&EPA
United States
Environmental Protection
Agency
      Electrochemical Design Associates
      (formerly Geokinetics International, Inc.)
      Lead Recovery Technology Evaluation
      Building 394 Battery Shop
      Pearl Harbor Naval Shipyard and
      Intermediate Maintenance Facility
      Honolulu, Hawaii
      Innovative Technology
      Evaluation Report
                SUPERFUND INNOVATIVE
               TECHNOLOGY EVALUATION

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                                                  EPA/540/R-04/506
                                                    September 2003
                           FINAL

   INNOVATIVE TECHNOLOGY EVALUATION REPORT
       ELECTROCHEMICAL DESIGN ASSOCIATES
   (FORMERLY GEOKINETICS INTERNATIONAL, INC.)
     LEAD RECOVERY TECHNOLOGY EVALUATION

                            at the

              BUILDING 394 BATTERY SHOP
PEARL HARBOR NAVAL SHIPYARD AND INTERMEDIATE
                MAINTENANCE FACILITY
                   HONOLULU, HAWAII
                         Prepared for:

                U.S. Environmental Protection Agency
                 Office of Research and Development
            National Risk Management Research Laboratory
                        Cincinnati, Ohio
                         Prepared by:

                       Tetra Tech EM Inc.
                  1230 Columbia Street, Suite 1000
                    San Diego, California 92101
                   EPA Contract No. 68-C-00-181
                        September 2003

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                                    CONTENTS

Section                                                                         Page

NOTICE	i

FOREWORD	 ii

ABSTRACT  	iii

ACKNOWLEDGMENTS	iv

ACRONYMS AND ABBREVIATIONS	 v

EXECUTIVE SUMMARY	  ES-1

1.0     INTRODUCTION	1-1

       1.1    PROJECT BACKGROUND	1-1

       1.2    TECHNOLOGY DESCRIPTION	1-2

       1.3    KEY CONTACTS	1-5

2.0     TECHNOLOGY APPLICATIONS ANALYSIS  	2-1

       2.1    FEASIBILITY STUDY EVALUATION CRITERIA  	2-1

             2.1.1   Overall Protection of Human Health and the Environment	2-1
             2.1.2   Compliance with Applicable or Relevant and Appropriate Requirements ... 2-1
             2.1.3   Long-Term Effectiveness and Permanence	2-8
             2.1.4   Reduction ofToxicity, Mobility, or Volume Through Treatment	2-8
             2.1.5   Short-Term Effectiveness	2-8
             2.1.6   Ability to Implement 	2-9
             2.1.7   Cost	2-9
             2.1.8   State Acceptance	2-9
             2.1.9   Community Acceptance	2-9

       2.2    TECHNOLOGY APPLICABILITY	2-10

       2.3    KEY FEATURES OF THE TREATMENT TECHNOLOGY	2-10

       2.4    MATERIALS HANDLING REQUIREMENTS  	2-10

       2.5    SITE SUPPORT REQUIREMENTS 	2-11

       2.6    LIMITATIONS OF THE TECHNOLOGY 	2-12

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3.0    ECONOMIC ANALYSIS  	3-1

       3.1     INTRODUCTION	3-1

       3.2     CONCLUSIONS	3-1

       3.3     ISSUES AND ASSUMPTIONS	3-2

       3.4     BASIS FOR ECONOMIC ANALYSIS 	3-10

              3.4.1   Site and Facility Preparation Cost 	3-10
              3.4.2   Permitting and Regulatory Costs	3-11
              3.4.3   Equipment Costs	3-11
              3.4.4   Start-up and Fixed Costs  	3-12
              3.4.5   Labor Costs	3-12
              3.4.6   Supplies and Consumable Costs  	3-13
              3.4.7   Utilities Costs	3-13
              3.4.8   Effluent Treatment and Disposal Costs	3-13
              3.4.9   Residuals and Waste Shipping, Handling, and Transport Costs	3-13
              3.4.10  Analytical Costs	3-14
              3.4.11  Facility Modification, Repair, and Replacement Costs	3-14
              3.4.12  Site Restoration Costs	3-14

4.0    TREATMENT EFFECTIVENESS  	4-1

       4.1     BACKGROUND	4-1

              4.1.1   Site Description 	4-1
              4.1.2   Evaluation Objectives and Approach	4-2

       4.2     EVALUATION PROCEDURES  	4-2

              4.2.1   Evaluation Preparation	4-2
              4.2.2   Evaluation Design  	4-3
              4.2.3   Sampling Melhods  	4-5
              4.2.4   Quality Assurance and Quality Control Program  	4-7

       4.3     EVALUATION RESULTS AND CONCLUSIONS  	4-8

              4.3.1   Primary Objectives	4-12
              4.3.2   Secondary Objectives	4-14
              4.3.3   Data Quality	4-18
              4.3.4   Conclusions  	4-19

5.0    TECHNOLOGY STATUS	5-1

6.0    REFERENCES	6-1

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                                FIGURES

Figure                                                                Page

1-1         SYSTEM SCHEMATIC	1-4

3-1         ESTIMATED TREATMENT COSTS FOR 5 TONS OF SOIL USING EDA
           LEAD REMOVAL TECHNOLOGY 	3-8

3-2         ESTIMATED TREATMENT COSTS FOR 500 TONS OF SOIL USING EDA
           LEAD REMOVAL TECHNOLOGY 	3-9


                                 TABLES

Table                                                                Page

ES-1        EVALUATION CRITERIA FOR THE EDA LEAD RECOVERY
           TECHNOLOGY	 ES-4

2-1         SUMMARY OF APPLICABLE REGULATIONS	  2-2

2-2         POTENTIAL FEDERAL ARARs FOR THE EDA LEAD RECOVERY
           TECHNOLOGY	2-5

3-1         ESTIMATED COSTS FOR TREATMENT USING THE EDA LEAD
           RECOVERY TECHNOLOGY	3-3

3-2         ESTIMATED COST PERCENTAGES FOR TREATMENT USING THE EDA
           LEAD RECOVERY TECHNOLOGY	3-7

4-1         TREATMENT BIN 1 	4-9

4-2         TREATMENT BIN 2	4-10

4-3         TREATMENT BIN 4	4-11

4-4         RESULTS FOR LEAD USING EPA METHOD 6010B	4-12

4-5         AVERAGE REMOVAL EFFICIENCIES	4-13

4-6         RESULTS FOR LEAD USING TCLP	4-14

4-7         MASS OF SOLID LEAD RECOVERED BY THE ESMS	4-14

4-8         RECOVERY EFFICIENCY OF THE ESMS  	4-15

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                                         NOTICE

The information in this document has been funded by the U.S. Environmental Protection Agency's
(EPA) under Contract No. 68-C-00-181 to Tetra TechEM Inc. It has been subjected to the Agency's
peer and administrative reviews and has been approved for publication as an EPA document. Mention of
trade names or commercial products does not constitute an endorsement of recommendation for use.

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                                         FOREWORD

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

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

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

                                            E. Timothy Oppelt, Director
                                            National Risk Management Research Laboratory
                                               11

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                                          ABSTRACT

This report presents performance and economic data from U.S. Environmental Protection Agency (EPA)
Superfund Innovative Technology Evaluation (SITE) Program evaluation of Electrochemical Design
Associates (EDA), formerly known as Geokinetics International Inc., Lead Recovery Technology
Evaluation.  The demonstration evaluated the technology's ability to remove lead contamination from
soil.

The EDA technology was operated by injecting electrolyte solution into the treatment tank, allowing the
electrolyte solution to migrate vertically and horizontally through the soil. The ethylene diamine
tetraacetic acid in the electrolyte solution acted as a chelating agent, forming a soluble Pb-EDTA2"
complex. The Pb-EDTA2" complex within the electrolyte was removed from the bottom of the treatment
tank through extraction pipes. From here, the electrolyte solution flowed into the header tank and fed
directly into the proprietary electrolyte solution management system (ESMS). The ESMS consisted of
proprietary electrochemical lead recovery cells. Once it had passed through the ESMS, the electrolyte
solution was delivered to a holding tank where it was stored and the pH was adjusted.  From here, the
electrolyte solution was re-delivered to the treatment tank and the process was repeated. The entire
system is a batch closed-loop process, which is initiated and controlled by a single automated process
control  system (Gil 1998b).

This demonstration tested the ability of the EDA technology to remove lead from in two phases. Phase I
was conducted at Building 394 Battery Shop from August 8 to September 28, 2001 and Phase II was
conducted from April 1 to July 22,2002.

Primary demonstration objectives evaluated whether the EDA technology reduced lead concentrations in
soil to below the clean-up goal of 2,000 milligrams per kilogram (mg/kg).  The EDA technology reduced
lead concentrations in soil; however, not below the 2,000 mg/kg clean-up goal for all batches.

Potential sites for applying this technology include Superfund and other hazardous waste sites where
soils are contaminated with lead.  Economic data indicate that remediation costs of using this technology
are affected  by site-specific factors, such as the availability to  electrical and water lines. The operating
cost for implementing the EDA technology is estimated to be $11,980 per ton for a 5-tonpilot study, and
$546 per ton for a 500-ton full-scale study.  Capital costs are not available at this time.
                                               ill

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                                  ACKNOWLEDGMENTS

This report was prepared for the U.S. Environmental Protection Agency (EPA) Superfund Innovative
Technology Evaluation (SITE) program by Tetra Tech EM Inc. (Tetra Tech) under the direction and
coordination of Mr. Thomas Holdsworth at the National Risk Management Research Laboratory
(NRMRL) in Cincinnati, Ohio.

The lead recovery technology evaluation was a cooperative effort that involved the following personnel
from EPA NRMRL SITE Program in cooperation with the Pacific Division Naval Facilities Engineering
Command (PACNAVFACENGCOM), and Electrochemical Design Associates (EDA), formerly known
as Geokinetics International Inc.:
Annette Gatchett
Thomas Holdsworth
Ann Vega
Clint Zenigami
Randal Kido
Richard Sturm
Lewis Mitani
Mike Miyasaka
Stephen Clarke
Carl Rhodes
Greg Swanson
Linda Hunter
Roger Argus
Barry Hicks
Donna Rydberg
EPA NRMRL Assistant Director of Technology
EPA NRMRL Work Assignment Manager
EPA NRMRL Quality Assurance Coordinator
PACNAVFACENGCOM Remedial Project Manager
Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility
AMEC Project Manager
EPA Region IX Project Manager
State of Hawaii Department of Health Project Manager
Electrochemical Design Associates Project Manager
Tetra Tech EM Inc. SITE Program Manager
Tetra Tech EM Inc. SITE QA Manager
Tetra Tech EM Inc. Project Quality Control Coordinator
Tetra Tech EM Inc. Project Manager
Tetra Tech EM Inc. Project Field Manager
Severn Trent Laboratory Project Manager
                                             IV

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                         ACRONYMS AND ABBREVIATIONS
ARAR

CAA
CAMU
CERCLA
EDA
EDTA
EE/CA
EPA
ESMS
ETU

ITER

kg

mg/kg
mg/L
MS/MSD

NRMRL

OSWER
ORD

PACNAVFACENGCOM
PPE

QA
QA/QC
QC

RCRA
RI
RSE

SARA
SI
SITE
Applicable or relevant and appropriate requirement

Clean Air Act
Corrective action management unit
Comprehensive Environmental Response, Compensation, and
Liability Act

Electrochemical Design Associates
Ethylene diamine tetraacetic acid
Engineering evaluation/cost analysis
U.S. Environmental Protection Agency
Electrolyte solution management system
Electrochemical treatment unit

Innovative technology evaluation report

Kilogram

Milligram per kilogram
Milligram per liter
Matrix spike/matrix spike duplicate

National Risk Management Research Laboratory

Office of Solid Waste and Emergency Response
Office of Research and Development

Pacific Division Naval Facilities Engineering Command
Personal protective equipment

Quality assurance
Quality assurance/quality control
Quality control

Resource Conservation and Recovery Act
Remedial investigation
Removal site evaluation

Superfund Amendments and Preauthorization Act of 1986
Site inspection
Superfund Innovative Technology Evaluation

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TCLP                      Toxic Characteristics Leaching Procedures
Tetra Tech                 Tetra Tech EM Inc.
                                          VI

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                                  EXECUTIVE SUMMARY

The Electrochemical Design Associates (EDA), formerly known as Geokinetics International Inc., lead
recovery technology was evaluated as a remediation technology to remove lead from the soil. The
evaluation was accomplished through a partnership between the U.S. Environmental Protection Agency
(EPA) Superfund Innovative Technology Evaluation (SITE), and Pacific Division Naval Facilities
Engineering Command (PACNAVFACENGCOM). The demonstration was conducted at Building 394
Battery Shop, Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility, Honolulu, Hawaii.

The purpose of this Innovative Technology Evaluation Report (ITER) is to present information that will
assist SITE decision-makers in evaluating the lead recovery technology as a potential remediation
alternative for application at sites with lead contamination in soil.

The executive summary briefly describes the lead recovery technology, provides an overview of the SITE
evaluation of the technology, summarizes the SITE evaluation results, and discusses the Superfund
feasibility evaluation criteria for the lead recovery technology.

The Lead Recovery Technology

The basic process for electrokinetic treatment of soil ex-situ is similar to in-situ treatment, except that the
ex-situ soil contact with the process fluids is within a water-tight soil containment vessel, eliminating
problems with loss of fluids and potential mobilization of lead to beyond the treatment area.

Drainage at the bottom of the soil containment vessel is provided through a gravel pack, which contains a
manifold of slotted well screen to improve flow to the collection pump. One or two layers of filter fabric
(drainfield cloth or equivalent) and a screen separate the soil and gravel pack to reduce the movement of
soil particles into the electrochemical treatment unit (ETU).

An ethylene diamine tetraacetic acid (EDTA) solution is infiltrated through the soil. Lead within the soil
bonds with the EDTA during infiltration, forming a Pb-EDTA2" complex. The solution is recovered at
the bottom of the tank, and transferred to the  ETU where lead is removed from the EDTA solution by
electroplating. The EDTA solution is then reconditioned in the electrolyte solution management system

                                             ES-1

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(ESMS) as necessary (pH adjustment, EDTA concentration adjustment) and recirculated through the soil.
Plated lead is scraped from the electrodes and containerized.  Treated soil is stored under cover and
tested for disposal purposes.

Overview of the Lead Recovery Technology SITE Demonstration

The EDA lead recovery technology demonstration was conducted in two phases using lead-contaminated
soil from the former battery acid pit adjacent to Building 394. The first phase was conducted from
August 8, 2001 to September 28, 2001, and the second phase was conducted from April 1, 2002 to July
22, 2002.

The SITE evaluation for the lead recovery technology was designed with three primary and three
secondary objectives to provide potential users  of the technology with the information necessaryto
assess the applicability of the lead recovery technology for other contaminated sites.

The primary objectives  (P) of the technology demonstration were as follows:

       PI     Determine if the EDA Technology is able to reduce soil lead concentrations in the
              treatment tank to less than the regulatory threshold limit of 2,000 mg/kg.

       P2     Determine the removal efficiency of the EDA technology for lead within the treatment
              tank.

       P3     Determine whether the post-treatment soil meets the Resource Conservation and
              Recovery Act (RCRA) landban standards for Toxic Characteristics Leaching Procedure
              (TCLP) for lead concentration.


The secondary objectives (S) of the technology demonstration were as follows:

       S1     Evaluate the mass of lead recovered by the electrolyte solution management system
              (ESMS) and estimate the recovery efficiency of the ESMS.
                                             ES-2

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       S2     Document specific EDA system operation and maintenance parameters.

       S3     Estimate capital and operating costs for constructing a full-scale EDA system.

 Key findings of the EDA technology are listed below:

       •      Approximately six percent of the total post-treatment soil samples met the regulatory
              threshold lead concentration of 2,000 milligrams per kilogram or less (1 of 18 post
              treatment samples).
       •      The average lead removal efficiency was 59 percent for all three bins. Due to variations
              in the treatment process for Bin 4, which included changing the concentration of the
              EDTA solution and extensively flushing the soil with water, the removal efficiency was
              81 percent.
       •      TCLP lead concentrations did not meet the RCRA landban standard of the 5.0 milligrams
              per liter for samples collected from Bin 1 and Bin 2 due to adsorption of the Pb-EDTA2"
              complex to soil particles during infiltration. Extensive flushing of water in Bin 4
              effectively removed sorbed solution, which resulted in a reduction in TCLP lead
              concentrations and attainment of the RCRA landban standard.

 Technology Evaluation Summary

Table ES-1 briefly discusses the Superfund feasibility evaluation criteria for the lead recovery technology
to assist Superfund decision-makers considering the technology for remediation of lead-contaminated
soils at hazardous waste sites.
                                             ES-3

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                                                                     Table ES-1
                                            Evaluation Criteria for EDA Lead Recovery Technology
Overall Protection of
Human Health and the
Environment
Compliance with
Federal ARARs
Long-Term Effectiveness
and Performance
Short-Term
Effectiveness
Reduction of Toxicity, Mobility,
or Volume Through Treatment
Provides both short- and
long-term protection by
removing lead in soil.
Requires compliance with
Toxic Substances Control
Act (TSCA) regulations
for treatment,
management, and disposal
of lead-contaminated
waste.

Prior to cleaning a site, the
contaminated material
must be sampled to
determine waste
management
requirements.


May require compliance
with hazardous waste
storage requirements,
depending on the
contaminant extracted.
Effectively removes lead with
high level of treatment
efficiency.

Does not destroy or degrade the
physical properties of the
affected media.

(Note: This lead recovery
Technology FEATS evaluation
did not directly evaluate the
"long-term" effectiveness of this
technology; however destruction
of contaminants is considered to
be a "long-term" treatment.)
Presents minimal short-
term risks to workers and
nearby community,
including noise and
exposure to airborne
contaminants.

Pretreatment of material
(i.e. grinding) can enhance
treatment success.
Reduces toxicity and mobility of
contaminated soil by extracting lead from
the soil.

Minimal waste is generated during the
contaminant destruction process.
                                                                        ES-4

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                                                         Table ES-1 (Continued)
                                      Evaluation Criteria for EDA Lead Recovery Technology
Implementability
Cost
Community Acceptance
State Acceptance
Technology is a mobile system that
can be transported anywhere.

Can be applied to any amount of
material.  There is no maximum or
minimum volume.

System is not labor intensive and
requires minimal physical effort.
The equipment cannot be left to run
unattended.
Based on information from Gil, and
observations made during the SITE
evaluation, the estimated cost is
$45,063 per ton for treating 5 tons of
soil; and $28,252 per ton for treating
25 tons of soil.  These costs include
personnel, equipment and supplies,
chemicals, and technical support.

Actual cost is site-specific and
depends on the media to be treated,
severity of contamination,
contaminant, and amount of material
to be treated.
Minimal short-term risks and long-term
permanence make this technology
favorable to the public.

Implementation of the technology
creates low levels of noise and creates
no traffic problems.
If remediation is conducted as part
of a Resource Conservation and
Recovery Act (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 technology.
However, the effectiveness of the
technology make it favorable for
state acceptance.

(Note: For the sites in Hawaii
where the FEATS demonstration
soil was collected,  EPA and DOH
required a lead cleanup goal of
2,000 mg/kg.)
                                                                     ES-5

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                                    1.0 INTRODUCTION

This section describes the U.S. Environmental Protection Agency (EPA) Superfund Innovative
Technology Evaluation (SITE) Program and reports the purpose and organization of the innovative
technology evaluation report (ITER), the demonstration background, and the ability of the
Electrochemical Design Associates (EDA), formerly known as Geokinetics International Inc., lead
recovery technology to remove lead contamination from soil. For additional information about the SITE
Program, the EDA lead recovery technology, and the evaluation site, refer to key contacts listed at the
end of this section.

1.1    PROJECT BACKGROUND

The primary purpose of the SITE Program is to advance the development and demonstration, and thereby
establish the commercial availability, of innovative treatment technologies applicable to Superfund and
other hazardous waste sites. The SITE Program was established by the EPA Office of Solid Waste and
Emergency Response (OSWER) and Office of Research and Development (ORD) in response to the
Superfund Amendments andPreauthorization Act of 1986 (SARA), which recognizes the need for an
alternative or innovative treatment technology research and demonstration program. The SITE Program
is administered by ORD's National Risk Management Research Laboratory (NRMRL) in Cincinnati,
Ohio. The overall goal of the SITE Program is to carry out a program of research, evaluation, testing,
development, and demonstration of alternative or innovative treatment technologies that can be used in
response actions to achieve more permanent protection of human health and welfare and the
environment.

The SITE Program consists of four component programs:  (1) the Demonstration Program, (2) the
Emerging Technology Program, (3) the Monitoring and Measurement Technologies Program, and (4) the
Technology Transfer Program.  This ITER was prepared under the  SITE Demonstration Program. The
objective of the Demonstration Program is to provide reliable performance and cost data on innovative
technologies so that potential users can assess a given technology's  suitability for specific site cleanups.
To produce useful and reliable data, demonstrations are conducted  at hazardous waste sites or under
conditions that closely simulate actual waste site conditions.  Innovative technologies chosen for a SITE
                                             1-1

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demonstration must be pilot- or full-scale applications and must offer some advantage over existing
technologies.

Implementation of the SITE Program is a significant, ongoing effort involving ORD, OSWER, various
EPA regions, and private business concerns, including technology developers and parties responsible for
site remediation. Cooperative agreements between EPA and the innovative technology developer
establish responsibilities for conducting the demonstrations and evaluating the technology. The
developer is typically responsible for demonstrating the technology at the selected site and is expected to
pay any costs for the transport, operation, and removal of related equipment EPA is typically
responsible for evaluating the performance of the technology during the demonstration. This
responsibility includes project planning, site preparation, technical assistance support, sampling and
analysis, quality assurance and quality control (QA/QC), report preparation, information dissemination,
and transport and disposal of treated waste materials.

In 1990, an expanded Site Inspection (SI) at the site was conducted  Based on the results of the SI, a
remedial investigation was conducted including: a geophysical  survey; collection of soil and groundwater
samples; analysis of samples for chemical and geotechnical parameters; assessment of hydraulic aquifer
characteristics; and performance of a land survey. Following the remedial investigation, and based on
the analytical findings, a removal site evaluation (RSE) was conducted for the site.  In July 1997, Tetra
Tech conducted soil sampling at the site in support of the proposed lead remediation technology
evaluation (Tetra Tech 1997a). In April 1999, Tetra Tech conducted pre-treatment sampling at Building
394 site in accordance with the previously planned lead remediation technology evaluation (Tetra Tech
1999a).

1.2    TECHNOLOGY DESCRIPTION

The Electrochemical Design Associates Lead Recovery Technology  is a soil remediation process that
mobilizes lead in soil by introducing ethylene diamine tetraacetic acid (EDTA), a lead chelating agent,
into the soil mass. EDA conducted Phase I and Phase II treatability studies on site soil to determine an
appropriate chelating agent.  EDTA, a weak acid, was identified by EDA as a successful chelating agent
due to its ability to absorb lead from the highly buffered soil present  at the site.  EDTA is a non-
hazardous and environmentally safe organic acid which naturally biodegrades (Gil 1998b).

                                               1-2

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EDA found that by saturating the soil column in the laboratory with an electrolyte solution containing
EDTA (0.3 molar concentration) at a pHof 5 to 6, lead was mobilized in ionic form (in solution) by the
formation of a Pb-EDTA2" complex. To mobilize and remove lead from the site soil by the EDA ex-situ
process, EDA used a 4-cubic-yard batch treatment process (Dimensions: 4 feet by 4 feet by 6 feet).
Treatment involved flushing the soil with the EDTA electrolyte solution. The electrolyte solution was
introduced into the treatment tank containing the volume of soil to be treated through a manifold of
microjets distributed across  the top of the tank. The solution, then, migrated through the soil column
while the EDTA extracted lead from the soil; thus forming the Pb-EDTA2" complex. The electrolyte
solution (containing Pb-EDTA2" complex) was then allowed to drain the bottom of the tank. Once the
electrolyte solution was removed from the tank, it was then delivered to a holding tank prior to being
cycled through a proprietary electrochemical processing unit. Here lead was electroplated out of
solution and recovered as metallic lead. Afterward, the electrolyte solution was delivered to a holding
tank where it was regenerated (pH adjusted) before being reintroduced to the soil undergoing treatment.
Lead removed from the electrolyte solution was accumulated and transported off site for recycling. The
entire system is a batch, closed-loop process. During operation, frequent sampling and analysis was used
to monitor the  concentration of lead in the electrolyte solution extracted from the soil.

Site-Specific Configuration

The system designed by EDA for this evaluation  consisted of the following:

       •       Two 1,500-gallon primary electrolyte solution holding tanks
       •       An electrolyte solution management system
       •       One 1,500-gallon header tank
       •       A process control system

Figure 1-1 shows the general configuration of the proposed ex-situ treatment process.
                                              1-3

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                                   Electrolyte Solution
                                   Management System
   EDTA Electrolyte Solution
   Influent Stream Containing
   Soluble Lead (Pb-EDTA2)
  1,500-gallon
 Header Tanks
EDTA Return
Lines
                 ES-1
                 (In-line
                 Sampling
                 Port)
                  Electrolyte
                  Pumps
                 ""A
                   \
                    \
                                                                          EDTA Delivery
                                                                          Line Containing
                                                                          Reconditioned EDTA
                                                                          Electrolyte Solution
                    \   EDTA Electrolyte Solution
                     ^      Effluent Stream
                    \
                  ES-2
                  (In-line
                  Sampling
                  Port and
                  flow meter)
                                                                       1,500-gallon
                                                                      Holding Tanks
       II     I   I    I   I
I   I    I   I
I    I   I   I      I
                                                                       EDTA Injection
                                                                       Points
                        Soil  Treatment Tank
                                 Screen and filter fabric
                                     EDTA Extraction Pipe
                                                         ELECTROCHEMICAL DESIGN ASSOCIATES, INC.
                                                                TECHNOLOGY EVALUATION
                                                                     FIGURE 1-1
                                                                 SYSTEM SCHEMATIC

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1.3    KEY CONTACTS

Additional information regarding the SITE Program and the evaluation can be obtained from the EPA
SITE Task Order:

                     Mr. Thomas Holdsworth
                     U.S. Environmental Protection Agency
                     Office of Research and Development
                     26 W. Martin Luther King Drive
                     Cincinnati, Ohio 45268
                     Telephone: (513)-569-7675 and (513) 569-7635
                     FAX: (513)-569-7676 and (513) 569-7585
                     E-mail:  holdsworth.thomas@epa.gov
Additional information on the EDA Lead Recovery technology or the evaluation can be obtained from
the technology developer:

                     Stephen Clarke
                     Electrochemical Design Associates
                     829 Heinz Street
                     Berkeley, CA 94710
                     Telephone: (510) 704-2940
                     FAX: (510) 848-1581
                     E-mail: steve.clarke@e-d-a.com

Additional information on the demonstration area or the evaluation can be obtained from Pacific Division
Naval Facilities Engineering Command (PACNAVFACENGCOM):

                     Clint Zenigami
                     Pacific Division
                     Naval Facilities Engineering Command
                     Environmental Restoration Branch
                                            1-5

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                     258 Makalapa Drive, Suite 100
                     Code ENV1821
                     Pearl Harbor, Hawaii  96860-7300
                     Telephone: (808) 472  - 1433
                     FAX: (808) 421 - 3800
                     Email: zenigamict@efdpac.navfac.navy.mil

Information on the SITE Program is also available through the following on-line information
clearinghouse: The Vendor Information System for Innovative Treatment Technologies (Hotline: (800)
245-4505) database contains information on 154 technologies offered by 97 developers. Technical
reports may be obtained by contacting U.S. EPA/NCEPI, P.O. Box 42419, Cincinnati, Ohio 45242-2419,
or by calling (800) 490-9198.
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                       2.0 TECHNOLOGY APPLICATIONS ANALYSIS

This section of the report describes the general applicability of EDA's lead recovery technology to
contaminated sites. The analysis is based primarily on this SITE demonstration, which evaluated the
treatment of lead contaminated soil. Conclusions are based exclusively on these data since only limited
information is available on other applications of the technology. Vendor claims regarding the
applicability of the lead recovery system are included in the appendix.

2.1    FEASIBILITY STUDY EVALUATION CRITERIA

2.1.1   Overall Protection of Human Health and the Environment

The system was setup and maintained by EDA.  Soil treated was characterized by AMEC based on the RI
and engineering evaluation and cost analysis (EE/CA) for the subject site (Ogden 1995, 1996); and Tetra
Tech during pre-treatment sampling for the proposed in-situ technology evaluation.

Personal protective equipment (PPE) was worn to protect field personnel from known or suspected
physical hazards and from potential airborne contamination. The levels of personal protection used
during excavation and sampling were selected based on known or anticipated physical hazards,
concentration of contaminants that may be encountered on site, and their chemical properties, toxicity,
exposure routes, and contaminant matrices.

Field personnel wore Level D clothing when initially entering the site. Chemical-resistant clothing was
worn when Level C protection was warranted. Chemical-resistant clothing protected the skin from
contact with skin-destructive  and absorbable chemicals, and helped to prevent contaminants from leaving
the site when removed before leaving the treatment area.  Lead concentrations in dust were monitored to
establish when respirator protection was necessary.

2.1.2   Compliance with Applicable or Relevant and Appropriate Requirements

This section describes the performance of the EDA lead recovery technology in removing lead during the
evaluation and compliance with applicable or relevant and appropriate requirements (ARARs) identified

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for the technology demonstration.  Potential federal ARARs for the technology are presented in Table
2-1.  These regulations include the Comprehensive Environmental Response, Compensation and Liability
act (CERCLA); Resource Conservation and Recovery Act (RCRA); the Clean Air Act (CAA); and
Occupational Safety and Health Administration (OSHA) requirements.


                          Table 2-1  Summary of Applicable Regulations
 Act or
 Authority
Applicability       Application to EDA Lead Recovery
                    System
                                         Citation
 CERCLA
 RCRA
 CAA
 OSHA
 Requirements
Superfund sites
Superfund and

RCRA sites
Air emissions from
stationary and

mobile sources
All remedial actions
This program authorizes and regulates the
cleanup of environmental contamination. It
applies to all CERCLA site cleanups and
requires that other environmental laws be
considered as appropriate to protect human
health and the environment.

RCRA defines and regulates the treatment,
storage, and disposal of hazardous wastes.
RCRA also regulates corrective action at
generator and treatment, storage and disposal
facilities.

If VOC emissions occur or hazardous air
pollutants are of concern, these standards
may be applicable to ensure that air pollution
is not  associated with the use of this
technology. State air program requirements
should also be considered.

OSHA regulates on-site construction
activities  and the health and safety of workers
at hazardous waste sites installation and
operation of the system at Superfund or
RCRA sites must meet OSHA requirements.
40 CFR, Part 300
40 CFR, Parts 260

through 270
40 CFR, Parts 50

and 70
29 CFR, Parts 1900

through 1926
This discusses federal environmental regulations that could be pertinent to operation of the EDA
technology, including transport, treatment, storage, and disposal of wastes and treatment residuals during
a response action pursuant to the CERCLA of 1980 as amended by the SARA. CERCLA 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.
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EPA has prepared the National Oil and Hazardous Substances Pollution Contingency Plan (NOHSPCP)
for hazardous substance response.  The NOHSPCP is codified at Title 40 CFR Part 300, and delineates
the methods and criteria used to determine the appropriate extent of removal and cleanup for hazardous
substances, pollutants or contaminants as defined by CERCLA.

SARA includes a strong statutory preference for innovative technologies that provide long-term
protection and directs EPA to:
               •      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
               •      Avoid off-site transport and disposal of untreated hazardous substances or
                     contaminated materials when practicable treatment technologies exist [Section
In general, two types of response actions are possible under CERCLA: removal activities, and remedial
actions. The EDA lead recovery technology is likely to be part of a CERCLA remedial action. 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 lead recovery technology is a toxicity reduction technology, as it
reduces lead in solid media.

On-site CERCLA remedial actions must comply with federal and more stringent state ARARs. CERCLA
provides no ARARs itself; instead, CERCLA requires that remedial actions comply with the substantive
requirements of other environmental statutes. ARARs are determined on a site -by-site basis considering
the types of chemicals present (chemical-specific), actions taken and waste streams generated (action-
specific), and location of the site in relation to sensitive environments (location-specific). Location-
specific ARARs depend on site-specific conditions and are not addressed in this report. This discussion
addresses potential chemical- and action-specific ARARs. The waste streams generated relate to the
material to be treated, the material after treatment, and PPE. The lead recovery technology is an ex-situ
treatment technology and the generation and disposal of lead remediation waste is regulated by the Toxic

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Substances Control Act and its implementing regulations at 40 CFR Part 761.  If other contaminants are
also present at a site, the site wastes should be characterized to determine whether they meet the
definition of hazardous wastes under RCRA. If so, RCRA requirements for the management of
hazardous wastes will also be ARARs for this technology. Specific ARARs that may be applicable to the
lead recovery technology are identified in Table 2-2.

Resource Conservation and Recovery Act

RCRA, an amendment to the Solid Waste Disposal Act, is the primary federal legislation governing
hazardous waste  activities. RCRA was enacted in 1976 to address safe disposal 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
relevant and appropriate to CERCLA activities where hazardous wastes are managed.  The Hazardous
and Solid Waste Amendments 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 applicable to the lead recovery technology only if RCRA-defined hazardous wastes
are generated during the CERCLA action.  The regulations that are likely to be listed as ARARs include
the requirement to characterize waste fora hazardous waste generator (40 CFR P262.11); the
requirement to determine if the hazardous waste is restricted from land disposal (40 CFR 268.7(a)); and
either 40 CFR 262.34(a) for storage of waste on site up to 90 days prior to off-site shipment, or 40 CFR
264.553 for storage  of waste in a temporary unit for up to 1 year prior to disposal. However, the
requirements for treatment and disposal units are  not ARARs unless these activities (such as land
disposal or storage of waste) will be conducted on site. Potential hazardous wastes generated by using
lead recovery technology include the extracted contaminants in the soil to be treated, the residual process
chemicals,  and used PPE. If these wastes are determined to be hazardous according to RCRA (either
because of a characteristic or a listing carried by the waste), all substantive RCRA requirements
regarding management and disposal of hazardous waste must be addressed by the remedial managers.
Criteria for identifying characteristic hazardous wastes are included in 40 CFR Part 261 Subpart C.
Listed wastes from specific and nonspecific industrial sources, off-specification products, spill cleanups,
and other industrial  sources are itemized in 40 CFR Part 261 Subpart D.  The technology could be used
on sites where lead,  cadmium, chromium or other metals are present and could, depending  on

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                                                                      Table 2-2
                                          Potential Federal ARARs for the Lead Recovery Technology
 Process Activity
ARAR
Description
Basis
Response
 Waste treatment
40 CFR Part
761.3 and
761.61 or state
equivalent
Standards   that  apply   to
treatment and disposal of Pb
remediation wastes
Generally applies to materials
contaminated from Pb releases
more than 48 hours old
Three options provided for Pb remediation
waste disposal; includes cleanup  levels and
performance
 On-site/off-site
 disposal
40 CFR Part
761.61(b)or
state equivalent
Technology-specific
performance standards for
disposal of Pb remediation
waste
Pb remediation wastes may be
disposed by meeting
technology-specific
performance standards for
chemical landfills,
incinerators, etc.
Permitted landfills, incinerators or other
technologies may be used for disposal of Pb
remediation waste
 On-site/off-site
 disposal (continued)
SARA Section
Requirements for the off-site
disposal of wastes from a
Superfund site.  This statutory
requirement is not an ARAR
and cannot be waived.
If the waste is being generated
from a response action
authorized under CERCLA,
there may be additional disposal
requirements.
Wastes must be disposed of at a permitted and
compliant waste disposal facility.
 Transportation for off-
 site disposal
4 CFR Part 172
or state
equivalent
DOT requirements for
packaging and labeling
hazardous materials prior to
transport
The treated waste must be
managed as a hazardous
material under DOT regulations
Packaging and labeling requirements for
hazardous materials are not ARARs and may
not be waived.
Notes:
        ARAR           Applicable or Relevant and Appropriate Requirements
        CERCLA         Comprehensive Environmental Response, Comensation, and Liability Act
        CFR             Code of Federal Regulations
        DOT             Department of Transportation
        Pb               Lead
        SARA           Superfund Amendments and Reauthorization Act
                                                                         2-5

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concentrations, be characteristic hazardous wastes. Contaminated PPE is subject to land disposal
restriction only if it contains more than 5 percent contamination per square inch.

Listed hazardous wastes (40 CFR Part 261 Subpart D) remain listed wastes regardless of the treatment
they may undergo and regardless of the final contamination levels in the resulting effluent streams and
residues. This regulation implies that, even after remediation, treated wastes are still classified as
hazardous if the pre-treatment material was a listed waste.  Under the contained-in policy, listed wastes
contained in other materials that are managed as waste require that those materials be managed as listed
wastes.  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.

RCRA corrective action regulations regarding corrective action management units (CAMU) and
temporary units may be ARARs for CERCLA action involving RCRA hazardous waste. The CAMU rule
allows for disposal of remediation wastes without triggering landfill disposal requirements and minimum
technology requirements.  The temporary units rule allows treatment or tanks without triggering RCRA
tank regulations.

Other Non-ARAR Requirements

Several requirements must be addressed by remedial managers although they are not ARARs. These
requirements cannot be waived. CERCLA remedial actions and RCRA corrective actions must be
performed in accordance with the OSHA requirements detailed in 29 CFR Parts 1900 through 1926,
especially 29 CFR 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 conducted in
accordance with 29 CFR Part 1926, 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 lead recovery system are required to have completed an OSHA training
course and must be familiar with all OSHA requirements relevant to hazardous waste sites. Noise levels
are not expected to be high.  The levels of noise anticipated are not expected to adversely affect the
community.

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Department of Transportation Regulations

Off-site shipment of hazardous materials is subject to Department of Transportation (DOT) requirements
for packaging and placarding. The treated soil from the lead recovery technology would likely be a
hazardous material subject to DOT regulations regulations in 49 CFR Parts 172 and 173. These
requirements cannot be waived, and as such, are not ARARs.

CERCLA Off-Site Rule

The CERCLA Off-Site Rule requires that wastes taken from a CERCLA site for off-site disposal must be
transported to permitted waste disposal facilities.  These facilities must be properly permitted and must
not have any violations that adversely affect human health or the environment. Each EPA region has a
coordinator for assistance in identifying disposal facilities in the region that are in compliance with their
appropriate permits and that are approved to receive waste from CERCLA sites.

Clean Air Act

The CAA as amended in 1990 regulates stationary and mobile sources of air emissions.  CAA regulations
are generally implemented through combined federal,  state, and local programs. The CAA requires that
treatment, storage,  and disposal facilities comply with primary and secondary ambient air quality
standards. Air emissions from the EDA lead recovery system may result from dust during the excavation
process.  State air quality standards may require additional measures to prevent fugitive  emissions.

Occupational Safety and Health Administration Requirements

OSHA regulations  in 29 CFR, Parts 1900 through 1926, are designed to protect worker health and safety.
Both Superfund and RCRA corrective actions must meet OSHA requirements, particularly Part
1910.129, "Hazardous Waste Operations and Emergency Response." Part 1926, "Safety and Health
Regulations for Construction," applies to any on-site construction activities. For example, electric utility
hookups for the EDA lead recovery system must comply with Part 1926, Subpart K, "Electrical."
Product chemicals used with the EDA lead recovery system must be managed in accordance with OSHA

                                             2-7

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requirements (for example, Part 1926, Subpart D, "Occupational Health and Environmental Controls, "
and Subpart H, "Materials Handling, Storage, and Disposal").  More stringent state or local requirements
must also be met, if applicable. In addition, health and safety plans for site remediation should address
chemicals of concern and include monitoring practices to ensure that worker health and safety are
maintained.

2.1.3   Long-Term Effectiveness and Permanence

This criterion refers to the ability of a remedy to maintain reliable protection of human health and the
environment over time. Electrokinetics is a treatment technology for metals in the soil. Electrokinetics
transforms the physical state of contaminated soil to clean soil with a solid-metal product.

2.1.4   Reduction of Toxicity, Mobility, or Volume Through Treatment

This criterion refers to the anticipated performance of the treatment technology potentially employed in a
Superfund remediation. With electrokinetics, the contamination of the soil is reduced by permanently
removing the metals from the soil. If high-density soil treatment blocks are desired, the runs of
electrolyte solution would increase. When the EDA system is run the  way that was originally planned for
the SITE demonstration (that is, in situ), there would be no waste product planned for disposal as it
would be completely remediated.

Results of lead tests indicated that the EDA process reduced the lead in the soil. However, this did not
reach below the regulatory limit defined for a characteristic waste as defined by RCRA.

2.1.5   Short-Term Effectiveness

This criterion addresses the period of time needed to achieve lasting protection of human health and the
environment as well as any adverse impacts that maybe posed during  the construction and
implementation period before cleanup goals are achieved.
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2.1.6  Ability to Implement

This criterion considers the technical and administrative feasibility of a remedy, including the availability
of materials and services needed to implement a particular option. EDA operates other pilot programs,
but does not operate on the open market yet.  Therefore, only the primary and secondary objectives need
to be evaluated for this criterion.

2.1.7  Cost

This criterion addresses estimated capital, operation and maintenance costs as well as net present worth
costs. Costs for treatment by the EDA technology will depend on site-specific factors such as the volume
of material to be treated, physical properties of the material, contaminant types and concentrations, and
site location. Section 3 of this report provides a detailed discussion of costs for the application of this
technology.

2.1.8  State Acceptance

Because few applications of the EDA ElectroMnetic system have been attempted beyond the bench- or
pilot scale, limited information is available to assess state acceptance of the system.  Although some
contaminants may be released during electrode and ancillary equipment installation, the potential for
emissions during  drilling is substantially lower than during excavation. State acceptance of the
technology may involve consideration of performance data from applications such as the SITE
demonstration and results from on-site, pilot-scale studies using the actual wastes to be treated during
later, full-scale remediation.

2.1.9  Community Acceptance

Because few applications of the EDA system have been attempted beyond the bench- or pilot scale,
limited information is available to assess state acceptance of the system. Although some contaminants
may be released during electrode and ancillary equipment installation, the potential for emissions during
drilling is substantially lower than during excavation.
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EDA claims one distinguishing feature of the lead recovery process is that no portion of the original
molecule is discharged to the atmosphere or to water. Further, EDA claims that the process is reductive
in nature and therefore not capable of forming dioxins or furans, which can be found in oxidizing
technologies. This result is especially beneficial because communities are becoming increasingly aware
of waste facilities and concerned over contaminant releases to the atmosphere and surrounding water.

Due the operational parameters of the lead recovery system, there are almost no potential hazards to the
community from implementation of the EDA technology. No loud or heavy equipment is associated with
the technology, and no substantial quantities of waste are generated apart from the treated soil. When
proper operational and safety procedures are followed, hazards to personnel are minimized and the
potential for a chemical spill to the environment that might endanger the community is minimal.

2.2      TECHNOLOGY APPLICABILITY

The EDA process was tested for the remediation of lead in the soil at the SITE  demonstration. However,
EDTA removes metals in a specific order within the plating process providing the potential capability to
remove other metals.

2.3      KEY FEATURES OF THE TREATMENT TECHNOLOGY

The most common remediation method for soil contaminated with metals is excavation and permanent
landfill disposal. The byproducts of the EDA lead recovery technology can be recyclable amounts of
lead and othermetals such as iron and copper that may present in treated soil.  Amajor advantage of this
technology is that contaminants can be reused rather than transferred to a landfill.

2.4      MATERIALS HANDLING REQUIREMENTS

It was imperative that sample logging and tracking procedures are in place and  followed.  Defined
procedures ensured that all core samples were properly labeled following retrieval from the sampler,
tracked through the homogenization area and homogenized correctly, and that appropriate sample
volumes of homogenized samples were collected and properly labeled before shipping to the analytical
laboratory.

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Prior to collecting the core samples from each grid-cell, the sampling personnel recorded the grid-cell
number being sampled, the sampler's name, and the date and time. This information was logged on a
field sampling form.  A field sampling form was completed for each grid-cell sample. As each 2-foot
core sample was retrieved, the sampling personnel recorded the time and the core samples were labeled
with their grid-cell number, depth interval, samplers initial, and date and time. This information was
written on the acetate sleeve with a permanent marker.

In addition, a site plan is required to provide for personnel protection and special handling measures.
Wastes need to be appropriately stored until sampling results indicate their acceptability for disposal or
release to a treatment facility.

2.5     SITE SUPPORT REQUIREMENTS

Site-specific factors can impact the application of the lead recovery system  These factors should
therefore be considered before the system is selected for remediation of a specific site.  Site-specific
factors addressed in this section include site access, area, and preparation requirements; climate
requirements; utility and supply requirements; support system requirements; and personnel requirements.

Site Access, Area, and Preparation Requirements: The site must be prepared for the mobilization,
O&M, and demobilization of the equipment.  Access roads are necessary for equipment transport.  The
site must be accessible to equipment necessary to install electrodes and ancillary equipment, such as
Geoprobe® and drill rigs.  The air space in the equipment installation area must be clear of obstacles
(such as overhead wires).

In addition to the treatment area and corresponding exclusion zone, enough space should be available to
accommodate the control trailer, hazardous waste storage area, water tanks, and supply storage.  This
additional area is estimated to require 8,800 square feet.

Climate Requirements: Climate does not determine the effectiveness or the applicability in this
demonstration.  The only time the climate may effect the demonstration is when the soil needs to be dried
after the treatment.
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Utility and Supply Requirements: The electrochemical treatment unit (ETU) system demonstrated at
Pearl Harbor Naval Shipyard was powered by a 20 kV DC power supply unit providing 200 amps at
100VDC.

Maintenance Requirements: Maintenance of a full-scale lead recovery system is estimated to require
15 hours weekly, 3 hours / 5 days per week. This estimate is based on the assumption that the design of
parts of the system that caused frequent shutdowns during the SITE demonstration, such as bladders and
float switches, would be modified to eliminate the problems.

2.6     LIMITATIONS OF THE TECHNOLOGY

Prior to implementing electrokinetic remediation at a specific site, field and laboratory screening tests
should be conducted to determine if the site is amenable to this technology.  Field conductivity surveys
are necessary to determine the soil's electrical conductivity. Also, buried metallic objects and utility
lines could short circuit the current path, thereby influencing the voltage gradient and affecting the
contaminant extraction rate. Electromagnetic surveys should be conducted to determine the presence of
buried metallic objects.

In addition, if volatile organic carbons (VOC) are present in soil undergoing electrokinetic treatment, the
VOCs may be  stripped from the soil to significantly increase the soil vapor VOC concentrations that
would result in significant VOC migration from the treatment area, if soil temperature exceeds 50°C.
Special measure therefore need to be taken to contain and control VOC emissions.
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                                    3.0 ECONOMIC ANALYSIS







This economic analysis presents the costs for using the lead recovery technology to remove lead from the



soil collected at Building 394 Battery Shop, Pearl Harbor Naval Shipyard and Intermediate Maintenance



Facility in Honolulu, Hawaii. Costs are organized under 12 categories applicable to typical cleanup



activities at Superfund and RCRA sites (Evans 1990).








3.1     INTRODUCTION







The primary purpose of this economic analysis is to provide a cost estimate for using EDA's Lead



Recovery Technology to commercially remediate lead-contaminated soil. This analysis is based on the



assumptions and costs provided by EDA, and on the results and experiences gained from the SITE



evaluation that was conducted at Building 394 Battery Shop, Pearl harbor Naval Shipyard and



Intermediate Maintenance Facility, Honolulu, Hawaii. The SITE demonstration included the treatment of



three 500-gallon bins of lead-contaminated soil. The average pre-treatment lead soil concentration



ranged from 13,800 milligrams per kilogram (mg/kg) to 153,000 mg/kg.  Results of the SITE



demonstration are presented in  Section 4.0 of this report.







Economic calculations were compiled for: (1) 5 tons of soil with lead contamination similar to the SITE



evaluation using the EDA lead recovery technology, and (2) 500 tons of soil with lead contamination



similar to the SITE evaluation using the EDA lead recovery technology. Many factors affect the cost of



treatment. These include, but are not limited to; treatment mass, initial soil contaminate concentration,



final required target soil contaminate concentration, treatment soil type and characteristics, system design



and operating parameters, and type of contaminants.








3.2     CONCLUSIONS







This analysis presents cost estimates for treating contaminated soil with the EDA lead recovery



technology.  Table 3-1 lists a detailed breakdown of each cost category for each of the cases.  Costs that



are assumed to be the technology-independent obligation of the responsible party or site owner have been
                                                3-1

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omitted from this cost estimate and are indicated by a line (—) in Tables 3-1 and 3-2. Categories with no



costs associated with this technology are indicated by a zero (0) in Tables 3-1 and 3-2.  Figures 3-1, and



Figure 3-2 show graphic presentations of the costs for pilot-study and the full-scale project respectively.







The estimated treatment costs are $11,980 per ton, and $546 per ton for the 5-ton case and the 500-ton



case, respectively. The  cost of labor required is directly proportional to the treatment time per ton of soil.



Therefore, the estimated treatment cost would be lower if the percent lead reduction per EDA run is



increased, and the treatment time per batch is decreased. Also, the treatment time decreases for lower



initial lead concentrations and therefore treatment costs could decrease. For the 5-ton case and the 25-



ton case, the treatment time per cycle is based on  7, 24-hour days.







3.3     ISSUES AND ASSUMPTIONS







This section lists the major assumptions, site-specific factors, equipment and operating parameters, and



financial calculations used in this economic analysis of the EDA lead recovery technology.



The cost estimates presented in this  analysis are representative of charges typically assessed to the client



by the vendor, but do not include profit.  In general, assumptions are based on information provided by the



vendor and observations made during this and other SITE evaluation projects.







Many actual or potential costs that exist were not included as part of this estimate. They were omitted



because site-specific engineering designs that are beyond the scope of this SITE project would be



required.  Also, certain functions were assumed  to be the obligation of the responsible party or site owner



and were not included in the estimates. These costs are site-specific; thus, calculations are left to the



decision-maker so that relevant information may be obtained for specific cases. Whenever possible,



applicable information is provided on these topics  so that a decision-maker can independently perform the



calculations  required to acquire relevant economic data.
                                                 3-2

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Table 3-1 Estimated Costs for Treatment Using the EDA Lead Recovery Technology
Treatment Unit
Treatment Volume per Batch (tons)
Number of Batches
Site and Facility Preparation Costs
Site selection and preparation
Soil collection, transportation, and stockpiling
Legal Searches
Access rights and roads
Preparations for support facilities
Auxiliary buildings
Technology setup costs (labor, assembly, testing)
Transportation of EDA system
Total Site and Facility Preparation Costs

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

Equipment Costs
Power Supply (DC)
Control computer and data acquisition
Sensors and signal conditioners
Tanks (other than ETU Cells)
Pilot Study
5
1

—
—
—
—
—
—
$4,100
$1,500
$5,600


—
—
—
—


$2,000
$1,200
$400
$1,000
Full-Scale Study
25
20

—
—
—
—
—
—
$8,000
$3,000
$11,000


—
—
—
—


$2,000
$1,200
$400
$1,000

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Treatment Unit
Treatment Volume per Batch (tons)
Number of Batches
Tanks (other than ETU Cells)
Cells (5)
Pumps (all)
Plumbing and hardware
Safety Equipment
Transformer (480V to 120V)
Total Equipment Costs

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

Labor Costs
Operator (Field Technician)
Chemist/supervisor
Total Labor Costs

Supplies and Consumables Costs
Health and Safety
Chemicals
Pilot Study
5
1
$1,000
$5,000
$2,000
$700
$1,000
$1,000
$14,300


—
—
—
—
—


$10,000
$4,000
$14,000


$200
$0
Full-Scale
Study
25
20
$1,000
$5,000
$2,000
$700
$1,000
$1,000
$14,300


—
—
—
—
—


$161,300
$32,200
$193,500


$2,100
$0
3-4

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Treatment Unit
Treatment Volume per Batch (tons)
Number of Batches
Spare Parts
Total Supplies and Consumables Costs

Utilities Costs
Electricity
Water
Total Utilities Cost

Effluent Treatment and Disposal Costs
On-site facility costs
Off-site facility costs
-recovered metal
-solution disposal
Total Effluent Treatment and Disposal Costs

Residuals and Waste Shipping, Handling and Transport
Costs
Preparation
PPE, drops cloths, and small equipment
Shipping & Handling
Total Residuals and Waste Shipping, Handling and
Transport Costs

Pilot Study
5
1
$300
$500


$300
$0
$300


—
—
$0
$15,000
$15,000


—
—
$100
$200

Full-Scale
Study
25
20
$2,400
$4,500


$2,400
$0
»,400


—
—
$0
$15,000
$15,000


—
—
$1,600
$1,600

3-5

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Treatment Unit
Treatment Volume per Batch (tons)
Number of Batches
Analytical Costs
Operations (laboratory)
Environmental monitoring (regulatory)
Total Analytical Costs

Facility Modification, Repair, and Replacement Costs
Design adjustments
Routine maintenance (material and labor)"
Total Facility Modification, Repair, and Replacement
Costs

Site Restoration Costs
Equipment demobilization
Transportation
Total Site Restoration Costs

TOTAL OPERATING COSTS
COST PER TON
Pilot Study
5
1

$2,000
—
$2,000


—
$oa
$0


$6,000
$2,000
$8,000

$59,900
$11,980
Full-Scale
Study
25
20

$14,500
—
$14,500


—
$0a
$0


$12,000
$4,000
$16,000

$272,800
$546
Maintenance labor is included in the operating labor.
                                                        3-6

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 Table 3-2 Estimated Cost Percentages for Treatment Using the EDA Lead Recovery
                                    Technology
Treatment Unit
Total Treatment Volume (tons)
Number of Batches
Site Facility Preparation Costs
Permitting and Regulatory Costs
Equipment Costs
Startup and Fixed Costs
Labor Costs
Supplies and Consumable Costs
Utilities Costs
Effluent Treatment and Disposal Costs
Residuals Shipping, Handling and
Transport Costs
Analytical Costs
Facility Modifications, Repair, and
Replacement Costs
Site Restoration Costs
Total Costs
Pilot Study
5
1
$5,600
—
$14,300
—
$14,000
$500
$300
$15,000
$200
$2,000
$0
$8,000
$59,900
*
9.3
—
23.9
—
23.4
0.8
0.5
25
0.3
3.3
0.0
13.4

Full-Scale Study
25
20
$11,000
—
$14,300
—
$193,500
$4,500
$2,400
$15,000
$1,600
$14,500
$0
$16,000
$272,800
*
4.0
—
5.2
—
70.9
1.6
0.9
5.5
0.6
5.3
0.0
5.9

Maintenance labor is included under operating costs
                                        3-7

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                      Analytical
                     $400 per ton
Site Restoration
 $1,600 per ton
                                                                               Site Facility Preparation
                                                                                  $1,120 per ton
     Residuals, Shipping,
   Handling, and Transport
        $40 per ton
           Effluent Treatment &
                Disposal
              $3,000 per ton
                                                                                               Equipment
                                                                                              $2,860 per ton
                           Utilities
                         $60 per ton
    Supplies and Consumables
           $100 per ton
                Figure 3-1 Estimated Treatment Costs for 5 Tons of Soil Using EDA Lead
                                                Removal Technology
 Permitting & Regulatory Costs were not included in the economic analysis.
'Facility Modifications, Repair, & Replacement Costs were included under Labor Costs and Equipment Costs.
                                                            3-8

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           Residuals Shipping,
         Handling, and Transport
                Costs
              $3 per ton
            Effluent Treatment &
            Disposal $30 per ton
             Utilities
            $5 per ton
        Supplies and Consumables
                 Costs
               $9 per ton
                             Analytical Costs
                               $29 per ton
Site Restoration
  $32 per ton
                        Site Facility Preparation
                             $22 per ton
                                                                                              Equipment
                                                                                              $29 per ton
              Figure 3-2 Estimated Treatment Cost for 500 Tons of Soil Using the EDA Lead
                                                Removal Technology
 Permitting & Regulatory Costs were not included in the economic analysis.
'Facility Modifications, Repair, & Replacement Costs were included under Labor Costs and Equipment Costs.
                                                            3-9

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3.4     BASIS FOR ECONOMIC ANALYSIS

In order to compare the cost-effectiveness of technologies in the SITE Program, EPA breaks down costs
into  12 categories (Evans  1990):

        •        Site and facility preparation costs
        •        Permitting and regulatory costs
        •        Equipment costs
        •        Start-up and fixed costs
        •        Labor costs
        •        Supplies  and consumable Costs
        •        Utilities costs
        •        Effluent treatment and disposal costs
        •        Residuals and waste shipping, handling, and transport costs
        •        Analytical costs
        •        Facility modification,  repair, and replacement costs
        •        Site restoration costs


These 12 cost categories reflect typical clean-up activities encountered at Superfund sites. The clean-up
activities are defined below, and form the basis for the detailed estimated costs presented in Tables 3-1
and 3-2.

3.4.1   Site and Facility Preparation Cost

Site preparation costs include administrative, treatment area preparation, treatability study, and system
design costs.  For the purposes of these cost calculations, "site" refers to the location where the EDA
technology is treating lead-contaminated soil.  It is assumed that preliminary site preparation and soil
excavation will be performed by the responsible party. The amount of preliminary site preparation
required will depend on the site.  Site preparation tasks include site design and layout, surveying,, legal
research, obtaining  access rights, preparations for support and decontamination facilities, utility
                                                 5-10

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connections, fixed auxiliary buildings, and excavation and stockpiling the soil.  Since these costs are site-



specific, they are not included as part of the site preparation costs in this cost estimate.







Only technology-specific site preparation costs are included. These are limited to transportation and setup



of the EDA system.  For this cost estimate, it is assumed that the site is 1,000 miles away and that



treatment will be outdoors. Transportation to the site for the ETU unit used in  the pilot-study case



includes one trailer and a mileage rate of $1.50 per mile for a total of $1,500. The full-scale study



assumes two trailers.







Technology-specific site preparation labor costs are required for setting up the equipment when it arrives



on site and are based on estimates by EDA and observations during the SITE evaluation. Labor to setup



the equipment and perform shakedown testing was $4,100 for the pilot study and $8,000 for the full-scale



study.








3.4.2   Permitting and Regulatory Costs







Permitting  and regulatory costs are generally the obligation of the responsible party (or site owner), not



that of the vendor. These costs may include actual permit costs, system monitoring requirements, the



development of monitoring and analytical protocols, and health and safety monitoring. No permitting and



regulatory costs  are included in Table 3.1.  Permitting and regulatory costs can vary greatly because they



are generally specific to the site and particular waste. Permitting costs are not included  in this analysis.








3.4.3   Equipment Costs







Equipment costs for the pilot and full-scale studies incorporates recent data from the evaluation completed



in Hawaii.  Equipment costs for both studies are assumed to be the same.
                                                 5-11

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3.4.4   Start-up and Fixed costs







The Lead recovery technology does require shakedown testing, since the lead recovery modules need to



be connected following transport to a site.  However, the equipment will be checked for proper assembly



after setup. Shakedown testing is included under technology-specific site preparation.







The cost for the initiation of monitoring programs has not been included in this estimate.  Depending on



the site and the location of the system, however, local authorities may impose specific guidelines for



monitoring programs. The stringency and frequency of monitoring required may have significant impact



on the project costs.







Contingency costs allow for any unforeseen or unpredictable cost conditions, such as strikes, storms,



floods, and price variations (Peters 1980) (Garrett 1989). Contingency costs, as well as annualized



insurance and taxes are not included.







3.4.5   Labor Costs








Once the system is functioning, it is assumed to operate continuously at the designed flow rate except



during routine maintenance, which EDA conducts (see Section 3.4.11 Facility Modification, Repair and



Replacement Costs).  One operator trained by EDA performs routine equipment monitoring and sampling



activities. Under normal operating conditions, an operator is required to monitor the system 2 hours per



day during the pilot study. This analysis assumes that the work is conducted by a full-time employee of



the site owner who is assigned to be the primary operator to the perform system monitoring and sampling



duty.  Full-scale  application will require two full-time operators.  Operator labor costs are $50 per hour.



Chemist/supervisory  labor is assumed to be $70 per hour.







Based on SITE demonstration on Bin  4, it is assumed 18 weeks of operation are required during the pilot



test to achieve the regulatory threshold limit, and 52 weeks of operation are required during the full-scale



study to reach the same desired limit.
                                                5-12

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3.4.6   Supplies and Consumable Costs







Supplies costs are limited to health and safety supplies and drums for residuals and waste storage.  Supply



costs are assumed to be $4 to $15 per worker per operational day. Drums are estimated to cost $35 per



drum, including freight charges.  A total of 10 drums and 200 drums are assumed for the pilot study and



full-scale study, respectively. Consumables are limited to chemicals and spare parts.  Based on the SITE



study, chemical cost is minimal and was not included.  Spare parts include 2 to 4 replacement pumps at



$500 per pump and  $400 of miscellaneous items.








3.4.7   Utilities Costs







Utilities required are limited to electricity and water for the EDA lead recovery technology.  For the pilot



study, it was assumed that 1,000 kiloWatt-hours (kWh) are used weekly based on the demonstration



project. Electricity rates are assumed to be $0.08/kWh.  Water is required for the technology to be



properly implemented. Water is assumed to cost $0.08  per 1,000 gallons and is included with the



electricity estimate.







3.4.8   Effluent Treatment and Disposal Costs







Effluent treatment and disposal is limited to scrubber water. Effluent volumes are based on the capacity



of the scrubber tank module for lead recovery technology.  An estimated 55 to 1,100 gallons of scrubber



water effluent will require disposal.







3.4.9   Residuals and Waste  Shipping, Handling, and Transport Costs







It is  assumed that the only residuals or solid wastes generated from this process will be used health and



safety and miscellaneous solid waste, including debris from the  treatment process (such as drop clothes),



as well as small equipment. The  disposal cost for solid waste is  estimated at $200 per 55-gallon drum.

-------
3.4.10  Analytical Costs







Required sampling frequencies are highly site specific and are based on treatment goals and contaminant



concentrations. Analytical costs associated with an electrokinetics treatment project include the costs of



laboratory analyses, data reduction, and QA/QC. This analysis assumes that samples were collected



from each days operation, for each soil flush,; and 12 pre-treatment soil samples, 12 post-treatment soil



samples, and associated QC samples (trip blanks, field duplicates, and matrix spike/matrix spike



duplicates) will be analyzed for total lead and TCLP lead concentrations.  The total analytical costs are



estimated to be $2,000 for the pilot study and $14,500 for the full-scale study.







The analytical costs associated with environmental monitoring have not been included in this estimate due



to the fact that monitoring programs are not typically initiated by EDA. Local authorities may, however,



impose specific sampling and monitoring criteria whose analytical requirements could contribute



significantly to the cost of the project.







3.4.11  Facility Modification, Repair and Replacement Costs







Maintenance costs are assumed to consist of maintenance labor and maintenance materials.



Maintenance costs are not included, since they are assumed to be routine for the Lead recovery



technology and are incorporated into the treatment time that accounts for an 80 percent run time



efficiency.  This assumption is made because the Lead recovery equipment is maintained by the operators



during the runs and should require little to no repairs in addition to the 80 percent run-time efficiency. In



addition, maintenance labor is included in the operating labor and the replacement part costs and tools are



included in the total equipment cost lump sum so no additional replacement part costs are included.







3.4.12  Site Restoration Costs







Site restoration requirements will vary depending on the future use of the soil and are assumed to be the



obligation of the responsible party. Therefore, the only site restoration costs included are for the



demobilization and transportation of the recovery equipment, estimated at 2 man weeks for the pilot study



and 4 man weeks for the full-scale study.





                                                3-14

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                             4.0  TREATMENT EFFECTIVENESS

This section addresses the effectiveness of the EDA lead recovery technology for treating soil
contaminated with lead. Because the SITE demonstration provided extensive data on the EDA
technology, the evaluation of the technology's effectiveness is based primarily on the demonstration
results.  This section provides an overview of the evaluation procedures and sampling/analytical
methods; summarizes the evaluation objectives, and results; presents the conclusion of the EDA lead
recovery treatment evaluation; and briefly discusses the data quality. Vendor claims regarding the
treatment effectiveness of the EDA lead recovery technology are included in the appendix.

4.1    BACKGROUND

The EDA lead recovery technology  was evaluated in two phases. Phase I was conducted from August 8
to September 28, 2001. Phase II was conducted from April 1 to July 22, 2002. During Phase I of the
evaluation, pre-treatment soil samples were collected and analyzed for lead.  Three bins (1, 2, and 4)
were treated during the evaluation.  Bin 1 was treated and sampled during Phase I, and bins 2 and 4 were
treated and sampled during Phase II.

4.1.1   Site Description

The system was set up and maintained by EDA.  Soil to be treated was characterized by AMEC based
during the RI.  The volume and extent of soil requiring remediation was defined during the EE/CA for
the subject site (Ogden 1995, 1996); and by Tetra Tech during pre-treatment sampling for the proposed
in-situ technology evaluation.  Tetra Tech excavated approximately 20 cubic yards of soil to fill the five
treatment bins  for this demonstration; however, only three of the five bins were treated due to
PACNAVENGCOM funding limitations.
                                              4-1

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4.1.2   Evaluation Objectives and Approach

Primary objectives were considered critical for evaluating the lead recovery technology. The primary
objectives (P) of the SITE demonstration were to validate EDA's performance claims for the technology.
These objectives focused on the ability of the lead recovery technology to remove the lead from the soil.
Three primary objectives were selected for the SITE evaluation as follows:

               PI     Determine if the technology is able to reduce soil lead concentrations to less than
                      the regulatory threshold limit of 2,000 mg/kg
               P2     Determine the removal efficiency of the EDA technology for lead within the soil
                      treatment bin
               P3     Determine whether the post-demonstration soil meets the RCRA landban
                      standards of 5.0 milligrams per liter (mg/L) for TCLP lead concentrations

Secondary objectives (S) provided additional information that was useful, but not critical, for the
evaluation ofthe lead recovery technology. The secondary objectives of the demonstration were to
collect and evaluate data that are useful in assessing system performance, cost, and applicability to other
sites.  Three secondary objectives were selected forthe SITE evaluation as follows:

               SI     Evaluate the mass of lead recovered by the ESMS and estimate the recovery
                      efficiency ofthe ESMS.
               S2     Document specific EDA system operation and maintenance parameters.
               S3     Estimate capital and operating costs for constructing a full-scale EDA system.

4.2    EVALUATION PROCEDURES

4.2.1   Evaluation Preparation

Tetra Tech excavated soil from different portions ofthe site in order to have soil with varying lead
concentrations within each ofthe five proposed treatment batches.  The goal was to have two high
concentration batches, two medium concentration batches, and one low concentration batch.  High,
medium, and low concentrations are defined as the following:

                                              4-2

-------
       1 .       High Soil Lead Concentration:         1 00,000 to 1 50,000 mg/kg lead
       2.       Medium Soil Lead Concentration:      25,000 to 50,000 mg/kg lead
       3.       Low Soil Lead Concentration:         1 0,000 to 20,000 mg/kg lead

4.2.2   Evaluation Design

The data analysis, like the sampling plan, was designed to address the objectives of the project.  To
evaluate the data, descriptive statistics, statistical tests, or construction of confidence intervals were used
to evaluate the populations from which the samples were collected. Descriptive statistics included
calculation of the range, upper and lower values, mean, median, and variance.

PI     Determine if the technology is able to reduce soil lead concentrations to less than the
        regulatory threshold limit of 2,000 mg/kg.

Twelve post-demonstration samples were collected from within each treatment batch. Samples were
analyzed for total lead and the data was used to determine the post-treatment lead concentration in each
sub-cell; concentrations were not averaged to obtain a mean concentration of lead within each grid-cell
column. All samples must exhibit analytical lead concentrations less than 2,000 mg/kg, for the
technology to be considered successful in removing lead from contaminated soils.

P2     Determine the removal efficiency of the EDA technology for lead within the
       treatment tank.

Twelve pre-treatment samples were collected from within the treatment tank.  Samples were analyzed for
total lead and the data were used to estimate the pre-treatment lead concentration in each sub-cell. The
data was combined with the post-treatment data obtained for primary objective PI  in order to provide a
total of 12 data pairs (before and after treatment lead concentrations for each sampled sub-cell). The RE
of each sub-cell was calculated according to the following formula:

                                     RE=  pre~
                                               pre
                                              4-3

-------
Where:
       RE    =      Removal efficiency (%)
       Cpre    =      The concentration of lead in each sub-cell within a pre-treatment grid-cell
                     column
       Cpost   =      The concentration of lead in each sub-cell within a post-treatment grid-cell
                     column

The laboratory reporting limit for lead in soil is 10 mg/kg. Given that the soil used for this demonstration

has previously been characterized as possessing very high lead concentrations, it was unlikely that many

results below this reporting limit would be obtained.


P3     Determine whether the post-demonstration soil meets the RCRA landban standards for
       TCLP lead concentrations.


To determine whether the TCLP lead concentrations in the post-demonstration samples meet RCRA

landban standards, post-demonstration samples were compared to the TCLP regulatory limit of 5.0 mg/

L. A successful result required that all TCLP extracts are below 5.0 mg/L.


SI     Determine the mass of lead recovered by the ESMS and estimate the recovery efficiency of
       the ESMS.


The mass of lead removed by the system was determined by summing the weight of all metal

electroplated out of solution for each test run and analyzing a composite sample of the metal for lead

purity. Based on the weight of the plated out metal and its purity (lead concentration), the mass of solid

lead removed is calculated for  each test run. The mass of solid lead removed from the ESMS was
calculated using the following  equation:

                                       Mp= WxC

Where:
       Mp    =      Calculated mass of solid lead plated out from the ESMS
       W     =      Total weight of metal removed from the ESMS
       C      =      The purity of lead in the composite metal sample


In addition, the recovery efficiency of the ESMS was estimated.  Samples of electrolyte solution were

collected before the electrolyte solution entered the ESMS, and after the electrolyte solution exited the
                                             4-4

-------
ESMS.  The concentrations of lead in solution entering and exiting the ESMS were used to estimate the
recovery efficiency of the ESMS.

The recovery efficiency for each sampling event was calculated using the following equation, which was
based on concentration since the flow volume in and out of the ESMS is the same:
                                 RCE.=
                                      1       C
                                               influentj
Where:
       RCE   =      Recovery efficiency (%)
       Qnfiuent  =      Concentration of lead in the influent stream composite sample
       Ceffiuent  =      Concentration of lead in the effluent stream composite sample
       i       =      {1,2, ...,m} and mis the total number of sampling events
4.2.3   Sampling Methods

Each treatment tank was subdivided into 18 4-foot grid-cells and each grid-cell was assigned a unique
number from 1 to 18. The sampling program for each treatment tank or batch included collecting
samples from 6 of the 18 grid-cells. A single sampling location near the center of six randomly selected
grid-cells was used to collect the pre-treatment samples.  The total treatment depth was 4 feet; therefore,
2-foot core samples were collected from each 1-foot by 2-foot interval, or sub-cell, within each grid-cell.
Each 2-foot core sample was fully homogenized in the field and then submitted to the laboratory for total
lead analysis on a dry weight basis. The lead concentration measured in each sample represented the
lead concentration for that sub-cell.

Post-treatment samples were collected as close to the proximity of the pre-treatment sample locations as
possible. This variance was due to health and safety risks caused by sampling too close to the edge of the
treatment bin siding. In treatment bin 1, post-treatment sample 9 was collected from grid-cell 8, post-
treatment sample 12 was collected from grid-cell 11, and post-treatment sample 15 was collected from
grid-cell 12. In treatment bin 2, post-treatment sample 9 was collected from grid-cell 8, post-treatment 12
was collected from grid cell 11, and post-treatment sample 15 was collected from grid-cell 12. In
                                              4-5

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treatment bin 4, post-treatment sample 9 was collected from grid-cell 8, post-treatment sample 12 was
collected from grid-cell 11, and post-treatment sample 15 was collected from grid-cell 12.

The same homogenization procedures were conducted for the post-demonstration samples to obtain a
representative sample for each sub-cell after the demonstration. The data were used to determine if post-
treatment lead concentrations within the treatment zone were less than the regulatory threshold and to
determine the removal efficiency for lead within the treatment zone.

Separate post-treatment soil samples were collected from randomly-selected grid-cells within the
treatment zone and analyzed for TCLP lead.  These data were used to evaluate whether post-treatment
TCLP lead concentrations meet RCRA landban regulatory criteria.

Electroplated Metal Weighing and Sampling

The total mass of metal electroplated out of the electrolyte solution was determined each time the
electroplated metal was removed from the electrochemical cells for disposal. Prior to and after each
batch treatment, each substrate was weighed and the weights recorded.  After each batch treatment, the
metal on each substrate was manually removed by EDA.  The recovered lead was weighed directly. In
general, 1 to 3 kilograms (kg) was recovered from each effort.  Recovered material was kept in a tared
container and allowed to dry for at least 18 hours before weighing. The lead scrapings were then placed
in a container labeled with the date and the mass recovered. At the end of the project, all individual
containers were emptied into lined, 5-gallons pails, and transported to a lead recycling facility. A sample
of the metal removed from the substrates (approximately 5-10 grams) was collected and composited in a
glass jar. The composite sample of metal was analyzed to determine lead purity, and the mass of lead
recovered by the ESMS was calculated for Treatment Bin 4. The composite sample of lead for bins 1
and 2 was not completed in the field.

Electrolyte Solution Sampling

A small volume of electrolyte solution was extracted from the electrolyte streams entering and exiting the
ESMS on a 4-hour interval and composited over each batch run Electrolyte solution was extracted from
both streams using an in-line automatic sampling device. Volumes extracted from each stream were

                                              4-6

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composited separately in two separate holding containers. For each batch run, a representative grab
sample was collected from each electrolyte solution composite batch. Samples were submitted to the
laboratory and analyzed for total lead Recovery efficiencies were calculated for each sampling event
and an averaged total for each treatment batch.

4.2.3.1 Total Lead Analysis

Total lead analysis was determined bylCP-AES analysis in accordance with EPA SW-846 method
6010B.  Soil samples and electrolyte solution samples were analyzed for lead only.

4.2.4  Quality Assurance and Quality Control Program

The overall QA objective for this evaluation was to produce well-documented data of known quality.
Quality was measured by monitoring data precision and accuracy, completeness, representativeness,
comparability, and reporting limits for the analytical methods.  All laboratory data met the quality control
criteria specified in the QAPP.

4.2.4.1 Field Quality Control Program

Field QC checks were collected to determine the quality of field activities, including sample collection,
homogenization, handling, and shipment. In general, the QC checks assessed the representativeness  of
the samples and ensured that the degree to which the analytical data was representative of actual site
conditions was known and documented. Field QC checks consisted of equipment blanks, field blanks,
and field sample duplicates.

4.2.4.2 Laboratory Quality Control Checks

Laboratory QC checks were designed to determine analytical precision and accuracy, demonstrate the
absence of interferences and contamination from glassware and reagents, and ensure the comparability of
data. Laboratory QC checks consisted of laboratory control sample/ laboratory control sample duplicates
(LCS/LCSD), method blank samples, matrix spike/matrix spike duplicates (MS/MSD) samples, and other
checks specified in the methods section of the QAPP. The laboratory also completed the initial

                                              4-7

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calibrations and continued throughout the process with calibration checks. Laboratory internal QC
checks for critical parameters are summarized on a method-specific basis in the QAPP.

4.2.4.3 Field and Laboratory Audits

For this project, an internal te chnical  systems audit (TS A) of field sampling and measurements systems
was not conducted. The field audit conducted during the pre-treatment sampling event for the originally
planned in-situ demonstration. Since the sampling and measurement methods for the proposed ex-situ
demonstration are generally the same, the first field audit was considered adequate. The field audit was
conducted by Dr. Greg Swanson, Tetra Tech's SITE QA Manager. Recommendations made by Dr.
Swanson based on audit observations were implemented during the sampling events, or by modification
to the QAPP. No significant findings were identified in the field audit.

Tetra Tech conducted laboratory audit of Severn Trent on May 10 and 11, 1999. Mr. John Schendel, the
project chemist, performed the audit. No significant findings were identified. Nine minor observations
were documented and discussed with laboratory staff. Appropriate corrective action was taken in
response  to all observations noted in the audit report.

4.3    EVALUATION RESULTS AND CONCLUSIONS

This section presents the performance data gathered for this evaluation by the testing methodology
described above. The data analysis procedures  and results associated with each of the project objectives
are presented.
                                             4-8

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                                                   Table 4-1: Treatment Bin 1
SAMPLE DEPTH INTERVAL
& ANALYSIS
Depth
(bts)
Oto2
2 to 4
Analysis & Results
Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

GRID-CELL NUMBER
4
Pre
20,100
8.1
NA
15.8
Post
15,400
71.5
NA
16.8
4,700
23.4

17,000
7.4
NA
13.9

10,800
73.8
NA
17.7
6,200
36.5


6
Pre
17,300
NA
NA
15.1
Post
5,770
NA
NA
17.6
11,530
66.6

19,200
NA
17,500
16.7

9,540
NA
8,990
18.8
9,660
50.3


11
Pre
18,500
7.6
NA
15.0
Post*
6,620
35.0
NA
17.4
11,880
64.2

17,000
7.8
NA
17.1

8,990
76.8
NA
16.6
8,010
47.1


14
Pre
19,600
NA
NA
15.0
Post
9,390
NA
NA
18.2
10,210
52.1

15,400
NA
19,000
16.2

10,100
NA
8,930
16.5
5,300
34.4


16
Pre
14,600
NA
NA
18.9
Post
13,300
NA
NA
21.4
1,300
8.9

17,600
NA
NA
21.8

9,740
NA
NA
20.8
7,860
44.7


18
Pre
18,000
8.5
NA
16.5
Post
8,620
105.0
NA
26.0
9,380
52.1

19,600
9.8
NA
17.0

9,110
88.2
NA
20.1
10,490
53.5


Notes:
bts       Below top of surface
mg/kg    Milligram per kilogram
mg/L     milligram per liter
TCLP    Toxic Characteristics Leaching Procedure
Dup      Duplicate
Pre      Pre-treatment sample
Post     Post-treatment sample
NA       Not analyzed

* Post Treatment sample 12 was taken from grid-cell 11 due to safety issues.
                                                                4-9

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                                                   Table 4-2: Treatment Bin 2
SAMPLE DEPTH INTERVAL
& ANALYSIS
Depth
(bts)
Oto2
2 to 4
Analysis & Results
Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

GRID-CELL NUMBER*
1
Pre
18500
7.5
NA
15.2
Post
3,720
25.1
NA
18.0
14,780
79.9

23300
7.3
NA
12.6

5,940
23.8
NA
20.8
17,360
74.5


2
Pre
19,600
NA
NA
11.8
Post
9,460
NA
NA
20.2
10,140
51.7

36,500
NA
32,800
16.8

7,060
NA
4,350
21.3
29,440
80.7


8
Pre
19,600
8.2
NA
13.6
Post*
19,200
78.9
NA
21.8
400
2.0

26,800
6.8
NA
17.5

12,600
86.4
NA
31.2
14,200
53.0


14
Pre
23,700
NA
NA
15.8
Post
41,500
NA
NA
7.8
-17,800
-75.1

26,500
NA
27,200
16.2

7,020
NA
8,110
8.0
19,480
73.5


12
Pre
13,600
NA
NA
10.8
Post*
15,400
NA
NA
13.6
-1,800
-13.2

37,400
NA
NA
16.7

10,900
NA
NA
14.5
26,500
70.9


15
Pre
12,100
8.0
NA
12.7
Post
10,200
74.2J
NA
11.7
1,900
15.7

12,600
9.4
NA
11.7

8,980
117J
NA
19.4
3,620
28.7


Notes:
bts       Below top of surface
mg/kg    Milligram per kilogram
mg/L     milligram per liter
TCLP    Toxic Characteristics  Leaching Procedure
Dup      Duplicate
Pre      Pre-treatment sample
Post     Post-treatment sample
NA       Not analyzed

* Post treatment sample 9 was taken from grid-cell 8 and Post Treatment sample 15 was
taken from grid-cell 12 due to safety issues.
                                                               4-10

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                                                   Table 4-3: Treatment Bin 4
SAMPLE DEPTH INTERVAL
& ANALYSIS
Depth
(bts)
Oto2
2 to 4
Analysis & Results
Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

Lead (mg/kg)
TCLP (mg/L)
Dup (mg/kg)
moisture (%)
Lead Reduction
Removal Efficiency

GRID-CELL NUMBER
1
Pre
8270
5.4
NA
6.7
Post
2,080
1.6
NA
12.7
6,190
74.8

24300
10.6
NA
12.2

5,870
2.3
NA
17.9
18,430
75.8


9
Pre
53,900
NA
NA
17.0
Post
2,620
NA
NA
11.2
51,280
95.1

82,300
NA
42,500
16.3

12,100
NA
8,180
21.4
70,200
85.3


12
Pre
21,100
9.3
NA
11.2
Post*
6,390
2.9
NA
13.7
14,710
69.7

43,100
15.3
NA
17.4

9,070
13.5
NA
16.6
34,030
79.0


14
Pre
18,400
NA
NA
11.9
Post
3,630
NA
NA
13.6
14,770
80.3

35,100
NA
45,600
15.1

16,200
NA
7,580
15.8
18,900
53.8


15
Pre
21,000
NA
NA
13.1
Post
2,520
NA
NA
13.3
18,480
88.0

23,300
NA
NA
13.3

1,880
NA
NA
9.2
21,420
91.9


17
Pre
23,100
13.9
NA
12.3
Post
2,100
0.6
NA
10.6
21,000
90.9

30,500
13.1
NA
14.9

3,600
1.7
NA
14.2
26,900
88.2


Notes:
bts      Below top of surface
mg/kg   Milligram per kilogram
mg/L    milligram per liter
TCLP   Toxic Characteristics Leaching Procedure
Dup     Duplicate
Pre     Pre-treatment sample
Post    Post-treatment sample
NA      Not analyzed

* Post Treatment sample 15 was taken from grid-cell 12 due to safety issues.
                                                               4-11

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4.3.1   Primary Objectives

To assess all of the primary objectives, 12pre-treatment and post-treatment soil samples, from each of
the three treatment bins, were collected and analyzed by EPA Method 601 OB for total lead and TCLP.
Details of the primary objective relating to the soil lead treatment efficiency are described below.

PI     Determine if the technology is able to reduce soil lead concentrations to less than the regulatory
       threshold limit of 2,000 mg/kg.

The primary objective was address by comparing the post-treatment soil samples for Total Lead to the
regulatory threshold of 2,000 mg/kg.  Twelve post-demonstration samples were collected from within
each treatment batch. In Treatment Bin 1, post-treatment soil samples ranged from 5,770 mg/kg to
15,400 mg/kg. In Treatment Bin 2, post-treatment soil samples ranged from 3,720 to 41,500 mg/kg. In
Treatment Bin 4, post-treatment soil samples ranged from 1,880 to 16,200 mg/kg (see Table 4-4). One of
the post-treatment soil samples collected from the Treatment Bin 4 met the regulatory threshold. The
average post-soil lead concentration for each bin was 17,285 mg/kg for Bin 1, 22,517 mg/kg for Bin 2,
and 5,672 mg/kg for Bin 4.

Because the treatment goal was not achieved for 17 of the 18 post-treatment grid-cells, the primary
objective was not met.
                       Table 4-4Results for Lead using EPA Method 6010B
Treatment Bin
Number
1*
2*
4**
Post-Treatment Range
(mg/kg)
5,770 to 15,400
3,720 to 41,500
1,880 to 16,200
Grid-cells Meeting
Regulatory Threshold
(2,000 mg/kg)
Oof 6
Oof 6
1 of 6
               Notes:
                              Bin 1 and 2 was flushed with an EDTA solution originaly mixed at 0.1M
                              Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution.
                                             4-12

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P2
Determine the removal efficiency of the EDA technology for lead within the treatment tank.
The second primary objective was to determine the treatment efficiency of the EDA lead recovery
technology for lead in the soil samples. The EDA lead recovery treatment process removed an average of
59 percent lead for all three bins. Bins 1 and 2 were treated with an EDTA solution witha 0.1M. Bin 4
was treated with an EDTA solution with an increased molarity of 0.2.  In Bin 4, nine cycles were made,
an increased amount of flush cycles.  The average removal efficiency was lower in Bins 1 and 2, with
percentages of 44.5 and 51.6, respectively.  The average removal efficiency for treatment Bin 4 was 81.1
percent (See Table 4-5).
                            Table 4-5 Average Removal Efficiencies
Treatment Bin
Number
1*
2*
4**
Pre-Treatment Range
(mg/kg)
14,600 to 20,100
12,100 to 37,400
8,270 to 82,300
Post-Treatment
Range (mg/kg)
5,770 to 15,400
3,720 to 41,500
1,880 to 16,200
Average Removal
Efficiency (%)
44.5
51.6
81.1
Notes:
               Bin 1 and 2 was flushed with an EDTA solution originally mixed at 0.1M
               Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution.
P3     Determine whether the post-demonstration soil meets the RCRA landban standards for TCLP
       lead concentrations.

To determine whether the TCLP lead concentrations in the post-demonstration samples meet RCRA
landban standard, the TCLP extract lead concentration in each of the four post-demonstration samples
from each batch were compared to the regulatory limit of 5.0 mg/L.  Of 18  cells in the 3 treatment bins,
only 5 of 6 grids from Bin 4 met the RCRA landban standards for lead by TCLP analysis. Bin 4 was
flushed with water extensively (600 gallons) in comparison to procedures used for the other two bins.
                                             4-13

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                              Table 4-6 Results for Lead using TCLP
Treatment Bin
Number
1*
2*
4**
Pre-Treatment Range
(mg/L)
7.4-9.8
6.8 - 9.4
5.4- 15.3
Post-Treatment
Range
(mg/L)
35- 105
23.8- 117
0.6- 13.5
Grid-cells Meeting
TCLP Threshold
(5 mg/L)
Oof 6
Oof 6
5 of 6
Notes:
               Bin 1 and 2 was flushed with an EDTA solution originally mixed at 0.1M
               Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution.
4.3.2   Secondary Objectives

Three secondary objectives were established to evaluate the lead recovery system.  The secondary
objectives are described below.

SI      Evaluate the mass of lead recovered by theESMS and estimate the recovery efficiency of the
        ESMS.

Due to missing composite metal samples from Treatment Bins 1 and 2, the purity of lead is unknown.
Thus, the mass of lead recovered for these bins could not be calculated.  The mass of lead recovered by
the ESMS was 12.8 kg  for Treatment Bin4 (see Table 4-7).

                       Table 4-7 Mass of Solid Lead Recovered by the ESMS
Treatment Bin
Number
1
2
4
Total Weight of Metal
Removed from the
ESMS (kg)
2.1
58
75.2
Purity of Lead
(mg/kg)
—
—
17%J
Mass of Solid Lead
Plated Out from the
ESMS (kg)
NA
NA
12.8
Notes:    J       Method blank contamination. The asso ciated method blank contains the target analyte at a report able level
        k§ „    kilogram
        mg/kg   milligram per kilogram
        —      missing sample data
        NA     not available
The recovery efficiency of the ESMS system has been calculated for each sampling event, during the
different flushing cycles (See Table 4-8).
                                                4-14

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Table 4-8 The Recovery Efficiency of the ESMS
Treatment
Bin
Number
1
2
4
Number
of
Cycles
1
1
2
3
4
5
5
5
1
1
1
2
2
3
3
3
3
3
3
3
3
3
4
Electrolyte
Solution
Entering Bin
(|tg/L)
159,000
197,000
1,310,000
402,000
991,000
124,000


20,100 L


269,000
340,000









4,320,000
Concentrati
on of Lead
in the
Influent
Stream
(|tg/L)
179,000
1,390,000
1,250,000
432,000
873,000
261,000 L
440,000 L
532,000 L
307,000
415,000
914,000

262,000
8,640,000
7,630,000
9,050,000
7,500,000
7,350,000
6,290,000
5,670,000
4,960,000
6,320,000

Concentratio
n of Lead in
the Effluent
Stream
(|tg/L)
154,000
1,290,000
1,190,000
509,000
1,150,000
422,000 L
344,000 L
390,000 L
388,000
286,000
265,000

369,000
8,580,000
7,550,000
8,350,000
7,360,000
7,300,000
6,320,000
5,590,000
4,890,000
7,700,000

Recovery
Efficiency
(%)
14.0
7.2
4.8
-17.8
-31.7
-61.7
21.8
26.7
-26.4
31.1
71.0

-40.8
0.7
1.1
7.7
1.9
0.7
-0.5
1.4
1.4
-21.8

Average
Total
Recovery
Efficiency
(%)
14.0






-7.2















                     4-15

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Table 4-8 The Recovery Efficiency of the ESMS
Treatment
Bin
Number
4
Number
of
Cycles
4
4
4
4
4
5
5
5
5
5
5
6
6
6
6
6
7
7
8
8
9
9
9
Electrolyte
Solution
Entering Bin
(|tg/L)
4,310,000




2,990,000





860,000 J
1,230,000 J



514,000 J
514,000 J


579,000 J
706,000 J

Concentrati
on of Lead
in the
Influent
Stream
(|tg/L)
6,120,000
5,670,000
4,510,000
4,080,000
3,200,000
5,110,000
4,690,000
582,000 J
804,000 J
676,000 J
772,000 J

659,000 J
646,000 J
497,000 J
527,000 J

818,000 J
603,000 J
277,000 J

530,000 J
998,000 J
Concentratio
n of Lead in
the Effluent
Stream
(|tg/L)
5,950,000
5,120,000
4,550,000
3,680,000
3,120,000
5,470,000
4,370,000
664,000 J
857,000 J
580,000 J
91 1,000 J

453,000 J
526,000 J
612,000 J
665,000 J

911,000 J
525,000 J
805,000 J

154,000 J
847,000 J
Recovery
Efficiency
(%)
2.8
9.7
-1.0
9.8
2.5
-7.1
6.8
-14.1
-6.6
14.2
-18.0

31.3
18.6
-23.1
-26.2

-11.4
12.9
-190.6

70.9
15.1
Average
Total
Recovery
Efficiency
(%)























                      4-16

-------
                      Table 4-8 The Recovery Efficiency of the ESMS
Treatment
Bin
Number
4
Number
of
Cycles
9
9
10
10
10
10
10
10
Electrolyte
Solution
Entering Bin
(|tg/L)


439,000 J
562,000 J




Concentrati
on of Lead
in the
Influent
Stream
(fig/L)
743,000 J
795,000 J

179,000 J
11 7,000 J
42,800 J
37,200 J
91,400 J
Concentratio
n of Lead in
the Effluent
Stream
(|tg/L)
692,000 J
71 1,000 J


239,000 J
48,500 J
214,000 J
53,400 J
Recovery
Efficiency
(%)
6.9
10.6


-104.3
-13.3
-475.3
41.6
Average
Total
Recovery
Efficiency
(%)







-15.6
Notes:   L       Serial dilution of a digestate in the analytical batch indicates that physical and chemical interferences are present
       |ig/L    micrograms per liter
       J       method blank contaminat ion. The associ ated method b lank contai ns the target an alyte at a reportab le level


S2     Document specific EDA system operation and maintenance parameters.


During the technology demonstration, the vendor collected and recorded data to monitor the proper
operation and maintenance parameters of the technology.  The operating parameters are those parameters
that can be varied during the treatment process to achieve desired results and treatment goals.  EDA
claims the ETU system is able to run reliably with one daily visit requiring about 2 hours  on-site.  The
principal factor affecting the lead recovery system performance is the rate lead is plated out of the soil
and the maximum current used without causing other limitations to the system.


A normal amount or maintenance and repair activities of the system were performed during the SITE
demonstration, requiring approximately 4 hours weekly. Spare parts included:  replacement pumps,
solenoid valves, motor valves, signal conditioners, and SSRs. Between one or two of each item was
necessary to have on-site to minimize the replacement time to the system.  Minor leakages in plumbing
systems were expected and encountered, requiring small amounts of time for repair.
                                              4-17

-------
Maintenance of a full-scale system is estimated to require 8 hours weeMy. This estimate is based on the
assumption that the design of parts of the system that caused frequent shutdowns during the SITE
demonstration, such as bladders and float switches, would be modified to eliminate problems.

 S3    Estimate capital and operating costs for constructing a full-scale EDA system.

A detailed discussion of costs is included in Section 3.0 of this report.

4.3.3   Data Quality

A data quality review was conducted by Tetra Tech to evaluate the field and laboratory QC results,
evaluate the implications of QC data on the overall data quality, document data use limitations for data
users, and remove unusable values from the demonstration data sets. The results of this review were
used to produce the final data sets used to assess the treatment technology and to draw conclusions.  The
QC data were evaluated with respect to the QA objectives defined in the project quality assurance project
plan (QAPP [Tetra Tech 2001]).

The analytical data for the samples collected during the SITE demonstration were reviewed to ensure that
they are scientifically valid, defensible, and comparable. A data quality review was conducted using both
field QC samples and laboratory QC samples.  The field QC samples included field blanks, rinseate
blanks, trip blanks, MS/MSD, and sample duplicates.  Laboratory QC checks included laboratory blanks,
surrogate spikes, and LCS/LCSD. Initial and continuing calibration results were also reviewed to assure
the quality of the data and that proper procedures were used.  The review focused on assessing the
precision, accuracy, completeness, representativeness, and comparability of the data. In addition to the
above QC checks, reviews of sample chains of custody, holding times, and critical parameter
identification and quantification were performed.  All laboratory data met the quality control criteria
specified in the QAPP. Please refer to the Technology Evaluation Report for data tables that present
analytical results for field QC samples and MS/MSD results.
                                              4-18

-------
4.3.4   Conclusions

The primary evaluation objectives were to determine whether the lead recovery technology removed lead
from soil, and if so, how efficiently they were moved.

       •       Approximately six percent of the total post-treatment soil samples met the regulatory
               threshold lead concentration of 2,000 mg/kg or less (1 of 18 post treatment samples).
       •       The average lead removal efficiency was 59 percent for all three bins.  Due to variations
               in the treatment process for Bin 4, which included changing the concentration of the
               EDTA solution and extensively flushing the soil with water, the removal efficiency was
               81 percent.
       •       TCLP lead concentrations did not meet the RCRA landban standard of the 5.0 mg/L for
               samples collected from Bin 1 and Bin 2  due to adsorption of the Pb-EDTA2" complex to
               soil particles during infiltration. Extensive flushing of water in Bin 4 effectively
               removed sorbed solution, which resulted in a reduction in TCLP lead concentrations and
               attainment of the RCRA landban standard.
                                             4-19

-------
                                5.0 TECHNOLOGY STATUS

The EDA lead recovery system SITE demonstration was modified several times over the history of the
project.  Data obtained from the demonstration allowed EDA to continue the engineering development
for electrokinetic remediaiton. This will enhance the speed of the EDA lead recovery system.  EDA has
a goal of treating one ton of soil per hour.

Site information pertinent to electrokinetic remediation includes the following:

General Information

1.      Contaminated area size and depth
2.      Utilities layout
3.      Soil type and moisture content profile

Chemical information

1.      Contaminant type
2.      Contaminant concentrations and distribution
3.      Soil permeability

Other information

1.      Maximum amount of electrical current
2.      Surface area of electrode plates

At this time, the recovery process is not available on the open market.
                                             5-1

-------
                                     6.0 REFERENCES

Acar, Y.B.; Alshawabkeb, A; Gale, RJ. Waste Management, 13, 141, 1993

Acar, Y.B.; Alshawabkeb, A.; Hamed, J.; Gale, R.J., "Cd(II) Removal From Saturated Kaolinite by
       Application of Electrical Current," Geotechnique, 44(3), pp 239-254, 1994.

ECHOS, Environmental Cost Handling Options and Solutions. 2001.  "Environmental Remediation Cost
       Data - Assemblies."  R.S. Means Company and Talisman Partners, Ltd. 7th Annual Edition.

ECHOS, Environmental Cost Handling Options and Solutions. 2001.  "Environmental Remediation Cost
       Data - Unit Price." R.S. Means Company and Talisman Partners, Ltd. 7th Annual Edition.

Freeze, R., A., and J. A., Cherry.  1979.  Water. Prentise-Hall, Inc. p. 60.

Geokinetics International, Inc. (Gil). 1998a. "Bench Scale Electrokinetics Remediation Study. The
       Electrokinetic Removal of Lead from the Soil of Building 3 94 Battery Shop at Pearl Harbor".
       Produced for Ogden  Environmental and Energy Services Co., Inc.  April.

GIL  1998b. Personal Communication between Dr. Steven Clarke, President of Gil, and Bob Breglio,
       Tetra Tech.

GIL  2002. Personal Communication between Scott Stevenson of Gil, and Lauren Loberg of Tetra Tech.

Gray, D.H., and Mitchell, J.K., "Fundamental Aspects of Electro-Osmosis in  Soil," Journal of the Soil
       Mechanics and Fundamental Division, ASCE, SM 6, pp. 206-236, 1967.

Hamed, J.; Acar, Y.B.; Gale, R.J., "Pb(II) Removal from Kaolinite by Electrokinetics," Journal of
       Geotechnical Engineering Division, ASCE, Vol. 117, No. 2, pp 241-271, 1991.

Ogden Environmental and Energy Services Company, Inc. (Ogden). 1995. "Remedial Investigation
       Report for Building 394, Pearl Harbor Naval Shipyard, Pearl Harbor, Hawaii".  Contract No.
       N62742-90-D-0019,  Contract Task Order (CTO) No. 0045.  September.

Ogden.  1996.  "Engineering Evaluation/Cost Analysis Report for Building 394 Battery Shop, U.S.
       Naval Shipyard, Pearl  Harbor, Hawaii."  Contract No. N62742-90-D-0019, CTO No. 018.
       February.

Pamuchu, S., and Whittle, J.K., "Electrochemical removal of Selected Heavy Metals From Soil,"
       Environmental Progress, AIChE, Vol. 11, No3,pp 241-250, 1992.

Renaud, P.C.; Prostein, R.F.,PCH,Physiochemical. Hydrodynamics. 1987, 9, 345.

Tetra Tech EM Inc. (Tetra Tech). 1997a. "Results of Characterization Sampling at the Building 394 Site
       for the SITE Demonstration of the Geokinetics International Inc. Electrokinetics Soil
       Remediation Technology." Contract No. 68-C5-0037, Work Assignment (WA) No. 0-27.
       September.

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Tetra Tech. 1998.  "Results of the Geotechnical Sampling at the Building 394 Site for the SITE
Demonstration of the Geokinetics International, Inc. Electrokinetics Soil Remediation
Technology." Contract No. 68-C5-0037, Work Assignment No. 0-27. November.

Tetra Tech. 1999. "Health and Safety Plan; Geokinetics International, Inc. Electrokinetics
       Technology Evaluation at the Building 394 Battery Shop, Pearl Harbor Naval Shipyard,
       Honolulu, Hawaii." Contract No. 68-C5-0037, Work Assignment No. 0-27. January.

U.S. Environmental Protection Agency (EPA). 1996.  Test Methods for Evaluating Solid Waste,
       Volumes IA-IC: Laboratory Manual,Physical/Chemical Methods; and Volume II:  Field Manual,
       Physical/Chemical Methods, SW-846, Third Edition, Revision IV. Office of Solid Waste and
       Emergency Response, Washington, D.C.

EPA. 1998. Methods for Chemical Analysis of Water and Wastes. EPA-600/4-79-020 and
       Subsequent EPA-600/4 Technical Additions. Environmental Monitoring and Support
       Laboratory, Cincinnati, Ohio.

EPA. 1998a. Guidance for Data Quality Assessment.  EPA QA/G-9, EPA/600/R-96/084. January.

EPA. 1991. Preparation Aid for the Development of Category II Quality Assurance Project Plans.
       Office of Research and Development. EPA/600/8-91/004

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