated form while the Sponge in the
fourth column was in an aluminum presaturated form.  The Developer  stated that although both forms
would be  effective for the  critical heavy metals, the  aluminum form might have a greater affinity for
chromium  and also would  be less  affected by the high  concentration  of  sulfate in the groundwater.
Further, according to the Developer, replacement or  regeneration of the columns was not necessary, since

                                              48

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Groundwater
   I Well
 Raw
Influent
 Tank
(
Sponge
(A)
SP2)


Sponge
(B)
                                                         [SP4]
                SP )  = Sampling Point
0  =
Sponge
(C)


Sponge
(D)
Flow Meter/Totalizer Unit
                                          Treated
                                          Effluent
                                            Tank
                                        Figure 4-1         TM
    Process Flow Diagram for the Dynaphore, Inc. Forager Sponge Demonstration
  none of the columns were anticipated to become saturated (i.e., no further absorption capacity available
  for the critical metals).  This assumption was based on laboratory absorption tests performed on standard
  metal salt solutions. Four columns were reportedly needed to provide sufficient path length to meet the
  demonstration goals.

  4.3     Methodology

         Although concentrations of some of the critical metals exceeded cleanup goals for the site, the
  groundwater was spiked with nitrate solutions of lead, copper, and cadmium to assure effective evaluation
  (quantification)  of the Developer's claim.  Due to disproportionately high concentrations of other ions,
  such as calcium and  sodium, samples required  dilution  prior to analyses to eliminate the  matrix
  interference problem.  Diluting the samples resulted in raising detection limits and due  to the low initial
  groundwater concentrations, spiking the groundwater was necessary.  Spiked solutions were added to the
  influent storage tank approximately 24 hours prior to the start of the demonstration.  The tank was kept
  well mixed via recirculation throughout the demonstration.

         Grab samples  for analysis of critical  parameters were collected from the  raw influent, final
  effluent, and intermediate column effluent points (see Figure 1).  A total of 162 samples were collected
  for the critical parameters. Thirty-six samples were taken for each of the intermediate points and the final
  effluent and eighteen samples for the raw  influent.  The frequency of grab sample collection was every
  two hours for the intermediate points and final effluent and every four hours for the raw  influent. Sample
                                                49

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frequency for the raw influent was less because the tank was filled prior to the start of the demonstration
and was kept mixed during the entire demonstration. Samples for critical parameters were analyzed either
by SW846 Method 6010 (Cd, Cr, Cu) or SW846 Method 7421  (Pb).

        In  addition to critical parameters, three  equal volume 24-hour  grab-composite samples were
collected for total metals, chemical oxygen demand, total suspended solids, total dissolved solids, sulfate,
and gross alpha and gross beta radioactivity.  COD, TSS, IDS, and sulfate were only collected at the raw
influent and final effluent while total metals and alpha and beta radioactivity were collected at all five
locations. Pressure, pH, and temperature were also monitored at all sampling locations.  Flow rate and total
volume were monitored  at  the  final effluent.    Since the  Developer  reported that replacement or
regeneration of the columns was not necessary, side tests on laboratory scale columns treating standard
metal salt (nitrate) solutions were performed  to aid in evaluating the absorption capacity and regenerative
capabilities  of the sponge.

        EPA-approved sampling, analytical, and quality assurance and quality control (QA/QC) procedures
were followed to ensure reliable data.

4.4     Performance Data

        This section presents the performance data gathered  by the testing methodology described above.
Results are  presented and interpreted below.  Data is  presented in tabular and/or graphic form.  For
samples measured at non-detect values, the detection limit  was  used for the purposes of conservatively
calculating the mean concentration.

4.4.1    Summary of Results for Critical Parameters

        Table 4-1  presents raw influent, final effluent, and percent removal data with respect to the
Developer's  claim for the critical metals.  Data is reported  at 90% confidence intervals using Student's
t-statistics with the exception of the final effluent and percent removal data for copper.  Since all the final
effluent concentrations  for  copper were  measured at non-detect values, use  of t-statistics  was not
appropriate.  Instead, for copper these values  are reported nonparametrically as "<" the  detection limit (50
ug/L) for the final effluent concentration and ">" the calculated percent removal.  Figure 4-2 graphically

                                               50

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TABLE 4-1 PERFORMANCE FOR CRITICAL METALS
Parameter



Cadmium
Chromium
Copper
Lead
90% Confidence
Interval for
Avg. Influent
Cone. (ug/L)
537 ± 11
426 ±31
917 ± 14
578 ± 12
90% Confidence
Interval for
Avg. Effluent
Cone. (ug/L)
57 ± 13
290 ± 30
<50(*>
24 ±2
90% Confidence
Interval for
Percent Removal
(%)
89 ± 2.4
32 ± 8.4
>94(')
96 ± .40

Claim (%)



80
50
90
90
(t) - t-statistics not applied
                                Figure 4-2
                         Final Effluent - Critical Metals
                                             « «>-f »««««««»»»
                                                l^^^
1  3 5  7
          11 13 15  17  19  21  23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 61 63 65 07 08 71 73 75 77
                                 Elapsed Time (Hours)
                                   Legend
                       Cadmium  —+— Chromium  +  Copper    jfc Lead
                                     51

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depicts final effluent concentrations versus time for the critical metals. Review of the data shows that
claims for cadmium, copper,  and lead were achieved. The technology did not achieve the  claim for
chromium.  Claims were based on comparing the mean concentration of the raw influent to the mean
concentration of the final effluent over the 72-hour test period. The variability in concentrations between
influent and effluent grabs is relatively small as indicated in Table 4-1.

       As shown in Figure 4-1, effective removal of chromium (based on the 50% claim) was achieved
within the first 10 hours of operation until performance markedly decreased.  The decrease in removal
efficiency could be the result of the Sponge's higher affinity for the other critical metals. Although the
cadmium claim was met based on the overall effluent average, final effluent cadmium concentrations were
below desired performance levels (107 ug/L) at approximately the 61st hour of operation. This is due to
the lower than anticipated absorption capacity for cadmium which resulted in saturation of the first two
columns within the test period.

       Tables  4-2  through 4-5   provide  effluent  data for all four  columns for each of the critical
parameters. In addition,  Figures 4-3 through 4-6 provide graphs of effluent column concentrations versus
time for each of the critical parameters. The technology had the greatest affinity for copper. One column
was sufficient to meet the Developer's 90% removal claim for approximately 53 hours of the 72 hour test.
Copper concentrations for columns  2,  3, and 4,  were  at or near  detection  limits  throughout the
demonstration test.  Individual column data reveal the poor affinity  for chromium compared to the other
critical metals.  Based on column 4 effluent data, minimal improvement was observed  for the aluminum
presaturated Sponge for  chromium.

       Although  claims for  cadmium and lead were met, some of the columns became saturated  with
these metals during the demonstration. Specifically, the first column  became saturated with both cadmium
and lead, while the second column became saturated with only cadmium. Saturation is defined when the
effluent concentration of a given metal is approximately equal to or greater than the influent concentration.
Referring to Table 4-2 and 4-5, the first column is saturated with both cadmium and lead at approximately
the 49th hour. Approximately 10 hours later, cadmium saturates the  second column. None of the columns
were saturated with copper during the demonstration test. Based on a non-linear extrapolation of the data,
the first column would  have become saturated with copper after  approximately 4 days of continuous
operation.

                                              52

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TABLE 4-2 CADMIUM COLUMN DATA
HOUR
1
3
5
7
9
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
43
45
47
49
51
53
55
57
59
61
63
65
67
69
71
Avg. Cone.
Avp. % Rem.
INFLUENT"'
523

529

476

537

503

558

568

554

574

545

548

566

566

481

552

514

547

532

537

COL.1 EFF""
103
213
198
181
166
199
192
191
209
233
250
284
321
376
413
436
440
501
535
501
567
530
524
530
508
648
658
630
663
558
647
634
549
566
549
540
423
21»>
COL.2 EFF(>)
<10
102
128
133
122
118
107
93
96
86
85
90
103
106
118
127
144
194
224
238
273
275
310
315
343
450
467
568
528
547
564
542
627
569
596
561
277
3S
COL.3 EFF("

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TABLE 4-3 CHROMIUM COLUMN DATA
HOUR
1
3
5
7
9
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
43
45
47
49
51
53
55
57
59
61
63
65
67
69
71
Avg. Cone.
Avp. % Rem.
INFLUENT00
324

326

327

339

311

378

403

398

442

437

447

469

477

486

498

520

537

540

426

COL.l EFF(a)
131
310
335
293
300
350
358
348
309
324
323
367
364
368
355
381
348
391
408
381
409
424
409
382
388
458
444
457
520
409
488
518
468
486
488
443
387
g(t)
COL.2 EFF(>)
17
222
271
286
309
326
332
323
309
292
310
337
357
338
330
340
335
367
399
395
409
394
414
357
386
425
404
424
458
439
452
479
492
476
505
416
365
6
COL.3 EFF<"
27
47
187
220
244
309
288
299
265
264
292
791
320
365
310
366
342
347
368
354
376
384
398
350
365
394
400
412
444
452
461
474
443
271
405
417
346
5
COL.4 EFF(>)
61
10
79
142
194
225
217
236
222
236
255
269
252
275
260
248
269
298
312
304
338
312
326
327
319
372
382
384
418
348
439
473
415
413
415
406
290
16
TOTAL % REM
86
98
81
67
54
47
49
45
48
45
40
37
41
35
39
42
37
30
27
29
21
27
23
23
25
13
10
10
2
18
-3
-11
3
3
3
5

3200
a = all concentrations in ug/L
b = removal efficiency based on average raw influent concentration = 426 ug/L
                                                   54

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TABLE 4-4 COPPER COLUMN DATA
HOUR
1
3
5
7
9
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
43
45
47
49
51
53
55
57
59
61
63
65
67
69
71
Avg. Cone.
Avp. % Rem.
INFLUENT(1)
1010

930

912

877

849

947

922

904

903

923

922

946

958

890

881

904

908

913

917

COL.l EFF(>)
<50
<50
<50
<50
<50
<50
<50
<50
<50
53
<50
<50
<50
<50
<50
<50
58
<50
56
<50
<50
<50
57
51
68
95
94
117
139
132
182
169
156
161
177
176
80
QIC"
COL.2 EFF(<)
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
>•?«
COL.3 EFF(>)
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
52
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
96
<50
<50
<50
<50
<50
<50
0
COL.4 EFF00
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
<50
0
TOTAL % REM
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94
>94

>Q4)
a = all concentrations in ug/L Concentrations < 50u.g/L are non-detectable.
b = removal efficiency based on raw influent concentration =917 ug/L
                                                   55

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TABLE 4-5 LEAD COLUMN DATA
HOUR 1 INFLUENT*'1 1 COL.I FFF"' 1 COL.2 FFF*"1 1 COL.3 FFF(1) 1 COL 4 EFF(" 1 TOTAL % RFM
1
3
5
7
9
11
13
15
17
19
21
23
25
27
29
31
33
35
37
39
41
43
45
47
49
51
53
55
57
59
61
63
65
67
69
71
Avg. Cone.
Avp. % Rpm.
626

545

571

584

480

609

608

571

585

586

573

588

585

572

577

572

603

560

578

68
109
107
85
89
55
65
93
86
253
129
158
136
236
178
185
380
252
278
312
321
443
406
381
599
664
453
488
447
775
980
590
534
534
536
494
331
4-,w
30
51
65
56
56
34
<20
51
34
33
23
34
28
<20
30
<20
44
88
47
73
62
85
83
89
118
127
148
167
164
195
351
183
231
375
308
312
107
68
48
<20
26
33
36
<20
<20
27
<20
31
<20
22
<20
37
<20
<20
<20
<20
<20
28
<20
<20
30
22
<20
20
39
52
23
49
67
62
80
88
85
108
36
66
63
<20
<20
24
24
<20
31
27
30
29
21
<20
<20
<20
26
<20
<20
<20
<20
<20
<20
<20
<20
<20
20
<20
<20
<20
<20
<20
<20
29
23
37
<20
26
24
33
89
97
97
96
96
97
95
95
95
95
96
97
97
97
95
97
97
97
97
97
97
97
97
97
97
97
97
97
97
97
97
95
96
94
97
96

Qfitb)
a = all concentrations in ng/L; Concentrations < 20jag/L are non-detectable.
b = removal efficiency based on raw influent concentration = 578ug/L
                                                    56

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                                      Figure 4-3
                           Cadmium Concentration vs. Time
  3  5  7   8  11  13 15  17  19 21  23 25 27  29 31  33  35 37 39  41 43  45  47 49  51  53 55  57  59 61  63  65 67 69  71 73
                                        Elapsed Time (Hours
                                           Legend
                              Col 2 Effluent   »  Col 3 Effluent   A  Col 4 Effluent
                                                                        Avg Influent
                                      Figure 4-4
                          Chromium Concentration vs. Time
1   3  5  7  9  11  13 15  17  19 21  23 25 27  29 31  33  35 37 39  41 43 45  47 49 51  53 55 57  59 61  63  65 67 69  71 73
                                        Elapsed Time (Hours)
                                           Legend
                              Col 2 Effluent    »  Col. 3 Effluent

                                             57
Col. 4 Effluent  	 Avg. Influent

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                                           Figure 4-5

                                 Copper Concentration vs. Time
o

0)  400
Q.
Q.

8
     1   3   5  7  9  11  13  15 17  18 21 23  25 27 29  31 33  35  37 39  41  43 45  47 49 51  53 55 57  59 61  63  65 67 69  71  73

                                             Elapsed Time (Hours)
-^
Col
1 Effluent — i
4— Col
2 Effluent -
Legend
-+— Col. 3 Effluent
-+-
Col
4 Effluent
	 Avg
Influent
O
1
                                           Figure  4-6

                                   Lead Concentration vs. Time
     1   3  5  7  9  11  13 15 17  19 21  23  25 27 29  31 33  35  37 39  41 43 45  47 49 51  53 55 57  59 61 63  65  67 69 71  73
                                             Elapsed Time (Hours)
                                                Legend

                     Col 1 Effluent   +  Col 2 Effluent   »  Col. 3 Effluent   A  Col 4 Effluent


                                                    58
Avg Influent

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       Based on data from the 72-hour demonstration,  the actual absorption capacity for the critical
metals was significantly  lower than anticipated by the Developer's predemonstration absorption capacity
estimates and the data from the demonstration absorption capacity side tests.  These side tests, which
confirmed the Developer's estimates, revealed that the Sponge should theoretically be able to absorb 3%
to 5% by weight of each critical metal in a mixed metal solution. Based on the actual demonstration data,
not including chromium, the capacity was approximately 0.04% for cadmium, 0.07% for lead, and 0.4%
for  copper.  The Developer theorizes that anion species such as sulfate and phosphate may have reduced
the Sponge's absorption capacity for these  metals. These anion species are believed to have complexed
with the calcium present  on the  starting  Sponge, binding the calcium and thereby not allowing the
absorption of target metals.

       In addition to the regeneration of the small test columns, the Developer conducted regeneration
tests in his laboratory using Sponge cubes taken from the demonstration columns.  Both tests showed that
regeneration is feasible for lead, copper, and cadmium.  Regeneration of chromium was only evaluated
for the small test columns and showed  only partial regeneration.  The number of effective regenerative
cycles could not be conclusively determined from these tests.

4.4.2 Summary of Results for Non-Critical Parameters

Total Metals
       Table 4-6 presents a summary of analytical results for non-critical heavy metals.  As shown,
effective removal of cadmium, copper,  and lead was achieved in the presence of disproportionately high
concentrations of cations such as calcium, magnesium, sodium, potassium, and aluminum. Concentrations
for these cations ranged  from 70 mg/L for  magnesium to  6,000 mg/L for sodium. The technology's low
affinity for these cations was supported by the calculated negative removal rates of these ions. Except
for calcium and aluminum, the negative removals are probably data anomalies and representative of zero
removal rates. Negative removal rates are feasible for calcium and aluminum since the Sponge did contain
these ions in the presaturated (starting) form. Reportedly, calcium and aluminum are exchanged (released)
from the Sponge for ions with greater affinity.

       In addition to 89%+ removal rates for the critical parameters, excluding chromium, the technology
also achieved similar removal rates for vanadium. It should be noted that vanadium most likely exists

                                               59

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TABLE 4-6 REMOVAL DATA FOR NON-CRITICAL HEAVY METALS
Parameter
Aluminum
Arsenic
Barium
Beryllium
Calcium
Cobalt
Iron
Lithium
Magnesium
Manganese
Mercury
Nickel
Phosphorus
Potassium
Sodium
Strontium
Vanadium
Zinc
Average
Raw Influent
Cone. (ug/L)
149,000
47.7
50.2
15.9
224,000
176
199,000
460
71,700
5870
0.39
378
1520
82,300
6,030,000
557
1310
1300
Average
Cone. (ug/L)
Column 1
151,000
45.5
44.4
15.4
228,000
170
202,000
464
72,100
5930
0.40
352
1510
84,300
6,150,000
559
828
1300
Average
Cone. (ug/L)
Column 2
155,000
40.8
40.8
14.9
226,000
171
200,000
465
72,700
5940
0.36
271
1310
82,600
6,090,000
555
190
1260
Average
Cone. (ug/L)
Column 3
154,000
47.0
48.4
14.1
242,000
169
205,000
487
73,600
6000
0.29
195
1070
85,500
6,280,000
570
53.2
1190
Average
Cone. (ug/L)
Column 4
152,000
44.4
46.3
13.9
248,000
146
199,000
473
72,300
5880
0.21
107
557
83,700
6,130,000
562
53.2
1190
Average
Total
% Removal
-2
7
8
13
-11
17
0
-3
-1
-1
46
72
63
-2
-2
-1
96
9

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as an anionic species in this groundwater.  Review of the individual daily composites reveals that the first
column did  become saturated with vanadium during the third day.   Based on the observed absorption
capacities and removal efficiencies for the non-critical metals presented in Table 4-6, and the observed
absorption capacities  and removal efficiencies for the critical  metals  presented  in  Table 4-1, the
technology's affinity sequence for metals present in the groundwater is as follows:

Copper>Lead,Vanadium>Cadmium>Nickel>Phosphorus>Mercury>Chromium>Cobalt>Beryllium
Zinc>Barium>Arsenic>Iron,Strontium,Manganese,Aluminum,Potassium,Sodium,Lithium,Magnesium,
and Calcium

        The technology's ability to remove radioactive contaminants could not be adequately assessed for
this groundwater.  Raw influent concentrations of gross alpha and beta radioactivity were significantly
lower than anticipated, as the majority of values were at or near detection limits.

Conventional Data
        Data for conventional parameters analyzed for the raw  influent and final effluent are presented
in Table 4-7.  As shown the groundwater contained high concentrations of sulfate and TDS averaging
around 23,600 mg/L and 20,000 mg/L, respectively. An approximate 5% sulfate reduction was observed
which could support the Developer's theory regarding sulfate binding on the Sponge. Although this is a
small percent reduction, the sulfate concentration is over 10,000 times greater than the total concentration
of critical metals. Therefore, even a minimal reduction of sulfate could significantly decrease the capacity
for critical metals removal, if the Developer's theory is correct.  Influent TSS concentrations averaged
approximately 93  mg/L.  It is interesting to note that, except  for the  second day, TSS concentrations
increased across the system, especially during the first day.  TSS concentrations for the first 24-hour
period increased from 85 mg/L in the influent to 597 mg/L in the final effluent.  This could possibly be
due to excess cellulose or polymer material washing off the Sponge during the early stages of treatment.
This may be supported by the fact that COD increased approximately 150%.
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Table 4-7 - Data Summary of Conventional Parameters
Parameter
(mg/L)
TSS
IDS
Sulfate
COD
Day 1
Influent
85
23,500
23,000
346
Effluent
597
23,700
19,000
870
Day 2
Influent
107
23,800
19,000
424
Effluent
71
23,400
20,000
405
Day 3
Influent
86
23,500
21,000
327
Effluent
102
22,900
20,000
211
72-Hour Average
Influent
93
23,600
21,000
365
Final
256
23,300
20,000
495

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       The raw influent pH of the groundwater during the 72-hour test ranged from 3.1 to 3.8.  Figure
4.7 presents a graph of column effluent pH over time. As shown, the initial pHs of the columns were
higher than the raw influent pH until they gradually decreased to the influent pH range. For example, the
final pH (column 4 effluent) was initially approximately 7.6 and gradually decreased to the groundwater
pH range of 3.1 to 3.8 at approximately the 60th hour of operation.  The Developer theorizes that this
increased pH  effect  was possibly due to  anion  exchange  of sulfate in the groundwater, releasing
(i.e.exchanging) a hydroxyl group which caused the subsequent rise in pH.  As fewer exchange sites for
sulfate became available, the pH  decreased toward that of the influent.

Process Measurements
       Flow rate during the demonstration averaged 0.98 gpm. There was minimal variability in flow
as indicated by a % relative standard deviation of only 6%.  The raw influent temperature was increased
from  17° C to 31° C  via the water heater. This temperature was kept fairly constant throughout  the
demonstration.  Based on the pressure measurements taken, input pressures  as low as 4.4 psig were
sufficient to pump groundwater  through the four  columns.   Due to the range of the pressure  gauges
utilized (0 to 10 psig) they were not sensitive enough to accurately read pressures on the third and fourth
columns. Gauges read zero for these columns during the majority of the demonstration.  The average
pressure drop across the system was approximately 5 psig.  Estimates of the pressure drop resulting from
the piping system indicate the pressure drop is minimal; therefore,  the drop in pressure can be attributed
primarily to the Sponges.

4.5    Process Residuals

       Treated  effluent was stored in a  20,000 gallon  storage tank.   This wastewater along with
wastewater  collected from prior treatability  tests was hauled to a local POTW for treatment because there
were no sewer lines on site. Approval was received from the POTW for acceptance of the waste prior
to the stall  of the demonstration.

       Spent  Sponges from the demonstration test and prior  treatability tests were hand compacted into
55-gallon drums.  A maximum of four fishnet bags of  Sponges could be manually placed in a drum. The
waste was handled as a hazardous waste for off-site disposal.
                                              63

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                           Figure 4-7
                              pH vs Time
Influent      +  Column 1
 Elapsed Time (hrl
o  Column 2      A  Column 3
x  Column 4

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                                         SECTION 5
                          OTHER TECHNOLOGY REQUIREMENTS

5.1    Environmental Regulation Requirements

       Before implementing the Forager™ Sponge Technology, state regulatory agencies may require a
number of permits to be obtained. For example, a permit may be required to operate the system as a TSD
facility, if the wastewater is considered a RCRA waste. A TSD permit is also required for  storage of
hazardous wastes generated (i.e., spent Sponges, spent regenerant solution) on-site for greater than 90
days. At the conclusion of treatment, appropriate wastewater discharge permits will need to be obtained
for discharge to a publicly owned treatment works (POTW), into surface waters, or through underground
injection wells.  If off-site disposal of contaminated waste is required, the waste must be taken by a
licensed transporter to a permitted landfill.

       Section 2 of this report  discusses the environmental regulations that  apply to this technology.
Table 2-1  presents a summary of the Federal and State ARARs for the Forager™ Sponge  Technology.

5.2    Personnel Issues

       Two technicians are required for initial installation of the system. Once the system is operating
at steady state, one technician familiar with the system and the contaminant-specific requirements will be
sufficient to monitor the system.  This may include checking process parameters (i.e., flow, temperature,
pH), collecting any samples for field and/or laboratory analysis, and making any process modifications.
When replacement or regeneration of the bags of Sponges is required, based on chemical analysis or
performance history, one or two technicians will be needed. Estimated labor requirements for system
operation are discussed in Section 3.

       For most sites,  personal protective equipment (PPE)  for  workers will include gloves,  safety
goggles, steel-toed boots, and coveralls. Depending  on contaminant types and  concentrations, additional
PPE may be required.
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5.3    Community Acceptance

       Potential hazards related to the community are minimal.  The Forager™ system generates no
chemical or particulate air emissions. The Forager™ Sponge trailer unit is a closed system; therefore even
if wastes containing volatile organic contaminants were treated, the potential for on-site exposure to
airborne contaminants would be low. Potential chemical hazards exist for workers handling acid solutions
used for  regeneration.  However, when handled appropriately with proper PPE the potential risks are
minimized. Proper and secure chemical storage practices for acid solutions and waste regenerant solution
and spent Sponges will result in a minimal potential threat of exposure to the community. The quantity
of containerized wastes that would be produced is relatively small, thus the movement of transport vehicles
through the community would not be significant.
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                                          SECTION 6
                                   TECHNOLOGY STATUS

       This  section discusses the  experience of the  Developer in performing treatment using the
Dynaphore, Inc. Forager™ Sponge Technology. It also examines the capability of the Developer in using
this technology at other sites contaminated with heavy metals in aqueous media.

6.1    Previous Experience

       To date, this SITE demonstration represents the first full-scale use of this technology. The trailer-
mounted unit was built exclusively for this SITE demonstration.  Dynaphore Inc., has no experience in
the remediation of contaminated sites. To overcome this hurdle, the Developer has formed a liaison with
a known environmental remediation firm, Adtechs  Corporation of Herndon,  Virginia, to provide the
necessary expertise  in performing full-scale remediations.

       Potential in-situ applications of the technology may be promising, but there is insufficient data
currently available which demonstrates the viability of this treatment option.

6.2    Scaling Capabilities

       The trailer unit can be modified to include additional columns of the same size. A larger scale
unit can also be constructed. This unit uses larger columns which would be just as effective as the smaller
system but could operate at approximately double the flow rate.
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                                         APPENDIX A
                                     VENDOR'S CLAIMS

       This appendix was generated and written solely by Dr. Norm Rainer of Dynaphore, Inc.  The
statements presented herein represent the vendor's point of view and summarize the claims made by the
vendor, the Dynaphore,  Inc. regarding  its Forager™ Sponge Technology.  Publication herein does not
represent the EPA's approval or endorsement of the statements made in this section.

A.I    INTRODUCTION

       The removal of heavy metal species from water has most often been accomplished by techniques
involving the addition of a precipitating agent, followed by removal of the resultant precipitate. The  high
capital investment required for such techniques is often prohibitive except for municipalities or large
industrial installations.  Ion exchange and reverse osmosis equipment for removal of metal species also
involve considerable capital investment, and further require pre-treatment to remove oil and suspended
solids. In many instances, a water source containing heavy metals must be remediated where one or more
of the following factors  are involved:

a)     the site is unattended by operating personnel,  or seasonally inaccessible,
b)     electricity is not available,
c)     the water contains considerable oil and/or organics and suspended matter,
d)     the removed species are radioactive, and the simplest absorption and disposal process is needed,
e)     the problem is periodic or short term,
f)     the concentration of heavy metals and/or the volume of water is small, or
g)     budgetary constraints exist.

       In such instances, it is desirable to employ an  unattended,  passive or in-situ remediation system
requiring little, if any capital investment, and unaffected by oil or suspended solids. Typical applications
may include groundwater,  landfill leachate, storm water, acid mine drainage, mine  tailings, and other
industrial effluents.
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        The selective removal of certain cationic species from aqueous solutions by way of polymers of
specialized composition is well known.  Specialty chelating  resin products1'2 have been  marketed for
selective absorption of cation species, such resins generally being in the form of 20-200 mesh beads of
styrene-divinylbenzene copolymer having iminodiacetic acid  functional groups.  The properties of such
polymers have been extensively studied.3'4-5'6 Naturally occurring substances such as algal cells7, peat
moss8 fungal biomas13 and municipal sewage sludge9 are also capable of selective cation absorption.

        In general, highly selective chelation resins function by way of forming coordination bonds which
preferably produce 5 member rings involving nitrogen and/or oxygen atoms. A unique order of affinity
series for cations is usually characteristic of each particular polymer, based upon its specific  functionality.
The affinity series is further dependent upon  solution parameters such as pH and anion content. Because
of the need for sufficient chemical functionality to absorb a single cation by way of formation of a chelate
ring, the cation absorption capacity of chelating resins is in the relatively low range of about 0.8 to 3.0
meq/dry gram of resin.  By way of comparison, strong acid ion exchange resins based upon polystyrene
sulfonic acid can absorb  up to about 5.5 meq/dry gram of  resin.  Furthermore, chelating resins are
generally more costly than ion exchange resins.

A.2    THE DYNAPHORE TECHNOLOGY

        A low cost chelating resin has been developed by Dynaphore, Inc. of Richmond VA.10 The resin
is a cross-linked aliphatic  polyamine/polyamide hydrogel polymer having pendant carboxyl groups.  In
order to protect the carboxyl groups during polymerization, a polyvalent cation such as Ca++,  Mg^ or Al+++
is added. In various laboratory and field investigations, the general order of affinity of metal cations for
the  polymer has been found to be as follows:
        Cu > Hg > Pb > Cd > Ni > Cr > Co > Fe > Zn > Mn » Al > Ca > Mg » Na

        The polymer is capable of forming several different kinds of chelate rings, and is further capable
of simple ion exchange reactions and non-chelate complexation reactions. Because of the several different
modes of polymer/metal ion interaction, the  affinity sequence for a  given cation mixture  is not always
predictable with certainty.  Absorbed metals may be displaced by other metals in the course of continued
exposure of the polymer to a cation mixture.  The final result is dependent upon relative concentrations
                                              69

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and stability constants of the several modes of chemical bonding.  Reaction kinetics may be an important
factor in determining which metals are absorbed under specific water treatment conditions.

        It has further been found that the polymer, once saturated with multivalent cations,  functions as
a selective anion exchange resin.11  Although it is not yet certain  which metal/polymer bond structure is
involved in anion exchange, the following typical equation is visualized
        R - M~ S04~ + SeOf  -»  R - M++ Se03~ + S04~

        In anion  exchange  reactions, those reactions are favored wherein  the  analogous inorganic
compound has the smallest solubility  product (Ksp).   Although the anion exchange  feature offers
interesting applications, (e.g. removal of chromate, arsenate, or cyanide complexes) it can complicate a
cation absorption scenario because absorbed cations which associate with a strongly held anion may not
exchange with other cations that would otherwise form a stronger cation bonding complex.

        The  above-described chelating  polymer  is produced by Dynaphore,  Inc. as porous  Sponge
products12 marketed as FORAGER™ Sponge, having a cation absorption capacity of about  1.5 meq/dry
gram. In the Sponge format, the polymer produces very little impedance to the flow of water. Also, the
Sponge  can be  confined within fishnet bag containers instead of the pressurized vessels conventionally
required for bead-form ion exchange resins. Such characteristics make the Sponge well adapted for in-situ
applications.

A.3     THE NL SUPERFUND DEMONSTRATION

        In the NL Superfund Demonstration, a pump-and-treat  approach was used, relying  upon an
existing well and  accumulating tank on site.  The Dynaphore  apparatus consisted of four plexiglas
columns, each of 8"  I.D. and 5' height, interconnected for upward series flow.   Each column held a
removable fishnet container filled with pieces of FORAGER™ Sponge of 1/2" cube size. Employing a
12 volt  storage  battery, the groundwater was pumped from the accumulating tank through the apparatus
at  a flow rate  of  1 gal/min, producing a  pressure drop of only 4 psig across the four columns.  If
alternatively, the four columns had been laid upon the ground in series hook-up, it is quite likely that
gravity  flow alone from the accumulating tank  would  have provided the same  flow rate.   In such
disposition, however, regeneration of the Sponge on site would require separate equipment.

                                              70

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       The Sponge in the first 3 columns was in a calcium pre-saturated  form, achieved by way of
calcium-aided polymer production. The Sponge in the fourth column was in an aluminum pre-saturated
form. The rationale for employing Ca and Al pre-saturated polymer is that, whereas both metals are easily
replaceable by other cations, the Ca form might become deactivated by interaction with the vast amount
of S04" in the groundwater. The aluminum form would be expected to survive the effects of high sulfate
concentration.

       The NL groundwater has a pH of about 3.2, a sulfate concentration of about 20,000 ppm, and high
concentrations of cations such as calcium, magnesium,  and aluminum.  Concentrations of these cations
range from 70 ppm for magnesium to 6000 ppm for sodium. The remediation objective  was to remove
Cu"1^, Pb^,  Cd++ and Cr^ which are present at levels of about 1 ppm.  An ordinary ion exchange resin,
if applied to this situation, would saturate with the abundant ions without absorbing the sought  heavy
metal ions.

       In laboratory tests employing pure nitrate salt solutions,  Sponge of the type emplaced  in the
columns was found to hold at saturation 4% Cu^,  3% Pb^, 3% Cd++ and 1% Crw (dry weight basis).
It was not possible to run saturation trials in the laboratory using actual  groundwater shipped from the NL
Superfund  site  because  the levels of the treated metals was low and the water  is not  storage stable.
Exposure to air caused precipitation.  A sample of about 300 pieces of Sponge was removed from the
bottom of the first column  at the end of the NL trial. The sample was randomized, dried,  powdered, and
dissolved in Aqua Regia. Upon analysis of the resultant solution by atomic absorption, it was ascertained
that this sample, presumably saturated with Cu, Pb, Cd and Cr, contained only 0.6% Cu, and less than
0.1% each  of Cd, Cr and Pb.  In further testing of the same Sponge  sample, it was found that elution
treatment with 10% HC1 removes only 6% of the calcium.  By way of comparison, the starting Sponge,
when similarly  treated, discharges essentially all of its calcium.  It therefore appears that the calcium
content of the starting sponge, which occupies most of the absorption  sites of the polymer, reacted with
anion species such as sulfate, phosphate, silicate and vanadate to form intractable compounds.  Such effect
further explains the lower than expected saturation  levels with Cu, Cd, Pb and Cr.  The aforementioned
anion species, with the exception of sulfate,  also interacted with the aluminum  pre-absorbed in column
4.
                                              71

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       It is to be emphasized that the NL trial represents essentially a single experiment aimed at solving
a difficult problem.  The FORAGER™ Sponge technology is amenable to chemical variations tailored to
specific applications.  It is quite  likely that a modified polymer structure  might have performed better.
In fact, the simple expedient of an activation treatment with dilute HC1 prior to the NL trial would have
produced markedly improved results.  Such treatment, by removing all pre-absorbed cations, would have
minimized  interference by anions.

A.4    OTHER APPLICATIONS

       In-situ applications employ a tubular fishnet container filled with the Sponge and placed in shafts
or trenches to intercept an existing flow of water. Figure 1 shows a single container bag unit of Sponge
vertically emplaced at the neck region of a convergent groundwater collecting zone downstream of the
plume.  Figure 2 shows a trench installation for  groundwater remediation employing a multitude of
containers of Sponge horizontally placed in a sand bag type of arrangement.  Containers of Sponge  can
also be utilized tea-bag style or placed within a conduit through  which water flows  by gravity effect.
Loose Sponge is being evaluated in tumble  operations in soil washing treatments and in stirred tanks for
sludge remediation.
                                              72

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                      o
74

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       The saturated Sponge can be eluted and re-used in many applications.  Alternatively, or after
numerous use cycles, the Sponge may be disposed of by incineration, compaction, or landfill.  Because
of the non-aromatic chemical composition of the  Sponge and  the  absence  of sulfur and halogens,
combustion gases resulting from incineration are relatively innocuous.  The cost of the Sponge is such as
to make one-time use feasible in many instances.

A.5    COSTS

       In an idealized situation where the Sponge will absorb cations to laboratory confirmed levels, and
if the Sponge is utilized just once to saturation and then disposed of,  the cost of absorbing trace  heavy
metals from water will be  in the range of about 20 cents to 40 cents per gram of metal removed. The
exact cost under such circumstances is dependent upon the atomic weight of the metal and its efficiency
of absorption.

       If the Sponge is regenerated employing 5% HC1, followed by a water wash, and if the HC1 is
recovered by distillation, the operating cost will be essentially the fuel cost for the HC1 recovery.

       Additional  costs will be involved in the transportation, handling and  ultimate disposal of the
Sponge.

A6.    ACKNOWLEDGEMENTS

       Dynaphore,  Inc. is appreciative of the very efficient and highly professional efforts of SAIC in
conducting the NL Superfund Demonstration and evaluating the results. We are also grateful to the EPA,
and in particular to Carolyn Esposito for persevering in a difficult challenge for a new technology.  We
are also thankful to Lou Reynolds of the Adtechs Corp. of Herndon, VA for his early efforts leading to
the Superfund Demonstration.

SUMMARY
       FORAGER™ Sponge represents a specialized new approach for the selective removal of  heavy
metals from water.  It portends the in-situ remediation of water sources at potentially low cost.  The
product can be modified to some extent for improved efficiency in particular applications.

                                              75

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References:
1.      Chelex 100, Bio Rad Laboratories, Richmond, CA
2.      Dowex A-100, Dow Chemical Co., Midland, MI
3.      R. Hering, J. Prakt, Chem. 14 285 (1961) (CA 56 6690g, 1962)
4.      R. Hering, J. Inorg. Nucl. Chem. 24 1399 (1962) (CA 58, 9655C)
5.      R. Hering, Z. Chem.  5 (5), 194 (65) (CA 63, 8556h, 1965)
6.      H. Gold and C. Calmos, A.l.Ch.E. Symposium Series No. 192, V.76, p. (60) (1980)
7.      Alga SORB, Bio-Recovery Systems, Inc. Las Cruces, NM
8.      T. Jeffers, et al., U. S. Bureau of Mines, Randal Gold Forum p. 112, Apr. 1991
9.      H. G. Brown et al, U.S. EPA, Environmental Letters 5(2) p. 103 (1973)
10.    U. S. Patent 3,715,339 and other patents and patent applications
11.    U. S. Patent 5,187,200
12.    U. S. Patent 5,096,946, and other patents and patent applications
13.    U. S. Patent 4,732,681
                                             76
                                                              *U.S. GOVERNMENT PRINTING OFFICE:  1995-652-860

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