United States
Environmental Protection
Agency
Office of
Research and Development
Cincinnati, OH 45268
EPA/540/R-502a
July 2004
&EPA
MINE
WASTE
TECHNOLOGY
PROGRAM
Stabilization of Mercury in
Waste Material from the Sulfur
Bank Mercury Mine
Innovative Technology Evaluation Report
EPA DOE Moncana Tech impMnwnlBd by MSŁ Tucftnotogy Applications, loc.
SUPERFUND INNOVATIVE
TECHNOLOGY EVALUATION
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EPA/540/R-04/502
July 2004
Stabilization of Mercury in Waste
Material from the Sulfur Bank Mercury
Mine
Innovative Technology Evaluation Report
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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Notice
The information in this document has been funded by the U.S. Environmental Protection Agency
(EPA) under Contract Nos. 68-C5-0036 and 68-COO-179 to Science Applications International
Corporation (SAIC). 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 or recommendation for use.
11
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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 support and 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 (NRMRL) is the Agency's center for investigation of
technological and management approaches for preventing and reducing risks from pollution that threaten
human health and the environment. The focus of the Laboratory's research program is on methods and their
cost-effectiveness for prevention and control of pollution to air, land, water, and subsurface resources;
protection of water quality in public water systems; remediation of contaminated sites, sediments and
ground water; prevention and control of indoor air pollution; and restoration of ecosystems. NRMRL
collaborates with both public and private sector partners to foster technologies that reduce the cost of
compliance and to anticipate emerging problems. NRMRL's research provides solutions to environmental
problems by: developing and promoting technologies that protect and improve the environment; advancing
scientific and engineering information to support regulatory and policy decisions; and providing the technical
support and information transfer to ensure implementation of environmental regulations and strategies at
the national, state, and community levels.
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.
Lawrence W. Reiter, Acting Director
National Risk Management Research Laborator
in
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Abstract
This report summarizes the findings of an extensive treatability study of three stabilization
technologies for mercury immobilization on materials collected from the Sulfur Bank Mercury Mine
(SBMM), located north of San Francisco, in Lake County, California. The SBMM site is believed to be
contaminating the adjacent Clear Lake environment with mercury derived from historic mining
practices at the site. The study was conducted as a joint effort between EPA's Superfund Innovative
Technology Evaluation (SITE) Program and the Mine Waste Technology Program (MWTP). Two
mercury contaminated materials were selected for treatment by three types of stabilization
technologies.
The purpose of the study was to determine the effectiveness of the three stabilization technologies for
immobilizing mercury in the waste rock materials and therefore reducing leachable mobile mercury in
the effluent. Several mercury-bearing materials from the site were considered for testing. A material
with high levels of leachable mercury was selected as the primary target of the study, and is referred
to as "Mercury Ore". As a secondary objective, treatment effectiveness was evaluated on material
that was lower in mercury concentration, but present in large quantities and is referred to as "Waste
Rock".
Three stabilization technologies were evaluated as part of this study: (1) a Silica Micro Encapsulation
(SME) process developed by Klean Earth Environmental Company (KEECO), (2) an inorganic sulfide
stabilization technology (ENTHRALL®' developed by E&C Williams, and (3) a generic phosphate
treatment.
The primary objective of this study was to determine the effectiveness of the three stabilization
technologies (silica encapsulation, phosphate, and sulfide) in reducing the quantity of leachable
mercury from SBMM material. Waste material evaluated in this study consisted of "mercury ore" from
the south white gate pile and "waste rock" from the north yellow pile. The mercury ore was the
primary test material due to its demonstrated ability to produce consistent and detectable levels of
leachable mercury. The waste rock was included because it is a common material at the site, even
though it yields lower levels of leachable mercury. In order to evaluate the performance of the three
technologies, the leachable and mobile mercury (defined as the mercury in the <25u filtered leachate
fraction) from control columns receiving no treatment was compared to the leachable and mobile
mercury in the treatment columns. Specifically, the objective was to achieve a 90% reduction in the
total mass of mercury leached from each treatment relative to the control over a 12-week continuous
column leaching study.
Leachability results from the no treatment control columns revealed that the predominant source of
leachable mercury was found in the particulate fraction, i.e. approximately 96%. The phosphate
treatment dramatically increased the levels of both the particulate and dissolved fractions (<0.45um)
over the course of the 12-week study. The dramatic rise in leachable mercury brought about by the
phosphate treatment invalidates its utility as a remedial alternative for materials at the SBMM site.
The E&C William's ENTHRALL® Technology did not appear to be effective in reducing the levels of
mobile mercury in the mercury ore column tests. The total mass of mercury in both the particulate
and dissolved fractions are statistically similar to the control. KEECO's Silica Micro Encapsulation
Technology applied both in situ and ex situ, was effective in reducing mobile mercury (<25 urn) very
close to the 90% reduction goal of the study. However, there was a significant increase in the mass
mercury levels in the dissolved fraction (<0.45um). The in situ applications exhibited a 198%
increase relative to the control, and the ex situ exhibited a 238% increase.
iv
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Contents
Notice ii
Foreword iii
Abstract v
Tables viii
Figures ix
Abbreviations and Acronyms x
Acknowledgement xii
Executive Summary xiii
1.0 Introduction 1-1
1.1 Background 1-1
1.1.1 Description ofthe SBMM Site 1-1
1.1.2 E&C Williams Enthrall® Technology 1-1
1.1.3 Kleen Earth Environmental Company Silica Micro Encapsulation (SME)
Process 1-2
1.1.4 Phosphate 1-3
1.2 Brief Description ofthe Superfund Innovative Technology (SITE) and Mine
Waste Technology (MWTP) Programs 1-4
1.3 The SITE Demonstration Program and Reports 1-4
1.4 Purpose of the Innovative Technology Evaluation Report (ITER) 1-5
1.5 Sources of Further Information 1-5
2.0 Technology Application Analysis 2-1
2.1 Key Features ofthe Stabilization Process 2-1
2.2 Operability ofthe Technology 2-2
2.3 Applicable Wastes 2-2
2.4 Availability and Transportability of Equipment 2-2
2.5 Materials Handling Requirements 2-2
2.6 Range of Suitable Site Characteristics 2-3
2.7 Limitations ofthe Technology 2-4
2.8 Applicable or Relevant and Appropriate Requirements (ARARs) for
Stabilization Processes 2-3
2.8.1 Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) 2-3
2.8.2 Resource Conservation and Recovery Act 2-5
2.8.3 Clean Air Act (CAA 2-5
2.8.4 Clean Water Act (CWA) 2-6
2.8.5 Safe Drinking Water Act (SDWA) 2-6
2.8.6 Occupational Safety and Health Administration (OSHA) Requirements.. 2-6
3.0 Economic Analysis 3-1
3.1 Introduction 3-1
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3.2 Cost Estimate Scope 3-1
3.3 Factors Affecting Estimated Cost 3-1
3.4 Issues and Assumptions 3-2
3.4.1 Site Characteristics 3-2
3.4.2 Design and Performance Factors 3-2
3.4.3 Financial Assumptions 3-2
3.5 Basis for Economic Analysis 3-2
3.5.1 Site Preparation 3-2
3.5.2 Permitting and Regulatory Requirements 3-2
3.5.3 Capital Equipment 3-2
3.5.4 Startup and Fixed Costs 3-3
3.5.6 Labor 3-3
3.5.6 Consumables and Supplies 3-3
3.5.7 Utilities 3-3
3.5.8 Effluent Treatment and Disposal 3-3
3.5.9 Residuals Shipping and Disposa 3-4
3.5.10 Analytical Services 3-4
3.5.11 Maintenance and Modifications 3-4
3.5.12 Demobilization/Site Restoration 3-4
3.6 Vendor Cost Estimates 3-4
3.6.1 E&C Williams Enthrall® Technology 3-4
3.6.2 KEECO's SME Technology 3-7
3.7 Cost Summary 3-10
4.0 Treatment Effectiveness 4-1
4.1 Pre-demonstration Studies 4-1
4.1.1 SPLP Characterizations 4-1
4.1.2 Leachability Studies 4-2
4.1.3 Geochemical and Mineralogical Evaluation of Particulates 4-3
4.1.4 Extended Leachability Study 4-4
4.1.5 Conclusion From Leachability/Characterization Studies 4-5
4.1.6 Pre-Demonstration Kinetic Column Studies 4-6
4.2 Project Objectives 4-6
4.2.1 Primary and Secondary Objectives 4-6
4.2.1.1 Primary Objective 4-7
4.2.1.2 Secondary Objectives 4-9
4.3 Experimental Design 4-9
4.3.1 Column Studies 4-9
4.3.2 Humidity Cell Tests 4-11
4.3.3 Mineralogical and Geochemical Tests 4-11
4.3.4 Humic/Fulvic Acid Tests 4-11
4.4 Results 4-12
4.4.1 Kinetic Column Study Results 4-12
4.4.1.1 Column Studies on Mercury Ore Material - Primary Objective. 4-12
4.4.1.1.1 Control Column 4-15
4.4.1.1.2 Phosphate Treatment 4-16
4.4.1.1.3 E&C Williams Sulfide Treatment 4-17
4.4.1.1.4 KEECO In Situ and Ex Situ 4-18
4.4.1.2 Waste Rock Column Studies 4-20
4.4.2 Humidity Cell Tests 4-22
4.4.3 Synthetic Precipitation Leaching Procedure (SPLP) 4-23
4.4.4 Humic/Fulvic Acid Leaching Tests 4-23
4.4.5 Geochemical and Mineralogical Analyses 4-25
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4.5 Developer's Comments 4-25
4.5.1 E&C William's Comments 4-25
4.5.2 KEECO's Comments 4-25
5.0 Quality Assurance Summary 5-1
5.1 Introduction 5-1
5.2 Conclusions and Data Quality Limitations 5-1
vn
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Tables
Table
2-1 Potential Federal and State ARARs for Stabilization Remediation Processes 2-4
3-1 Labor Unit Costs 3-9
3-2 Cost Summary 3-10
4-1 SPLP Leachability Results from Various SBMM Materials 4-2
4-2 Replicate SPLP Analyses on Roasted Tailings 4-2
4-3 Results of Triplicate SPLP Leaching Experiment 4-3
4-4 Results from the Modified MWMP Leachate Test with Variable Filtration 4-3
4-5 Results from the Extended Leachability Study 4-5
4-6 Mercury in Untreated Mercury Ore and Waste Rock Materials 4-6
4-7 Kinetic Column Leachability Study 4-7
4-8 Treatability Study Test Parameters 4-8
4-9 Total Mass Mercury Leached from Mercury Ore Columns Over Twelve Weeks 4-13
4-10 Mercury Ore Leachability Results By Week 4-14
4-11 Weekly Average Mass Mercury Leached from Waste Rock Columns 4-21
4-12 SPLP Results for Mercury Ore and Waste Rock Material 4-23
4-13 Results from the Humic/Fulvic Acid Leaching Tests 4-24
5-1 Accuracy Data for Mercury for SBMM Column Leachates 5-1
5-2 Accuracy Data for Mercury for SBMM Extended Column Leachates 5-1
Vlll
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Figures
1-1 Features ofthe SBMM site 1-2
4-1 Locations of samples from SBMM site 4-1
4-2 Turbidity and leachable mercury from SPLP and MWMP tests 4-3
4.3 Mercury adsorbed on clay particles as indicated by the number of x-ray counts
adjusted by the sample 4-4
4-4 Comparison ofthe total mass mercury leached from the mercury ore columns 4-13
4-5 Dissolved and particulate leached Hg (mass) from mercury ore control columns 4-16
4-6 Turbidity vs. Hg for the <0.45um fraction - mercury ore control columns 4-16
4.7 Dissolved and particulate leached Hg (mass) from mercury ore phosphate columns.. 4-17
4-8 Dissolved and particulate leached Hg (mass) from mercury ore sulfide columns 4-18
4-9 Dissolved and particulate leached Hg (mass) from mercury ore KEECO
in situ columns 4-18
4-10 Dissolved and particulate leached Hg (mass) from mercury ore KEECO
ex situ columns 4-18
4-11 Turbidity vs. Hg for the <0.45um fraction - mercury ore, KEECO,
and control columns 4-19
4-12 pH of KEECO and control column effluents - mercury ore material 4-19
4-13 Turbidity vs. Hg for the <0.45,wm fraction waste rock phosphate column 4-20
4-14 Turbidity vs. Hg forthe <0.45^m fraction waste rock KEECO columns 4-22
4-15 Results from Humidity Cell tests on mercury ore material - <25um fraction 4-22
4-16 Results from Humidity Cell tests on mercury ore material - <0.45um fraction 4-22
4-17 Turbidity vs. Hg forthe <0.45um and <0.1um fractions -humic/fulvic
acid leaching tests 4-25
IX
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Abbreviations and Acronyms
AQCR Air Quality Control Regions
AQMD Air Quality Management District
ARARs Applicable or Relevant and Appropriate Requirements
ASTM American Society for Testing and Materials
CAA Clean Air Act
CCNY City College of New York
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CFR Code of Federal Regulations
CSCT Consortium for site characterization
CV Coefficient of variation
CWA Clean Water Act
Dl Deionized
DOE U.S. Department of Energy
ECWI E&C Williams Incorporated
EPA U.S. Environmental Protection Agency
FS Feasibility study
G&A General and administrative
HSWA Hazardous and Solid Waste Amendments
ICV Internal calibration verification
ITER Innovative Technology Evaluation Report
IM Interim measure
KEECO Kleen Earth Environmental Company
LCS Laboratory control sample
L/hr Liters per hour
mg/Kg Milligrams per kilogram
mg/L Milligrams per liter
mL Milliliter
MS/MSD Matrix spike/matrix spike duplicate
MWMP Meteoric Water Mobility Procedure
MWTP Mine Waste Technology Program
NA Not analyzed
NAAQS National Ambient Air Quality Standards
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NPDES National Pollutant Discharge Elimination System
NRMRL National Risk Management Research Laboratory (EPA)
NSCEP National Service Center for Environmental Publications
ND Non-detectable, or not detected at or above the method detection limit
NPDWS National primary drinking water standards
NTU Nephelometric turbidity unit
OSHA Occupational Safety and Health Administration
ORD Office of Research and Development (EPA)
OSWER Office of Solid Waste and Emergency Response (EPA)
PDI Prosonic Drilling Company
ppb Parts per billion
ppm Parts per million
ppmv Parts per million by volume
PPE Personal protective equipment
PQL Practical quantitation limit
PVC Polyvinyl chloride
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POTW Publicly owned treatment works
QA/QC Quality assurance/Quality control
QAPP Quality assurance project plan
RI/FS Remedial Investigation / Feasibility Study
RCRA Resource Conservation and Recovery Act
RPD Relative percent difference
RSD Relative Standard Deviation
SARA Superfund Amendments and Reauthorization Act
SAIC Science Applications International Corporation
SBMM Sulfur Bank Mercury Mine
SDWA Safe Drinking Water Act
SEM/EDS Scanning Electron Microscopy/Energy Dispersive Spectroscopy
SME Silica Micro Encapsulation
SVE Soil vapor extraction
SPLP Synthetic Precipitation Leaching Procedure
SW-846 Test methods for evaluating solid waste, physical/chemical methods
SWDA Solid Waste Disposal Act
SITE Superfund Innovative Technology Evaluation
S.U. Standard units
TCLP Toxicity Characteristic Leaching Procedure
TER Technology Evaluation Report
ug Micrograms
ug/L Micrograms per liter
urn Micron
UCL Upper confidence level
USEPA United States Environmental Protection Agency
USGS United States Geological Survey
w/w Weight to weight ratio
XRD X-ray diffraction
XRF X-ray fluorescence
XI
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Acknowledgments
This report was prepared under the direction of Mr. Edward Bates, the EPA Technical Project
Manager for this SITE demonstration, and Mr. Roger Wilmoth, Director of EPA's Mine Waste
Technology Program, both of the National Risk Management Research Laboratory (NRMRL) in
Cincinnati, Ohio. EPA review of this report was conducted by Diana Bless of USEPA and Dan
McMindes of USAGE.
The demonstration required the combined services of several individuals from MSE-Technology
Applications (MSE-TA), and Science Applications International Corporation (SAIC). Ms. Suzzann
Nordwick served as the project manager for MSE-TA. Dr. Scott Beckman of SAIC served as the
SITE work assignment manager for the implementation of treatability study activities and completion
of all associated reports. The treatability study was performed at MSE-TA's facility in Butte, Montana.
The cooperation and efforts of these organizations and individuals are gratefully acknowledged.
This report was prepared by Dr. Scott Beckman, Ms. Melissa Hammett, and Ms. Rita Stasik of SAIC.
Ms. Stasik also served as the SAIC Quality Assurance (QA) Coordinator for data review and
validation. Joseph Evans (the SAIC QA Manager) internally reviewed the report.
xn
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Executive Summary
Three innovative technologies for in situ stabilization of
heavy metals were demonstrated in a large-scale
treatability study performed on materials from the Sulfur
Bank Mercury Mine, a superfund site in northern
California. The treatability study was jointly sponsored by
two EPA programs; the Mine Waste Technology
Program (MWTP) and the Superfund Innovative
Technology Evaluation (SITE) Demonstration Program.
The purpose of the study was to determine the
effectiveness of these stabilization technologies for
immobilizing mercury in sulfide mine waste materials
such as those found at the Sulphur Bank Mercury Mine
(SBMM) site and therefore reduce the potential for
leaching and mobilizing mercury into the environment.
The SBMM is a non-operating facility located on the
South shore of Clear Lake in northern California where
some of the highest mercury concentrations in the world
have been recorded. Several mercury-bearing materials
from the site were considered for testing. A waste
material with high levels of leachable mercury (mercury
ore) was selected as the primary target of the study. As
a secondary objective, treatment effectiveness was
evaluated on a waste material that was lower in mercury
concentration, but present in large quantities (waste
rock).
Stabilization technologies use chemical reagents to
reduce the mobility of contaminants in a solid matrix.
The three processes used in the treatability study are:
(1) the Silica Micro Encapsulation (SME) process,
developed by Klean Earth Environmental Company
(KEECO) which encapsulates metals in an impervious
microscopic silica matrix, thus preventing metals in the
treated material from leaching into the environment, (2)
Enthrall®, developed by E&C Williams, Inc., which uses
an inorganic sulfide chemical to bind metals within the
matrix, and (3) a generic phosphate treatment that forms
insoluble phosphate salts containing the contaminant.
Since metal contaminants cannot be destroyed, each of
the selected technologies is targeted to inhibit the
release of mercury from the mine materials into the
environment.
The treatability study took place at the research facility of
MSE in Butte Montana, from November 15, 2000 to April
29, 2001. The primary test procedure was an in situ
kinetic column leach. The vendors each applied their
reagent to four-kilogram splits of each of the two test
materials that had been loaded into 3-foot PVC columns.
The SME technology was applied ex situ as well, and
then the treated material was loaded into the columns.
To evaluate each technology's ability to reduce the
amount of leachable mercury, single pass, low flow
leaching was performed for twelve weeks, with weekly
sampling for mercury and other constituents. The
primary objective of the study was for each technology to
achieve a 90% reduction in the mass of mobile mercury
in the leachate over the twelve week period, as
compared to untreated control columns receiving a water
leach. Several secondary studies were performed
along with the primary column study, including humidity
cell testing to simulate extreme weathering conditions,
and humic/fulvic acid leaching to simulate the effect of
high molecular weight organic constituents from
vegetative caps. Treated and untreated samples and
leachates were also analyzed to determine other
chemical characteristics and mineralogical changes due
to the treatments.
Conclusions from the study are summarized below:
• Pre-demonstration leachability studies revealed that
the dominant form of leachable mercury was in a
particulate and mobile form. These studies
indicated that leaching with a meteoric solution
released particulates that remained suspended in
solution and therefore could be mobile in a
groundwater and/or surface water hydraulic system.
Levels of dissolved mercury were low in these
leaching studies. Based on these tests, a
continuous column leaching test design was used to
collect effluent samples over a 12-week period to
evaluate leachable mercury in mobile (<25um) and
dissolved (<0.45um) fractions from treated and
control columns.
• The conventional phosphate treatment dramatically
increased the levels of mobile mercury (<25um
fraction) over the course of thel 2-week study in the
mercury ore columns. A 947% increase in the total
Xlll
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mass of mercury leached occurred relative to the
control.
E&C Williams' sulfide treatment did not appear to be
effective in reducing the levels of mobile mercury in
the mercury ore column tests. There was no
significant difference in the cumulative levels of
mobile mercury in the effluent from the sulfide
treatment relative to the control.
• KEECO's Silica Micro Encapsulation Technology
was effective in reducing mobile mercury (<25 urn)
very close to the 90% reduction goal of the study.
However, the dissolved mercury portion (<0.45um)
of the mobile fraction increased by approximately
200% relative to the control.
• A leachability test using humic and fulvic acids on
untreated mercury ore was performed to determine if
these organic acids would accelerate the release of
mercury from the waste material. A vegetative cap
may be used to reduce meteoric water infiltration,
and plant derived organic acids could impact
mercury leachability. Leaching with humic/fulvic
acids did not increase the generation of either
particulate or dissolved mercury under the
conditions of the test.
xiv
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Section 1.0
Introduction
This section provides background information about the
Superfund Innovative Technology Evaluation (SITE)
Program and the Mine Waste Technology Program
(MWTP), discusses the purpose of this Innovative
Technology Evaluation Report (ITER), describes the
Sulfur Bank Mercury Mine (SBMM) site, and describes
the technologies that were applied in the treatability
study on the SBMM materials. Key contacts are listed at
the end of this section for inquires regarding the SITE
and MWTP Programs, the technologies, and the site for
which the treatability study was conducted.
1.1 Background
A treatability testing program was conducted to
determine the effectiveness of in situ stabilization
technologies on controlling the release of mobile
mercury from the Sulfur Bank Mercury Mine in Lake
County, California. Three stabilization technologies
were evaluated during this study: (1) E&C Williams'
Enthrall® sulfide based treatment, (2) Kleen Earth
Environmental Company's (KEECO) Silica Micro
Encapsulation (SME) process, and (3) a generic
phosphate treatment. Pre-demonstration studies
identified suitable materials from the site for testing,
identified a potential mercury release mechanism, and
evaluated several leachability protocols. Samples of two
types of material from the site (mercury ore from the
south white gate pile and waste rock from the north
yellow pile) were collected and screened in the field,
then taken to the research facility of MSE in Butte,
Montana for demonstration testing. Kinetic column
leaching tests were performed to determine the
effectiveness of the treatments in reducing the
generation of mobile mercury.
1.1.1 Description of the SBMM Site
The Sulfur Bank Mercury Mine (SBMM) is an EPA
Superfund site, located on the south shore of the Oaks
Arm of Clear Lake, in Lake County, California (Figure 1-
1). With a surface area of 68 square miles, Clear Lake
is the largest lake entirely in California and is a popular
fishing, resort and watersport destination; thus the
mercury contamination in the lake has caused great
concern. Sulfur Bank was mined periodically from 1865
to 1957 with open pit mining beginning in 1915. In the
late 1920's, heavy earthmoving equipment began to be
used on a large-scale basis, which dramatically
increased the environmental impacts of mining. Various
mining activities over the years have deposited amounts
of mercury in the Clear Lake ecosystem.
Several pits were excavated at the mine, the larger
being Herman Pit, which is located a few hundred feet
from the lake. Surface runoff, subterranean streams,
surface seeps and groundwater have all played a part in
filling the pit, which seeps through the waste rock dam
into Clear Lake. Metal-laden acid mine drainage results
from the interaction of surface and ground waters with
sulfide bearing mine wastes, in and around the pit.
Degradation of water quality in Clear Lake may have
been caused largely by sulfate and acidity loading from
the Sulfur Bank Mercury Mine, though the transport
mechanisms remain unclear.
1.1.2 E&C Williams Enthrall Technology (as
provided by E&C Williams)
Enthrall® is a chemical stabilization process that uses
inorganic sulfide to target heavy metals and/or cyanide
in soil, liquid or sludge. The product, available in solid,
liquid or granular form, has been developed for use in in-
line treatment systems. The granular, pelletized form
has also been developed that can be used as a reactive
filter bed, which captures metals by forming sulfide
bonds as the contaminated solution flows through the
pellets. The treatment forms a permanent bond between
the Enthrall® surface and heavy metals. Bonds remain
resistant to leaching even though subsequent conditions
may involve harsh pHs, as has been demonstrated by
the Multiple Extraction Procedure that subjects materials
repeatedly to an acidic environment. According to E&C
Williams, a typical conventional treatment increases the
volume of the treated material by 25 to 200%, whereas
the ENTHRALL® addition often increases volume by only
5-10%. The smaller volume is advantageous during
treatment, as less material must be handled.
Additionally, the reduced quantity of treated material that
must be transported or stored can significantly lower
costs.
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Figure 1-1. Features of the SBMM site.
The ENTHRALL® technology is applicable to in-line
process streams and wastes containing heavy metals
and/or cyanide and may be applied by either in situ or ex
situ methods. The reagent may be applied to the
surface and mixed in, or may be injected under pressure
to achieve contact with deeper materials.
Successful application of the ENTHRALL® reagent must
take place in a neutral to alkaline environment. When
the calcium sulfide reagent is applied under acidic
conditions, some hydrogen sulfide gas is produced,
which reduces the effectiveness of metals stabilization.
No hazardous residuals are produced by the technology.
In an in-line process the residual would be a
nonhazardous form of the original potentially hazardous
material, which could then be stored on site or disposed
of in a Subtitle D landfill.
1.1.3 Kleen Earth Environmental Company Silica
Micro Encapsulation (SME) Process (as
provided by KEECO)
Klean Earth Environmental Company (KEECO) has
developed a Silica Micro Encapsulation (SME) process,
which encapsulates metals in an impervious microscopic
silica matrix, thus eliminating the availability of the
metals to have adverse human health or environmental
effects. KEECO has developed three products for
applying the technology to water (KB-1), solid waste
(KB-SEA) and radioactive wastewater (META-LOCK).
KB-SEA was used in this treatability study.
The SME process is a high-performance, low-cost
technology for preventing and treating metal
contamination in water and soils, as it uses silica, which
is one of the most common and inert substances on
earth. The durability of silica also contributes to the
value of the treatment, which works by isolating the
metals in question from contacting the environment.
Metals cannot be destroyed, nor can they be broken
down into other forms, so the most effective control
method is to simply isolate them from contacting
humans and the natural environment. KEECO's SME
process differs from typical stabilization treatments in
that the chemical formulation causes an electrokinetic
reaction which facilitates transport of the metals towards
the SME reactive components, thus enhancing contact
with the target metals and reducing the amount of
chemical required to achieve the desired results. The
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use of silica itself is another significant departure from
more typical stabilization treatments.
The SME reagent is designed to be applied in situ by
mixing a small amount, in either dry or slurry form, into
the contaminated soil. Boulder-sized material would be
coated with a slurry of the reagent. The volume of the
material should only be increased by 1-2% due to the
quantity of reagent added. If the reagent is applied dry,
a small amount of water may be added to initiate the
chemical reaction. A reaction period of 48 hours is
recommended before initial testing for results. For areas
of high metals concentration, a tilling device may be
used to produce further contact between reagent and
contaminated soil. This may be indicated in areas of
high concentration and hydraulic transport rates.
SME is applicable to wastewater, sediment, sludge, soil,
mine waste, radioactive wastewater and other complex
media. Silica bridging between encapsulated particles in
treated materials increases compressive strength over
time, which can enhance the usefulness of the treated
waste as backfill.
One problem that could be encountered with
stabilization treatments is that weathering and exposure
to changes in pH can break down the bonding and allow
metals to be released. The long-term stability
associated with SME treated wastes may indicate
applicability for large in situ applications where treated
materials will remain on site, exposed to the
environment. The SME technology has been designed
to treat metals-contaminated water and soils without
producing any hazardous by-products.
Where the technology is applied correctly and in a
manner that allows for thorough contact with the metal
contaminants of concern, no hazardous wastes should
be produced. Water treatments using the SME products
produce a dense sediment or sludge that can be
separated from the water and disposed of on-site or in a
sanitary landfill. Treated soils and other solids can be
left in place or used as backfill material.
The effectiveness of the SME process is somewhat
dependent on the substrate pH. Highly alkaline
substrates (such as unstable sludge from water
treatment plants, or soils that have been amended with
lime) having a pH greater than 8 may produce
resistance to the reactive process. In such an
environment, a pretreatment step to lower the pH by
may be necessary prior to the addition of SME. In this
case, an evaluation of the effectiveness and economics
of the multi-step treatment would be required.
According to KEECO, the single most limiting factor in
the effectiveness of the SME technology is contact with
the metal-bearing particles. Where the chemicals
cannot make contact with all the metal bearing
substrate, for example in the in situ treatment of large
waste rock or tailings piles, effectiveness would be
limited. KEECO is in the process of designing deep
subsurface injection methods to more effectively
introduce the reagent, in an effort to overcome this
inherent limitation of in situ treatment. SME is solely
applicable as a stabilization technology and cannot be
used as a reactive barrier.
1.1.4 Phosphate
Phosphate-based binders have been used successfully
to reduce solubility of heavy metal contaminants,
particularly lead, in soils. The reagents form bonds with
metal ions to form insoluble metal complexes called
pyromorphites. The kinetics of the reaction depends on
the phosphate form in the reagent. Phosphates have
been used in in situ remediation by land farming
(plowing and grading), injection, and surface application
and auguring.
During the design phases of the treatability study, there
was an interest in testing phosphate as a binding agent
for mercury. A generic phosphate reagent was obtained
for testing. Phosphates stabilize metals by chemically
binding them into new stable phosphate phases, such as
apatites, and other relatively insoluble phases in the soil.
Phosphates have been included in the reagent mixes for
stabilizing lead during remediation of several Superfund
sites.
Metals stabilized in apatite minerals are durable and
resistant to leaching because the mineral structure is
stable from pH 2 to 12 and up to 1000 degrees C, in
liquids or solids and through geologic disruptions.
Previous studies have indicated that as little as 1% (w/w)
phosphate addition could remediate metal-contaminated
soils.
Earlier studies have found phosphates to be effective at
stabilizing copper, lead, zinc, cadmium, nickel,
lanthanides and actinides (Chen et al., 1997).
Generally, the process is applicable to inorganics,
including radionuclides, but not to organic contaminants
or pesticides.
As with all stabilization remediations, the success of the
process is dependent on the reagent and the waste.
Generally, site-specific treatability studies are required.
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Additionally, long-term stability has not been identified
for very many combinations, so durability studies may be
required. Lead phosphate is toxic by inhalation, so the
formation of that compound would also have to be
evaluated. While phosphate-binding has been well
documented for lead remediation, there is little
information on mercury stabilization.
1.2 Brief Description of the Superfund Innovative
Technology Evaluation (SITE) and Mine
Waste Technology (MWTP) Programs
The SITE Program is a formal program established by
the EPA's Office of Solid Waste and Emergency
Response (OSWER) and Office of Research and
Development (ORD) in response to the Superfund
Amendments and Reauthorization Act of 1986 (SARA).
The SITE Program promotes the development,
demonstration, and use of new or innovative
technologies to clean up Superfund sites across the
country.
The SITE Program's primary purpose is to maximize the
use of alternatives in cleaning hazardous waste sites by
encouraging the development and demonstration of
new, innovative treatment and monitoring technologies.
It consists of three major elements:
• Demonstration Program,
• Consortium for Site Characterization
Technologies (CSCT)
• Technology Transfer Program.
The objective of the Demonstration Program is to
develop reliable performance and cost data on
innovative technologies so that potential users can
assess the technology's site-specific applicability.
Technologies evaluated are either available
commercially or close to being available for full-scale
remediation of Superfund sites. SITE demonstrations
usually are conducted at hazardous waste sites under
conditions that closely simulate full-scale remediation
conditions, thus assuring the usefulness and reliability of
the information collected. Data collected are used to
assess: (1) the performance of the technology; (2) the
potential need for pre- and post-treatment of wastes; (3)
potential operating problems; and (4) the approximate
costs. The demonstration also provides opportunities to
evaluate the long-term risks and limitations of a
technology.
Existing and new technologies and test procedures that
improve field monitoring and site characterizations are
explored in the CSCT Program. New monitoring
technologies, or analytical methods that provide faster,
more cost-effective contamination and site assessment
data are supported by this program. The CSCT
Program also formulates the protocols and standard
operating procedures for demonstration methods and
equipment.
The Technology Transfer Program disseminates
technical information on innovative technologies in the
Demonstration and CSCT Programs through various
activities. These activities increase awareness and
promote the use of innovative technologies for
assessment and remediation at Superfund sites. The
goal of technology transfer activities is to develop
interactive communication among individuals requiring
up-to-date technical information.
The Mine Waste Technology Program (MWTP) is an
interagency effort by the EPA and U.S. Department of
Energy (DOE) focused on developing and proving
technologies that provide solutions to the remedial
problems of abandoned mines and the compliance
issues of active mines throughout the United States.
Excluding coal production, the mining industry produces
between 1 and 2 billion tons of mine waste annually.
The 1985 Report to Congress estimated the total
noncoal mine waste volume in the United States at 50
billion tons. MWTP priorities include at-source control
technologies, improvements of short-term technologies
for the alleviation of extreme environmental problems
and implementing resource recovery methods to help
alleviate the costs of remediation.
1.3 The SITE Demonstration Program
and Reports
Technologies are selected for the SITE Demonstration
Program through annual requests for proposals. This
solicitation ended in 1995. EPA Office of Research and
Development (ORD) staff review the proposals to
determine which technologies show the most promise
for use at Superfund sites. Technologies chosen must
be at the pilot- or full-scale stage, must be innovative,
and must have some technological and/or cost
advantage over existing technologies. Mobile
technologies are of particular interest.
Once the EPA has accepted a proposal, cooperative
agreements between the EPA and the developer
establish responsibilities for conducting the
demonstration and evaluating the technology. The
developer is responsible for demonstrating the
technology at the selected site and is expected to pay
any costs for transport, operation, and removal of the
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equipment. The EPA is responsible for project planning,
sampling and analysis, quality assurance and quality
control, preparing reports, disseminating information,
and provides arrangements for transporting and
disposing of treated waste materials. Usually, results of
Demonstration Programs are published in three
documents: the SITE Demonstration Bulletin, the
Technology Capsule, and the Innovative Technology
Evaluation Report (ITER). The Bulletin describes the
technology and provides preliminary results of the field
demonstration. The Technology Capsule provides more
detailed information about the technology, and
emphasizes key results of the SITE demonstration. The
ITER provides detailed information on the technology
investigated, a categorical cost estimate, and all
pertinent results of the SITE demonstration. An
additional report, the Technology Evaluation Report
(TER), is not formally published. The TER contains the
raw data collected during the demonstration and
provides a detailed quality assurance review of the data.
For the treatability study using KEECO's SME, E&C
Williams' Enthrall® and a generic phosphate technology,
a SITE Capsule and ITER have been prepared; all for
use by remedial managers in making detailed
evaluations of the technologies for applications to
specific sites and wastes. A TER is also submitted for
this demonstration to serve as verification
documentation.
1.4 Purpose of the Innovative
Technology Evaluation Report (ITER)
This ITER provides information on a treatability study
performed using KEECO's SME, E&C Williams'
Enthrall®, and a generic phosphate treatment. This
report includes a comprehensive description of the study
and its results. The ITER is intended for use by EPA
remedial project managers (RPMs), EPA on-scene
coordinators (OSCs), contractors, and other decision-
makers carrying out specific remedial actions. The ITER
is designed to aid decision-makers in evaluating specific
technologies for further consideration as applicable
options in a particular cleanup operation. This report
represents a critical step in the development and
commercialization of a treatment technology.
To encourage the general use of demonstrated
technologies, the EPA provides information regarding
the applicability of each technology to specific sites and
wastes. The ITER includes information on cost and
desirable site-specific characteristics. It also discusses
advantages, disadvantages, and limitations of the
technology.
Each SITE demonstration evaluates the performance of
a technology in treating a specific waste matrix. The
characteristics of other wastes and other sites may differ
from the characteristics of the treated waste. Therefore,
a successful demonstration of a technology at one site
does not necessarily ensure that it will be applicable at
other sites. Data from the demonstration may require
extrapolation for estimating the operating ranges in
which the technology will perform satisfactorily. Only
limited conclusions can be drawn from a single field
demonstration.
1.5 Sources of Further Information
EPA Work Assignment Manager
Ed Bates
U.S. EPA
National Risk Management Research Laboratory
(NRMRL)
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
(513)569-7774
Mine Waste Technology Program
Roger Wilmoth
U.S. EPA
National Risk Management Research Laboratory
(NRMRL)
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
(513)569-7509
E&C Williams Project Manager
Charlie Williams
E&C Williams, Inc.
120 Varnfield Dr, Ste. A
Summerville, SC 29483
(843)821-4200
KEECO Project manager
Amy Anderson
19023 36th Ave. West, Ste. E
Lynnwood, WA 98036
(425)778-7165
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Section 2.0
Technology Application Analysis
This section addresses the general applicability of
stabilization processes to sites containing mercury
contamination, with specific information regarding the
technologies evaluated in the SBMM treatability study
where appropriate. Since the report is based on a
treatability study rather than a field scale demonstration,
there is no actual treatment system to describe; however,
the vendors were asked to conceive and provide cost
estimates for a full scale application to two piles at the
SBMM site. Details on the selected piles can be found in
Section 3.2.
Stabilization technologies include a broad range of
treatment options that are designed to immobilize
contaminants in the existing material, rather than reducing
or removing them. Stabilization processes depend on a
chemical reaction between the reagent and the
contaminant of concern to stabilize the contaminant within
the matrix. All of the technologies in this treatability study
are stabilization methods, each comprised of a unique
chemical system. The technologies in the study are also
innovative in that a reduced volume of reagent is required
as compared to traditional stabilization processes. This is
beneficial in that it reduces the amount of material that
must be handled and stored during treatment, and
generally produces treated material with a minimal
increase in volume.
Limited information on mercury stabilization is available;
therefore, the analysis is based on the body of data that is
available, and on the more widely available information on
stabilization treatments for other heavy metals, as well as
information provided by the technology vendors who
participated in the treatability study.
2.1 Key Features of the Stabilization
Process
The primary components of a stabilization treatment
system are the reagents and equipment used to mix it into
the treatment matrix. In addition to the treatment reagent,
the matrix characteristics and depth of the material and the
application type (in situ or ex situ) would determine the
equipment requirements. Unless ground or surface water
contamination is an immediate concern (e.g. very shallow
watertable beneath treatment zone), monitoring can be as
simple as auguring samples from the treated pile after the
treatment has been performed in order to determine the
success of the treatment.
The application design for ECWI's ENTHRALL® process
would use a proprietary sonic drilling rig subcontracted
from Prosonic Drilling Company, Inc (PDI) of Phoenix,
Arizona. The reagent would be injected directly into the
pile at 15 foot intervals, which should allow the reagent to
thoroughly permeate the material.
KEECO's design calls for a modified ex-situ approach
wherein a mixing facility would be constructed adjacent to
each pile. The material would be hauled by dump trucks to
the facility where it would be dumped onto a mixing pad,
reagent would be mixed in by a front end loader and the
material would be hauled back to the pile by dump truck
and then replaced and compressed in place. Each mixing
facility would be enclosed to prevent fugitive dust
emissions.
2.2 Operability of the Technology
Stabilization processes are among the simplest of
remediation technologies, consisting mainly of a chemical
reagent and the mixing/drilling equipment required to apply
it. The effectiveness of stabilization technologies is largely
dependent on the degree of contact between the reagent
and the contaminated matrix. Thorough mixing is desirable
to ensure the maximum particle contact, though in in situ
treatments, mixing may not be practical and application of
the chemical would have to be accomplished by drilling and
injection into the material. In such cases, care would have
to be taken in designing the application to ensure complete
contact between the reagent and the treated matrix.
Existing environmental conditions are generally not a
problem and may be incorporated into the process (e.g.
natural moisture content of the matrix). In most
stabilization technologies, the chemical reaction takes
place quickly, making weather and temperature much less
significant factors than in other methods with longer
treatment times.
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Ensuring thorough contact with contaminants in the matrix
is easier in ex situ applications due to the ease of mixing
when material is moved to the treatment locale, which can
consist of moving to a lined pad near the area of
contamination. In situ treatments are inherently more
complicated, but developing technologies for this form of
application is desirable because of the reduced cost,
reduced contact with contaminants, and lowered risk of
spillage and air contamination during transport of the
material to a treatment facility.
The chemical reagents used in stabilization technologies
are usually applied dry or are available in a concentrated
form that can be mixed with water on site, thus minimizing
the amount of chemical that must be transported. For
smaller applications, where equipment is likely to be used
for only a few days, portable generators and mixers can be
rented, reducing capital investments. At large treatment
sites it may be more cost effective to purchase equipment;
however, the treatments designed by the technology
vendors for the Sulfur Bank Mercury Mine site use either
specialized equipment that would be subcontracted, or
heavy equipment in such quantity that purchase would not
be feasible. In addition to environmental remediation
applications, stabilization treatment is also applicable to
industrial waste products and to contaminated waters, as
discussed in detail in Section 2.3.
2.3 Applicable Wastes
As discussed in the previous section, stabilization
technologies are applicable to solid matrices such as
contaminated soil or mine wastes. Stabilization treatment
is also applicable to industrial waste products that are still
in the production system and to contaminated waters,
though this is more likely to be used in a contained system,
as opposed to a natural environment, because the resulting
contaminated sludge would have to be removed. Since the
process works by binding an environmentally neutral
element with contaminants in the environment, there are
minimal hazardous byproducts. The process is also
applicable in situations where subsurface utilities limit or
preclude the use of technologies requiring excavation,
though special care would have to be taken when drilling
was used in the product application.
2.4 Availability and Transportability of
Equipment
Stabilization technologies can be implemented anywhere
the chemical can be delivered and a drill rig/mixing
equipment can be used. Since all-terrain drill rigs are
available, most locations would be accessible. KEECO's
silica technology would be applied by mixing with front end
loaders in a facility constructed on site for that purpose.
Standard earth-moving, heavy equipment that is normally
moved from site to site would be used. Application of the
ENTHRALL® technology as used in the SBMM treatability
study would require the use of a sonic drill rig. The rig is
truck-mounted and easily transportable to the site.
2.5 Materials Handling Requirements
Materials handling for stabilization processes are generally
limited to transporting the reagent to the site, and mixing
and applying it to the contaminated matrix. There should be
no residuals or waste products that have to be removed
from the site, other than a small quantity of personal
protection equipment (PPE), which could be removed from
the site in a sealed drum, by a facility qualified to dispose
of hazardous waste.
For an application such as the piles at SBMM, where the
treatment matrix is unconsolidated rock, minimal site
preparation would be required. The size of the piles can be
measured, with the depth of the piles being estimated from
pre-mining topographic maps. Where dumping records are
not available, core samples may be taken to verify
consistency of material in the piles, and some sampling
should be done regardless of records to check for changes
in the material since it was deposited.
Drilling services are generally subcontracted to a company
that has both the required equipment (drill rigs, augers,
samplers) and personnel trained in drilling operation. If
work is to be performed on a hazardous waste site, drilling
personnel must have the OSHA-required 40-hour health
and safety training. Process monitoring would be required
initially to ensure that the reagent was making full contact
with the contaminated matrix, and samples of post-
treatment material would be collected at intervals
throughout the application to determine the success of the
technology, and any modifications that were required.
ECWI would subcontract drilling and injection of the
reagent for the SBMM project. All personnel working on
site would be required to complete safety training. The
SBMM treatment designed by ECWI calls for one weekly
sample of treated material to be collected and analyzed for
leachable mercury. This would ensure that sufficient
reagent was being applied and that complete contact
between reagent and contaminated material was being
achieved.
KEECO's design includes two mixing facilities, each of
which would be operated two shifts per day. Their
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sampling plan calls for one sample of treated material to be
collected daily by each shift.
2.6 Range of Suitable Site Characteristics
Stabilization technologies can be applied at any site that is
accessible to the drilling and mixing equipment. Electrical
power and water would be required at most sites, but if
necessary, a generator could provide electricity and water
could be hauled in. Application of reagents would need to
be done when temperatures were above freezing to avoid
the reagent solidifying before full contact with the targeted
contaminant was made.
2.7 Limitations of the Technology
The main limitation of stabilization technologies is that
while the process is easily applied to most solid wastes, the
success of the treatment depends on a very specific
chemical reaction. To ensure complete stabilization, the
reagent must be mixed into the soil thoroughly enough to
ensure complete contact; therefore success is limited by
mechanical access to materials. Very deep or relatively
impermeable bodies of material would not be thoroughly
treated without specialized equipment and application
techniques, which could make in situ treatment difficult.
The pH of the material being treated can limit the
effectiveness of the reagent, but this can often be remedied
by adding the appropriate buffering material to the reagent
before it is applied.
In a diverse waste body, such as the piles found at SBMM,
the majority of the material being treated is not necessarily
the same as the relatively small amount of material that
was sampled priorto treatment application. Heterogeneous
matrices may require extensive testing to insure that the
mode of treatment is applicable to the entire volume. If
heterogeneity affects performance, than separate
treatment scenarios may need to be developed for each
component. This may impact cost and schedule.
As with any technology, results in the field often differ from
lab scale results, so modifications to the process may be
required during application. Stabilization treatments are
generally designed to be one-time applications, but due to
the variability of the reaction and potential interferences,
additional applications may be indicated.
2.8 Applicable or Relevant and
Appropriate Requirements (ARARS)
for Stabilization Processes
The National Contingency Plan (NCR) of 1985, codified in
Title 40 Code of Federal Regulations (CFR) Part 300,
delineates the methods and criteria used to determine the
appropriate extent of removal and cleanup for hazardous
waste contamination. The NCR required compliance with
Federal applicable or relevant and appropriate
requirements (ARARs) in order to make use of other
programs' or agencies' standards. The Comprehensive
Environmental Responsibility, Compensation and Liability
Act (CERCLA), as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986
codified and expanded the provisions.
This subsection discusses specific federal ARARs that are
pertinent to the application of stabilization technologies,
including the transport, treatment, storage, and disposal of
wastes and treatment residuals. State and local regulatory
requirements, which may be more stringent than those set
by the federal agencies, must also be addressed by
remedial managers. ARARs that apply to stabiliation
remedial technologies have been promulgated in various
regulatory acts, including: (1) the Comprehensive
Environmental Response, Compensation, and Liability Act;
(2) the Resource Conservation and Recovery Act; (3) the
Clean Air Act; (4) the Clean Water Act; (5) the Safe
Drinking Water Act, and (6) the Occupational Safety and
Health Administration regulations. These six regulatory
acts are discussed below; with specific ARARs that may be
applicable to the stabilization process being identified in
Table 2-1.
2.8.7 Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
The CERCLA of 1980, as amended by SARA of 1986,
provides for federal funding to respond to releases or
potential releases of any hazardous substance into the
environment, as well as to releases of pollutants or
contaminants that may present an imminent or significant
danger to public health and welfare or to the environment.
SARA states a strong statutory preference for remedies
that are highly reliable and provide long-term protection. It
directs EPA to do the following:
• use remedial alternatives that permanently and
significantly reduce the volume, toxicity, or the
mobility of hazardous substances, pollutants, or
contaminants:
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Table 2-1. Potential Federal and State ARARs for Stabilization Remediation Processes.
Process Activity
Waste
Characterization of
Untreated Waste
Waste
Processing
Determination of
Cleanup
Standards
Waste Disposal
Worker Safety
ARAR
RCRA: 40
CFR Part 261
(or State
equivalent)
RCRA: 40
CFR Part 264
(or State
equivalent)
CAA: 40 CFR
Part 50
(or State
equivalent)
SARA:
Section
121(d)(2)(ii);
SDWA: 40
CFR Part 141
RCRA: 40
CFR Part 262
OSHA: 29
CFR Parts
1900-1926;
or State
equivalent
Description
Standards that apply to
identification and
characterization of
wastes.
Standards apply to
treatment of wastes in a
treatment facility.
Regulations govern toxic
pollutants, visible
emissions and
particulates.
Standards that apply to
surface & groundwater
sources that may be used
as drinking water.
Standards that pertain to
generators of hazardous
waste.
Worker health and safety
standards
Basis
Chemical and physical
properties of waste
determine the suitability
of treatment by a
stabilization/solidification
process.
Applicable to stabilization
processes only when
applied in a waste
treatment facility.
Mixing reagent into soil
could create particulate
dust in the air.
Applicable to stabilization
processes only when
runoff or seepage of
solutions from treatment
may contact surface and
groundwaters.
Generated hazardous
wastes would, in most
cases, be limited to PPE,
other contaminated
supplies and possibly
washwater.
CERCLA remedial
actions and RCRA
corrective actions must
follow requirements for
the health and safety of
on-site workers.
Response
Chemical and physical
analyses must be
performed to determine if
waste is a hazardous
waste.
Compliance with
requirements for
operations, record keeping,
and contingency planning.
Where materials being
treated cause dust
particulate, surface should
be wetted, or dust
containment facilities
installed.
Application must be
designed to ensure no
significant amounts of
runoff or seepage into
groundwater.
Generators must dispose of
wastes at facilities that are
permitted to handle the
waste. Generators must
obtain an EPA ID number
prior to waste disposal.
Workers must have up to
date training and medical
monitoring; use of
appropriate protective
equipment is required.
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• select remedial actions that protect human health
and the environment, are cost-effective, and
involve permanent solutions and alternative
treatment or resource recovery technologies to the
maximum extent possible; and
• avoid off-site transport and disposal of untreated
hazardous substances or contaminated materials
when practicable treatment technologies exist
[Section 121(b)].
In general, two types of responses are possible under
CERCLA: removal and remedial actions. Superfund
removal actions are conducted in response to an
immediate threat caused by a release of a hazardous
substance. 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
or pollutants.
Stabilization technologies qualify for use in CERCLA
remedial actions as the process may permanently reduce
the mobility of the contaminants of concern. Most
stabilization processes also reduce toxicity in the treated
matrix by binding contaminants in a neutral compound.
On-site remedial actions must comply with federal and
state ARARs, which are determined on a site-by-site basis.
These regulations may be waived under six conditions: (1)
the action is an interim measure, and the ARAR will be met
at completion; (2) compliance with the ARAR would pose a
greater risk to health and the environment than
noncompliance; (3) it is technically impracticable to meet
the ARAR; (4) the standard of performance of an ARAR
can be met by an equivalent method; (5) a state ARAR has
not been consistently applied elsewhere; and (6) meeting
the standard for that particular ARAR, with respect to the
degree of protection or reduction of risk afforded by it,
would incur such costs that standard and remedial actions
at other sites would be jeopardized. These waiver options
apply only to on-site actions, and justification forthe waiver
must be clearly demonstrated.
2.8.2 Resource Conservation and Recovery Act
(RCRA)
RCRA, an amendment to the Solid Waste Disposal Act
(SWDA), was passed in 1976 to provide a framework for
achieving environmentally sound management of both
hazardous and nonhazardous wastes. Subtitle C of RCRA
regulates the generation and handling of hazardous waste,
with most of the regulations also being applicable to
CERCLA activities. The Hazardous and Solid Waste
Amendments (HSWA) of 1984 greatly expanded the scope
and requirements of RCRA.
RCRA defines two types of hazardous wastes:
characteristic and listed. Criteria for identifying
characteristic hazardous wastes, given in 40 CFR Part 261
Subpart C, are: ignitability, corrosivity, reactivity, and
toxicity. 40 CFR Part 261 Subpart D provides a list of
wastes from specific and nonspecific industrial sources,
which comprise the "listed" wastes. RCRA regulations do
not apply to sites where RCRA-defined wastes are not
present.
RCRA regulations define hazardous wastes and regulate
their transport, treatment, storage, and disposal. These
regulations are only applicable to stabilization processes if
RCRA defined hazardous wastes are present.
In a typical stabilization application, hazardous wastes
would be limited to the material being treated, and a small
amount of personal protective equipment (PPE) that may
have become contaminated during treatment. If wastes
were determined to be hazardous according to RCRA,
essentially all RCRA requirements regarding the
management and disposal of this hazardous waste would
have to be addressed by the remedial managers.
In order to legally generate any hazardous waste, the
responsible party must obtain an EPA identification
number. Other applicable RCRA requirements may
include a Uniform Hazardous Waste Manifest (if the waste
is transported off-site), restrictions on placing the waste in
land disposal units, time limits on accumulating waste, and
permits for storing the waste.
Requirements for corrective action at RCRA-regulated
facilities are provided in 40 CFR Part 264, Subpart F and
Subpart S. These subparts also generally apply to
remediation at Superfund sites. Subparts F and S include
requirements for initiating and conducting RCRA corrective
action, remediating groundwater, and ensuring that
corrective actions comply with other environmental
regulations. Subpart S also details conditions underwhich
particular RCRA requirements may be waived for
temporary treatment units operating at corrective action
sites and provides information regarding requirements for
modifying permits to adequately describe the subject
treatment unit.
2.8.3 Clean Air Act (CAA)
The CAA establishes national primary and secondary
ambient air quality standards for sulfur oxides, particulate
matter, carbon monoxide, ozone, nitrogen dioxide, and
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lead. It also limits the emission of 189 listed hazardous
pollutants such as vinyl chloride, arsenic, asbestos and
benzene. States are responsible for enforcing the CAA.
To assist in this, Air Quality Control Regions (AQCR) were
established. Allowable emission limits are determined by
the AQCR, or its sub-unit, the Air Quality Management
District (AQMD). These emission limits are based on
whether or not the region is currently within attainment for
National Ambient Air Quality Standards (NAAQS).
The CAA requires that treatment, storage, and disposal
facilities comply with primary and secondary ambient air
quality standards. Provided that the stabilization reagents
are mixed into the soil matrix without generating excessive
dust, there should be no clean air issues associated with
the process.
2.8.4 Clean Water Act (CWA)
The objective of the Clean Water Act is to restore and
maintain the chemical, physical and biological integrity of
the nation's waters by establishing federal, state, and local
discharge standards. If treated water is discharged to
surface water bodies or Publicly Owned Treatment Works
(POTWs), CWA regulations will apply. A facility desiring to
discharge water to a navigable waterway must apply for a
permit under the National Pollutant Discharge Elimination
System (NPDES). When a NPDES permit is issued, it
includes waste discharge requirements. Discharges to
POTWs also must comply with general pretreatment
regulations outlined in 40 CFR Part 403, as well as other
applicable state and local administrative and substantive
requirements. Stabilization technology applications involve
minimal amounts of water, and should produce no excess
solution; therefore, CWA criteria would not generally apply.
2.8.5 Safe Drinking Water Act (SDWA)
The SDWA of 1974, as most recently amended by the Safe
Drinking Water Amendments of 1986, requires the EPA to
establish regulations to protect human health from
contaminants in drinking water. The legislation authorized
national drinking water standards and a joint federal-state
system for ensuring compliance with these standards. The
National Primary Drinking Water Standards (NPDWS) are
found in 40 CFR Parts 141 through 149. There should be
minimal effluent from the treated material during a
stabilization process, so safe drinking water regulations
would only apply where any effluent, if produced, could
impact surface or groundwater drinking water sources.
2.8.6 Occupational Safety and Health A dministration
(OSHA) Requirements
CERCLA remedial actions and RCRA corrective actions
must be performed in accordance with the OSHA
requirements detailed in 20 CFR Parts 1900 through 1926,
especially Part 1910.120, which provides for the health and
safety of workers at hazardous waste sites. On-site
construction activities at Superfund or RCRA corrective
action sites must be performed in accordance with Part
1926 of OSHA, which describes safety and health
regulations for construction sites. State OSHA
requirements, which may be significantly stricter than
federal standards, must also be met.
All personnel who are working at a hazardous waste site
are required to have completed an OSHA training course
and must be familiar with all OSHA requirements relevant
to hazardous waste sites. Workers at hazardous waste
sites must also be enrolled in a medical monitoring
program. An acceptable program must include: (1) a
health history, (2) an initial exam before hazardous waste
work starts to establish fitness for duty and as a medical
baseline, (3) periodic examinations (usually performed
annually) to determine whether changes due to exposure
may have occurred and to ensure continued fitness for the
job, (4) appropriate medical examinations after a suspected
or known overexposure, and (5) an examination at
termination.
For most sites, minimum PPE for workers will include
gloves, hard hats, steel-toed boots, and Tyvek? coveralls.
Depending on contaminant types and concentrations,
additional PPE may be required, including the use of air
purifying respirators or supplied air. At the sites where
stabilization treatments will be applied, the minimal list of
PPE will usually be sufficient. Noise levels are not
expected to be high, except during the operation of mixing
and drilling equipment. During these activities, noise levels
should be monitored to ensure that workers are not
exposed to noise levels above a time-weighted average of
85 decibels over an eight-hour day. If noise levels were to
exceed this limit, then workers would be required to wear
hearing protection, however, hearing protection should be
available for any level of discomfort from noise. The levels
of noise anticipated are not expected to adversely affect
the community, but this will depend on proximity to the
treatment site.
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Section 3
Economic Analysis
3.1 Introduction
The purpose of this economic analysis is to estimate
costs (not including profits) for commercial treatment of
mercury-contaminated material at the Sulfur Bank
Mercury Mine in Northern California using the Enthrall®
and SME technologies that were demonstrated in the
treatability study. Since a field-scale demonstration has
not been performed, best efforts to reasonably estimate
costs have been based on past experience of the
vendors and reasonable engineering assumptions. The
cost figures provided in this economic analysis are
considered "order-of-magnitude" estimates, and may
significantly change if field testing is performed.
The technology vendors were asked to provide cost
estimates based on twelve categories of costs that are
associated with typical cleanup activities at Superfund
sites. Where the vendor did not supply costs, an
estimate has been included based on past SITE
program experience, or generic treatment costs. The
phosphate treatment was applied in the treatability study
as a generic treatment, and based on the results, further
experimentation and product modification would have to
be performed before the reagent would be considered
for use at the SBMM site; therefore, vendor costs for a
full scale treatment using phosphate were not included
in the estimates.
3.2 Cost Estimate Scope
The technology vendors were asked to provide cost
estimates for treatment of two piles at the site, the North
Waste Pile and the Waste Rock Dam. For purposes of
the cost estimate, the mercury content in the piles was
assumed to be the same as that in the mercury ore used
in the treatability study.
The vendors were asked to estimate costs based on the
following dimensions:
North Waste Pile:
Surface area = 894,000 square feet
Volume = 877,000 cubic yards
Estimated maximum depth = 75 feet
Calculated average depth = 26.5 feet
Waste Rock Dam:
Surface area = 1,034,000 square feet
Volume = 556,000 cubic yards
Estimated maximum depth = 70 feet
Calculated average depth = 14.5 feet
The costs associated with typical cleanup activities at
Superfund sites have been broken down into 12
categories:
(1) Site Preparation
(2) Permitting and Regulatory Activities
(3) Capital Equipment
(4) Start-up and Fixed
(5) Labor
(6) Consumables and Supplies
(7) Utilities
(8) Effluent Treatment and Disposal
(9) Residuals Shipping & Disposal
(10) Analytical Services
(11) Maintenance and Modifications
(12) Demobilization/Site Restoration
The technology vendors were asked to estimate costs
for treating the specified piles based on the above
categories.
3.3 Factors Affecting Estimated Cost
Since the technologies have only been applied to SBMM
materials in the small scale of the treatability study,
rather than a field scale demonstration, it is understood
that the costs presented here are estimates only, based
on past experience of the vendors and engineering
assumptions as specified in the following descriptions.
There are a number of factors that could affect the
actual cost of treatment of mercury-contaminated
material using stabilization technologies. Cost estimates
in this report have been provided by the vendors based
on the assumption that the mercury and other metals
content is the same as that in the material that was
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treated in the treatability study. A larger sampling of the
material in the piles would be required prior to an actual
application and the results could indicate significantly
different concentrations. Analytical evaluation of the
actual materials to be treated may also indicate that
modifications to the reagents are necessary, which could
impact costs. The characteristics of the material may
also be a factor. Estimates are based on "typical
material" characteristics; however, the actual material
may require special handling depending on particle size,
stability and compaction. Should the initial sampling
results vary widely, additional sampling points would be
required in order to ensure that the proper reagents and
ratios were applied.
3.4 Issues and Assumptions
This section summarizes the major issues and
assumptions used in estimating the cost of implementing
the Enthrall® and SME technologies at full-scale. The
vendors were given the dimensions of the piles and told
that the material would be assumed to match the
mercury ore material. Additional assumptions were
specified by ECWI and KEECO in presenting their costs.
3.4.1 Site Characteristics
The Sulfur Bank Mercury Mine is comprised of two pits
and extensive piles composed of various materials.
Cost estimates have been prepared for two existing piles
at the site, but characteristics of the material in the piles
were assumed to be the same as that in the mercury ore
from the treatability study. The maximum depth at any
point in the pile has been estimated based on pre-mining
maps. Since the volume of both piles was estimated
from maps, the actual volume could differ due to map
scaling or errors, and changes in the heap topography
overtime.
For purposes of cost estimation, characteristics for a
typical site material were assumed. These included the
assumptions that the material is unconsolidated, with
sizes ranging from fines to large gravels and that the
rock can be completely treated by the methods
described in the following vendor sections.
3.4.2 Design and Performance Factors
ECWI and KEECO each designed the application
technique for their respective reagents. These
processes are described in later sections with details of
each vendor's cost estimates. Both processes include
monitoring or pilot testing to verify complete contact
between the reagent and the contaminated material in
order to optimize treatment performance. The products
used in the treatability study are all designed to be a
one-time application.
3.4.3 Financial Assumptions
All costs are presented in 2001 U.S. dollars without
accounting for interest rates, inflation or the time value of
money. Insurance and taxes are assumed to be fixed
costs lumped into the Startup and Fixed Costs category
(see subsection 3.5.4).
3.5 Basis for Economic Analysis
In this section, each of the 12 cost categories that reflect
typical clean-up activities encountered at Superfund
sites, will be defined and discussed. These 12 cost
categories form the basis for the estimated costs
submitted by the vendors and presented in sections
3.6.1 and 3.6.2.
3.5.1 Site Preparation
Since the material being treated is already in piles and
will be treated on site, the site preparation for
implementing the stabilization technologies would be
limited to bringing the necessary equipment for
application and monitoring to the site, and constructing
usage and storage facilities. Storage facilities for
chemicals and fuels would have to comply with
environmental regulations governing the site. The
SBMM site is already fenced so no additional security
costs should be incurred.
3.5.2 Permitting and Regulatory Requirements
Several types of permits may be required for
implementing a full-scale remediation. The types of
permits required will be dependent on the type and
concentration of the contamination, the regulations
covering the specific location, and the site's proximity to
residential neighborhoods. Extensive studies have
previously been conducted on contamination in Clear
Lake, so pretreatment site characterization should also
be minimal for permitting purposes.
If site characterization were required for permitting, the
non-analytical costs incurred for receiving approval from
the regulatory agency to install the treatment system
would be included under the Permitting and Regulatory
Activities category. These costs would include the
preparation of site characterization reports that establish
a baseline for the site contamination, the design
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feasibility study for the pilot system, and meetings with
regulators for discussing comments and supplying
related documentation for acquiring approval for
installing and implementing the treatment.
Depending upon the classification of a site, certain
RCRA requirements may have to be satisfied as
discussed in section two of this report. Since the SBMM
site is an active Superfund site, it is possible that the
technology could be implemented under the umbrella of
existing permits and plans. Certain regions or states
have more rigorous environmental policies that may
result in higher costs for permits and verification of
cleanup. Added costs may result from investigating all
of the regulations and policies relating to the location of
the site, and for conducting a historical background
check for fully understanding the scope of the
contamination.
3.5.3 Capital Equipment
Capital equipment includes all equipment for the
treatment process, whether it is purchased or rented.
Different specialized equipment is required for each of
the technologies as specified in the following vendor's
cost estimates. For this particular project, all equipment
costs were based on rental or subcontracting rates
rather than purchases.
3.5.4 Startup and Fixed Costs
Startup and Fixed costs can include such variables as
insurance, taxes, initiation of monitoring programs,
contingency funds, and the cost of physically starting the
treatment such as building facilities, transporting
equipment, etc. In requesting cost estimates from the
vendors for the SBMM piles, the list of cost categories
was provided, but developing and categorizing costs
was left up to the vendors. Physical startup costs have
been included in the site preparation category, leaving
insurance, taxes, etc. in the startup costs, where they
were included in the vendor's estimate.
Often, insurance and taxes are estimated to be 10% of
the total annual purchased equipment costs.
Contingency costs that allow for unforeseen
circumstances such as strikes, floods and price
variations, are often estimated at the same cost as
insurance and taxes.
3.5.5 Labor
Included in this subsection are the labor costs of
implementing the technologies and the associated
monitoring that would be required to verify the results of
the process. Where labor is performed but accounted
for in other categories, an explanation has been included
in those categories. The hourly labor rates presented in
this subsection are loaded, which means they include
base salary, benefits, overhead, and general and
administrative (G&A) expenses. Travel and per diem
expenses are additional costs included in this section.
Monitoring requirements for this project are based on the
assumption that the material characterization has
already been done, and costs are required only for the
tests that would be necessary to determine the degree
to which the process is working, and to satisfy
environmental monitoring requirements. Sampling labor
would include collecting and appropriately packing
samples for shipping to the analytical lab and then
delivering the samples to the nearest shipping office.
3.5.6 Consumables & Supplies
The category of consumables and supplies consists of
materials used in the treatment process and supplies
bought to support the treatment effort. In the SBMM
treatments, the reagent and diesel fuel account for the
consumables and supplies would consist primarily of
personal protective equipment (PPE) and miscellaneous
supplies.
PPE is routinely used by individuals who are active in
treatment application, sample collection, and during any
activity in which there is a potential for being exposed to
contaminated soil or groundwater. Expendable items
would primarily include nitrile gloves and tyvek coveralls;
and possibly spent respirator cartridges if the work is
conducted in Level C or higher.
3.5.7 Utilities
Utilities are generally comprised of electricity and water.
At the SBMM site, the equipment in both treatment
scenarios is diesel fueled, so only a small electrical cost
to supply lighting and possibly for a phone and facsimile
hookup would be needed. A water source would be
needed for decontamination and incidental activities;
however those costs are considered negligible.
3.5.8 Effluent Treatment and Disposal
For these technologies there is no effluent produced;
therefore, it is assumed that there will be no effluent
treatment and disposal expense.
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3.5.9 Residuals Shipping and Disposal
No residuals would be anticipated from an in situ
stabilization process conducted according to the method
used in the treatability study. For the modified ex situ
process designed by KEECO, material is removed from
the pile to an adjacent mixing facility where it is mixed
with reagent. At this point in the treatment process,
KEECO considers the treated material to be residuals
and included the cost of returning the material to the
original location in the residual handling costs. Disposal
of small amounts of decontamination wastewater that
may be generated from cleaning sampling equipment is
considered negligible.
3.5.10 Analytical Services
All samples of treated material would be sent to an off-
site analytical laboratory. The level of testing required to
substantiate site cleanup was specified by each of the
vendors in their respective treatment scenarios. Both
vendors based costs on analysis of leachable mercury
only. Unlike the treatability study, which determined
success by percent reduction in comparison with a
water-leach control, actual remediation projects focus on
attaining a specific cleanup concentration target level.
3.5.11 Maintenance and Modifications
Remediation efforts often include installation of a
treatment system that would require ongoing
maintenance. Using heavy equipment to apply the
reagent directly to portions of the material would perform
both treatment scenarios designed for the SBMM site.
Maintenance on the equipment would be performed as
required and no significant amounts of maintenance
should be required elsewhere on the project.
Modifications would be determined by analytical results,
and should only be necessary in the volume or
technique of reagent application.
3.5.12 Demobilization/Site Restoration
Demobilization and site restoration are performed at the
conclusion of the treatment project, and would therefore
be a one time cost. Restoration of a mine site often
includes capping and revegetation; however, this is
beyond the scope of the treatment designs for the
SBMM site. For these cost estimates, it was assumed
that demobilization/site restoration would consist of
returning the equipment to the appropriate locations, and
dismantling the mixing facilities in KEECO's design. It
should be noted that boreholes in ECWI's design are not
cased wells and it was assumed that no abandonment
procedures would be required.
3.6 Vendor Cost Estimates
This section presents the cost estimates provided by the
technology vendors. The estimates were to be based on
the twelve cost categories specified above. In sections
where a cost was not estimated by the vendor, an
estimate has been included based on available
information.
3.6.1 E&C Williams Enthralf Technology
ECWI designed an in situ treatment that was based on
an application strategy related to the techniques used in
the treatability study. In this method, a truck-mounted
sonic drill rig would be used to drill into the pile and
inject the ENTHRALL® reagent at depth intervals that
were calculated to allow for complete permeation of the
material. ECWI would provide the chemical reagent and
serve as technical consultants, but would subcontract
the actual drilling and injection to Prosonic Drilling
Company, Inc (PDI) of Phoenix, Arizona. Drilling costs
in this estimate are based on information supplied by
PDI.
Based on previous experience, ECWI has estimated
costs on the assumptions that application at each
borehole will treat a radius of 15 feet, and that injection
to the average depth of the pile will provide sufficient
treatment. Two rigs would operate concurrently on the
heap, with one tanker truck supplying reagent to both.
The rig would drill to the specified depth, inject the
reagent and pull out the shaft, leaving a dispensable
drive point in each hole. The treatment design calls for
two eight-hour shifts on each rig per day. It was
assumed that boreholes could be left in the pile and
would not require abandonment procedures. Prior to
beginning full-scale application, on-site pilot injection
holes would be required to test the design assumptions.
Costs were estimated by ECWI for each of the specified
piles, based on the assumption that treatment of the
piles would take place sequentially, requiring only one
mobilization and demobilization cycle. The following
cost estimate is based on the 12 cost categories
described above, and was provided by ECWI, except
where otherwise indicated.
(1) Site Preparation: There is minimal site preparation
required for the working site since the drill rigs are
mobile and designed for field work. Prior to beginning
treatment at the site, ECWI personnel would obtain
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training in spill containment and remediation procedures
at ECWI's expense, and would visit the site to determine
requirements and costs to construct storage areas with
secondary containment for diesel fuel and the chemical
reagent. ECWI would provide poly storage tanks with
secondary containment as working storage for the
drilling/injecting teams at no charge to the project.
ECWI did not include a cost for the fuel and chemical
storage and secondary containments in their estimate.
Based on general information available from
miscellaneous vendor publications a rough estimate for
the fuel and reagent containers and secondary
containments has been made at $40,000.
(2) Permitting and Regulatory Activities: PDI is
licensed to work in California. Any additional required
business licenses or permits would be the responsibility
of ECWI, and they would have to be informed of such
requirements in advance of a site application with
sufficient lead time to procure the appropriate permits.
As discussed in Section 3.5.2, permit requirements are
very site specific, and may be modified by the existing
status of the project as a superfund site. ECWI has not
been to the site, or been informed of permitting
requirements so a cost for this budget item was not
included in their estimate.
RCRA and State regulations may have to be satisfied in
addition to Superfund requirements. Since the site is an
active Superfund site, it is possible that the technology
could be implemented under the umbrella of existing
permits and plans held by the site owner or other
responsible party. Added costs may result from
investigating the regulations and policies relating to the
location of the site. Based on past experience with
similar projects, the cost associated with permitting
activities was estimated at $20,000.
(3) Capital Equipment: Major equipment for the
treatment at SBMM would consist of two rotosonic drill
rigs and a fluid tanker with pumping equipment, both to
be supplied by PDI. Costs for use and operation of this
equipment was provided on a per-diem basis. The cost
per day for the rigs, including operators, is $5,300. The
cost for the fluid tanker, including an operator who would
transport and assist in injecting fluid is $750.00 per day.
The combined total costs for capital equipment would be
$1,633,500 according to the individual pile costs as
follows:
North Waste Pile
The estimated time for set up, drilling, injection of
reagent, moving between holes and tearing down is 160
man-days for the North Waste Pile, based on 12-hour
day maximums. This equates to $848,000 for drilling
equipment and $120,000 for the fluid tanker, totaling
$968,000 in capital equipment costs.
Waste Rock Dam
For treatment of the Waste Rock Dam, the estimated
time for set up, drilling, injection of reagent, moving
between holes and tearing down is 110 man-days,
based on 12-hour day maximums, which would amount
to $583,000 for drilling equipment and $82,500 for the
fluid tanker, totaling $665,500 in capital equipment
costs.
(4) Start-up and Fixed Costs: This category typically
includes mobilization costs and initial supplies to begin
operations. Mobilization costs to transport the drill rigs
and support equipment from PDI's office in Arizona to
the site would be $25,000. Mobilizing ECWI's tanks and
other equipment to the site would cost another $20,000,
bringing the total to $45,000.
(5) Labor: The treatment design calls for two shifts per
day. The term "days" in the labor costs refers to man-
days consisting of 8 hours. Labor costs for the crews
who run the rigs have been included in the
subcontractor's costs for the rigs under capital
equipment. ECWI would also provide labor, which
would include ten full-time workers with regular
supervisory visits from ECWI management. ECWI
would also contract professional assistance, including
geologists and project managers. A safety officer would
be appointed for on-site processing periods, and ECWI
would be responsible for ensuring that site personnel
were current in the 40 Hour HAZWOPER training.
ECWI considers the cost of safety training to be an
overhead expense and not a cost the project would pay.
Workers would be employed to work 8-hour days at an
hourly rate of $15 plus $80 per diem. [Note: An hourly
rate of $15 hour (loaded) is considered low. Anticipate
higher labor rates. Also, a supervisor will be required at
a higher rate.] Three professionals would be hired at the
rate of $150 per hour, but would only be needed for 2
hours a day, and would not be required for the entire
duration of the project. The per diem rate for the
professionals would be $100 per day. The combined
labor total is $903,300, which breaks down as follows:
North Waste Pile
The required ten workers for 160 days would cost
$320,000. Three additional professionals for two hours
per day, plus per diem, for 100 days would add another
$120,000 in consultation fees. The wages for the PDI
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drilling crew were included in the cost of the rig, which
was listed under capital costs, but an additional per diem
of $85.00 for each member of the four-man crew over
the period of 160 days would add $54,400. Providing for
shift travel for off-work days at $2,500 every ten days
equals $40,000. The total labor costs would equal
$534,400.
Waste Rock Dam
Ten workers for 110 days would cost $220,000. Three
additional professionals would be needed for an
estimated 70 days for two hours per day with per diem,
which would add another $84,000 in consultation fees.
The wages for the PDI drilling crew were included with
the rig under capital costs, but an additional per diem of
$85.00 for each member of the four-man crew over the
110 days period would add $37,400. Providing for shift
travel for off-work days at $2,500 every ten days equals
$27,500. The total labor costs would equal $368,900.
(6) Consumables and Supplies: Costs predominately
consist of the chemical reagent. Additional costs also
include diesel fuel, an expendable drive point for each
borehole and a small quantity of other supplies
necessary for administrative and safety concerns. The
unspecified supplies would constitute a very minor cost
and are not detailed here.
The required quantity of reagent has been determined
by 1:10 w/w ratio of reagent to material. The weight of
the material was calculated by multiplying the volume of
each pile by a typical density for a mixed soil type, 1.5
tons/cubic yard. If the density of the material in the pile
were determined to be higher, then more reagent would
have to be applied to maintain the same ratio. The
ENTHRALL® addition rate was determined from its
weight of 9.2 pounds/gallon, which converts to 217.39
gallons per ton of reagent.
Diesel fuel usage was estimated at 100 gallons/day for a
total of 110 days. Fuel costs are highly variable, but
based on an anticipated maximum of $2.00/gallon, this
brings the total diesel cost to $22,000.
The expendable drive points, which would be required
for drilling and would be left in the borehole, cost $14
each. Based on the assumption that each borehole will
treat an area with a radius of 15 feet, the number of
boreholes that would be required to inject the reagent
into each pile was calculated from the specified surface
areas. The category total costs would be $57,008,477
for the reagent and $50,840 for other supplies and
consumables.
North Waste Pile
Applying the ENTHRALL® reagent at a 1:10 w/w ratio to
the 1,315,500 tons of material in the North Waste Pile
would require 28,597,826 gallons which would cost
$34,889,348. This equates to a reagent cost of $26.52
per ton of material. If the density of the material in the
pile was determined to be higher than 1.5, more reagent
would have to be applied to maintain the same ratio.
Based on a density of 1.7 tons per cubic yard, the cost
would be $39,541,261.
The surface of the North Waste Pile was specified as
approximately 894,000 square feet. This would require
960 boreholes, each of which would be 25 feet deep
based on the average depth of the pile being 26.5 ft.
The cost of 960 expendable drive points, at $14 each,
would be $13,440.
Waste Rock Dam
Applying the ENTHRALL® reagent at a 1:10 w/w ratio to
the 834,000 tons of material in the Waste Rock Dam
would require 18,130,435 gallons which would cost
$22,119,130. This equates to a reagent cost of $26.52
per ton of material.
The surface of the Waste Rock Dam was specified as
being approximately 1,034,000 square feet. This would
require 1,100 boreholes, each of which would be 15 feet
deep based on the average depth of the pile being 14.5
ft. The cost of 1,100 expendable drive points, at $14
each, would be $15,400.
(7) Utilities: Electricity and water are usually the
primary utilities required for a remediation project. An
overall electrical requirement was estimated at
$500/month for four months, or $2,000. Incidental
amounts of water would be required for cleaning and
human usage, but the cost should be small and was not
included in the estimate.
In order to have a night shift running, a light plant would
need to be provided, and could be rented for $175 per
day. A reduced cost for lighting may be achieved if the
commercial power grid is accessible from the treatment
site. Portable generators may provide electricity for
incidental usage also, but access to the commercial
power grid is preferred. Portable toilets should be
provided for field workers, and can be rented for $65 a
month, which would total $520 for the life of the project,
treating both piles.
North Waste Pile
Utilities for the project were not separated by piles with
the exception of light plant rental, which would cost
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$14,000 for the 80 calendar days that would be required
for the North Waste Pile.
Waste Rock Dam
Running the light plant on the Waste Rock Dam for the
duration of treatment application, 55 days, would run
approximately $9,652.
(8) Effluent, Treatment and Disposal: In this in situ
application of the technology, no effluent requiring
treatment or disposal would be generated.
(9) Residuals, Shipping and Disposal: As this is an in
situ technology, no residuals requiring treatment or
disposal would be anticipated.
(10) Analytical Costs: Further investigation of the site
would be required in order to define required monitoring
parameters. Assuming that mercury is the only
constituent requiring analysis, and that TCLP or SPLP
followed by cold-vapor analysis is to be performed, the
cost for each sample including the fees for a one-week
turnaround time should be approximately $200 for each
sample. A flow model would be used to estimate the
time for the reagent to permeate the material and for the
treatment reaction to occur. Sampling of treated material
would begin on a weekly basis when the model indicated
that the treatment was complete. ECWI would be
responsible for sample collection and for getting the
analysis performed Copies of the analytical report would
be sent from the laboratory to a designated third party
for review and storage, while the originals would be
maintained by ECWI until the treatment phase of the
project was closed. Based on the $200 per sample,
ECWI estimated the analytical costs to be approximately
$10,400. This was based on approximately one year of
weekly sampling, with one target metal of mercury and a
one-week turnaround on results.
(11) Maintenance and modifications: Maintaining
equipment owned by ECWI and PDI would be the
responsibility of the respective owners. No modification
of equipment is anticipated; however, modifications to
the process may be found necessary in technique or
reagent application, but these should not significantly
impact costs. ECWI allocates approximately
$25,000/year for maintenance.
(12) Demobilization/Site Restoration: ECWI
estimated the cost of demobilizing their own equipment
from Clear Lake back to Summerville, SC to be $20,000.
Demobilizing PDI's rigs would cost approximately
$25,000. No site restoration costs were estimated.
3.6.2 KEECO's SME Technology
KEECO refers to the approach that was designed for
use at the SBMM site as a modified ex situ process, in
that the material is removed from its location for
treatment, but only to an adjacent on-site facility for the
addition and mixing of the reagent. The costing is based
on a design that includes building a mixing facility
adjacent to each of the piles. Each facility would consist
of a concrete mixing corral with raised side berms inside
an enclosed portable building. Each facility was
designed for an hourly throughput of 300+ tons per hour
per facility and would be equipped with an air handling
unit, reagent delivery silos and a water storage tank to
wet the soils in order to prevent fugitive dusts during the
mixing process.
Excavators and dump trucks would be employed to
move the material from the pile to the mixing facility. The
material would be dumped in the mixing facility where a
measured amount of reagent would be applied from the
silo. Water would be applied to control fugitive dusts as
a front end loader mixed the reagent into the material.
In KEECO's design, the treated material is considered
"residual" and costs for returning it to the heap and
compacting it after treatment has been performed are
covered under the residuals category.
KEECO used a typical density for mixed soil types, 1.5
tons per cubic yard, to calculate the weights that were
used in the cost estimate. The calculated weights are
1,315,500 tons, in the North Waste Pile and 834,000
tons in the Waste Rock Dam. The cost estimate
provided by KEECO was based on the combined mass
of the two piles; therefore figures are presented for
treatment of 2,149,500 tons without differentiating time
and effort between the two piles. The treatment time
required to treat the entire mass is 247 working days,
based on an average daily throughput of 8,700 tons per
day.
The cost estimates for KEECO's application were based
on the assumption that mixing operations would be
scheduled to operate on a 16 hours (consisting of two 8-
hour shifts) per day, five days per week basis. A daily
use factor of 90 percent of the design capacity was used
based on the simplicity of the operation and reliability of
the standard equipment selected. Based on an
expected daily throughput of 8,700 tons per day, it is
estimated that the mixing operations will be completed in
247 working days (one year). An additional training
period of five days prior to treatment beginning and ten
days at the end for demobilization should also be
included in the schedule.
3-7
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The cost estimate provided by KEECO is based on a
preliminary design, which was produced without the
benefit of data from a pilot project; therefore, cost ranges
presented in this estimate may be wider than would
normally be expected in a fully developed cost estimate.
It should also be noted that SME reagent use rates in
this cost estimate were taken from the lab scale
treatability study, whereas historically, field use rates are
considerably lower than lab use rates resulting in
reduced reagent costs.
The cost estimate has been developed according to the
twelve categories specified in Section 3.2 above.
(1) Site Preparation: The primary preparation cost
would be the construction of the mixing facilities, which
was estimated at $420,000 each. The total site
preparation costs for facilities at both piles would be
$840,000.
(2) Permitting and Regulatory Activities: The cost for
State and Federal air treatment permits for the mixing
facilities is estimated to be $20,000 including labor for
data review, estimating emissions and permitting fees.
Construction permits were estimated to be $2,500 and
permitting costs for onsite disposition of the treated
material were estimated at $40,000. Costs for
permitting, regulatory activities, monitoring and waste
transportation and disposal are highly dependent on the
site, and as such could be significantly higher than the
estimated total of $62,500.
(3) Capital Equipment: Heavy equipment would be
rented or leased for the project. The following
equipment list includes monthly rental rates for each
piece of equipment: 2 excavator/backhoes at $15,000, 2
10-KW generators at $1,000, 4 dump trucks at $4,000, 4
front end loaders at $14,000 and 1 water truck at
$3,000. The total monthly equipment rental would be
$107,000, bringing the total for the estimated 12-month
project duration to $1,284,000.
(4) Start-up and Fixed Costs: This category includes
transportation of personnel and equipment, safety
training, working capital, insurance, monitoring, and a
contingency fund. Transportation costs for 14 pieces of
rental equipment were assumed to be $7,000. The
transportation of personnel cost was based on the
purchase of six $1,200 round trip airline tickets for a total
of $7,200. The remaining project staff would be hired
locally. Safety training would consist of a 40 hour
HAZWOPER course, which each member of the site
team would be required to complete. Based on a crew
size of 32 persons, the estimated cost of the training
would be $57,000. Total transportation and training
costs are estimated at $71,200.
Working capital consists of the costs of borrowing capital
for operating supplies, utilities, and labor necessary to
keep the project running without financial constraints.
Working capital for this project is estimated at
$1,000,000, based on maintaining 2 months of payroll,
and sufficient inventory for all other items. The cost of
capital is assumed to be 9% of the working capital,
making the estimated working capital cost $90,000 per
annum. Insurance was estimated at $50,000 per year
and a contingency factor should be included in the
budget to cover unforeseen events, for which KEECO
estimated $150,000 as an appropriate figure.
Environmental monitoring is assumed to be required for
fugitive dust emissions from the mixing facility only, and
was estimated to cost $6,000. The combined total of
costs in this category is $367,200.
(5) Labor: It is assumed that treatment operations
would be conducted over 247 days, working in two
shifts, for a total of 16 hours per day, 5 days per week.
Total labor cost for treatment is estimated to be
$2,986,800. Table 3-1 gives a breakdown of the
number and types of employees, expected pay rates
and the number of hours that would be required for each
type of labor.
3-8
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Table 3-1. Labor Unit Costs.
Description
Site Manager
Foreman
Truck Driver
Excavator Operator
Front End Loader Operator
Water Truck Driver
Laborer
SSHO
Facility Operator
Number of
Persons
1
2
8
4
8
2
4
1
2
Cost Per
Hour
$90
$55
$40
$45
$45
$40
$35
$65
$40
Total Hours
2096
4192
16768
8384
16768
4192
8384
2096
4192
TOTAL
Total Cost
$188,640
$230,560
$670,720
$377,280
$754,560
$167,680
$293,440
$136,240
$167,680
$2,986,800
(6) Consumables and Supplies: The most significant
cost in the treatment estimate is the chemical reagent.
The material requires a 5% by weight add ratio. The
estimated cost of $23,107,000 assumes that a
temporary batch mixing plant would be established on
site to defray excessive transportation costs. This also
assumes that utilities are available to support the
operation of a temporary batch mixing plant.
Diesel fuel is required to operate the earth moving
equipment and generators. It was estimated that fuel
consumption would be 50 gallons of fuel per piece of
equipment per day. This amounts to 650 gallons of fuel
per day. Using a rate of $1.40 per gallon, daily fuel cost
was estimated to be $910. Assuming 247 operating
days, total fuel costs were estimated to be $224,770.
Supplies consist of operating supplies and SME reagent.
Operating supplies consist of items such as safety
equipment, PPE, office supplies, custodial supplies,
potable water and the like. Operating supplies were
estimated at 1 percent of annual labor, or $29,600.
Combining the three costs for consumables and supplies
brings the category total to $23,361,370 for
consumables and supplies.
(7) Utilities: Water is used to minimize fugitive dust
emissions during operations. Assuming a water use rate
of 2 percent of the volume being treated, and a cost of
$2 per 1000 gallons, the total cost of water for the
project would be estimated at $20,600. Electricity would
be required, but incidental usage should not add
significant costs.
(8) Effluent, Treatment and Disposal: The treatment
process produces no effluent, however, cleaning PPE
and equipment may produce wash water that requires
decontamination. It was assumed in the cost estimate
that this would be a small enough quantity that any
associated costs could be absorbed into the overall
project costs.
(9) Residuals, Shipping, & Disposal: Residuals from
the SME process can include treated waste, waters and
sludge and waste from decontamination activities. It
was estimated that treated material could be moved
from the treatment facility, replaced and compacted
onsite for $3 per ton or $6,448,500 for the entire project.
This figure includes the equipment and labor used to
return the treated material to the pile (not included in the
previous cost sections) as KEECO differentiated
treatment from residuals handling in these costs. It is
expected that the project would generate one drum of
contaminated PPE each week. Assuming a disposal
cost of $500 per drum, the disposal cost for PPE was
estimated at $26,000. The total cost of residuals, waste
shipping, handling and transport was estimated to be
$6,474,500.
(10) Analytical Services: It was assumed that 4
composite samples would be taken each day: one per
shift per facility. It was also assumed that the sample
number would be increased by 10% to provide QA/QC
samples. With an assumed cost of $90 per sample to
analyze for leachable mercury, the estimated cost for
analytical services is $97,800.
(11) Maintenance and Modifications: Maintenance
costs vary with the nature of the wastes, and the time
between failures of the equipment. For the purposes of
this cost estimate, these costs were assumed to be 2%
of the cost of facilities and equipment and were
estimated at $38,480.
(12) Demobilization/Site Restoration: It was assumed
that a total of 10 days would be required for
3-9
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demobilization activities. It was further assumed that the
entire project staff would be involved in the
demobilization effort. Demobilization efforts will include
facility dismantlement, equipment decontamination, and
transportation. It is assumed that demolition of the
mixing pads would not be required. Costs for the
demobilization effort were estimated at $157,000.
3.7 Cost Summary
Table 3-2 presents the summarized costs by category
for treating the SBMM piles. The volume of material at
the SBMM site is extremely high compared to most
waste sites, resulting in very large figures in the cost
estimates; however the cost per cubic yard of treated
material by either technology is in the low end of the cost
range for comparable stabilization technologies. A study
conducted for EPA in 1997 entitled "Recent
Developments for In Situ Treatment of Metal
Contaminated Soils" reported that, according to vendors
of stabilization technologies, in situ applications range
from $20 to $40 per cubic yard for treatment under
optimum conditions, ranging upwards to $200 to treat
high concentrations at great depths.
The cost estimates were developed independently by
the vendors (with additions as noted) and because of
differences in exclusions and assumptions, cannot be
used for direct cost comparisons, but do provide an
overview of cost magnitudes and a breakdown into cost
categories and percentages of total costs. KEECO
included working capital and contingency financing in
their startup costs, and ECWI did not include these in
their estimate, but they would be relevant costs to any
Table 3-2. Cost Summary.
ITEM
Site Preparation
Permitting and Regulatory
Equipment
Startup and Fixed
Labor
Chemical Reagent
Other Supplies & Consumables
Utilities
Effluent Treatment & Disposal
Residuals and Waste Handling
Analytical
Maintenance & Modifications
Site Demobilization
Total Operating Costs
Cost per Ton
ECWI
Category
Cost*
$40,000**
$20,000**
$1,633,500
$45,000
$903,300
$57,008,000
$50,840
$26,145
$0
$0
$10,400
$25,000
$45,000
$59,807,000
$27.82
Percent of Total
Cost
0.1%
0.0%
2.7%
0.1%
1 .5%
95.3%
0.1%
0.0%
0.0%
0.0%
0.0%
0.0%
0.1%
100.0%
KEECO
Category
Cost*
$840,000
$62,500
$1,284,000
$367,200
$2,986,800
$23,107,000
$254,370
$20,600
$0
$6,474,500
$97,800
$38,480
$157,000
$35,690,000
$16.60
Percent of Total
Cost
2.4%
0.2%
3.6%
1 .0%
8.4%
64.7%
0.7%
0.1%
0.0%
18.1%
0.3%
0.1%
0.4%
100.0%
*Costs rounded to a maximum of five significant digits.
**Costs for this category not provided by vendor; assumed value as described in Section 3.6.1.
3-10
-------
project. The largest area of discrepancy, residuals
handling, is a legitimate difference between the two
processes, however, as the ENTHRALL® process would
not generate residuals whereas handling treated
material is a major element of KEECO's SME process.
It is clear for both treatments that the chemical reagent
is the largest cost factor, at $26,700,000 (68% of total
costs) for SME and $57,008,000 (93.5% of total costs)
for ENTHRALL®. The vendors based their application
ratios on the amounts used in the treatability study, and
if it was determined that the quantity required for a field
application was reduced, then associated reagent costs
would also be lower. Neither vendor indicated any cost
reduction for high volume usage.
The equipment cost of $1,633,500 for the Enthrall®
treatment constitutes only 2.7% of the total, but is the
second highest cost category. KEECO's process is
unusual in that it requires residual handling to the extent
that it is the second highest cost factor, lowering the
equipment costs to the fourth highest category despite
the $1,283,000 estimated cost.
3-11
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Section 4.0
Treatment Effectiveness
4.1 Pre-demonstration Studies
Pre-demonstration studies were undertaken to: (1) attain
a suitable test material with sufficient mercury
leachability for treatability testing; (2) elucidate the
mechanism(s) of mercury leaching to develop
appropriate testing procedures; and (3) provide samples
of material to vendors, along with the testing criteria, to
optimize their processes prior to the large-scale
treatability studies.
Leachability methods for solid waste were developed to
simulate the leaching behavior of the material when
subjected to specific solutions and conditions. For
example, the Toxicity Characteristics Leachability
Procedure (TCLP) and the Synthetic Precipitation
Leachability Procedure (SPLP) were developed for
simulating the leaching conditions for landfilled wastes.
The Meteoric Water Mobility Procedure (MWMP) and
the Humidity Cell Procedure were developed specifically
to simulate the conditions encountered by mining waste.
Each leachability procedure may provide different
results, based on the leaching fluids used, duration,
leachate preparation, and nature of the waste material.
In order to quantitatively evaluate the effectiveness of
the stabilization technologies tested for the mercury
contaminated SBMM material, it was necessary to
identify both a suitable material and leaching protocol.
The objectives for the study required a material with
leachable levels of mercury so that a reduction of 90%
from a control could be observed. Furthermore, the
leaching protocol would need to simulate the generation
of mercury from the SBMM material so that the
stabilization technologies could appropriately control the
types and levels of mercury being generated from the
site.
4.1.1 SPLP Characterizations
Leachability characterizations of materials from several
locations at the SBMM site using the SPLP method
demonstrated generally low overall mercury leachability.
Figure 4-1 is an aerial photograph of the SBMM
depicting the locations of samples collected for SPLP
characterization. Table 4-1 presents the SPLP results
as well as the whole rock mercury values. The levels of
leachable mercury generated by the SPLP method for
the tested materials were too low to be used in this
technology evaluation. SPLP leachability was low even
for materials exhibiting high whole rock mercury values
of 1,000 mg/Kg.
July 10, I 993
Figure 4-1 . Locations of samples from SBMM site.
The lack of appreciable leachable mercury from SBMM
materials despite high levels of whole rock mercury
prompted additional studies to determine a suitable
material and leaching protocol for the technology
evaluation. Furthermore, the additional studies
investigated possible mechanisms of mercury
leachability from SBMM materials.
4-1
-------
Table 4-1. SPLP Leachability Results from Various SBMM Materials.
LOCATION
#1
#2
#3
#4
#5
#6
#7
#8
#9
#10
Waste Rock- Shoreline Material #1 (Middle Shoreline Pile)
Waste Rock - Shoreline Material #2 (Northwest Pit Shore)
Waste Rock - Shoreline Material #3 (West Shoreline Pile)
Drill Cuttings MW1 1 D 0 to 25 feet
Drill Cuttings MW1 1 D 25 to 45 feet
Drill Cuttings MW15D 0 to 20 feet
Mercury Ore (South Hill White Pile)
Waste Rock (South Hill Waste rock Pile)
Waste Rock (North Side Gray Pile)
Waste Rock (North Side Waste rock Pile)
Total
Mercury
762 mg/Kg
37.5 mg/Kg
175 mg/Kg
4 1.9 mg/Kg
58.5 mg/Kg
76.1 mg/Kg
1 000 mg/Kg
905 mg/Kg
35 mg/Kg
484 mg/Kg
SPLP Mercury
ND (0.2) ug/L
ND (0.2) ug/L
ND (0.2) ug/L
ND (0.2) ug/L
ND (0.2) ug/L
1 .39 ug/L
19.9 ug/L
10.5 ug/L
0.47 ug/L
9.84 ug/L
4.1.2 Leachability Studies
Roasted tailings from the site were used in a series of
studies to determine mechanisms of mercury
leachability. The roasted tailings are material derived
from the retorting of the ore. This material was used
because it exhibits consistent levels of whole rock
mercury and constant particle size.
Replicate analyses using the SPLP method on the
roasted material revealed consistent whole rock mercury
values, but highly variable SPLP leachates (Table 4-2).
Visual observations of the leachate from the SPLP
extraction revealed a correlation between the visual
turbidity of the sample and the concentration of mercury.
This association prompted a more thorough evaluation
of the relationship between leached particulates and
extractable mercury.
Table 4-2. Replicate SPLP Analyses on Roasted
Tailings
Replicate
SBMM-RF#1
SBMM-RF#2
SBMM-RF#3
Total Hg
(mg/Kg)
25.7
26.6
37.8
SPLP Hg
(ug/L)
60
195
487
The original roasted tailings material tested in triplicate
was further studied. Triplicate samples of the roasted
tailings were analyzed for total mercury (whole rock) and
SPLP extractions. The extracts were filtered through a
0.7um filter (standard for the method) and analyzed for
SPLP Hg, pH, total solids, and turbidity. The remaining
extract was filtered through a 0.45um filter and analyzed
for the same analytes, as well as a 0.2um filter. The
experiment resulted in the generation of nine leachate
samples (triplicate analyses at three levels of filtration).
Results form the experiment (Table 4-3) indicates that
total mercury was consistent between the three
replicates (as observed in the original analysis). SPLP
mercury at the standard filtration (0.7um) was lower but
exhibited much lower variability as compared to the
original triplicate analyses. SPLP mercury at the 0.45um
and 0.2um levels produced ND at the 1.0 ug/L level.
The results from the study suggested that leachable
mercury is associated with particulates. Furthermore,
there is a strong association between the turbidity in the
sample and the level of filtration. Although the finer
filters produced non-detect values, there is a correlation
between the SPLP mercury and turbidity. The results
from this experiment prompted an additional experiment
to determine the relationship between particle size,
turbidity, and leachable mercury.
Results from the test are presented in Table 4-4. There
is a strong relationship between level of filtration,
turbidity, and mercury content. Furthermore, the
relationship between turbidity and mercury content is
illustrated by plotting the mercury values for the filtered
samples from both the SPLP and modified MWMP test
(Figure 4-2). There is a high correlation between the
turbidity of the sample and the mercury content of the
leachate. This suggests that mercury in leachate
samples is associated with particulates of various sizes,
and is not predominately found in a dissolved state.
4-2
-------
Table 4-3. Results of Triplicate SPLP Leaching Experiment
Replicate 1
0.7|jm
0.45|jm
0.2|jm
Replicate 2
0.7|jm
0.45|jm
0.2|jm
Replicate 3
0.7|jm
0.45|jm
0.2|jm
Total Hg Reporting
(mg/Kg) Limit
(mg/Kg)
24 0.049
23 0.052
22 0.049
SPLP
(M9/L)
3.0
ND
ND
5.2
ND
ND
3.6
ND
ND
Reporting
Limit
(M9/L)
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
1.00
PH
(SU)
6.15
3.26
2.85
7.09
3.63
3.19
6.89
3.85
6.13
Total
Solids
(mg/L)
64
48
58
24
24
10
34
26
ND
Turbidity
(NTU)
29.2
7.24
0.35
40.2
0.58
0.43
36.1
0.59
0.49
5 10 15
Leachable Hg (ug/L)
20
Figure 4-2. Turbidity and leachable mercury
from SPLP and MWMP tests.
Table 4-4. Results from the Modified MWMP Leachate
Test with Variable Filtration
Filtration
Level
Unfiltered
25 |jm
8 |jm
2.5 |jm
1 |jm
0.7 |jm
Hg
UQ/L
402
18.2
7.4
1.2
0.7
0.6
PH
4.07
4.31
4.25
4.25
4.25
4.65
Turbidity
(NTU)
362
140
64
3.5
0.76
1.17
All filter blanks, Hg = ND
0.7 |jm filter blank had turbidity = 0.28
4.7.3 Geochemical and Mineralogical Evaluation of
Particulates
A mineralogical and geochemical study was performed
at the City College of New York to characterize the
particulate fractions generated during leaching and to
identify potential mechanisms for release and transport.
Roasted tailings were placed in distilled water for three
weeks without agitation. The water immediately became
4-3
-------
cloudy, and the degree of turbidity appeared to per sist
unchanged throughout the three week period.
Characterizations were performed both on fines that
were suspended in the water and on particles re-
suspended by stirring the mixture. Both the suspended
particles and the particles re-suspended (stirred) are
termed auto-released solids due to their ability to easily
dissociate from the solid matrix.
The structure of auto-released solids was determined by
using standard techniques for the x-ray analysis of clay-
sized particles. Preliminary study of a randomly oriented
sample demonstrated that the auto-released particles
belong primarily to the clay mineral family. Glycolation
treatment revealed that the auto-released particles
contain chlorite-smectite interlayer clays. The clay thus
possesses both a filled metal-hydroxide layer and a
partially filled expandable interlayer.
Sieving and mounting procedures were used to estimate
the quantity of mercury on particles of various sizes.
The procedure involves entrapping mercury on sieves of
varying sizes using a Mylar filter to fix the particles to the
sieve material. The mylar-shielded samples were then
analyzed using a Philips 1410 series x-ray fluorescence
spectrometer and counting times of 400 seconds on
both peak and background. The results are plotted as
counts-above-background adjusted by weight using the
relationship:
Mercury-Adsorbed Clay
C
adjusted
f _f
peak background
W
Where: peak is the number of counts on the mercury
peak using a LIF200 crystal,
nd js tne number of counts at ± 1 degree
of the peak maximum, and
W is the microgram weight of the clay.
The adjusted counts indicate the distribution of mercury
within the sample irrespective of the amount captured on
a given sieve. Since the actual weight of sample is
greater toward the larger sieve sizes, the relative error
increases as the sieve-size decreases. The plot of this
distribution (Figure 4-3) indicates that the bulk of the
mercury is carried by the 10 to 20 micron clay fraction,
but that a given amount of mercury is present in all sieve
fractions, including the <0.45um set. The results
establish that clay is auto-released from roasted tailings.
o
o
0
A A
0
0.01 0.1 1 10 100
Sieve Size (microns)
^ Stirred A Suspended
Figure 4-3. Mercury adsorbed on clay particles as
indicated by the number of x-ray counts
adjusted by the sample.
4.1.4 Extended Leachability Study
Three SBMM solid matrices were evaluated by a
modified MWMP (Meteoric Water Mobility Procedure)
over various time intervals to assess the change in
leachability of mercury over time. The study was
conducted to determine if dissolved mercury is
generated when leaching times and exposure to
aqueous solutions is extended. Conventional leaching
procedures require only a 24-hour exposure to the
leaching agent. The samples chosen for this exercise
consisted of: (1) a roasted tailings composite, (2) waste
rock (shoreline #1) form the middle shoreline pile, and
(3) waste rock (# 10) from the north side waste rock pile.
Whole rock mercury concentration of each matrix are 25
ppm for the roasted tailings, 762 ppm for the shoreline
#1, and 484 ppm for the mine tailings #10.
The modified MWMP utilized a 1:1 ratio of solid material
to leaching medium (deionized water) placed in a
column-type apparatus and exposed to the leachate in a
single pass manner over a 24-hour period. After each
24-hour period the leachate volume was collected and
reapplied to the top of the column. The solution was
passed back over the solids in the column until the end
of the test period (for 72 hour tests) or for five days
(Monday-Friday). For the 1, 2 and 4 week test periods,
the solution was allowed to remain in contact with the
solids over the weekend (with the column top covered),
and then drained over 24 hours starting again on
Monday.
4-4
-------
The following tests were performed:
Matrix # of Tests Test Duration
Roasted tailings
5 24 hrs
72hrs
1 week
2 weeks
4 weeks
Waste Rock (spl#1) 2
Waste Rock (spl#10) 2
24 hrs
2 weeks
24 hrs
2 weeks
The leachate from each test was split, with one-half of
the sample set-aside for unfiltered analyses, while the
second-half of the leachate sample was filtered through
a 0.45|jm filter. The leachate samples (unfiltered and
filtered) were analyzed for the following analytes:
mercury, sulfate, pH, turbidity, and total solids.
Analytical results from the study are presented in Table
4-5. For the roasted tailings, and as in previous studies,
mercury appears to be associated with the particulate
fraction (>0.45um). For the unfiltered samples, mercury
leachability is lower for the two week and 4 week
samples. Mercury leachability, therefore, does not
increase with longer leaching cycles, and actually
decreases. For the filtered samples, mercury
concentration is low and variable. There is no indication
that extended leaching results in the generation of
significant dissolved mercury.
Waste Rock spl#1 exhibited the highest leachable
mercury concentration of the unfiltered samples.
Table 4-5. Results from the Extended Leachability Study
Although high particulate mercury concentrations were
encountered, filtered mercury was low. The sample
completely dissociated after five days into a hydrous
clay, necessitating cessation of the leaching tests. The
hydrous clay was submitted to CCNY for
characterization. The sample was characterized as a
mixture of two clays with properties similar to the auto-
released clays from the first roaster fine study.
Furthermore, the sample contained very high mercury
content as measured by X-ray fluorescence. The
complete dissociation of the sample and the presence of
high mercury content in the clay fraction provide further
evidence for a particulate transport mechanism.
Extended leaching of the waste rock spl #10 failed to
provide significant concentrations of mercury in either
the unfiltered and filtered fractions. There is some limited
evidence that mercury content decreases over time in
both fractions.
4.1.5 Conclusions from Leachability and
Characterization Studies
The following conclusions are based on the results from
the previously discussed studies:
• Mercury is found associated with particulates that
auto-release from SBMM material and can remain
suspended, and therefore mobile, in solution. There
is no strong evidence from any of the leaching
studies that a dissolved mercury fraction exists in
the leachate.
• There may be clays in the material that are easily
dissociable, contain mercury, and can be suspended
and transported in an aqueous medium. Since the
clays are expanded layer smectites, the mercury
Sample
Roasted Tailings 24 hrs
RoastedTailings 72 hrs
Roasted Tailings 1 week
Roasted Tailings 2 weeks
Roasted Tailings 4 weeks
Waste Rock (spl #10) 24 hrs **
Waste Rock (spl #10) 24 hrs
Waste Rock (spl#10) 2 Weeks
Unfiltered
Hg
(ug/L)
20.0
14.0
16.0
8.3
2.5
96.1
9.0
7.5
PH
6.86
7.52
7.25
7.38
7.18
3.11
3.04
3.15
Sulfate
(mg/L)
9.7
10
10.4
10.2
15.1
7010
2630
2360
Turbidity
NTU
434
154
188
90.1
99.6
155
4.9
8.15
Total
Solids
(mg/L)
333
250
190
220
200
9110
3440
3300
Filtered (0.45 urn)
Hg
(ug/L)
3.30
2.30
1.50
ND (1.2)
8.3
2.20
6.00
ND (2.5)
PH
7.26
7.4
7.71
7.12
7.32
3.13
3.09
3.24
Sulfate
(mg/L)
10.2
10.1
7.8
10.3
13.9
5270
2350
2210
Turbidity
NTU
19.4
5.77
4.42
25.1
36.2
0.42
0.52
0.1
Total
Solids
(mg/L)
NA
NA
NA
NA
NA
NA
NA
NA
** spl #1 was observed to completely dissociate to a clay-mud after approx. 5 days
NA = Not Applicable
ND = Non detectable at level in parentheses
NR = Not Reported
4-5
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may be bonded within the interlayers. These clays
may be associated with the ore and rock, or may
exist as discrete deposits that were segregated
during the mining process.
• Mercury associated with the particulates may
undergo further chemical and biological diagenetic
changes in the groundwater and/or lake environment
that release dissolved mercury during transport.
• The remedial solution may require technologies that
can control the release of particulates from SBMM
materials.
• The leaching protocol for the stabilization evaluation
should simulate the generation of mercury-laden
particulates from a solid matrix.
4.7.6 Pre-demonstration Kinetic Column Studies
A kinetic column configuration was investigated as a
leaching protocol for evaluating the effectiveness of the
stabilization technologies. In the kinetic column,
leaching solutions are continuously passed over the
material. For this evaluiation material from the south
white gate pile ("mercury ore") and "waste rock" were
tested. For the mercury ore material, whole rock
mercury concentrations ranged from 300-1360 mg/Kg
and SPLP mercury concentrations as high as 113 ug/L
were encountered (Table 4-6). For the waste rock
material, whole rock mercury concentrations ranged
from 130 to 450 mg/Kg with leachable mercury below 10
ug/L in all three samples. Two kinetic column studies
were initiated for each of the materials. For one set of
experiments, leachant (15 L de-ionized water adjusted to
a pH of 5) was applied to the column in flow-through
Table 4-6. Mercury in Untreated Mercury Ore and
Waste Rock
Matrix
Mercury
Ore
Waste
Rock
Total Hg
(mg/Kg)
751
312
1360
447
441
130
SPLP Hg
(ug/L)
37
0.5
113
1.5
0.9
5.6
mode
as a single-pass leach. The second set of experiments
used approximately 15 liters of the solution in a recycle
mode. Leachate was analyzed for mercury both as in an
unfiltered sample and filtered through a 0.45um filter.
The results, presented in Table 4-7, indicated that: (1)
the flow-through method generated higher and more
consistent leachable mercury, (2) the unfiltered samples
contained significantly higher levels of mercury, and (3)
the mercury ore material generated significantly higher
levels of leachable mercury. Based on these results a
kinetic column leaching protocol using mercury ore
material from the site and focusing on control of the
particulate fraction would be relevant for evaluating the
performance of the stabilization technologies.
4.2 Project Objectives
For all MWTP and SITE projects, specific objectives are
defined in a Quality Assurance Project Plan (QAPP)
prior to the initiation of treatability studies or fieldwork.
The QAPP specifies the objectives to be achieved and
provides experimental design. This section states the
project objectives and summarizes each of the
experiments performed as part of the treatability study.
4.2.1 Primary and Secondary Objectives
Objectives are subdivided into two categories: primary
and secondary. Primary objectives are those goals of
the project that must be achieved in order to adequately
compare demonstration results with the claims made by
the developer(s). The analytical results and field
measurements required for achieving primary objectives
are referred to as critical measurements. Secondary
objectives are specified to obtain additional information
of interest about the technology, but are not imperative
for validating developer claims. The data and field
measurements required for achieving secondary
objectives are referred to as noncritical measurements.
Immobilization of mercury in material from the Sulfur
Bank Mercury Mine (SBMM) was the goal of the
treatments used in this treatability study. The objectives
of the study are to evaluate the technologies' ability to
achieve this end. Primary objective satisfaction was
evaluated by treating "mercury ore" material from the
site. The same testing process was applied to "waste
rock" material to achieve secondary objectives. The
actual testing procedures are described in their
respective sections below. The success of the various
treatments was evaluated by measuring the parameters
as specified in Table 4-8.
4-6
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Table 4-7: Kinetic Column Leachability Study
Unfiltered
<0.45|jm
Filtered
Leach Time
(days)
2
9
15
23
29
38
2
9
23
29
38
Hg in Mercury Ore Leachate (ug/L)
Recirculating
210
210
180
90
93
140
11
11
5.0
2.0
2.0
Flow-through
410
530
420
410
270
390
28
9.0
7.0
9.0
7.0
Hg in Waste Rock Leachate (ug/L)
Recirculating
0.6
0.3
0.4
0.8
0.1
0.2
ND
ND
ND
ND
ND
Flow-through
1.2
2.1
ND
1.0
ND
0.2
ND
ND
ND
ND
ND
4.2.1.1 Primary Objective
The primary objective of the treatability study was to
evaluate each technology's ability to immobilize, and
therefore reduce the leachability, of mobile mercury in
the SBMM mercury ore material. Mobile mercury is
defined in this project as the mercury associated with the
<25um filtered fraction. Previously discussed studies
revealed that particulates containing mercury are
released from SBMM materials and can become
suspended and therefore mobile in aqueous systems.
The <25um fraction was chosen based on the results
from the previous studies. Success at immobilizing
mercury was to be determined by comparison of the
amount of mobile mercury (<25um fraction) in each
treatment columns leachate to the amount of mercury in
leachate from untreated control columns. Each
technology and control was tested in triplicate. After
being loaded into columns and treated, the material was
leached daily with fresh deionized water, adjusted to a
pH of 5.0. The leachate was collected, measured,
filtered and analyzed weekly for the critical parameters
of dissolved and total mercury. The original design
called for a minimum of eight weeks of leaching. This
was extended an additional four-weeks for one of each
type of column during the study.
Each technology was evaluated to determine the
reduction in the cumulative mass of mercury in the
<25/j,m filtered leachate, relative to the control column
<25^m filtered leachates. The target reduction for the
treatments was 90%. Mercury mass was calculated
from leachate concentrations by multiplying the
concentration in micrograms per liter by the volume of
total sample collected each week (in liters), resulting tin
the total micrograms leached from each column.
Percent Mercury Reduction was determined from the
difference between the amounts of mercury leached
from treated columns and control columns as follows:
Mercury Massr
1 00
Mercury Mass
(controi)
Where Mercury Mass is the summation of the average
weekly mercury mass for each treatment or control over
the 12-week test.
Mercury mass was determined for each column each
week and then averaged for that week and summed to
derive the total mass of mercury leached for each
treatment or control. Leachate characteristics were also
collected for turbidity, pH, redox potential, sulfate,
sulfide, conductivity, alkalinity/acidity and the metals
arsenic, iron and antimony. Primary and secondary
objectives of the treatability study are summarized in
Table 4-8. The table gives a description of the objective
and the method by which each was evaluated.
4-7
-------
Table 4-8. Treatability Study Test Parameters
Matrix
Kinetic Test Column
Leachates -
mercury ore material,
treated and untreated
controls
Mercury ore material
prior to leaching,
treated and untreated
Mercury ore material
after leaching, treated
and untreated control
Kinetic Test Column
Leachates
Waste rock material,
treated and untreated
controls
Waste rock material,
prior to leaching,
treated and untreated
Waste rock material
after leaching, treated
and untreated control
Parameter
Mercury-dissolved
(<0.45um)
Mercury-mobile
(<25um)
Leachate volume
Metals (As, Fe, Sb)
Sulfate
Sulfide
Alkalinity
Acidity
Turbidity
PH
Conductivity
Redox potential
SPLP (Hg/As/Sb/Fe)
X-ray diffraction
X-ray fluorescence
SEM/EDS
Humidity Cell Test
X-ray diffraction
X-ray fluorescence
SEM/EDS
Mercury-dissolved
Mercury-mobile
Leachate Volume
Metals (As, Fe, Sb)
Sulfate
Sulfide
Alkalinity
Acidity
Turbidity
PH
Conductivity
Redox potential
X-ray diffraction
X-ray fluorescence
SEM/EDS
SPLP
X-ray diffraction
X-ray fluorescence
SEM/EDS
Classification
Non-critical
Critical
Critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Non-critical
Type
Analytical
Analytical
Field
Analytical
Analytical
Analytical
Analytical
Analytical
Field
Field
Field
Field
Analytical
Mineralogical
Mineralogical
Mineralogical
Analytical
Mineralogical
Mineralogical
Mineralogical
Analytical
Analytical
Field
Analytical
Analytical
Analytical
Analytical
Analytical
Field
Field
Field
Field
Mineralogical
Mineralogical
Mineralogical
Analytical
Mineralogical
Mineralogical
Mineralogical
Purpose
Primary objective: evaluating
leachable Hg reduction
Secondary objective: Evaluate
leachate quality after treatment of
primary test matrix
Secondary objective: evaluate
impact of treatment on
conventional leachability
Secondary objective: evaluate
mineralogical changes of solids
after treatment
Secondary Objective: assess
weathering effects on treated
material
Secondary objective: evaluate
mineralogical changes of solids
after leaching
Secondary objective: evaluate Hg
reduction in second matrix
Secondary objective: Evaluate
leachate quality after treatment of
secondary test matrix
Secondary objective: evaluate
mineralogical changes of solids
after treatment
Secondary objective: evaluate
impact of treatment on
conventional leachability
Secondary objective: evaluate
mineralogical changes of solids
after leaching
4-8
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4.2.1.2 Secondary Objectives
Secondary objectives are designed to provide
information, in addition to the critical parameters, for
evaluating the effectiveness of technology applications.
The secondary objectives are:
Assess Mercury Contaminant Reduction in Treated
Waste Rock Test Material: The same kinetic column
leach test that was described for the primary mercury
ore material was also run on the waste rock material,
with results being evaluated in the manner described
above. The waste rock material columns were not run in
triplicate, but were run in duplicate for the control and
single for the treatments.
Evaluate Leachate Quality After Treatment and
During Column Testing: During and at the end of the
column leach tests, filtered samples were analyzed for
parameters in addition to mercury, in order to assess
changes in the leachate chemistry. Samples were
analyzed for the additional metals: arsenic, iron, and
antimony, as well as pH, redox potential, sulfate, sulfide,
conductivity, alkalinity/acidity, and turbidity. This
analysis was done on both mercury ore and waste rock
column effluents.
Evaluate Mineralogical Changes in the Treated
Material: Samples of the mercury ore material were
collected after reagents had been applied, but before
leaching was begun for the evaluation of the
mineralogical changes that may have occurred during
treatment. Mineralogical analyses included x-ray
diffraction, x-ray fluorescence and optical mineralogy.
Humidity Cell Test Protocol Using the Mercury Ore
Material: Mercury ore material that had been treated
but not leached was subjected to the Humidity Cell Test
procedure. Leachate from the test was evaluated for
both dissolved (<0.45um) and mobile mercury (<25um),
and again reductions were evaluated by comparison to
leachate from controls cells. Two control cells and one
cell for each technology were run.
Evaluate Treated Materials for Conventional (Static
Test) Leachability: After the reagents had been
applied, but prior to the start of kinetic leach testing,
samples of the treated and untreated (control) material
were evaluated to determine the leachability of mercury
and other metals in a static test protocol. Routine
leachability testing is most commonly performed using
the Synthetic Precipitation Leaching Procedure (SPLP)
method 1312 as described in SW846, which is a one-
time contact over a 24 hour duration. Both of the
material types were subjected to SPLP leaching, which
was performed on each of the treated materials and an
untreated control sample. Resulting leachates were
analyzed for mercury, antimony, arsenic, and iron.
4.3 Experimental Design
Several tests were designed to achieve the project
objectives. In order to assure that the critical mercury
ore material was homogenous so that each test unit
(column or humidity cell) received equitable material,
splits were carefully prepared. As it was collected in the
field, the mercury ore material was screened to pass a
0.5-inch mesh. The material was transported to MSE's
research facility where it was thoroughly mixed and split
into batches of 5-6 kilograms. Each batch was split to
obtain a 300 to 500 gram sample for mercury analysis.
The requirement for successful homogenization of
samples was a Relative Standard Deviation (RSD) of
<25% for whole-rock mercury content. The analysis of
the 32 split batches yielded a mean of 1,969 mg/Kg Hg,
with a standard deviation of 313, resulting in an RSD of
16%, indicating successful homogenization.
4.3.7 Column Studies
The primary objective was achieved by performing
column leach studies on the mercury ore material. Each
column consisted of a 3-foot 4-inch section of clear
schedule 40, 3-inch diameter PVC pipe, fitted with a cap
on the bottom. A drain in the cap connected to 0.25-inch
tubing. Columns were prepared by filling the first two
inches with 1/8-inch stone to provide a drain layer. After
the treatment on material in the columns was completed,
two more inches of the 1/8-inch stone was added to the
top surface to disperse the liquid being dripped onto the
column.
For the ex situ application, four batches of mercury ore
material were treated with KEECO's KB Sea dry
reagent. Half of a batch (~2000 grams) was spread out
in a bin and half of the dry reagent was sprinkled on top
of it. The other half of the material and reagent were
added in the same manner and the entire amount was
thoroughly mixed together by hand turning. A total of
195.46 grams of KEECO's KB Sea dry reagent was
added to each batch. Four kilograms from each of three
batches was loaded into columns. The fourth batch was
reserved for physical and chemical investigations, SPLP
and humidity cell testing on treated material.
The three in situ treatments on mercury ore material
were each applied to four columns, again to provide
4-9
-------
triplicate samples and an additional quantity of treated
material for physical and chemical investigations, SPLP
and humidity cell testing. In situ application was
accomplished by loading the material into the columns in
"lifts" of approximately 5 to 7 inches, with first and last
lifts having somewhat more variability in depth. As each
lift was placed, a liquid form of the reagent was added
by the use of a garden sprayer, which allowed the
solution to be injected into the material. This procedure
was repeated until four kilograms had been treated in
each column.
E&C Williams provided the ENTHRALL® reagent in a
concentrated form, which was diluted with three parts
deionized water to one part product. The four treatment
columns with mercury ore material were each loaded in
seven lifts. A total of 300 ml treatment solution was
applied to each column as described above.
Phosphate treatment was provided in liquid form and
was diluted with one part deionized water to three parts
phosphate. Four columns were loaded with mercury ore
material and treated in six lifts, as described above and
300 ml of the diluted phosphate was applied to each
column.
KEECO's KB-1 product was applied to the mercury ore
material for the in situ treatments. The reagent was
applied as-supplied, with 1,184 ml being applied to each
4,000 gram column load. The first and last lifts were 3
inches deep, with intermediate lifts being 6 to 6.5 inches
thick. Again, four columns were treated in this manner
to allow for leachability testing in triplicate and enough
treated material for further testing.
Since testing on the waste rock material was secondary
to testing on the mercury ore, a less intensive regimen
was prescribed. Columns were loaded and treated as
above for leachability testing, but instead of treating an
entire column to provide SPLP and laboratory analysis,
a small amount of material was treated. A 500-gram
sample of material was placed in a 500-ml sample jar
and treated with the same ratio of reagent to material as
was used in the columns with mercury ore material.
Two columns were loaded with waste rock material and
treated with E&C Williams' ENTHRALL® process as
described above. As with the mercury ore material,
each column was loaded with 4,000 grams of material
and treated with a total of 300 ml ENTHRALL® solution.
A 500-gram portion of the material was treated with 37.5
ml ENTHRALL® for SPLP and laboratory analysis. The
phosphate product was demonstrated on the waste rock
material in the same manner, with the same quantities
being applied. Products were diluted as described for
mercury ore material above.
The KEECO treatments on the waste rock material were
only tested in one column each. For the ex situ
application, 217.84 grams of KB-Sea was mixed into
4,000 grams of waste rock material, and loaded into a
column. A 500 gram portion was treated with 27.23
grams of reagent for lab analysis. In situ treatment of
the waste rock material was performed by loading the
column in lifts, as previously described, and applying
KB-1 reagent to each lift. The initial and final lifts were
three inches deep, with intermediate lifts being 6-6.5
inches thick. A total of 1,305 ml of KB-1 was applied to
the column.
Three columns were each loaded with 4,000 grams of
mercury ore material and two columns were loaded with
the same amount of waste rock material. These were
the experimental controls for the testing that was to
follow.
Kinetic leach testing was then used to determine the
success of the treatments. Deionized-distilled water, pH
adjusted to 5.0, was applied at a constant rate of 0.09
L/hr, with leachate being collected weekly. The original
design called for leaching to continue for a minimum of 8
weeks. The entire volume of effluent was collected and
mixed weekly. After recording the volume, the effluent
was taken to the lab where measurements of turbidity,
pH, conductivity and redox potential were taken.
Approximately 3 to 4 liters of leachate was then filtered
through a 25um filter for analysis of mobile mercury and
through a 0.45um filter for dissolved mercury analysis.
Unfiltered samples from weeks 1, 4 and 8 were analyzed
for total mercury to provide data on the relationship
between total, dissolved and mobile mercury. Where
necessary to satisfy secondary parameters, additional
analysis was also performed, as detailed below.
After the initial eight week leach period, the columns
were allowed to rest for four weeks. This was intended
to simulate a drying period during which oxidation
reactions would naturally occur in a dump or pile. If the
mercury leachability was due to chemical reactions,
there should have been a peak in mercury when
leaching was restarted. Following the rest period, one
column of each treatment type and one control was
leached for another four weeks.
The column studies on the waste rock material were
similar to the mercury ore column studies with the
exception that the KEECO treatments were tested on
only one column each and E&C Williams' columns and
4-10
-------
the phosphate columns were run in duplicate. The
waste rock material control columns were also run in
duplicate. Application rates and sampling were identical
to the study on the mercury ore material.
In addition to mercury analysis, weekly samples were
analyzed for sulfate, sulfide, alkalinity and acidity to
satisfy secondary objectives. Sample splits for weeks 1,
4 and 8 were also analyzed for the metals antimony,
arsenic and iron.
4.3.2 Humidity Cell Tests
"Humidity cell" testing, detailed in ASTM D 5744-96, is a
protocol designed to meet kinetic testing regulatory
requirements for mining wastes and ores. In this test
method, the sample is subjected to alternate periods of
dry air, moist air and water leaching in an effort to
simulate the weathering process that the ore would
undergo in a natural environment. The rigorous
conditions applied in the test design subject the material
to potential worst-case scenarios in that the extreme
changes from moist to dry air and complete wetting of
the ore.
For the treatability study, humidity cell testing was
performed on the mercury ore material only. A 1,000
gram aliquot of each of the treated materials and the
untreated material was placed in each cell. To perform
the initial leach, one liter of deionized water was slowly
added to each in a manner that would avoid hydraulic
agitation. The flooded sample was allowed to sit for one
hour, and then the cell was drained overnight into a
sample collection vessel. Dry air was then introduced
into the cell at a rate of two to three liters per minute for
three days. This was followed by a wet air purge for the
following three days. Wet air was created by using a
humidifier with Dl water at a temperature of 30+ 2°C.
The wet air was supplied for three days at approximately
the same rate. The first week's testing was completed
by a Deionized water leach, as described above. The
cycle of dry-air purge, wet-air purge and water leach was
repeated weekly for a total of seven weeks after the
initial water leach. Leachate was collected and analyzed
for dissolved and mobile mercury, pH and turbidity,
sulfate, sulfide and acidity/alkalinity.
4.3.3 Mineralogical and Geochemical Tests
Mercury ore and waste rock samples were analyzed for
mineralogical parameters by optical microscopy, x-ray
diffraction (XRD) and x-ray fluorescence (XRF) in the
Department of Earth and Atmospheric Sciences at the
City College of New York (CCNY).
X-ray diffraction is a technique for gathering information
about the structural state, including the degree of
crystallinity of the materials in a sample. At the CCNY
lab, the samples were pulverized in an agate mortar and
pestle and mixed with a lanthanum boride standard.
The samples were then mounted on a quartz non-
reflecting holder and step-scanned at 0.02 degrees two
theta over the appropriate range at 40kv/20 milliamps
with a counting time of 1-4 seconds per step. For unit
cell refinements, peak locations were obtained using a
Philips APD package for single peak fits, or by a
modified Pearson-VII peak fitting or related algorithm.
Upon correction for peak position error, reflections were
analyzed for unit cell parameters using either a Philips
unit cell program or an in-house program that provides
estimations of cell axes and angles and standard errors.
For mineral identification, peak positions were obtained
using the Philips APD package for fitting all spectral
positions.
Samples were prepared for analysis by x-ray
fluorescence by pulverizing under methanol in an agate
mortar and pestle to a grain size of less than 50 microns.
The pulverized material was then mixed in a 40:60
(rock:flux) ratio with lithium tetraborate and fused at
1000 degrees centigrade for 20 minutes. The material
was then poured onto a hot aluminum plate and pressed
into a pellet, approximately 0.6 inches in diameter. The
pellets were epoxyed into one inch cylindrical holders
leaving a glass face exposed. The glass is polished to a
smooth face using silicon carbide polish, then corundum,
and finally diamond micro-polish. For quantitative
analysis, an automated Philips 1400 series x-ray
fluorescence spectrometer was used under standard
conditions, typically 50kv 50 ma for 50-100 seconds.
Oxide values were determined using linear least squares
corrections of data. Semi-quantitative XRD was also
performed on samples that had been pulverized as
above, then dispersed in distilled water and collected on
0.2 or 0.4 urn polycarbonate filters. The dried filters
were then pressed into borax holders at about 20 tons
pressure. The samples were analyzed using the
spectrometer and compared to linear least squares
corrections based on USGS pellets and standard
analyzed minerals.
4.3.4 Humic/Fulvic Acid Tests
All natural environmental systems contain some amount
of decomposed plant and animal matter called humus.
The soluble portion of humus is called humic acids, and
is further broken down into three fractions: humic acid,
ulmic acid and fulvic acid. Humic acid is a long chain
molecule, high in molecular weight, dark brown and
4-11
-------
soluble in alkaline solutions and is insoluble in water,
acids, ethanol and acetone. Fulvic acid is a short chain,
low molecular weight molecule. It is soluble in acid, alkali
and water and is waste rock in color.
Mercury and methyl mercury bind strongly to soil and
sediments by forming strong complexes with organic
substances, including humic acids. Previous studies
have indicated that humic and fulvic acids dissolve
mercury from cinnabar in the environment, and
subsequently release it into aqueous systems.
Vegetative caps can be used on tailings and piles to
inhibit the downward migration of meteoric waters
through evapo-transpiration, and help stabilize the pile
from erosion and collapse. A vegetative cap may
produce these organic acids, which could then seep
down and mobilize mercury in the underlying material.
In order to determine whether this would be a concern at
SBMM if a vegetative cap would be considered, a
supplemental test was added to the original
experimental design. The additional test for humic/fulvic
acid leachability was a modification of the MWMP
described earlier. The design used glass columns 50
cm tall and 2.5 cm in diameter. Five identical columns
were loaded with untreated mercury ore material. Three
of these columns were leached with a synthetic
dissolved organic carbon mixture consisting of 20 mg/L
of humic acid and 10 mg/L of fulvic acid in deionized
water. To ensure complete dissolution of the acids, the
pH of the solution was brought to 9.0 with a sodium
hydroxide addition, and then adjusted to a pH of 6.0 by
adding acetic acid. The remaining two columns were
leached with deionized water adjusted to a pH of 6.0 as
a duplicate control. The 1:1 ratio from the MWMP was
maintained, so the design called for the columns to be
slowly leached with one solution volume equaling one
material volume over each 24-hour period. The columns
were loaded with 150 grams of material.
Leachate was collected on days 3 and 7 and then
weekly for weeks 2, 3 and 4. The entire volume of
leachate was collected, mixed and filtered. Each sample
was analyzed after filtration through 25um and 0.1 urn
with additional filtration at 0.45um performed on day
seven and week four. Turbidity and pH were measured
immediately after each sample was filtered.
4.4 Results
Results are presented in this section for each set of
tests.
4.4.7 Kinetic Column Study Results
The column studies were the primary leaching method to
evaluate the effectiveness of the stabilization
technologies on SBMM material. In particular, column
tests using the mercury ore material were used to
evaluate the primary objective, i.e. 90% reduction in the
cumulative mass of mercury leached from the <25um
fraction relative to the control columns. Column study
results will be presented individually for the mercury ore
and waste rock material.
4.4.1.1 Column Studies on Mercury Ore Material -
Primary Objective
Overall, the column studies using the mercury ore
material enabled a quantitative evaluation of treatment
effectiveness. Variability between the triplicate columns
was low and detectable levels of mercury were
encountered in all effluents from the control and
treatments.
Evaluation of the primary objective for each technology
consisted of summing the total mass of mercury leached
from the <25um fraction (volume x concentration) from
an average of the triplicate columns over the 12-week
test and comparing to the mass of mercury leached from
the control column. For definitional purposes, this
fraction is considered the "mobile" fraction based on
previous studies that demonstrated the potential for
particulate (colloidal) transport. In addition to calculating
the mobile fraction, the "dissolved" fraction was
determined by using data from the <0.45um analyses,
as well as calculating the "particulate" fraction as the
difference between the <25um and <0.45um fractions.
Table 4-9 presents a summary of the total mass (in
micrograms) of mercury leached for each treatment and
the control over the 12-week testing period on the
mercury ore material. The table shows the mercury
mass of the <25um filtered (mobile), the <0.45um
(dissolved), and calculates the particulate fraction (as
the difference between the <25um and <0.45um
fractions). The last column shows the calculation for the
% difference in mass of mercury of the mobile fraction
for each treatment relative to the control column. Figure
4-4 is a graphical presentation of the data presented in
Table 4-9. The graph shows the mobile fraction leached
and illustrates the contribution of the particulate and
dissolved fractions.
4-12
-------
Table 4-9. Total Mass Mercury Leached from Mercury Ore Columns Over Twelve Weeks
Treatment
Control
Phosphate
E&C Sulfide
KEECO In Situ
KEECO Ex Situ
Mass Hg (|jg)
Leached
<25um
(Mobile)
12,509
131,018
13,836
1,532
1,723
Mass Hg (|jg)
Leached
<0.45um
(Dissolved)
488
74,211
731
1,452
1,650
Mass Hg (|jg)
Leached
0.45um to 25um
(ParticulateJ
12,021
56,808
13,105
80
72
% Difference Relative
to Control
<25um Fraction
(Mobile)
947%
11%
-88%
-86%
140,000 -
120,000 -
^ 100,000 -
I
I 80,000
I 60,000 -
"~ 40,000 -
20,000 -
D 25um to 0.45um fraction (Particulate)
• <0.45 um fraction (Dissolved)
Control
Phosphate E&C Sulfide KEECO In Situ
KEECO Ex
Situ
Figure 4-4. Comparison of the total mass mercury leached from the mercury ore columns.
Table 4-10 presents the leachability data for each week A discussion of the results from the control columns and
of the 12-week test period. The table shows the mass of
mercury (in micrograms) leached from the control and
treatment columns during each week of leaching for both
the particulate fraction (25um-0.45um) and the
dissolved fraction (<0.45um).
each set of treatment columns are presented and
discussed relative to the primary objectives.
Observations of the technology's performance and
applicability to SBMM material are made when
appropriate.
4-13
-------
Table 4-10. Mercury Ore Leachability Results By Week
Week
Weekl
Week 2
WeekS
Week 4
WeekS
Week 6
Week 7
Treatment
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Average Whole
Rock Hg
Concentration
(mg/Kg)
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
Mercury
Mass Removed
(M9)
Participate
25um -0.45um
1276.3
48623.0
506.6
19.8
6.1
671.7
2933.1
495.7
14.6
1.5
891.4
584.3
1054.3
0.00
0.00
1477.5
738.8
1668.0
23.3
33.5
1559.3
592.4
1392.5
3.5
0
11196.0
657.5
1688.8
5.0
5.8
1050.3
NA
1761.0
6.4
1.9
Dissolved
<0.45um
14.6
66318.0
12.4
92.1
16.0
15.1
3078.3
19.2
149.5
193.7
37.7
1563.1
38.2
194.8
266.4
52.9
954.5
85.1
177.2
222.0
67.3
509.4
106.1
140.6
170.5
40.7
359.0
99.7
137.2
155.1
56.9
NA
86.7
110.5
129.0
NA = Not Analyzed
4-14
-------
Table 4-10 continued. Mercury Ore Leachability Results By Week
Week
Week 8
WeekS
Week 10
Week 11
Week 12
Treatment
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO SME In Situ
KEECO SME Ex Situ
Average Whole
Rock Hg
Concentration
(mg/Kg)
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
1888
1830
1867
2101
2066
Mercury
Mass Removed
(ug)
Particulate
25um -0.45um
935.3
425.8
1375.5
8.8
16.4
915.0
912.6
1248.5
0.00
4.4
823.0
489.4
707.2
1.3
0.0
705.3
422.1
620.6
0.0
0.0
519.8
428.8
586.1
6.8
6.0
Dissolved
<0.45um
27.8
220.4
64.9
101.5
111.2
55.5
452.4
60.5
119.9
128.5
22.7
188.9
31.2
80.4
93.9
43.4
261.3
56.2
77.0
84.7
53.2
305.5
70.6
71.6
79.5
NA = Not Analyzed
4.4.1.1.1 Control Column
Mercury leachability from the control columns was
calculated as a comparative benchmark for the
treatment columns as well as to elucidate potential
leaching properties of the mercury ore material. The
total mass of mercury leached from the control in the
<25um fraction was 12,509 ug over the course of the 12-
week period. This was derived from the average of the
three replicate columns. Overall, variability between the
three columns was low with an average coefficient of
variation (CV) of 30%. The CV is calculated as the
standard deviation over the mean (as a percent), and is
a normalized measure of the parameter's variability.
The <0.45um fraction exhibited a total mass mercury of
488 ug, and also exhibited a relatively low coefficient of
variation of 36%. The calculated total mass mercury in
the particulate fraction (25um to 0.45um) was 12,021 ug.
4-15
-------
Detectable levels of mercury were encountered in all
weekly effluent fractions with mass means (of the three
columns) ranging from 573 ug to 1,627 ug for the <25um
fraction, and 14.59 ug to 67.31 ug for the <25um
fraction.
Figure 4-5 depicts the mass of mercury leached
(particulate and dissolved) from the control columns
(average of the three columns) over the 12-week test
period. Overall, there are much greater levels of
particulate-associated mercury in the leachate over the
entire test period as compared to the dissolved mercury.
After the fifth week of leaching, particulate mercury
steadily decreased to week 12. The four-week rest
period between weeks eight and nine did not
significantly increase the mass of leachable mercury in
either the particulate or dissolved fractions, suggesting
that chemical oxidative processes are not enhancing
mercury leachability with a water rinse.
The pH of the effluent over the course of the 12 weeks
was relatively constant with a mean of 4.16 (CV=6.25%)
and ranged from 3.54 to 4.52. The Eh of the solutions
indicated oxic conditions throughout the test with a mean
of 455 and a range from 384 to 500. There are no
correlations between either the pH and leachable
mercury or Eh and leachable mercury under the
leaching conditions of this test.
concentration (Figure 4-6) of samples filtered through
the 0.45um filter reveals a general linear relationship.
This suggests that the mercury from the control column
leachates is associated with sub-micron particles, such
as clays, which can transport the mercury as a colloidal
suspension. This may have important implications in the
transport and fate of mercury in the SBMM-Clear Lake
system.
8-
Q. -
0)4-
X
2-
468
Turbidity (NTU)
10
Figure 4-6. Turbidity vs. Hg for the <0.45um fraction
mercury ore control columns.
2000-
-31750-
D
-1500-
0)
-§1250-
.§1000-
I 750-
en
!g 500-
5 250-
n—
Mercury Ore Control
..
fr~\
x / \ Particulate
\ / ^v
\ / ^x^c
\/ ~*^-x
X.
Dissolved
nnncnnnnni-inn
1 2 3 4 5 6 7 8 9 10 11 12
Week
Figure 4-5. Dissolved and particulate leached Hg
(mass) from mercury ore control columns.
As observed in the pre-demonstration studies, it does
not appear that the <0.45um fraction contains truly
dissolved mercury. A plot of the turbidity vs. mercury
4.4.1.1.2 Phosphate Treatment
The total mass mercury leached from the phosphate
columns was compared to the control columns to
evaluate the primary objective. The total mass of
mercury leached from the phosphate treatment in the
<25um fraction was 31,018 ug over the course of the 12-
week period. This represents a significant increase in
leachability of 947% relative to the control. The overall
variability between the three columns was low with a CV
of 22%. The <0.45um fraction exhibited a total mass
mercury content of 74,211 ug over the 12-week test
period. The overall variability between the three columns
was low with a CV of 24%. The weekly average mass of
mercury ranged from 646 ug to 114,941 ug for the
<25um fraction, and 189 ug to 66,318 ug for the <0.45
urn fraction. The calculated total mass of mercury in the
particulate fraction (25um to 0.45um) was 56,808 ug.
The phosphate treatment dramatically increased the
levels of both the particulate and dissolved fractions
over the course of thel2-week study. Figure 4-7
depicts the leachability profile over time for both the
particulate and dissolved fractions. The mass of
mercury leached was extremely high during the first two
4-16
-------
5000-
^§ 4000-
"O
•g 3000-
03
1
o> 2000-
I
w
w
| 1000-
n
Mercury Ore Phosphate
x Particulate
S D Dissolved
\
\
\
\
\a
\
D n b^^
12345
6 7
Week
8 9 10 11 12
Figure 4-7. Dissolved and particulate leached Hg
(mass) from mercury ore phosphate
columns.
weeks, so these values are not shown on this graph in
order to maintain scale for subsequent weeks.
Although approximately 88% of the total leached
mercury in both the dissolved and particulate fractions
was leached out in the first week, significantly higher
levels of mercury were still leached from the phosphate
treatment during subsequent weeks as compared to the
control. For example, from weeks 2 through 12 the
total mass mercury leached from the phosphate
treatment's dissolved fraction was 7,893 ug as
compared to 473 ug from the control over the same
period.
The pH of the solutions averaged 6.7 (6.38 to 6.87) and
exhibited very low variability (CV=2%). The pH of the
phosphate effluents was higher than the control. The
average Eh of the solutions was slightly lower (338) than
the control but still exhibited oxic leaching conditions.
The Eh ranged from 166 to 420.
As with the control column, there is evidence that the
mercury in the <0.45um fraction is associated with sub-
micron particles. This suggests that the phosphate
treatment accelerated the breakdown of the mercury ore
material matrix and facilitated the release of particulates.
Therefore, it does not appear that the increase in
mercury brought about by the phosphate treatment is
due to true dissolution. The phosphate treatment greatly
exaggerated the processes releasing mercury from the
solid matrix.
The dramatic rise in leachable mercury brought about by
the phosphate treatment invalidates its utility as a
remedial alternative for materials at the SBMM site.
Additional investigations could be carried out to
determine the cause of the increased leachability for the
purpose of identifying potential mechanisms that may be
responsible for mercury leachability from SBMM (if
occurring) and other mercury-bearing materials.
4.4.1.1.3 E&C Williams Sulfide Treatment
The total mass mercury leached from the sulfide
treatment columns was compared to the control columns
to evaluate the primary objective. Total mass mercury
leached from the sulfide treatments averaged 13,835 ug
in the <25um fraction over the course of the 12-week
study. This represents a slight, and statistically
insignificant, increase in the leachable mercury. The
overall variability between the three replicate columns
was low, exhibiting a CV of 14%. The total mass of
mercury in the <0.45um fraction was 731 ug over the 12-
week testing period, and exhibited low variability
between the three replicate columns (CV=30%). The
range of weekly mass mercury values was 515 ug to
1,847 ug for the <25um fraction, and 12.41 ug to 106 ug
for the < 0.45um fraction. The calculated particulate
fraction (25umto 0.45um) was 13,105 ug.
The mass of mercury leached over the 12-week period
is depicted in Figure 4-8. As illustrated in the figure, the
overall pattern and magnitude of mercury leachability is
similar to the control. Furthermore, as in the control
columns, it appears that the leachable mercury in the
<0.45um fraction is associated with sub-micron particles.
The average pH in the effluent over the course of the 12-
week test was 4.01 (3.26 to 4.41) and exhibited a low
CV of 8%. The Eh of the solutions indicated oxic
conditions with an average value of 469 and a range of
469 to 507.
The E&C William's ENTHRALL® technology did not
appear to be effective in reducing the levels of mobile
mercury in the mercury ore material column tests. The
total mass of mercury in both the particulate and
dissolved fractions are statistically similar to the control.
Furthermore, the temporal pattern and magnitude of
mercury leaching between the control and sulfide
treatment are similar. In addition, the association of
mercury with particulates is very similar to the control.
E&C Williams provides an explanation for their
technology's performance in Section 4.51.
4-17
-------
2000-
1750-
1500-
l250-
1000-
750-
500-
250-
0-
Mercury Ore Sulfide
x—x
/ K
J, Particulate
Dissolved
n a
1 2 3 4 5 6 7 8 9 10 11 12
Week
Figure 4-8. Dissolved and participate leached Hg
(mass) from mercury ore sulfide
columns.
treatment. Overall variability was very low with a CV of
16% for the in situ and 15% for the ex situ. The
calculated total mass mercury in the particulate fraction
(25um to 0.45um) was extremely low, i.e. 80 ug for the
in situ treatment and 72 ug for the ex situ treatment.
250-
,3200-
H175-
8150-
.3125-
o>100-
8 75-
| 50-
25-
0-
Mercury Ore KEECO In Situ
Dissolved
/xParticulate
4.4.1.1.4 KEECO In Situ and Ex Situ
Both of the KEECO treatments (in situ and ex situ) will
be discussed in this section, since performance results
for both modes of treatment were similar. The total
mass mercury leached from each of the KECCO
treatment columns was compared to the control columns
to evaluate the primary objective. Figures 4-9 and 4-10
present the temporal mass mercury leachability results
for the in situ and ex situ columns, respectively. Note
that the overall level of mercury leached was much lower
than the control and other treatments, but unlike the
other tests, the mass of mercury was much higher in the
<0.45um fraction (dissolved) than in the 25um - 0.45um
fraction (particulate).
In general, both modes of application performed similarly
in terms of levels and timing of mercury leaching. The
total mass mercury leached in the <25um fraction from
the in situ and ex situ columns was 1,532 ug and 1,723
ug, respectively. This represents a reduction in
leachability of 88% (in situ) and 86% (ex situ) as
compared to the control. The overall variability between
the three replicate columns for both applications was
very low, 17% for the in situ and 12% for the ex situ.
Weekly total mercury mass ranged from 76 ug to 201 ug
for the in situ columns, and 22 ug to 265 ug for the ex
situ columns. The <0.45um fraction exhibited total mass
mercury of 1,452 ug for the in situ, and 1,650 ug for the
ex situ. This represents an overall increase in mercury
for that fraction as compared to the control. Weekly
mass mercury ranged from 71.55 ug to 195 ug for the in
situ treatment and 16 ug to 266 ug for the ex situ
1 2 3 4 5 6 7 8 9 10 11 12
Week
Figure 4-9. Dissolved and particulate leached Hg
(mass) from mercury ore KEECO in
situ columns.
250-
o200-
ro
100-
5 50-
0-
^ttth
Whi4e
Dissolved
n n
n
Particulate
/\
n n
1 2 3 4 5 6 7 8 9 10 11 12
Week
Figure 4-10. Dissolved and particulate leached Hg
(mass) from mercury ore KEECO ex
situ columns.
KEECO's Silica Micro Encapsulation Technology applied
both in situ and ex situ, was effective in reducing mobile
4-18
-------
mercury (<25|jm) very close to the 90% reduction goal
of the study. Furthermore, the process was very
effective in reducing the generation of mercury
associated with the particulate fraction (25um to
0.45um). Both the in situ and ex situ treatments
achieved a 99% reduction in particulate-associated
mercury relative to the control. However, there was a
significant increase in the mass mercury levels in the
dissolved fraction (<0.45um). The in situ applications
exhibited a 198% increase relative to the control, and
the ex situ exhibited a 238% increase. The form of
mercury in this fraction for the KEECO treatment
appears to be in a truly dissolved state as compared to
the nano-particulate nature of the <0.45um fraction from
the control columns. This is based on the relationship
between mercury concentration and turbidity in the
<0.45um fraction for the KEECO treatments and control
as depicted in Figure 4-11. For the control (and for the
other treatments), there is a general linear relationship in
which the samples with higher mercury concentrations
exhibit higher turbidity (presence of particles). It is
postulated that the mercury in these effluents are
associated with sub-micron particles (such as clays) that
carry the mercury in the interstitial layers. The KEECO
effluents from the <0.45um fraction exhibit higher
mercury with little or no turbidity, indicating that the
mercury is not associated with sub-micron particles and
is in a truly dissolved state.
Control
KEECO Ex Situ
KEECO In Situ
to the elevated pH in the KEECO effluents. Figure 4-12
depicts the pH results from the KEECO effluents and the
control effluents over the 12-week test period. As
illustrated in the graph, the pH of the control effluents
maintained a near constant pH of around 4 over the
course of the study. Both of the KEECO treatments
effluents' pH was elevated relative to the control, starting
out at approximately 12 and stabilizing to around 9.
Furthermore, after an initial drop after the first two
weeks, the pH did not decrease over the duration of the
study. This indicates that the KEECO treatments
permanently modified the geochemical properties of the
mercury ore material. The increase in dissolved
mercury due to the elevated pH is supported by an
Eh/pH leaching study on SBMM material1. The study
demonstrated that alkaline conditions favored the
dissolution of mercury. The maximum solubility
occurred between a pH of 10 to 10.5. Furthermore, the
addition of iron (in the form of ferric nitrate) inhibited the
solubility of mercury at all pHs.
PH
14
12
10
8
6
4
2
0
-Control
-KEECO
In Situ
-KEECO
Ex Situ
1 2 3 4 5
6 7 8 9 10 11 12
Week
01 23456789 10 11
Turbidity NTU
Figure 4-11. Turbidity vs. Hg for the <0.45|jm fraction -
mercury ore, KEECO and control columns.
The increase in the dissolved mercury concentration
(relative to the control and other treatments) may be due
Figure 4-12. pH of KEECO and control column
effluents - mercury ore material.
The data from the column studies suggests that two
mercury mobilization/immobilization processes are
occurring due to the KEECO treatments. The treatment
was effective in inhibiting the generation of particulate
associated mercury, which under the leaching conditions
in the control test, is the dominant mercury mobility
mechanism. The control of the generation of particulate
associated mercury is probably due to the physical
stabilization and binding of the matrix. However, due to
the elevated pH brought about by the treatment, a
chemical reaction dissolved a portion of the mercury. It
1 Characterization and Eh/pH Based Leaching Tests of
Mercury-Containing Mining Wastes from the Sulfur Bank
Mercury Mine, Lake County, California. EPA/600/R-
02/032, September 2001.
4-19
-------
is important to note that the amount of mercury
dissolved by the KEECO treatment is still significantly
less than the mass of particulate mercury leached from
the control. The KEECO treatment may have bound the
matrix, thereby reducing the overall reactive surface
area available for mercury dissolution. It is suggested
that in order to inhibit the dissolution of mercury due to
elevated pH, the vendor should consider iron
amendments as part of their process for this material.
4.4.1.2 Waste Rock Column Studies
Results from the columns studies on the waste rock
material are presented in Table 4-11. The whole rock
mercury concentration in the waste rock was
approximately one-half the levels in the mercury ore
material, yielding lower levels of leachable mercury as
compared to the mercury ore material. However, the
levels of leachable mercury in the particulate fraction
from the mercury ore material control columns were two
orders of magnitude greater than from the waste rock
control columns. This indicates that the waste rock may
be less prone to releasing particulates when exposed to
a leaching solution. The average pH from the waste
rock control column leachates was 3.36 (3.06 to 3.61)
and was lower than the pH from the mercury ore column
controls (4.16). The Eh of the leachate solutions
indicated oxic conditions throughout the 8-week period
(mean=522, range 485-573).
Although there was significantly less mercury in the
leachate from the waste rock column studies, the tests
revealed similar technology performance results. The
large number of non-detect values in the tests makes
quantitative assessments and numerical comparisons
difficult. However, a semi-quantitative discussion of
each technology application follows.
A demonstrated in the mercury ore material columns,
the phosphate treatment greatly increased the levels of
mercury from the waste rock material (as compared to
the control) in both the particulate (25um to 0.45um) and
dissolved (<0.45um) fractions. Since the phosphate
treatment increased the level of mercury in the <0.45um
fraction (relative to the control), it was possible to
evaluate the relationship between mercury concentration
and turbidity. As depicted in Figure 4-13, there is a
relationship between the mercury concentration and
turbidity, indicating that leachable mercury in the waste
rock material may also be associated with sub-micron
particles. Therefore, it is concluded that the mercury
generated from the waste rock material is associated
with particulates. The pH of the weekly leachate
samples averaged 4.99 (3.71 to 5.61), which was lower
than the average from the mercury ore columns (6.7).
The average Eh (383) indicated oxic conditions
throughout the test and was similar to the average Eh of
the mercury ore column leachates (338).
There appears to be minimal differences between the
leaching characteristics of the E&C Williams Sulfide
treatment and the Control for the waste rock material.
However, the E&C Williams treatment may have slightly
reduced leachable levels of mercury in both the
particulate and dissolved fractions. This is indicated by
the greater numbers of non-detect levels of mercury
encountered in the E&C Williams treated waste rock
material relative to the control. The pH from the weekly
effluents averaged 3.25 (3.15 to 3.39), which was similar
to the pH of the control effluents, and lower than the
average weekly effluent of the treated mercury ore
material (4.01). Eh conditions indicated oxic conditions
throughout the testing period (mean of 534).
45-
40-
35-
s^so-
S25-
^20-
15-
10-
5-
0J
0
i i i T ~ ~ i i i r ~ ~ T i
5 10 15 20 25 30 35 40 45 50 55
Turbidity (NTU)
Figure 4-13. Turbidity vs. Hg for the <0.45^m fraction
waste rock phosphate column.
The leachability characteristics of the KEECO
treatments on the waste rock material performed
similarly to the mercury ore material. As in the mercury
ore material tests, the KEECO treatments reduced the
levels of particulate-associated mercury in the leachate.
However, due to low levels of overall particulate
generation in the control columns, the magnitude of this
reduction cannot be quantitatively assessed. As
observed with the mercury ore material, the KEECO
treatment increased the levels of dissolved mercury
demonstrated by an increase in the mass of mercury
4-20
-------
Table 4-11. Weekly Average Mass Mercury Leached from Waste Rock Columns
Week
Weekl
Week 2
WeekS
Week 4
WeekS
Week 6
Week 7
WeekS
Treatment
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEEC) Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Control
Phosphate
E&C Williams ENTHRALL®
KEECO In Situ
KEECO Ex Situ
Average Whole
Rock Hg Cone.
(mg/Kg)
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
864
889
976
776
900
Mercury
Mass Removed
(M9)
Participate
25um -0.45um
43.6
411.7
55.9
16.3
1.3
3.3
2772.2
ND
18.3
0.0
1.9
4533.7
ND
7.7
0.0
0.0
2990.2
ND
14.2
0.0
2.2
1888.8
7.8
6.3
2.8
ND
514.9
ND
1.5
1.4
ND
NA
ND
3.1
0.0
ND
1623.2
ND
6.1
5.8
Dissolved
<0.45 urn
11.2
35.8
19.5
60.2
23.8
2.4
172.1
ND
75.0
58.6
ND
320.7
ND
57.4
65.3
2.0
383.4
ND
50.6
57.7
2.9
311.4
ND
42.4
45.8
ND
128.2
ND
42.7
43.2
ND
NA
ND
33.2
35.8
ND
229.1
ND
33.9
28.8
ND = Not
NA = Not
Detected
Analyzed
4-21
-------
generated in the <0.45|jm fraction. Due to the low
turbidity in the leachate from the <0.45um fraction
(Figure 4-14), it appears that the mercury is truly
dissolved and not associated with sub-micron particles.
As seen in the mercury ore column tests, the KEECO
treatment significantly increased the pH of the leachates
from the waste rock material relative to the control. This
pH increase may be responsible for the increase in
dissolved mercury relative to the control.
5-
4-
.a
Q-'"
O)
I
2-
1-
0-
0
1 2 3
Turbidity (NTU)
Figure 4-14. Turbidity vs. Hg for the <0.45um fraction
waste rock, KEECO columns.
4.4.2 Humidity Cell Tests
Results from the humidity cells on the mercury ore
material generally agree with the column studies from
both the mercury ore and waste rock materials. Figures
4-15 and 4-16 present the weekly results for the controls
and each treatment for the <25um and <0.45um
fractions, respectively. Note that due to the wide range
in mercury concentrations, the Y-axis is presented on a
logarithmic scale. As demonstrated in the previous
tests, the phosphate treatment significantly increased
the levels of mercury in the leachate relative to the
control. Based on the humidity cell results, the E&C
Williams sulfide treatment reduced the concentration of
mercury in both the <25um and <0.45um fractions
relative to the control. For the KEECO treatments, there
is a reduction in the concentration of the <25um fraction
relative to the controls, and an increase in the <0.45um
fraction relative to the controls. This is consistent with
previous findings in which the KEECO treatments
(relative to the controls) reduced the levels of particulate
associated mercury, but increased the amount of
.a
Q.
D)
I
100000-1
10000-:
1000-=
100-=
Y Y
X ^ Y v
\ ' Y Y
f^>4-t^4
12345678
Week
Y x-control n ECWI Sulfide
«— KEECO Ex Situ —KEECO In Situ
* Phosphate
Figure 4-15. Results from Humidity Cell tests on
mercury ore material - <25um fraction.
10000i
1000-1
s
100i
10^
J2
a.
Q.
D)
0.1-
Y
23456
Week
Y x-control n ECWI Sulfide
o- KEECO Ex Situ^- KEECO In Situ
T" Phosphate
Figure 4-16. Results from Humidity Cell tests on
mercury ore material - <0.45um fraction
dissolved mercury in the leachate. As in the column
tests, the KEECO process increased the pH of the
effluents relative to the control columns. This increase
4-22
-------
in pH may be responsible for the increased levels of
dissolved mercury (<0.45|jm fraction). However, the
KEECO process greatly reduced the generation of
particulate-associated mercury, thus causing an overall
reduction in the levels of mobile mercury (<25um).
4.4.3 Synthetic Precipitation Leaching Procedure
(SPLP)
SPLP tests were performed on un-treated and treated
mercury ore material to evaluate the performance of the
technology and to compare this widely used leaching
procedure to the results of the column and humidity cell
tests. Results from the SPLP tests are presented in
Table 4-12.
Table 4-12. SPLP Results for Mercury Ore and Waste
Rock Material
Mercury Ore Waste Rock
Sample (ug/L) (ug/L)
Control 1 (untreated)
Control 2 (untreated)
Control 3 (untreated)
Control 4 (untreated)
Control Mean
Phosphate 1
Phosphate 2
Phosphate Mean
Sulfide 1
Sulfide 2
Sulfide Mean
KEECO In Situ 1
KEECO In Situ 2
KEECO In Situ Mean
KEECO Ex Situ 1
KEECO Ex Situ 2
KEECO Ex Situ Mean
479
6260
224
2090
2263
11900
13100
72500
2650
404
7527
5
10
7
5
10
7
5.5
0.4
2.95
3200
3200
9.7
9.7
Not Analyzed
2.2
2.2
The SPLP results on the untreated mercury ore material
(control) exhibit a wide range of values and are much
higher than previously performed SPLP tests on material
from the site. The SPLP results on the untreated waste
rock material are low. The average SPLP value for the
untreated mercury ore material is almost 1,000 times
greater than the waste rock untreated material even
though the whole rock mercury concentration of the
mercury ore material is only two times higher than the
waste rock material. Column and humidity cell
leachability was also higher for the mercury ore material
relative to the whole rock mercury as compared to the
waste rock, but not as great as encountered in the SPLP
tests. The high SPLP values in the mercury ore material
may be due to the agitation during leaching which may
be dislodging more mercury-bearing particles in the
mercury ore material relative to the waste rock. This
may be the case if the mercury in the mercury ore
material is associated with fractures, which would be
more prone to contact with leaching solutions under
agitation.
As demonstrated in both the column and humidity cells,
the SPLP results indicate a significant increase in
mercury leachability after phosphate treatment for both
the mercury ore and waste rock materials. For the
sulfide treatment, the SPLP results do not indicate a
statistically significant reduction in mercury leachability
relative to the control for either the mercury ore or waste
rock material. For the KEECO treatments, there is a
significant decrease in mercury leachability relative to
the control for the mercury ore material. Due to low and
variable leachable mercury in the waste rock control,
there is no demonstratable leachability reduction for this
material.
Due to the high variability associated with leachability
results from the SPLP test on the materials studied in
this investigation, SPLP testing may not be a reliable
measure of mercury leachability or technology
performance. This may be due to the heterogeneous
association of mercury in the materials, the agitation of
the matrix during testing, and the relatively small sample
size used for testing. If SPLP testing is used, several
replicates may need to be analyzed and/or larger
sample sizes may be used in order to minimize the
variability.
4.4.4 Humic/Fulvic Acid Leaching Tests
A modified meteoric water mobility procedure (MWMP)
continuous leaching test using a humic/fulvic acid
solution (treatment) and a deionized (Dl) water control
was performed to determine the effects of plant derived
high molecular weight organic acids on mercury
leachability in mercury ore material from the SBMM site.
A total of 5 columns were tested, three with the organic
solution (containing humic and fulvic acids) as triplicate
test columns and the other two columns as the Dl water
control columns. The MWMP utilized a 1:1 ratio of solid
material to leaching medium (humic/fulvic acid or
deionized water) placed in a column-type apparatus and
continuously leached over a 4-week period. Samples
were collected for mercury and other characteristics
twice during the first week and on a weekly basis over
the next three weeks. Leachate volumes were
measured for each sample so that the mass of mercury
leached could be calculated. The treatment solution
4-23
-------
contained 10 mg/L humic acid and 5 mg/L fulvic acid,
adjusted to a pH of 6. The control solution consisted of
Dl water adjusted to a pH of 6. All samples were filtered
through either a 25um or 0.1 urn filter to determine the
relative amounts of mobile (<25um) and dissolved
(<0.1um) associated mercury. Table 4-13 presents the
results from the humic/fulvic acid leaching tests for the
<25um and <0.1um fractions. A 0.1 urn filter was
selected for these studies (as compared to the 0.45um
in previous studies) to characterize more of the truly
dissolved fraction. For each leaching interval the total
mass in ug was calculated, as well as the average
ug/day. The total mass of mercury (ug) was calculated
for each treatment and control.
between the mercury leached from the treatment versus
the control for this fraction (Prob>t 0.2907). For the
<0.1um fraction, the average mass mercury was 5 ug for
the humic/fulvic treated columns and 18 ug for the
control columns. A t-test demonstrated a significant
difference between the mercury leached in the treatment
versus the control (Prob>t 0.0315). Therefore, for the
SBMM mercury ore material tested under the conditions
of the experiment, there was no increase in the
particulate or dissolved mercury due to leaching with
humic and fulvic acids. Furthermore, it appears that the
humic/fulvic acids may have reduced the levels of
dissolved mercury relative to the control. However, the
overall levels of dissolved mercury leached from the
Table 4-13. Results From the Humic/Fulvic Acid Leaching Tests
Days
1to3
4 to 7
8 to 14
15 to 21
22 to 28
Total
Days
1 to 3
4 to 7
8 to 14
15 to 21
22 to 28
<25 Micron Fraction
HA/FA 1
ug ug/day
114.89 38.30
75.33 18.83
42.44 6.06
50.55 7.22
77.91 11.13
361.12
HA/FA 2
ug ug/day
16.06 5.35
67.94 16.99
120.29 17.18
100.87 14.41
33.64 4.81
338.80
HA/FA 3
ug ug/day
150.55 50.18
151.28 37.82
249.73 35.68
129.50 18.50
197.93 28.28
878.98
Control 1
ug ug/day
83.26 27.75
97.09 24.27
509.86 72.84
86.35 12.34
120.46 17.21
897.02
Control 2
ug ug/day
114.74 38.25
109.95 27.49
212.55 30.36
134.53 19.22
88.14 12.59
659.91
<0.1 Micron Fraction
HA/FA 1
ug ug/day
0.58 0.19
0.75 0.19
2.88 0.41
4.43 0.63
3.64 0.52
HA/FA 2
ug ug/day
0.89 0.30
1.38 0.34
2.94 0.42
19.65 2.81
0.70 0.10
HA/FA 3
ug ug/day
1.28 0.43
12.37 3.09
13.93 1.99
9.91 1.42
2.70 0.39
Control 1
ug ug/day
5.41 1.80
11.69 2.92
43.32 6.19
11.70 1.67
7.03 1.00
Control 2
ug ug/day
4.29 1.43
13.72 3.43
67.67 9.67
10.52 1.50
5.59 0.80
No significant pattern of mercury release over time was
observed for either the treated or control columns for
both the fractions tested. Therefore, the results were
grouped for the treatment and control for both fractions.
Statistical analyses were performed to determine
differences between the treatment and control for each
fraction.
As with all previous leaching tests, the leachable
mercury was predominately associated with the
particulate fraction for both the humic/fulvic acid treated
columns and the control. For the <25um fraction, the
average mass mercury was 105 ug for the humic/fulvic
treated columns and 156 ug for the control columns. A
Students t-test demonstrated no statistical difference
mercury ore material were low as compared to the
particulate-associated mercury. The higher levels of
dissolved mercury in the control samples relative to the
humic/fulvic acid treated samples may be attributable to
differences in the pH of the effluent samples. The
average pH of the control effluents was 6.31 as
compared to a pH of 4.58 for the humic/fulvic acid
treated material. As previously noted, an EPA study
observed higher dissolved mercury with increasing pH.
The humic/fulvic acid tests also corroborated previous
leaching experiments regarding the form of mercury
leached from the mercury ore material. A plot of
mercury vs. turbidity in Figure 4-17 reveals a linear
relationship between turbidity (particulates) and mercury
concentration. This relationship also extends to some of
4-24
-------
700-
600-
?500-
|
?400-
300-
200-
100-
0-
200 300 400 500
Turbidity (NTU)
The samples were further wet-filtered (10-44 micron
fraction) with distilled water retaining more than 95% as
sediment. The retained sediment was analyzed by x-ray
diffraction to assess mineralogical characteristics. The x-
ray diffraction revealed that only minor amounts of
mineral are present in the bulk sample. Two phases of
particular interest, quartz (peak at 26.64) and cinnabar
(peak at 26.52) are not matched by the presence of a
pronounced diffraction maxima. A minor broad peak
may indicate the presence of one or both phases, but is
not definitive. The presence of amorphous phases
(glass, secondary silica, possible biogenic silica, and
silica-bearing aggregates) is supported by the presence
of a broad radial distribution.
Figure 4-17. Turbidity vs. Hg from the <25um and
<0.1um fractions from the humic/fulvic
acid leaching tests.
the <0.1um fraction samples. This is significant since
several samples of the <0.1um filtered leachates
exhibited relatively high turbidities indicating the
presence of sub-micron colloidal material. The
correlation between mercury and turbidity further
supports a release of mercury associated particulates as
a leaching mechanism.
4.4.5 Geochemical and Mineralogical Analyses
Geochemical and mineralogical analyses were
performed on untreated and treated mercury ore
material by optical petrography and x-ray diffraction.
The purpose of the analyses was to document any
mineralogical or geochemical changes in the bulk
properties of the mercury ore matrix attributable to the
treatment technologies. Optical petrography and x-ray
diffraction did not reveal any significant differences in the
bulk mineralogy or geochemistry between the untreated
and treated mercury ore materials examined. One
noteworthy exception is higher phosphorus content in
the phosphorous treated sample.
The examination did reveal some information relating to
the mineralogical properties of the mercury ore material.
Samples were sieved using a sequential stack of brass
sieves in the order 500, 250, 150, 125, 63 microns.
Petrographic examination reveals that the rock
fragments are typical of an altered volcanic rock,
comprising variably devitrified glass, secondary silica
deposits, and siliceous aggregates with probable
secondary sulfides.
4.5 Developers' Comments
The technology developers (E&C Williams and KEECO)
were asked to comment on the performance of their
processes based on the results from this treatability
study. Their responses to this request are presented in
this section. These responses do not reflect the views
and assessments of either the Mine Waste Technology
or SITE programs and are presented here as a courtesy
to the technology developers.
4.5.1 E&C Williams' Comments
As we understand it, the KEECO system is one that
microencapsulates the soil/rock particles, sequestering
the leachable metals. Our calcium sulfide system is
different because we effect a chemical change, forming
metal sulfides which are insoluble and immobile. So,
our chemistry is more dependent on the number and
amount of metals in the soils. We had requested an
assay or characterization of the soils in order to confirm
our suspicions that the mercury ore soil contained more
metals, and more of them, than the waste rock. We
already knew from your work that the mercury content is
greater in the mercury ore soils. Our chemistry reacts
more on a "one-to-one" basis, making the dosage more
critical than a gross encapsulation. Plus, all metals
capable of forming sulfide compounds compete equally
for the sulfide molecules. So, if a lot of iron is present,
for example, that will "eat" the sulfides as readily as a
regulated metal. This isn't unusual for remediation or
treatment work where the chemistry is less dependent
on encapsulation.
Our conclusion on the performance of the calcium
sulfide system is that the dosage simply undershot the
level of metals, and a larger dose is all that is necessary
4-25
-------
to achieve the desired results. We are comfortable with
the application by injection, although we will recommend
that the points of injection be slightly increased so as to
slightly overlap the treated areas.
4.5.2 KEECO's Comments
Project Methods and Observations
In an effort to provide a comparison of in-situ treatment
versus ex-situ treatment of the mining waste rock from
the Sulfur Bank Mercury Mine Superfund site, KEECO
performed two distinctly different process application
techniques for the SITE project test program. The
overall goals established by EPA were to demonstrate
non-aggressive, realistic methods of chemical
amendment into the mine waste while producing
significantly decreased mercury mobility. Effectiveness
would be verified throughout the series of tests outlined
in the project Test Plan. Therefore, in truth, the
challenge was not only one of demonstrating that the
technology was able to achieve the goals of mercury
stability under a variety of leaching conditions, but that it
was able to do so using less-than-ideal techniques for
chemical incorporation.
Project Approach
The SME product KB-SEA was utilized for these tests.
For the ex-situ column samples, the dry chemical was
evenly broadcast over the test material followed by
gentle blending using a spoon to represent the type of
mixing that may be expected through the use of an
excavator to blend the material on site.
For the in-situ treatment, a slurry form of the product
was prepared by mixing the dry chemical with deionized
water. The untreated materials were loaded into the
columns prior to chemical amendment. A pre-
determined volume of chemical slurry was then applied
to each column and allowed to infiltrate through the pore
spaces. Although this technique is limited in its ability to
make effective contact between the metal contaminants
of concern and the reactive components of the SME
chemical, the results proved better than anticipated, as
outlined in Sections 2 and 3. Despite favorable results
from these laboratory tests, KEECO believes that it is
unlikely that the conditions present in the column would
accurately represent the conditions encountered on-site
using in-situ treatment techniques. Geochemical
conditions and transport mechanisms in the waste piles
are complex and not properly replicated in these
laboratory test cells. As such, a pilot test on-site would
be highly encouraged prior to full-scale treatment.
KEECO Objectives
In addition to the objectives of the study as outlined in
the project Test Plan, KEECO established further
objectives for the technology performance. They
included:
• A comparison of in-situ versus ex-situ treatment for
comparable trends, ability to control total metal
contaminant release, stability under each of the
project test methods and consistency of test results
from column to column;
• Verification of previously established theories that
materials treated with the SME Technology will
exhibit greater stability over time.
While this project proved useful in assessing in-situ
versus ex-situ chemical amendment and the ability of
the process to withstand various leach test conditions,
the tests will not however, demonstrate the optimum
performance of the SME Technology when incorporated
into materials using more aggressive mixing techniques.
Therefore, the differences between optimum technology
performance and performance as achieved with limited
mixing cannot be assessed from this study.
Effectiveness of SME Technology Application -
Mercury ore (Primary) Test Material
Despite the fact that the average whole rock mercury
concentration of the KEECO sample materials were
slightly higher (about 200 mg/kg) than the control, the
sulfide and the phosphate samples, effectiveness of the
SME application is evident as compared to results from
all other tests.
When applied to the mercury ore samples, the SME
chemical produced higher initial pH values than the
established target end points identified by KEECO Lab
for optimum performance. This suggests that the
samples were slightly over-treated. This could be due to
the mild mixing technique employed for the test, thus
releasing unreacted chemical into the leachate rather
than expending it in the reactive process typically
accomplished through vigorous mixing. However, both
the selected application techniques and the higher initial
pH appear to have only minor impacts on sample
stability.
Column Testing Observations
There are a number of observations that can be made
from the column tests. Comparisons between in-situ
4-26
-------
versus ex-situ performance are discussed in Section 2.5.
Overall, the SME treated columns achieved a significant
reduction in leachable mercury as compared to the
control columns. The objectives of the Test Plan were to
achieve a 90% reduction in the cumulative mass of
mercury in the test leachates relative to the control
column leachates. For the in-situ columns, as observed
in weeks 4, 8, 9 and 12, the total mass of mercury
released was reduced by an average of 90.8% relative
to the control, thus meeting the primary project objective.
For the ex-situ columns, an average of 88.2% reduction
of the mercury released into the leachate was observed
relative to the control.2 These figures were derived
using the formula for %Hg reduction as outlined in the
project Test Plan.
Another observation that can be made from the column
testing is that the majority of the mercury released from
the SME treated material was in a dissolved state.
Therefore, while the unfiltered and 25um fraction results
are more favorable with SME, results collected solely
from the 0.45um fraction indicate that the SME columns
leached a greater mass of dissolved mercury than both
the control and sulfide treated columns. This is likely
due to the method utilized to amend the samples,
leaving some of the material untreated. Dissolved
mercury will readily percolate under the influence of
filtration due to precipitation from untreated material
when the irrigation water is applied. Whereas,
suspended particulates that may be liberated from the
untreated material upon the outset of irrigation readily
adsorb to neighboring silica-encapsulated materials
before percolating completely through the column;
thereby minimizing the release of mercury from the
material that may not have received a thorough
application of SME product. Typically, the goals of
treatment for any project are to reduce the metal release
to background levels. By week 12, after gradual
improvement overtime, the average mean concentration
of dissolved mercury in the SME leachate was within 1.8
ug/L of the control columns.
As previously mentioned, one of the objectives that
KEECO established for this study was to verify the
theory that SME treated materials will exhibit increased
stability over time. Results gathered from both the
unfiltered and dissolved fraction data support this theory.
In addition, the coefficient of variation improved over
2 Week 1 results were not included due to the high variability
of the results, suggesting that the reactive process was not yet
complete. However, in week 1, the in-situ columns produced
a 96.3% reduction in the mass of mercury release relative to
the control; the ex-situ columns exhibited a 75.5% reduction.
time, demonstrating the ability of the chemical to control
the mercury release to consistent levels despite
variations of total mercury present in the untreated
material. This supports the prediction that material
containing widely variable mercury concentrations or
"hot spots" can be effectively treated with a single
application of SME chemical to the entire material
volume without having to separately treat the highly
concentrated portions.
The drying phase that was undertaken between test
weeks 8 and 9 did not show any significant impact on
mercury stability in the SME-treated columns. A 1.5
ug/L increase in mean Hg concentration in the ex-situ
columns was observed after the rest period, with a 4.6
ug/L increase evident from the in-situ columns. This
suggests that the onset of irrigation after the drying
period may have released a small amount of mercury
into the leachate from the untreated material that may
have been near the lower portion of the columns. As
compared to the other test columns, the SME column
increases were minimal, with a 19.1 ug/L increase from
the control column, a 75.3 ug/L from the phosphate
column and a 35.1 ug/L from the sulfide column. The
minimal amount of total release evident from the SME
treated columns suggests that a large contaminant
plume is unlikely from SME stabilized materials after
exposure to atmospheric oxygen.
SPLP Test Observations
The stability of mercury under static test conditions
following treatment with SME was evident as compared
to the control sample material. The control sample
released a mean mercury concentration of 2143.6 ug/L,
while the SME samples released 7.2 ug/L and 10.1 ug/L
Hg, a 99.6% average decrease in leachable mercury
relative to the untreated sample. The samples also
exhibited greater than a 99% improvement in mercury
stability relative to the sulfide and phosphate treated
material.
Humidity Cell Test Observations
The released mercury in the humidity cell tests is
primarily in a dissolved state. This is likely due to the
limited mixing technique not allowing for effective
contact and encapsulation of portions of the mercury-
bearing material. Particulate or suspended mercury, if
not encapsulated, will tend to adsorb to neighboring
encapsulated material; therefore, the release of larger
fraction particulate mercury is minimized. Even in this
adsorbed state the mercury is quite resistant to leaching.
This is evident when comparing the total mercury
4-27
-------
released from the control, sulfide and phosphate cells to
that released from the SME-treated cells. Although the
dissolved mercury concentrations were slightly higher
from the SME cells, the total mercury released in the 25
urn and 0.45 urn samples combined was much lower
overall.
In-situ versus Ex-situ
Overall the SME Technology appears to be a viable
option for stabilization of mercury in the mercury ore pile
material, regardless of whether the technology is applied
"in-situ" or "ex-situ." Both techniques exhibited
comparable stability that remained consistent throughout
the testing period. The greatest variations were
observed within the data gathered during week 1 of the
column tests. The in-situ columns appeared to release a
much lower mean concentration of mercury immediately
after treatment than the ex-situ columns (19.8 versus
125 ug/L respectively). However, from week 2
throughout the conclusion of the testing, the mean
concentrations of mercury in the in-situ versus ex-situ
samples were typically within 1 to 3 ug/L of each other.
The robust nature of the technology reaction despite
substantially different treatment methods is evident in
these test results.
After the drying period between test weeks 8 and 9, the
ex-situ columns produced slightly better results, with an
increase in the mean mercury concentration of only 1.5
|j,g/L from week 8 to week 9. In-situ columns produced a
mean mercury concentration increase of 4.6 ug/L over
the same period. By the end of the 12-week testing
period, when comparing mean concentrations of
mercury evident in the leachate of the in-situ versus ex-
situ columns, a difference of only 0.2 ug/L was evident.
With the exception of week 1 data, similar trends were
also observed in regards to dissolved versus mobile,
suspended mercury in the leachate. Of the total mercury
released into the leachate, the majority of the mercury
was present in the 0.45 urn fraction for both the in-situ
and ex-situ columns.
Because contact between the metal contaminants of
concern and the SME product is essential in order to
achieve proper stability, effective mixing techniques are
critical for the overall long-term stability of the treated
substrate.
Effectiveness of SME Technology Application -
Waste rock (Secondary) Test Material
Treatment of the waste rock pile test material with the
SME chemical KB-SEA was conducted to replicate an
ex-situ treatment method as well as an in-situ treatment
method as outlined in Section 1. Initial results, based
upon the pH of the leachate immediately after treatment,
showed that the in-situ material successfully achieved
the targeted pH end point of approximately 9.0. The ex-
situ material appeared to be slightly overtreated with a
pH of approximately 11.5 evident in week 1.
Since each test method involved treatment of only one
column of waste rock pile material, statistical averaging
and the ability to identify data spikes and anomalies
cannot be accomplished.
Column Testing Observations
The SME treated waste rock pile samples all released a
higher concentration of mercury into the leachate as
compared to the control column results for all samples
evaluated, with the exception of some of the week 1-
leachate samples.
The liberated mercury evident in the SME column
leachate appears to be predominantly in the 0.45 urn or
dissolved fraction. This was also evident in the mercury
ore pile testing.
Over the 8-week column test, a reduction in the
concentration of the mercury in the leachate was
achieved in the SME-treated columns, suggesting
enhanced stability over time. However, the control
sample leachate remained at or below the detection limit
of 0.2 ug/L for the majority of the 8-week test period.
While the SME treated materials never exceeded a
mercury concentration of 6.1 ug/L in the leachate, the
sulfide sample performed better with most of the
samples at or below the detection limit. Unfortunately,
since the control column also remained within detection
limits for the majority of the sample testing, no
technology could clearly be identified as successful for
these tests.
The ex-situ and in-situ columns appeared to generate
similar results after week 3, and by the conclusion of the
8-week test period, the concentrations of mercury were
with 2-4 ug/L of each other.
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SPLP Test Observations
The SME in-situ column material did not undergo SPLP
testing. The ex-situ column test material performed
better under SPLP test conditions than the control
samples, the phosphate samples and the sulfide
samples. However, the mercury leached from the
control sample material (only 3 ug/L) was again quite
low; therefore, no single technology could be identified
as having achieved a significant reduction in the
leachable mercury as compared to the untreated
materials.
The results of the waste rock pile tests were fairly
inconclusive, but suggest that further characterization of
the waste rock pile material should be undertaken to
determine whether chemical stabilization or any other
treatment is warranted.
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Section 5.0
Quality Assurance Summary
5.1 Introduction
Quality Assurance (QA) may be defined as a system of
activities the purpose of which is to provide assurance
that defined standards of quality are met with a stated
level of confidence. A QA program is a means of
integrating the quality planning, quality assessment,
quality control (QC), and quality improvement efforts to
meet user requirements. This includes all actions taken
by project personnel, and the documentation of
laboratory and field performance as specified in the
QAPP. The objective of the quality assurance program
is to reduce measurement errors to agreed upon limits
and to produce results of acceptable and known quality.
The QAPP specified the necessary guidelines to ensure
that the measurement system was in control and
provided detailed information on the analytical approach
to ensure that data of high quality could be obtained to
achieve project objectives. The results of the QA
processes applied to the Suulfur Bank project are
summarized below.
5-1. In addition, spiked blanks, or laboratory control
samples (LCSs), also met recovery limits of 85-115%.
A select number of test columns were allowed to sit
undisturbed for several weeks and the leaching process
was then continued for an additional 4 weeks. These
extended column leachate samples were also spiked,
LCSs were analyzed and accuracy assessed. These
data indicated as well that accuracy objectives were
achieved, as noted in Table 5-2.
Table 5-1. Accuracy Data for Mercury for SBMM
Column Leachates
Leachate Fraction
Total
25um filter
0.45um filter
MS/MSD
Average %
Recovery
102
102
104
LCS
Average %
Recovery
100
102
100
5.2 Conclusions and Data Quality
Limitations
A review of the critical sample data and associated QC
analyses was performed to determine whether the data
collected were of adequate quality to provide proper
evaluation of the project's technical objectives. The
critical parameters included mercury in the leachates
from the kinetic column studies. The results of the
measurements designed to assess the data quality
objectives are summarized below, along with a
discussion of the impact of the data quality on achieving
the project's technical objectives.
Accuracy: Samples were collected and analyzed from
each of the test columns over an initial 8-week period.
Spiked duplicate samples were analyzed and recovery
data were compared to the control limits established in
the QAPP (80-120% recovery). All spikes (36 MS/MSD
pairs) met QA objectives, as summarized below in Table
Table 5-2. Accuracy Data for Mercury for SBMM
Extended Column Leachates
Leachate Fraction
Total
25um filter
0.45um filter
MS/MSD
Average %
Recovery
107
100
100
LCS
Average %
Recovery
106
102
104
Accuracy was further assessed through the analysis of
second-source standards, or Initial Calibration
Verification (ICV) standards. These standards were
analyzed after each initial multi-point calibration curve
and all ICV concentrations were within 10% of the "true"
concentration, as required in the QAPP.
Precision of the mercury analyses was assessed by the
Relative Percent Difference (RPD) between the spiked
5-1
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duplicate sample concentrations. Data quality objectives
were established in the QAPP as RPD of less than 20%.
All spiked duplicates, in both the original 8-week study
and the extended study, had RPD values less than 10%,
therefore data met the objectives for precision.
Sensitivity objectives in terms of detection limits and
practical quantitiation limits were met for all samples.
Completeness objectives for the project were met. A
few non-critical parameters were not analyzed for some
leachates due to sample volume; this did not affect
overall data collection efforts.
Comparability was addressed in the QAPP through the
use of EPA approved methodology. Mercury was
determined in accordance with SW846 Method 7470 for
all critical column study leachates.
Representativeness refers to the degree with which a
sample exhibits average properties of the site at the
particular time being evaluated. This is assessed in part
by the analysis of field duplicates, which also provide
insight into the homogeneity, or heterogeneity, of the
matrix. Field duplicate samples have inherent in the
result combined field and analytical variability.
Periodically throughout the 8-week column study,
leachate samples were collected in duplicate. Mercury
analysis of these samples indicated that reproducibility
between the samples was within guidelines (RPD <
20%), with the exception of three duplicate leachate
samples (see Table 2-3) filtered through 0.45 urn filters
that had RPD values >50%.
5-2
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