Technology Evaluation Report:
BIOLOGICAL TREATMENT OF WOOD PRESERVING
    SITE GROUNDWATER BY BIOTROL,  INC.
  RISK REDUCTION ENGINEERING LABORATORY
   OFFICE OF RESEARCH AND DEVELOPMENT
  U.S. ENVIRONMENTAL PROTECTION AGENCY
          CINCINNATI, OH 45268

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                             NOTICE

The  information  in this  document" has  been funded  by the  U.S.
Environmental Protection Agency under the auspices of the Superfund
Innovative Technology  Evaluation  (SITE)   Program  under Contract
Nos.  68-03-3485  and  68-CO-0048  to  Science Applications  Inter-
national Corporation.  It has been  subjected to  the Agency's peer
and administrative review, and it 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.

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                             FOREWORD


The  Superfund  Innovative Technology Evaluation  (SITE) program was
authorized in the 1986 Superfund amendments. The program is a joint
effort between EPA's Office of Research and Development  and Office
of Solid Waste and Emergency Response. The purpose of the'program
is   to  assist  the  development  of  hazardous  waste  treatment
technologies necessary to implement new  cleanup standards  which
require   greater  reliance  on  permanent   remedies.   This   is
accomplished through technology demonstrations designed  to  provide
engineering and cost data on selected technologies.

This project consisted of a demonstration of BioTrol,  Inc.'s fixed-
film,  amended biological  treatment  process and  a  careful and
extensive analysis of  the  effectiveness  of the system.  The  study
was  carried  out  at the MacGillis and Gibbs  Company site in New
Brighton, Minnesota,  where wood  preserving  operations  have been
carried  out over  several  decades  using  first creosote,  later
pentachlorophenol, and most recently, chromated copper arsenate.  In
1984 the ^site  was added to  the National Priorities List as one
where  soil  and  groundwater  were  contaminated with  hazardous
chemicals. Documentation for the project consists of two reports.
The  field activities  and analytical  results  of  the  study are
summeirized  in  this Technology Evaluation Report.  The  companion
Applications Analysis Report analyzes the broader applicability and
economics of the  biological  treatment process for the elimination
of pentachlorophenol  and  polynuclear aromatic  hydrocarbons from
groundwater.

For further information, please contact  the Superfund Technology
Demonstration  Division   at   the  Risk  Reduction   Engineering
Laboratory.
E. Timothy Oppelt, -Director
Risk Reduction Engineering Laboratory
                               iii

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                            ABSTRACT

The BioTrol, Inc. Aqueous.. Treatment S_ystem (BATS),  a fixed-film,
aerobic biological treatment process for contaminated groundwaters
and other wastewaters,  was evaluated at three different throughput
rates,  each  maintained  for   2  weeks  to  provide  steady-state
conditions for both operation and sampling.

This report presents a  detailed description of the process and the
system and provides  detailed results of the six weeks of monitoring
at the  MacGillis and Gibbs Company wood preserving site  in New
Brighton,  MN.   Technological   effectiveness  of  the  process  is
assessed on the  basis  of  an extensive analytical program coupled
with a quality assurance program. The economics of the process were
also assessed.

From  the results of the  pilot scale  demonstration study  it is
concluded that (a) the fixed film aerobic process is effective at
degrading pentachlorophenol, achieving more than 96% removal; (b)
effluent concentrations of pentachlorophenol well below 1 ppm are
attainable by controlling throughput rate; (c)  removal of PGP  is
largely by mineralization to carbon dioxide,  water,  and salt; (d)
acute toxicity of the  groundwater to  minnows and water fleas is
eliminated, and (e)  operating cost is about $3.45/1000 gal at 5 gpm
and would decrease to $2.43/1000 gal at 30 gpm.
                                IV

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                      CONTENTS
                                                    Page

Foreword                                            " iii
Abstract                                             iv
Figures                                              vi
Tables                                               vii
Abbreviations and Symbols                            ix
Conversion Factors                                   xi
Acknowledgements                                     xii
 1.     Introduction                                 1
 2.     Process Description                          4
          Introduction                               4
          Process Description                        6
          Site Characteristics                       11
 3.     Field Operations                             13
          Predemonstration Well drilling             13
          Field operations                           16
 4.     Sampling and Analysis Program                22
 5.     Demonstration Results                        26
          Introduction                               26
          Results                                    26
            System Parameters                        27
            Pentachlorophenol                        34
            Polynuclear aromatic hydrocarbons        43
            Dioxins/furans                           45
            Heavy metals                             46
            Volatile organics                        47
            Biomonitoring                            47
 6.    Economics                                     48
          Introduction                               48
          Conclusions              .  .  .  .            48
          Operating Costs                            48
          Hypothetical Case Studies                  51
 7.    Conclusions                                   53
 8.    Bibliography                                  54

 Appendix
       Quality Assurance Review                      57

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                        FIGURES





Figure                                                  Page



 1     PVC Media - as used and schematic                 5



 2     BioTrol's Mobile Treatment System Trailer         8



 3     Schematic of Bioreactor                           9



 4     Carbon Adsorber                                  10



 5     Site layout - groundwater wells shown            12



 6     Schematic of wellhead  .                          17



 7     Operating and sampling schematic                 24

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                           TABLES
Table                          ,                          Page
  1    PGP Concentrations in Well #1 Borehole             14
  2    Analysis of Well #1 Groundwater after Development  15
  3    Analytical Results on Groundwater during Pump Test 15
  4    Field Measurements                                 19
  5    Sampling Schedule, methods                         23
  6    Nitrite/nitrate Analytical Results                 28
  7    Ammonia Analytical Results                         29
  8    Phosphate Analytical Results                       30
  9.    Temperature Summary Across BioTrol System          31
  10    Average TSS and Oil Across BioTrol System          31
  11    Oil and Grease Analytical  Results                  32
  12    TSS Analytical Results                             33
  13    VSS/TSS Analytical Results                         35
  14    Average PGP Removal by BioTrol  System              34
  15    Pentachlorophenol  Analytical Results                37
  16    Mass Removal of Pentachlorophenol                  38
  17    Soluble PGP/Total  PGP Analytical  Results           39
  18    Comparison of Chloride and TOG  Changes              40
  19    Chloride Analytical Results                        41
  20    TOG Analytical Results                             42
  21    Potential Chloride Contributions  from Partially
        Chlorinated Phenols                              43
                            vii

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                      TABLES  (cont'd)

Table                                                    Page


  22   Sludge Analysis Results                            44

  23   PAHs in Air Emissions from Bioreactor              45

  24   Dioxins/Furans Found in System                     45

  25   Dioxins/Furans Found in Sludge                     46

  26   Metals Found in System                             46

  27   Acute Biotoxicity of Groundwater
         and Treated Effluent                             47

  28   Operating Costs                                    49

  29   Estimated Costs of Treating Various Wastewater
         volumes               .                           52

  30   Treatment Costs over Five Years                    52
                           viii

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                    ABBREVIATIONS AND SYMBOLS


BATS      BioTrol Aqueous Treatment System

BGS       below ground surface

BOD       biochemical oxygen demand (mg oxygen/liter)

BTEX      benzene, toluene, ethyl benzene, and xylenes

CERCLA    Comprehensive Environmental Response, Compensation, and
          Liability Act of 1980

cfm       cubic feet per minute

COD       chemical oxygen demand (mg oxygen/liter)

EMSL      Environmental Monitoring Systems Laboratory

GC/MS     gas chromatograph/mass spectrometer

gpd       gallons per day

gpm       gallons per minute

HPLC      high pressure liquid chromatography

HSWA      Hazardous and Solid Waste Amendments to RCRA - 1984

kwh       kilowatt-hour

LC(50)    Lethal concentration to 50% of a test species
          population

Mgd       million gallons per day

mg/L      milligrams per liter                 .

ng/kg     nanograms per kilogram

ng/L      nanograms per liter

NPL       National Priorities List

O/G       oil and grease

                               ix

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ORD       Office of Research and Development
OSHA      Occupational Safety and Health Act/Administration
OSWER     Office of Solid Waste and Emergency Response
PAHs      polynuclear aromatic hydrocarbons
PCP       pentachlorophenol
PEL       Permissible Exposure Limit
POTW      publicly owned treatment works
ppb       parts per billion
ppm       parts per million
psi       pounds per square inch
PVC       polyvinyl chloride
QA/QC     quality assurance/quality control
RCRA      Resource Conservation and Recovery Act of 1976
RI/FS     Remedial Investigation/Feasibility Study
RREL      Risk Reduction Engineering Laboratory
SARA      Superfund Amendments and Reauthorization Act of 1986
SITE      Superfund Innovative Technology Evaluation
TCPs      tetrachlorophenols
TOG       total organic carbon (mg carbon/liter)
TSS       total suspended solids (mg solids/liter)

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                        CONVERSION FACTORS
                     English (US)
                                    x
Factor
Area:
Flow Rate:
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
ft*
in2
gal/min
gal/min
Mgal/d
Mgal/d
Mgal/d
ft
in
Yd
Ib
Ib
ft3
ft3
gal
.gal
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
9.2903 X 10"2
6.4516
6.3090 x 10'5
6.3090 x 10'2
43.8126
3.7854 X 103
4.3813 X 10'2
0.304S
2.54
0.9144
4.5359 X 102
0.4536
28.3168
2.8317 X 10"2
3.7854
3.. 7854 X 10'3
Length:
Mass:
Volume:
ft = foot, ft2 = square foot, ft3 = cubic foot
in = inch, in2 = square inch
yd = yard
Ib = pound
gal = gallon
gal/min  (or gpm) = gallons  per  minute
Mgal/d (or MGD) = million gallons per day
m = meter, m2 = square meter, m3 = cubic meter
cm = centimeter, cm2 = square centimeter
L = liter
g = gram
kg = kilogram
xr/s ==  cubic meters per second
L/s = liters/sec
m3/d ==  cubic meters per day
=  Metric

     m2 '
=    cm2

     m3/s
     L/s
     L/s
     ra3/cL
     m3/s

=    m
=    cm
=    m

     g
     kg
                                xi

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                         ACKNOWLEDGEMENTS


This report  was directed and coordinated by Mary K. Stinson, EPA
SITE Project Manager in the Risk Reduction Engineering Laboratory -
Cincinnati,  Ohio.

This report was prepared for EPA's Superfund Innovative Technology
Evaluation (SITE) Program by Herbert S.  Skovronek and William Hahn
of  Science Applications  International  Corporation for  the U.S.
Environmental Protection Agency under Contract Nos.  68-03-3485 and
68-CO-0048.

The  cooperation 'and  participation of  Thomas   J.  Chresand  and
supporting staff of BioTrol,  Inc.  throughout  the  course  of the
project and  in  review of this report are gratefully acknowledged,
as is the assistance of A.J. Bamby of MacGillis and Gibbs.

Mark Lahtinen of the Minnesota Pollution Control Agency (MPCA) and
Rhonda McBride, Linda Kern,  and Darryl Owens, the Remedial Project
Managers of  USEPA's Region V provided  invaluable  assistance and
guidance  in  initiating  the  project   and  in  interpreting  and
responding to regulatory needs of the project.

Ronald Lewis  and Gordon Evans of USEPA's  Risk Reduction Engineering
Laboratory and Linda D. Fiedler of the Technology Innovation Office
of OSWEK provided invaluable reviews of the draft report.

Finally, the project could not  have been carried out without the
tireless efforts of the many SAIC and Radian field and laboratory
personnel.
                               xii

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                            SECTION 1

                           INTRODUCTION


In response to the Superfund Amendments and Reauthorization Act of
1986  (SARA),   EPA's  Office of Solid Waste and Emergency Response
(OSWER)  and   the  Office   of  Research  and  Development  (ORD)
established the Superfund Innovative Technology Evaluation (SITE)
Program. The  goal  of this program is   to promote and accelerate
the development of  innovative technologies for consideration in the
clean up of Superfund sites across the country.

The  SITE Program  seeks to meet  new  federal and  state cleanup
standards by providing permanent remedies to waste problems, rather
than  temporary  measures.  Such   methods  include  destruction,
stabilization, and treatment  processes that  will  assure - to the
maximum extent possible - that problems will not resurface in the
future.

The  SITE   Program   is   composed   of  two  major  elements:   the
Demonstration Program and the Emerging Technologies Program.   The
focus  of  the  Demonstration  Program  is  to  provide  reliable
engineering  and cost  data  based  on  field  tests of  selected
technologies.   The    Emerging  Technologies   Program fosters  the
investigation and development  of technologies now at the laboratory
scale.- A third component of the SITE Program, the Measurement and
Monitoring  Technologies Program,  assists in the  development  of
innovative technologies to better characterize Superfund sites.

In this case,  EPA was able  to  carry out two demonstration projects
and the assessment of a measurement and monitoring methodology at
one  facility,  thereby  making  maximum  use  of  personnel  and
resources. Documented in this  report are the sampling and analyses
results used to evaluate the treatment of contaminated groundwater
by a fixed  film bioreactor. The other two research efforts,  soil
washing   and    an   Immunoassay   analytical    technique    for
pentachlorophenol,  are briefly noted and are documented in separate
reports.


PROJECT OBJECTIVES

The major objectives of this SITE Demonstration Project were to:

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1.   Determine the capability of the BioTrol technology to remove
     pentachlorophenol (PGP) from  groundwater at a wood treatment
     facility, where a range of other contaminants may be present;

2.   Determine  the  effect  of  throughput rate  (flow)  on removal
     efficiency;

3.   Determine  the  capability  of  the  BioTrol  process  to remove
     polynuclear   aromatic   hydrocarbons   from  a   wastewater
     contaminated by creosote;  and

4.   Determine  the  cost  of the treatment  and  the  factors  that
     impact on the cost of the  process.


DESCRIPTION OF PROJECT

Biological treatment has a long history of use  for a wide variety
of  municipal  and  industrial wastewaters.  Only recently has  it
become apparent that even organics thought to be highly resistant
to biodegradation, such as the  chlorinated phenols used to impart
rot  resistance to  wood,  could be  degraded  biologically,  under
carefully selected conditions.

On the basis of fundamental research over the last several years,
BioTrol, Inc.  developed an innovative process to carry out such a
biological  degradation   process  compactly,   efficiently,   and
economically.  The process is carried but aerobically in stages on
an inert support matrix. Local soil bacteria already able to resist
and even degrade  pentachlorophenol  are supplemented or "amended"
with an inoculum of a pentachlorophenol-specific bacterium to give
maximum biodegradation in the first stage, where the concentration
of the pentachlorophenol  is highest.  The  staged arrangement of the
technology then  allows other constituents to  be degraded in the
latter stages of the reactor, after the "toxic" pentachlorophenol,
has been reduced.

For the  demonstration  project, three  different throughput  rates
were examined over the course  of about six weeks to evaluate the --
effect of flow rate on the efficiency of treatment, particularly in
terms  of pentachlorophenol  removal. An  extensive  sampling ^and
analysis program defined by  an  EPA  Category II Quality Assurance
Project Plan (QAPP)  was an integral part of the project.

The site selected for the demonstration  was  a  wood  preserving
facility in New Brighton, .Minnesota.  Earlier screening of the site
as part  of  a  Remedial Investigation/Feasibility Study indicated
significant  contamination  of  both  soil  and  groundwater  with
pentachlorophenol and  polynuclear aromatic  hydrocarbons as  the
result of many years of operation with creosote, pentachlorophenol.
Currently,  chromated  copper  arsenate   (CCA)  is  used  and  waste

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management is consistent with current regulatory requirements. The
site had been added to EPA's National Priorities List in 1984.

This  report  and  the  companion  Applications  Analysis  Report
document,  analyze,  and  interpret  the  results   of  the    SITE
demonstration project.


PROJECT ORGANIZATION

Through a Cooperative Agreement between  EPA and BioTrol, Inc., the
developer was responsible for operating its equipment while EPA and
its contractor, Science  Applications International Corp.  (SAIC),
located and installed a suitable well to  supply the  groundwater for
the project,  prepared the demonstration plan, designed the sampling
plan, conducted  sampling and  analysis,  evaluated the  data,  and
prepeired  the final  reports.  In addition,  EPA's  contractor  was
responsible for pre-demonstration sampling of the groundwater, for
managing public information meetings, and for site decontamination.

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                            SECTION 2

                       PROCESS DESCRIPTION


INTRODUCTION

Biological processes have been widely  used  for many years in the
treatment of  industrial  and municipal wastewaters,  with aerobic
treatment being  the most widely used technology.  As industrial
products have been developed to provide resistance to degradation
by the environment,  it has often  been assumed that these chemicals
also would be resistant to conventional biodegradation. It has now
been  recognized  that  such  is  not the  case  and,   using  proper
procedures  and     suitable  biological   populations,  efficient
biodegradation of many organic  chemicals,  including chlorinated
aromatics such as pentachlorophenol, can be achieved.

To provide  the most  efficient  and cost effective  treatment  of
wastewaters  containing  such  contaminants,  BioTrol,  Inc.  has
developed a proprietary process based on amended fixed-film aerobic
treatment. Using a  multi-stage reactor,  an initial biogrowth  is
developed on an inert support matrix such as corrugated polyvinyl
chloride sheets (Figure 1) using  indigenous bacteria from a source
such as soil at the site. This bacterial population, having been
derived from the local soil,  is  resistant to  the toxicity of the
local contaminants  and may  even have a population distribution
which favors  the destruction of chemicals from  the site. After this
bacterial source has been allowed to   acclimate on  -the matrix  in
the presence  of nutrients, an inoculum of  a Flavobacterium specific
to  the  target chemical,  pentachlorophenol,   is added.  Further
acclimation then  is  allowed  to occur in a  total  recycle mode before
the system is ready  for once-through treatment  of the groundwater.

The design of  the BioTrol  system  allows the  development  of the
largest  concentration  or  population  of  bacteria  capable  of
degrading  pentachlorophenol  in  the   first  chamber,  where  the
concentration  is  highest.   As  the wastewater  flows  through the
reactor and the pentachlorophenol  concentration decreases,  other
bacteria more suitable to degradation of other contaminants,  but
perhaps more sensitive to deactivation by pentachlorophenol, have
the opportunity to grow and consume those contaminants.

The BATS fixed-film process has  a  further advantage in that very
little sludge is  generated and, consequently, sludge management is
not a significant factor in operation.

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                      BLOCKS
                   CROSS-STACKED
FIGURE   1. CORRUGATED POLYVINYL CHLORIDE MEDIA
                          '5

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BioTrol Soil Washing Process

In  addition  to the  BioTrol  Aqueous  Treatment System   (BATS),
BioTrol,  Inc.   also  has developed  a soil  washing  process that
separates coarser,  relatively uncontaminated soil from more heavily
contciminated fine material such as clay. PCP contamination of the
fines;  then  can be  treated by  other methods such  as  biological
degrsidation in  a  slurry bioreactor. The  relatively clean washed
soil and even  the slurry reactor-treated fines may then be returned
to the site. The BATS which is the subject of this report also is
employed in the soil washing sequence to treat the washwater used
to separate the sand and fine materials. The Soil Washing process
is the subject of a  separate  SITE Demonstration Program  at the
MacGillis and Gibbs facility and is reported separately.

Field Immunoassay for Pentachlorophenol

While  this project  was   being developed,  EPA's  Environmental
Monitoring Systems Laboratory (EMSL) in Las Vegas was searching for
a facility  where  a new  immunoassay method  for field  monitoring
pentaichlorophenol in wastewaters could be studied under real-world
conditions. The groundwater  study  at  the  MacGillis   and Gibbs
facility offered an ideal environment to evaluate this technique in
parallel with  the  extensive analyses being  done as part  of the
demonstration. Consequently, arrangements were made to have EPA's
contractor carry out the field test as part of their assignment.

The immunoassay test, developed by Westinghouse,  is based on the
inhibition of  bacterial enzyme  activity  when  a target chemical, in
this  case  pentachlorophenol,   is  present.   The  inhibition  is
observed by a color  change in a  reagent  matrix and  is  readily
quantified using standards.  Only very small samples of material are
needed  and  the results  are generated  in about an hour.  Field
experience was needed to learn how well results correlated with the
standard GC/MS analysis and larger, laboratory-scale immunoassays;.
how sensitive  the test was with  real-world wastewater matrices, and
how conveniently and reliably it could be carried out in the field
by relatively inexperienced personnel.

Reference is included to make the reader aware of this effort and
the potential  availability of the method. A report documenting .the
procedure and results of this study will be available separately.


PROCESS DESCRIPTION

The BioTrol equipment used in  this demonstration  consists  of  a
single  mobile  trailer  (20 ft.  in  length)  fitted  with all  the
necessary tanks, pumps, etc. (Figure 2). A level area  (ideally a
concrete apron) about 50 x 50 ft is needed to support the trailer
and auxiliary  facilities.  The   capacity of the  mobile  system is
about. 5 gpm, depending on the concentration of the pollutants to be

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degraded; and its hydraulic capacity is about 10 gpm. Contaminated
water  is  brought to the  100  gallon mixing or  conditioning tank
where  pH  is  automatically  adjusted to  slightly  above 7.0  by
metering  in  a   caustic  solution.  A  solution  of  nitrogen  and
phosphorus, nutrients  (urea plus  trisodium phosphate)  is  also
metered into  the conditioning  tank at  a  pre-determined rate.  For
this; study a  mixture of 2.5 Ibs  of urea  and 5.0 Ibs of trisodium
phosphate in 50  gal of water was metered in at a  rate of 2.5 ml/gal
of wastewater. The mixed water passes through a heat exchanger and
then a heater which is available to elevate the  temperature to
about  70°F (21°C) ,  which is considered  an optimal temperature for
biological treatment.

The influent  is then introduced into the base of the first of the
3-celled biological reactor (Figure 3) and moves from cell to cell
by  means  of underflow  weirs-.  In  the   pilot  unit  each  cell,
containing the PVC matrix,   has approximately 160 gallon capacity,
giving a total  system capacity of about  500 gallons.   Thus, at 5
gpm the retention time  is approximately 1.7 hours; at  3 gpm the
retention time would be 2.7 hours and at 1 gpm the retention time
would  be  8.3  hours.  Air is continuously  injected to  the base of
each chamber  and  distributed  by a  network of  sparger  tubes to
maintain  sufficient dissolved oxygen  (DO) to support  aerobic
conditions for biodegradation  (about  5 ppm).  The  combination of the
flow,  the  air sparging, and the design of  the  plastic  media are
such that upward and lateral distribution  of the water and the air
occur in each chamber. After moving through the three chambers, the
effluent exits from the third chamber via an overflow weir.

While  the process  is  claimed to be  relatively insensitive  to
suspended solids  and dispersed oil  and the  mobile  trailer is not
equipped  to  remove these  contaminants,  oil/water  separation or
solids removal could be added externally if necessary, depending on
the quality of the wastewater being treated. Such pretreatment was
deemed unnecessary with the MacGillis and Gibbs groundwater.

Similarly, while BioTrol's experience has been that post-treatment
such as suspended  solids  removal  or  carbon  polishing are  not
usucilly necessary,- EPA made the  decision  that a small bag filter
and a  carbon adsorber  would be added  to  the effluent  line to
assure  that  the discharge  to  the Minneapolis  Metropolitan POTW
would  be  of  high quality.  The  bag filter was installed  in the
effluent line leaving the bioreactor  and was followed by a 50 cubic
foot carbon  adsorber  (Figure  4).  EPA  also chose  to install  a
smaller carbon adsorber on  the air exhaust  line exiting from the
bioreactor to assure that  no  hazardous  volatile  chemicals were
emitted.  During  the course of the  demonstration,  analyses were
carried out before and after both carbon  adsorbers  to assess the
need for such protective devices.

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 SITE  CHARACTERISTICS

 In the demonstration program the mobile pilot scale system requiired
 only  a level base (ideally a concrete pad) ; potable water and power
 for pumps, the heater,  lighting, etc. were supplied by the facility
 operator.  If necessary  at  other  sites,  potable  water could be
 trucked  in and power could  be provided by an on-site generator.

 The MacGillis  and Gibbs Company facility has  been used for wood
 preserving for several  decades. Originally creosote was used in the
 treatment; subsequently,  in the  1950's,  pentachlorophenol in oil
 was  substituted. Operations  were  carried  out in  open troughs,
 presenting many opportunities for spills  and leaks. Treated lumber
 was stored on the site where further contamination could occur as
 the result of rain wash-off. In addition, for a period in the 50's,
 waste pentachlorophenol solution was used for weed control on the
 site.  As shown  in  Figure  5,  the  southwestern    section  of the
 MacGillis and Gibbs  property  where disposal has frequently taken
 place also  collects water and forms  a  pond.  There  has  been
 suspicion that some of  the contamination in this area may be due to
 run-off  from the  adjacent  Bell  Pole property.  In  the 1970's,
 MacGillis and Gibbs replaced pentachlorophenol with the chromated
 copper arsenate  process  and substituted closed reactors for the
 open  troughs,  thus  minimizing the opportunities  for inadvertent
 spills and leaks.

 The facility originally came to the attention of the EPA as part of
 an investigation of the neighboring Bell Pole facility where wood
 treatment was also being  carried out. Ultimately, as the result of
 an RI/FS,it  was  concluded that the soil and  groundwater at both
 sites  was   contaminated   with   pentachlorophenol   and  lesser
 concentrations of  polynuclear aromatic hydrocarbons.  Both sites
were placed on EPA's National Priorities List in 1984.

MacGillis and Gibbs  has  a discharge permit for discharge  of its
 sanitary wastewater to the Minneapolis/St. Paul Treatment Works. An
agreement was reached for the POTW to accept treated effluent from
the bioreactor on the condition that it contained <2 ppm of PCP.
                               11

-------
 CCA
 AREA
n
i PCP
      11.
 PROCESS
 AREA
 B!:LL
 POLE  •
         FIGURE    5. MACGILL1S & GIBBS SITE

                             12

-------
                            SECTION 3
                         FIELD OPERATIONS


PREDEMONSTRATION WELL DRILLING

Before the demonstration project could be initiated or a decision
reached as to whether this facility was appropriate for evaluation
of the process,  it  was  necessary to  establish whether a suitable
grouridwater was available.  Criteria established by the developer
were  (a)  up  to 100 ppm of pentachlorophenol;  (b)  flowrate of at
least 5  gpm,  and (c) some concentration of polynuclear aromatic
hydrocarbons.

Reports by Twin Cities Testing Corp.,  a Remedial Investigation  (RI)
contractor,   documented soil  borings at  the  site which strongly
suggested that suitable groundwater was present in the vicinity of
the disposal area and pond in the southwestern portion of the site.
Several of these  borings had been found to contain very high levels
of PCP and PAHs, but some had also indicated  high concentrations of
oil. Based on  these reports,  a  4-inch well  (#1)  was drilled by a
contractor in what appeared to be an attractive area, as shown in
Figure 5. The  well  was  drilled  to  a  depth of 45  ft.  and screened
from approximately  30 ft  to  45 ft. Samples were  taken  at 5 foot
intervals as  the  well  was drilled and rapidly  analyzed (24-hour
turnaround) using  BioTrol's  High  Pressure  Liquid Chromatography
(HPLC) method so that the operation could be  terminated if the well
proved to be unsuitable in PCP analysis.

The results of the initial analyses (Table 1)  showed considerably
less PCP  than anticipated; while not quantified, PAH concentrations
also appeared to be quite low.
                               13

-------
         TABLE 1.  PGP CONCENTRATIONS  IN WELL #1  BOREHOLE
depth
(ft)
10
15
20
25
30
35
40
PCP cone.
(ppm)
12.1
19.6
18.
13.4
29.2
31.4
45.7
Based  on  these  initial  results,   and  to  minimize  the  risks
associated with  relying on a  single well for  the demonstration
project, a second well was then drilled approximately 65 feet north
of Well #1, in an area where pentachlorophenol contamination also
was expected to  be high.  Starting  at about 10 feet, considerable
contamination with an oil-like material was observed in this well
and groundwater was not detected  in the borehole even down to 20
feet. A static water level  of  11  feet below ground surface (BGS)
was observed after operations   had  been left for the weekend and a
floating  liquid   layer  was also  clearly  evident. Drilling  was
continued  to  a  depth  of  46  feet where  clay-like material  was
encountered. Evidence  of oil  was  observed at.  several  different
depths.

Two groundwater samples were analyzed from Well #2, believed to be
representative of. 15  ft BGS  and 45  ft BGS.  Pentachlorophenol
concentrations at these depths were 97.8 and 5.7 ppm, respectively;
only traces of PAHs were detected in the 45 ft sample.

Each well was then developed using a surge block and submersible.
pump, continuing  the pumping until the water was turbidity-free and
field  measurements of   pH,  temperature,  and  conductivity  had
stabilized to within 10%. A sample  of Well #1 was then taken using
a Teflon bailer and submitted for extensive analyses.  The results <
of those analyses are  shown in Table 2.
                               14

-------
TABU! 2. ANALYSES OF WELL #1 GROUNDWATER AFTER DEVELOPMENT

  Constituent               Concentration   Units
Volatile Organics
methylene chloride
toluene
Semivolatile Organics
pent achl or opheno 1
2 -methyl phenol
4 -methyl phenol
2, 4 -dimethyl phenol
naphthalene
2 -methyl naphthalene
Metals
leeid
zinc
Total Phenol ics
TOG
Oil/Grease
Chloride
Dioxins

5*, 5*
6, 5*

15, 13
20, 23
20, 24
32, 33
86, 90
50, 52

8
280
0.859, 0.706
51
14, 10
23, 30#
All 
-------
Slug tests were also carried out on both wells  using a Hermit data
logger to provide additional flow rate data. Analysis of the data
indicated flow rates of 28 gpm and  3 gpm for Well #1 and Well #2,
respectively.

On the basis of the foregoing data,  a decision  was made to proceed
with the demonstration project using the groundwater from Well #1
as the  feed  water to the BioTrol system.  The  well  was cased and
protected as shown in Figure 6.


FIELD OPERATIONS

Once the well had been selected and constructed,  a 1 inch PVC line
running some  800  feet to the pilot BATS unit  was  installed.  The
line was buried where  it  traversed  railroad tracks  and a road to
avoid  accidental  rupture  and  interruption  of  operations.  A-
submersible pump was used to withdraw the groundwater.

In  anticipation of  start-up,  BioTrol  personnel acclimated  the
bioreactor to the groundwater contaminants,  first with closed loop
recycle of the water  from the well development and pump test, which
had  been  stored  in  tanks   adjacent  to   the  reactor  trailer.
Acclimation consisted of introducing air, nutrients, arid a slurry
of soil from the  site  to  supply indigenous bacteria.  After about
one week  of closed  loop  operation  with this  water  source,  the
flavobacterium specific to pentachlorophenol was  introduced to the
conditioning tank and acclimation was continued. Delays in start-up
of the demonstration phase of the  program  made  it  necessary for
BioTrol to continue operation for several weeks,  ultimately using
the groundwater directly from the well. In effect, this placed the
system in steady state operation  even before the demonstration was
initiated.

A separate trailer was brought on-site for contractor personnel to,
use in preparing samples and related documentation (and in which to
carry out the immunoassay  tests for  EPA-EMSL/Las Vegas). Composite
samplers were installed adjacent.to  the reactor trailer to collect
22-hour samples  from  the influent, each cell of  the bioreactor, and ,_
the effluent. Procedures were reviewed to assure  that all sampling
could be  carried  out as planned.  The  bag  filter and  the  carbon
adsorbers for the effluent and for  the  combined  exhaust from the
cover over the bioreactor were connected.

On July  24, 1989 the project was officially  initiated at an initial
flow rate of  1 gpm. Nutrient solution was  continuously added to the
conditioning tank and pH was  adjusted to  about  7.3 by the addition
of 50% caustic solution. Some problems were initially encountered
due to  foaming  in the bioreactor,  but  this soon subsided.  Both
composite and grab samples were collected  as  scheduled  over  the
course of two weeks of operation at this flow


                               16             .

-------
                 Vented  Stainless
                 Steel Cap
                             Steel Casing with
                             Cap  & Lock
                                      3"x5'  Steel
                                      Guard  Post
                                      Land Surface

                         4" I.D. Schedule 40 Type
                         304 Stainless Steel Riser

                           Cement Bentonite Grout
8" Borehole
Bottom of
Borehole  5®
                            Bentonite Pellet  Seal
                            Sand Pack
                           4"  I.D.  Schedule  40
                           Type 304 Stainless
                           Steel  Screen
                           (0.020"  Slot)
                         Flush  Plug
                   NOT TO SCALE
          FIGURE 6. WELL CONSTRUCTION
                         17

-------
rate. System  parameters (temperature, pH, dissolved  oxygen,  and
flow rate) were measured to  assure  that  the  system was operating
within planned parameters.  The summary of the system data for the
entire project is presented in Table 4.

After two weeks of operation  at 1 gpm,  the flow rate was increased
to 3 gpm on August 6, 1989 by changing the discharge pump rate. One
24-hour period was allowed for equilibration and return to steady
state before sampling was restarted.  Operation was again continued
for two weeks, to August 19,  1989.

On August 20,  1989,  flow was  again increased, to 5 gpm, and sample
collection resumed after one day of equilibration.

On  September   1,  1989, the  demonstration phase was  completed.
Because of the long delay in receiving analytical results for key
parameters, it was  not feasible to  review  data  as  a means  of
deciding whether any segment  of the project needed to be repeated.

Because  the  demonstration  project took  place during  the summer
months,  it was unnecessary to use the heater in the system.

[Originally, plans for the project had called for "spiking" of the
groundwater with  a much higher concentration  of  PCP to determine
the impact of such shock loading. However, all parties agreed that
(a)  such  shock   loading was  not  reasonable  to  expect   from  a
groundwater,  and  (b)  dilution of  such  a  spiked  feedwater  with
effluent or potable  water would be a  viable means  of preventing
shock loading. In  addition, plans called for the unit to be used in
the immediate  future for  treatment of wastewaters  from  the  soil
washing study. If successful,  the shock  loading  experiment would
have  deactivated  the  biological  growth  and  necessitated  re-
acclimation. Since this was  not desirable,  the spiking segment of
the study was not undertaken.]

Normally,  the  system would   have   been  decommissioned  after
completion of the  demonstration project; however, plans called for
the unit  to be used for  treating process waters from the  soil
washing demonstration. It was left in a "stand-by" mode, operating
at a low  flow rate on groundwater,  until the  second  project was
operational. When  that project was completed, the BATS was drained,
electrical and water- hook-ups  disconnected,  and the  PVC matrix
removed  and discarded. Wastes that were collected  during  the
project  included  sludge,  analytical wastes  such  as  cleaning
solvents, and  contaminated protective gear. Liquids and solids were
stored,   segregated,  in 55  gal  drums for off-site disposal  as
hazardous wastes.  The carbon  from both adsorbers was removed to be
thermally regenerated.
                               18

-------
TABLE 4.  SYSTEM FIELD MEASUREMENTS

DAY
OF
RUN
1
2
3
4
5
6
7-
3
9
10
11
12
1
2
3
4
5
6
7
8
9
10,
11
12
1
2
3
4
5
6
7
8
9
1O
11
12
SAMPLE
NUMBER
ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
ST1-C-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
Tl-C-06
Tl-C-07
Tl-C-08
Tl-C-09
Tl-C-10
Tl-C-11
Tl-C-12
PROCESS
FLOW
( MGD )
0.75
0.95
1.25
NA
NA
0.97
0.92
0 . 96
0.88
0.87
1.1
1.24
2.74
2.98
2.71
3.15
3.04
2.88
2.97
3.04
3.04
2.81
2.99
3. .24
NA
NA
4.96
5.24
5.17
5.21
5.05 .
5.04
5.21
4.84
4.97 .
5.06
pH ( s.u. )
""'•" SAMPLING POINT
#
INF
FIRST
GRAB
7.4
7.6
7.6
7.6
7.6
6.9
7.9
7.4
7.7
7.3
7.8
7.3
8.3
7.0
7.8
7.4
8.0
7.4
7.7
8.0
8.4
8.3
7.7
7.3
7.1
7.5
7.6
7.3
8.0
7.4
7.5
7.0
7.1
7.3
7.3
7.3
02
LUENT
SECOND
GRAB
7.9
7.6
7.6
7.6
6.9
7.9
7.7
7.6
7.9
7.5
7.4.
7.5
7.1
7.9
8.2
7.3
7.9
7.6
8.0
8.7
7.1
8.7
7.6
8.7
NA
7.2
7.5
"8.0
7.5
7.1
7.0
6.9
6.8
7.7
7.4
7.1
^
MID P
FIRST
GRAB
8.4
8.3
8.0
8.3
8.4
8.0
8.2
8.0
8.0
8.2
8.0
7.8
7.8
7.5
7.9
7.8
7.7
7.8
7.8
8.0
7.8
7.7
7.7
7.7
7.5
7.6
7.7
7.6
7.7
7.8
7.8
7.2
7.0
7.8
7.7
7.7
03
OINT 1
SECOND
GRAB
8.5
8.5
8.3
8.4
8.3
8.1
8.1
8.0
8.2
8.2
8.2
7.8
8.5
7.7
7.8
7.7
7.7
7.8
7.9
7.7
7.6
7.8
7.8
7.9
NA
7.8
7.6
7.9
7.7
7.2
7.4
7.3
7.2
7.7
7.7
7.7
#
MID F
FIRST
GRAB
8.4
8.3
8.3
8.3
8.3
8.0
8.4
8.0
8.1
8.3
8.2
8.5
8.0
7.7
7.8
7.7
7.8
7.9
7.9
8.0
7.9
7.8
7.8
7.7
7.5
7.9
7.7
7.6
7.7
7.8
7.5
7.1
7.0
7.7
7.7
7.8
04
OINT 2
SECOND
GRAB
8.3
8.4
8.3
8.4
8.2
8.1
8.2
8.2
8.3
8.4
8.4
8.1
7.8
7.9
7.8
7.9
8.0
7.9
7.9
7.8
7.6
7.8
7.8
7.9
NA
7.8
7.7
7.8
7.7
7.2
7.4
7.3
7.2
7.7
7.7
7.7
1
EFF
FIRST
GRAB
8.3
8.2
8.4
8.3
8.4
8.0
8.1
8.1
8.3
8.4
8.3
8.3
8.1
7.9
7.8
7.9
7.9
7.9
7.9
8.1
7.9
7.8
7.9
7.9
7.6
7.7
7.7
7.7
7.7
7.7
8.0
7.4
7.2
7.3
7.7
7.8
05
LUENT
SECOND
GRAB
8.4
8.4
8.2
8.4
8.3
8.2
8.3
8.4
8.4
8.4
8.4
8.2
8.1
7.9
8.0
8.0
7.9
8.0
7.9
7.8
7.6
7.9
7.8
8.0
NA
7.7
7.8
8.0
7.8
7.3
7.4
7.5
7.2
7.7
7.8
7.8
                        19.

-------
TABLE 4. SYSTEM OPERATING PARAMETERS  (cont'd)
              Dissolved Oxygen


DAY
OF
RUN


1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
a
9
10
11
12 .
1
2
3
4
5
6
7
8
9
10
11
12
SAMPLE
NUMBER



ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
ST1-C-01
ST1-C-02
ST1-C-03
STl-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
PROCESS
FLOW
( MGD )


0.75
0.95
1.25
NA
NA
0.97
0.92
0.96
0.88
0.87
1.1
1.24
2.74
2.98
2.71
3.15
3.04
2.88
2.97
3.04
3.04
2.81
2.99
3.24
NA
NA
4.96
5.24
5.17
5.21
5.05
5.04
5.21
4.84
4.97
5.06
Dissolved Oxygen ( mg/1 )
SAMPLING POINT


#02
INFLUENT
FIRST
GRAB
9.7
3.8
3.7
NA
6.56
5.8
6.12
6.7
3.6
5". 4
4.73
4.15
7.4
3.8
4.24
5.3
3.62
5.17
6.16
5.23
6.11
5.32
4.09
4.85
6.46
5.54
5.8
4.35
5.92
3.94
5.84
5.05
5.23
5.49
6.03
6.41
SECOND
GRAB
3.8
4.3
NA
NA
NA
NA
4.82
7.7
5.64
4.12
5.04
5.48
3.26
4.24
3.82
4.65
4.23
4.77
5.45
6.8
5.26
5.32
5.81
6.4
NA
5.85
5.12
6.4
5.96
6.31
6.03
5.16
4.95
5.33
5.77
5.33
#03
MID POINT 1
FIRST
GRAB
9.6
3.5
3.6
5.2
6.7
6.48
6.85
8.7
5.9
6.2
5.15
5.58
6.85
6.37
5.87
6.56
6o22
6.84
5.94
6.07
3.22
4.86
5.6
5.27
5.95
5.8
5.68
5.65
5.54
4.53
5.6
5.9
5.31
5.75
5.97
6.56
SECOND
GRAB
3.5
4.4
NA
NA
NA
NA
5.93
6.5
6.10.
6.88
5.76
6.14
6.83
6.45
6.08
6.48
5.78
5.92
5.81
5.06
4.96
5.51
5.52
4.37
NA
5.92
5.17
5.35
4.9
5.76
6.21
5.81
6.0
5.77
6.17
6.57
#04
MID POINT 2
FIRST
GRAB
9.6
3.5
3.3
5.86
6.64
6.62
7.17
8.7
5.6
6.03
5.75
5.75
7.63
5.5
5.92
6.54
6.11
6.49
6.11
6.56
5.93
5.22
6.04
5.5
6.1
5.57
5.81
5.3
5.49
4.44
6.29
5.52
5.07
5.1
5.47
6.16
SECOND
GRAB
3.6
4.4
NA
NA
NA
NA
8.16
7.4
6.52
5.92
5.99
6.63
6.03
6.58
6.58
6.52
6.42
6.43
5.85
6.23
5.75
5.24
5.31
5.07
NA
6.1
5.31
. 5.2
4.62
5.74
5.39
5.47
5.38
5.12
5.04
5.78
#05
EFFLUENT
FIRST
GRAB
9.8
3.2
3.8
5.28
7.3
0.42
6.79
8.1
7.1
6.5
5.96
5.42
7.26
4.75
4.85
6.35
5.72
6.6
5.81
6.02
5.67
2.0
4.88
5.81
5.83
5.92
5.06
5.65
5.92
3.61
5.88
5.96
5.64
5.89
6.03
6.2
SECOND
GRAB
3.5
4.7
NA
NA
NA
NA
6.17
7.7
6.37
5.86
5.89
6.21
6.8
6.1
5.34
4.95
4.74
6.33
6.23
6.06
5.26
5.51
5.62
5.24
NA
5.62
5.79
6.41
5.8
6.19
6.11.
6.32
6..1
6.13
6.31
5.58
                              20

-------
TABLE" 4. SYSTEM FIELD MEASUREMENTS (cont'd)
                  Temperature


DAY
OF
'RUN


1
2
3
4
5
6
7
8
9
10
11
12
1
2
3
4
5
6
7
8
9
1Q
11
12
1
2
3
4
5
6
7
8
9
10
11
12
SAMPLE
NUMBER



ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07.
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
ST1-C-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
PROCESS
FLOW
( MGD )


0.75
0.95
1.25
NA
NA
0.97
0.92
0.96
0.88
0.87
1.1
1.24
2.74
2.98
2.71
3.15
3.04
2.88
2.97
3.04
3.04
2.81
2.99
3.24
NA
NA
4.96
5.24
5.17
5.21
5.05
5.04
5.21
4.84
4:97
5.06
Temperature ( oF )

-------
                            SECTION 4

                  SAMPLING AND ANALYSIS PROGRAM

The Demonstration Test Plan for this project, dated July 1989, is
part of the Appendices to this report. The Plan provides a detailed
discussion  of  the  overall  sampling and analytical procedures and
methods  discussed  in this section. The Plan also references the
procedures  used  in  the  Predemonstration well drilling effort and
the HPLC method developed by BioTrol for PCP analysis.

In  essence,   the   sampling   and  analysis  plans  developed  in
anticipation of the study were adhered to during the investigation.
Composite samples of the influent, effluent, and midpoints of the
reactor were decreased from 24-hour samples to 22-hour samples to
allow equipment to be prepared for the next cycle within the same
24-hour period. Because  of access problems, it was necessary to use
a stainless steel beaker to withdraw certain grab  samples from the
reactor cells.

The one area where seripus sampling problems were encountered was
the sludge  in the bag filter. The nature and amount of the sludge
was such that the original  plan could not be adhered to. To obtain
any sample  it became necessary  to remove the bag  and  manually
separate solids  from the  layers of the  fabric. Even with  that
technique,  only a small  amount of sludge could be collected. These
difficulties  should  be considered when   reviewing  the  sludge
analysis data.

Air monitoring was carried  out in accordance with the EPA Modified
Method 5 (MM5), although it was necessary to provide additional air
by fan to obtain flow against the resistance" of the carbon canister
and  to  insure  isokinetic  sampling.  The simultaneous  3-point
sampling could not  be  achieved  because  of the narrow  chimney
exiting the bioreactor  cover. Instead,  3  samples were taken; on
consecutive days. Organic vapors were adsorbed on XAD resin traps
for subsequent analysis by  standard methods.  The procedure  is
discussed in  more  depth in the  Demonstration Test Plan  and the
Quality Assurance Project Plan.

The sampling schedule, sample  type, and analytical methods for all
tests are summarized in Table 5 as originally developed  for the. the
Quality Assurance Project  Plan  and the Demonstration  Test Plan.
Sampling points are  as shown on the schematic of the BATS in Figure
7.
                               22

-------
      TABLE 5. ANALYTICAL SAMPLING SCHEDULE AND METHODS

 medium   parameter             frequency            method
WATER PCP
Sol PAHs/PCP
Volatiles
Semi-volatiles
Dioxins/furans
Metals
Be, Cd, Cr, Cu,
Ni, Ag, Zn
Sb
As
Hg
Pb
Se
Th
Chloride
TOC
Total Phenolics
Oil/grease
Alkalinity
Residue
Ammonia
Nitrate/nitrite
Phosphate
Biotoxicity
SLUDGE*
PCP/PAHs
Semi-volatiles
- Dioxins/furans
Metals
Be, Cd, Cr, Cu,
Pb, Ni, Ag, Zn
Sb
As
Hg
Se
Th
Total Phenolics
Residue
daily
3/wk
1/wk
1/wk
1/wk
1/wk








daily
daily
1/wk
3/wk
1/wk
3/wk
3/wk
3/wk
3/wk
1/wk

1/wk
1/wk
1/wk
1/wk







1/wk
1/wk
846 3510/8270
ii it
846 8240
846 3510/8270
846 8280

846 3005/6010
it ii
846 3005/7041
846 7060
846 7470
846 3020/7421
846 7740
846 3020/7841
846 9252
846 9060
846 9065
846 9070
SM 403
SM 209
EPA 350.1
EPA 353.1
SM 424


846 3550/8270
846 3550/8270
846 8280

846 3050/6010
it ii
846 3050/7041
846 3050/7060
846 7471
846 3050/7740
846 3050/7841.
846 9065
SM 209
AIR
PAHS/PCP
l/2wk
                                               846  0010(collect)
                                               3510/3540/8270
* As noted in report, difficulties were encountered in obtaining
  sufficient sample for analyses.
                                23

-------
                                               W
                                              -p
                                               c
                                              •H


                                              &
                                               I
                                              0}
                                              •p
                                              •H




                                              i
                                               •
                                              r^

                                              0)


                                              CP
                                              •H
                                              fa
24

-------
As noted  earlier,  significant differences  were  observed between
results of  the   BioTrol HPLC method and  the EPA Standard Method
(8270) for PGP during the predemonstration well drilling. While the
cause of the difference remains unclear, it  may be attributable to
the  fact  that  the samples  for  GC/MS were collected while the
grouridwater was standing in the well. In any case, recognition of
the differences led to a small study which confirmed that the two
methods were comparable, at least down to 1 ppm of PCP.

The HPLC data became much more important during the demonstration
when  it  was found  that GC/MS results for  PCP  in  the composite
influent samples were considerably lower than the the values  (also
GC/MS)  obtained for  grab  samples of  the  well water.  Process
monitoring samples taken by  BioTrol  just  ahead of the bioreactor
(Sampling point "B" in Figure 7)  -— and also ahead of the influent
sampling point  (sampling point  #2 in Figure  7)  —  were analyzed
using  the HPLC  method and  consistently gave higher values  in
agreement with the  well water. These data suggested that some other
factor  was contributing  to  the inconsistency  of  the  influent
character  (sampling point  #2). Ultimately,  it was concluded that
backmixing under the weir separating each bioreactor cell from the
preceding cell was diluting the samples taken at sample points 2,
3 and  4,  leading to lower PCP results on samples taken  at those
points. While decreases  across   the  bioreactor  could still  be
measured using  either the HPLC  results  or the  well  water data,
these  findings  precluded any consideration of  changes  from one
chamber to the next for PCP or other pollutants.

Acute  biomonitoring  with two different species  was used  as the
ultimate test of the benefit of  the biotreatment.  The procedure
consisted of determining the LD(50) for sand fleas and fresh water
minnows when  various amounts of the groundwater,  influent,  and
effluent was added to the test water.
                               25

-------
                            SECTION 5

                      DEMONSTRATION RESULTS


INTRODUCTION

The  goal   of  this  demonstration  project  was  to  study  the
effectiveness   of   the  BATS   at   removing   relatively  high
concentrations  of PCP and PAHs from wood treating wastewaters.
Upon  consideration of  the  BioTrol  process and  the groundwater
available for testing, it was determined that the key variable that
could be tested was flow rate.  At a constant concentration, this
allowed the capacity  of the system in terms of pentachlorophenol
concentration and removal to be studied. To avoid shock loading and
the need for  re-acclimation,  it  was further determined that this
could best be  accomplished by incrementally increasing the flow and
allowing the  system to  stabilize at each flow so that analytical
results of "steady state" operation could be obtained. Based on the
capacity of the system (pumps,  tanks, etc.)  three experimental
stages, each of two-week duration, at 1 gpm,  3 gpm and 5 gpm, were
selected.

Using sampling and analytical methods as described in Section 5 and
in  the Appendices  to this  report,  an  extensive  data  base  was
collected.  These data allowed the  system to be evaluated  in terms
of (ci)- removal of PCP and other organics;  (b) the ultimate fate of
the PCP; (c)  the effect of  other contaminants such as oil/grease
and metals on  this and, potentially other applications of the BATS;/
and (d) the need to be concerned about air emissions and  disposal
of Ceirbon,   from either a health or an environmental perspective.

                                                                 J
RESULTS

Extensive analyses using standard methods for sampling and  analyses
were carried  out  over  the course of  the  study.  The  following
sections discuss the individual parameters and present essentially
all of the analytical  results. As noted earlier, it appears that a
backmixing or reverse flow phenomenon was occurring throughout the
study,   with  partially  treated   water passing  back  under  the
underflow weir  separating each  cell of the  bioreactor.  .This  was
detected in the  PCP analyses of  influent  to the system, where two
methods and two different sampling points were fortuitously used.
The data supporting this backmixing hypothesis are presented in the
section on  pentachlorophenol. From that data,  it must be assumed

                               26

-------
that analyses at the intermediate sampling points in the bioreactor
(points #3  and #4 in Figure 7) are  similarly affected while the
data  for  the  groundwater  and  the  effluent  are  unaffected.
Consequently,   the  most   reliable   assessments  of  changes  in
parameters are considered to be those based on differences between
the groundwater and the effluent,  at  least at  the lower flow rates
where, the backmixing seemed to have had its greatest impact.

System Parameters

Nitrogen,  as nitrate,  nitrite, and  ammonia;  and  phosphorus,  as
phosphate,   were  monitored   throughout  the   course   of   the
investigation.  No unusual  effects were observed; the presence of
residual  nutrients  in  the  effluents  suggests  that  reaction
(biodegradation) was not inhibited by insufficient nutrients. The
results are presented in tabular form for the three flow rates in
Table  6   (nitrate/nitrite),  Table  7  (ammonia),  and  Table  8
(phosphate).

Similarly,  dissolved oxygen  was measured in  each  chamber of the
reactor twice daily over  the  course of  the  study and  found to
remain between   5 and  6 ppm. There was a slight increase in the
dissolved  oxygen  as  the water passed through the  system and was
aerated  by  the  air  sparger  system.   The  incoming  groundwater
contained  <1.0 ppm  dissolved  oxygen.  This  data was  presented
earlier in Table 4.

Some variation in temperature was observed throughout the project,
as summarized in Table 9; complete data were presented earlier in
Table 4.  First, the  temperature of the  influent  to the bioreactor
was lower in the 3 gpm (14-17°C)  and the 5 gpm (14-21°C) experiments
than in the 1 gpm study (22-25°C) . This probably was partially due
to a decrease in the temperature of the groundwater over the course
of the program  (11-16°C) ,  and possibly partially due to the  heat
exchanger returning insufficient heat to the  incoming groundwater,
from the effluent to maintain a constant temperature for all three
runs. Since  the study  was carried out  in the summer,  the heater
which is  a part of- the BATS  was  not brought into operation.  As
would be expected, there was a slight temperature increase as the /
wastewater   passed   through   the  system,  i.e.,   the  effluent
temperature was slightly higher than the  influent temperature in
all three study segments.
                                27

-------
TABLE 6.  NITRATE/NITRITE ANALYTICAL
                  N02/N03  (mg/L)
RESULTS

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-0
ST1-A-0
ST1-A-0
ST1-A-04
ST1-A-0
ST1-A-0
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE
SD(n-1)
1
•2
3
4
5
6
7
8
9
10
11
12
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89.
8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1rB-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89
ST1-C-01
ST-1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL



<0.100




0.120


0.11
0.01


0.054





0.094


0.07
0.03
0.160








<0.020

0.09
0.10
#02
INFLUENT
0.370
0.091

0.680

0.095

0.620

0.230

0.35
0.26
0.120
0.320

0.120

NA

0.280

0.025

0.17
0.12
1.200
0.200

0.340


0.400

0.240
0.200

0.43
0.39
#03
MID#1







































#04
MID #2







































#05
EFFLUENT
8.100
7.700

9.900

1.800

5.600

8.500

6.93
1.19
3.400
3.600

2.700

4.000

1.700

2.500

2.98
0.35
0.025
0.670

0.370


0.620


0.500

0.44
0.10
      * - Not included in Calculation of Averages or Standard Deviations
                        28

-------
TABLE 7. AMMONIA ANALYTICAL RESULTS
             NIL   (mg/L)

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE

1
2
3
4
5
6
7
.8
9
10
11
- 12
SD(n-1)
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
| ST1-B-01
ST1-B-02
ST1-B-03
| ST1-B-04
ST1-B-05
ST1-B-06
| ST1-B-07
ST1-B-08
| ST1-B-09
ST1-B-10
(ST1-B-11
! ST1-B-12
AVERAGE

1
2
3
4
5
6
7
8
9
10
11
12
SD(n-1)
8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89
| ST1-C-01
ST1-C-02
! ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-ia
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL




0.06




<0.04


0.05
0.02



0.67





0.41


0.54
• 0.18

0.40








0.44

0.42
0.03
#02
INFLUENT
12.00

3.10

1.40

3.60

4.70

2.80

4.60
3.78
0.45
f
1.20

1.50

NA

2.10

2.20

1.49
0.71
0.24

0.64

0.56


0.83

0.80
0.68

0.63
0.21
#03
MID#1










































#04
MID #2










































#05
EFFLUENT
14.00

3.00

0.54

2.70

2.10

0.83

3.86
2.10
0.37

0.36

0.38

1.07

2.30

1.30

0.96
0.32
1.30

. 1.40

1.80


2.40

4.00
3.10

2.33
0.44
* - Not included in Calculation of Averages or Standard Deviations
                29

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TABLE  8.  PHOSPHATE ANALYTICAL RESULTS
                 PO,   (mg/L)

DAY
OF
RUN
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE
SD(n-1)
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1.0
2.0
3.0
4.0
.'5.0
15.0
7.0
3.0
9.0
10.0
11.0
12.0

8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89
ST1-C-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL



2.4




0.4


1.4
1.4



0.3





0.2


0.2
0.1
1.4









0.2

0.8
0.8
#02
INFLUENT
2.4
2.4

0.4

1.5

2.2

3.3

2.0
1.0
0.4
,
2.0

1.0



1.2

1.0

1.1
0.6
1.5

1.3

1.2
0.2

1.2


1.4

1.1
0.5
#03
MID#1









































#04
MID #2









































#05
EFFLUENT
2.3
3.2

2.7

1.3

3.0

0.1

. 2.1
0.5
1.4

2.0

1.0

3.4

0.8

0.6

1.5
0.4
1.5

0.8

0.5


0.6

2.8
0.6

1.1
0.4
#14
3UPUCATE



















„





















 - Not included in Calculation of Averages or Standard Deviations

                      30                .

-------
        TABLE 9. TEMPERATURE ACROSS BIOTROL SYSTEM
Flow
gpm
1
3
5
gdwater
#1
21
11
13
Temperature ( °C ,
influent midpt
#2 #3
23.4
15.7
14.6
24.6
20.4
20.8
avg)
midpt
#4
24.5
20.4
21.0
effluent
#5
24.8
20.9
20.9
While the developer's specifications called for a pH of about 7.3
in the tempering (conditioning)  tank,  the pH measured in the three
chambers   of  the  bioreactor   usually  was   somewhat   higher,
particularly  at  the two lower  flows  and, at least at the 1 gpm
flow,  appeared  to  increase  across  the  system.  The  pH  of  the
groundwater drawn from  the  well was  consistently in .the range of
6.7-6.9 standard units  (Table 4).

Initial oil and grease (O/G) concentrations of approximately 50 ppm
were reduced by passage through the system to <10 ppm (Table 10).
While the design of the  bioreactor cells is such that formation of
an oil  layer at  the underflow weirs might have  been  expected,   a
significant amount of oil was observed only occasionally during the
1 gpm portion of the study.  At these influent oil levels, there is
no reason to  expect the oil to  adversely affect the bioreaction;
considerably  higher levels  are  tolerated  well in conventional
activated sludge systems. The complete data for oil  and grease are
presented in Table  11.


     TABLE 10. AVERAGE TSS AND OIL ACROSS THE BIOTROL SYSTEM
Flow
gpm
1
3
5
2.
13
1.
groundwater
TSS O/G
mg/L
5+.07
+12.7
5+0.7
54.5+ 2.1
61.0+ 1.4
47.5±10.6
29
24
15
influent
TSS O/G
mg/L
.6+9.4
.2+17.6
. 7+8 . 9
57
37
50
.5+10
.8+14
.8+10
.7
.9
.5
effluent
TSS O/G
mg/L
53.6+ 6.6
26.3+11.1
22.5+ 9.5
6.
6.
8.
0+0 . 4
0+1.3
0+2 . 4
Total suspended solids (TSS) levels in the incoming well water were
quite low (<5 ppm) and increased somewhat (to 54 ppm at 1 gpm, 26
ppm at 3 gpm,  and 18 ppm at 5 gpm) over  the  course of the stxidy
(summarized in Table 10,  full data  in Table 12) . At these incoming
"levels, suspended solids would not be  expected to interfere with
the  reaction.   In the  effluent  the  suspended  solids  probably
contains biomass sloughed  from  the PVC  matrix. Even suspended
solids levels of 54  ppm, as observed in the  1 gpm portion of the
study, do not represent a significant mechanism for removal of
                                31

-------
TABLE 11. OIL AND GREASE ANALYTICAL RESULTS
                   (mg/L)

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12


SAMPLE
DATE

7/24/89
7/25/89
7/28/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89


SAMPLE
NUMBER

ST1-A-01
ST1-Ar-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-?A-11
ST1-A-12
AVERAGE
SD(n-1)
1
2
3
- 4
5
- 6
7
8
'• 9
10
11
12

8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89

ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
. 4
5
6
7
8
9
10
11
12

8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89

ST1-C-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL




56




53


54.5
2.1



60





62


61.0
1.4

55








40

47.5
10.6
#02
INFLUENT
8 *

47

53

58

371 *

72

57.5
10.7
57
.
15

31

33

50

41

37.8
14.9
58

59

37


58

42
NA

50.8
10.5
#03
MID#1
<5

<5

5

<5

48 "

20 *

5.0
0.0
7

14

9

9

13

12

10.7
2.7
12

14

32 *


10

18
15

13.8
3.0
#04
MID #2
5 *

5

5

5

20 *

5

5.0
0.0
<5

6

<5

5

<5

8

5.7
1.2
<5

19

12


11

15
10

12.0
4.7
#05
EFFLUENT
<5

8

7

<5

21 *

<5

6.0
0.4
<5

6

<5

8

<5

7

6.0
1.3
<5

11

9


.10

7
6

8.0
2,4

#14
DUPLICATE








19(EFF) *





57 (INF)









5{EFF) .













40 (INF)



•- Not included in Calculation of Average or Standard Deviation
                    32

-------
  TABLE 12.  TSS ANALYTICAL RESULTS
                   (mg/L)

DAY SAMPLE SAMPLE
OF DATE NUMBER
HUN
1
2
3
4
5
6
7
8
9
10
11
12
7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89
ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12

8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89
ST1-C-01
ST1-6-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06.
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL



3




2


2.5 ~
0.7


22





4


13.00
12.73

2








<1

1.50
0.71
#02
INFLUENT
29
38

39

4

26

16

29.6
9.4
10
54

23

NA

22

12

24.20
17.64
27

8

6


,13

26
14

15.67
8.91
#03
MID#1
26
48

53

4 *

46

50

44.6
2.7
10
84

22

20

18

8

27.00
7.78
34

12

11


8

50
12

21.17
4.67
#04
MID #2
35
47

52

4

54

69

51.4
3.6
10
72

16

14

94

6

35.33
12.05
31

12

10


8

36
9

17.67
4.01
#05
EFFLUENT
23
67

64

4

54

60

53.6
6.6
8
SB

12

67

11

4

26.33
11.09
32

14

8


6

66
9

22.50
9.52
#14
DUPLICATE







52 (EFF)





14 (INF)








6 (EFF)













11 (INF)



- Not Included In Calculation of Averages or Standard Deviations

                     33

-------
organic pollutants.  For example, at a 51 ppm increase in suspended
solids and a PGP concentration of 34 ppm,  this would account for
only 0.00025 Ibs of PCP over the course of the 12 days of operation
at 1 gpm. With total PCP removal during that period of 5.97 Ibs,
the  amount  in the  sludge is negligible.  The volatile suspended
solids  (VSS)  represent approximately 45%  of the  total suspended
solids, possibly increasing slightly (to "50%)  at the highest flow
rate (Table 13).

Pentachlorophenol Removal

With the receipt of the PCP  analytical data generated by SW-846,
Method  8270,   it  became clear  that  the  results  were  not  as
anticipated.  Influent  PCP  values  (point  #2  in  Figure  7)  were
significantly lower than the concentrations leaving the well (point
#1) , as summarized in Table 14.  Grab samples taken  by BioTrol from
a "T111 just before  the influent  chamber (point B on Figure 7) and
analyzed by BioTrol's HPLC method agreed well with the well samples
(point #1).  In addition, the groundwater  (point #1) and influent
(point #2) PCP values approached agreement  as the flow rate was
increased  each two  weeks.  Within  limits  discussed  later,  free
chloride  and   Total Organic  Carbon  (TOC)  data  at  the  various
sampling points also supported these observations.


   TABLE 14. AVERAGE PENTACHLOROPHENOL REMOVAL BY BIOTROL SYSTEM
Flow PCP
(gpm) (#1)
gdwtr
1
-3
5
42.0+7.1*
34.5+7.8*
27.5+0.7*
PCP
(#2)
infl.
6.9+3.4
19.0+5.8
24.2+6.8
PCP
(#5) [
effl.
0.13+.25
0.34+.15
0.99+.49
Removal
_________/ 9-N 1
\
gdw/eff
99.8
98.5
96.4
i^i j
infl/effl
98.1
98.2
95.9
     * The gradual decrease in groundwater concentration may
       be a result of well drawdown over the 6 weeks of
       operation.  -

At first it was thought that the difference might have been due. to
foaming during the extractions for the analytical procedure (SW-r846
Methods 3510/8270). While that problem did persist throughout the
study and did  affect the  recovery achievable for the samples, it
became clear that it was not the cause of the differences between
the well or BioTrol's samples and the influent chamber samples.

Other  possible  explanations  for  the  anomalous  results  were
considered,  including   absorption of  PCP on  the  walls of  the
bioresactor, separation of  a  PCP-in-oil layer, and backmixing under
the underflow weirs separating the chambers. Calculations indicated
that the amount of an absorbed film of PCP or a PCP-in-oil layer


                               34

-------
Table 13.  VSS/TSS ANALYTICAL RESULTS
                    (mg/L)

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12


SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE WT
SD(n-1)
,1
2
3
4
5
6
7
8
9
10
11
- 12

8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
. 8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE V/T
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12

8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/89
8/29/89
8/30/89
8/31/89
9/01/89
ST1-C-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
ST1-C-09
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE V/T
SD(n-1)
SAMPLING POINT

#01
WELL




2/3




1/2


0.58
0.12


-
4/22





3/4


0.47
0.40
<1/2








<1

0.75
0.35
#02
INFLUENT
8/29

16/38

16/39

2/4

10/26

7/16

0.40
0.07
4/10

27/54

11/23

«

8/22

6/12

0.45
0.06
16/34
6/8 *

3/6


4/13

*
6/14

0.49
0.16
#03
MID#1
11/26

17/48

20/53

2/4

18/46

21/50

O41
0.02
4/8

38/84

10/22

12/20

8/18

5/8

0.51
0.02
14/31
6/12 *

6/11


4/8

22/50
6/12

0.49
0.01
#04
MID #2
16/35

20/47

19/52

1/4

21/54

26/69

0.38
0.03
4/10

32/72

8/16

8/14

51/94

3/6

0.49
0.02
16/32
6/12 *

6/10


4/8

18/36
6/9

0.54
0.03
#05
EFFLUENT
10/23

29/67

25/64

1/4

20/54

22/60

" 0.37
0.04
2/8

27/56

6/12

33/67

5/11

4/4

0.53
0.13
1/2
8/14 *

4/8


3/6

32/66
5/9

0.52
0.02
               - Not Included in Calculation of Average
                    35

-------
needed  to  explain  the  differences  were  simply  not  present.
Consequently, backmixing  appeared to be  the best explanation for
the observed differences. And,  as  flow  through the  system was
increased each two weeks, the impact of the backmixing decreased,
explaining the gradual improvement in agreement between well water
data,   BioTrol  process monitoring data by  the HPLC  method,  and
influent data.

On the assumption that  the  "real"  concentration  of  PGP  in the
inflxient was about 45 ppm in the 1  gpm study but was measured at
about  7  ppm, it was  estimated  that approximately  5  gallons was
"leaking" back through the system for  every gallon introduced in
the first  two weeks. At  higher flows,  the effect  of backmixing
would be expected to be less.

Because  the  influent sampling  problem  was only  discovered when
samples had been analyzed, an additional QA study was carried out
to compare BioTrol' s HPLC method for  determining PCP concentrations
with   EPA's   Standard   Method    (SW-846,   Method   8270).   This
investigation, reported in the Quality Assurance Review Appendix to
this report,  confirms that the. two methods are  comparable when
extraction   efficiency   in  Method 3370/8270  is   taken  into
consideration.

On the basis of this  additional  information, it was concluded that
concentrations of PCP in the well water were better representations
of the concentrations entering  the  first cell of  the bioreactor
than the influent  samples. Because  of  the backmixing phenomenon,
the analytical data  from  the intermediate sampling points in the
bioreactor  (points #3  and #4)   were  used  only  to  confirm that
gradiial reduction in  PCP  (and other parameters)  was taking place in
the expected direction.  PCP analytical results  for all sampling
points are presented  in  Table 15. Removal efficiencies have been
based on well water and effluent data (both by Method 8270) instead
of the influent samples.

It remains clear that the BioTrol  Aqueous  Treatment System does
effectively remove PCP from the groundwater as it moves through the
system. Effluent concentrations  of PCP after treatment  (but before
carbon polishing)  averaged 0.13 ppm at  the 1 gpm  flow rate and
increased to approximately 0.99  ppm at the 5 gpm flow rate. Thus,
depending on the level of PCP required in the effluent, effluent
quality can be adjusted by adjusting the flow rate. Using the well
water data as the influent concentrations and the observed effluent
concentrations for PCP, the system achieves an average of 96.4% PCP
removal at the 5 gpm  flow rate  and  this  increases to 99+% at the
•lower flow rates.
                                36

-------
TABLE 15.  PENTACHLOROPHENOL ANALYTICAL RESULTS
                      PCP  (ug/L)

DAY
OF
HUN
1
2
3
4
5
6
7
8
9
10
11
12


SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8'
9
10
11
1?.

8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89

ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
1?

8/21/89 ST1-C-01
8/22/89 ST1-C-02
8/23/89 ST1-C-03
8/24/89 ST1-C-04
8/25/89 ST1-C-05
8/26/89 ST1-C-06
8/27/89 ST1-C-07
8/28/89 ST1-C-08
8/29/89 ST1-C-09
8/30/89 ST1-C-10
8/31/89 ST1-C-11
9/01/89 ST1-C-12
AVERAGE
SD(n-1)
SAMPLING . POINT

#01
WELL




47000




37000


42000.0
7071.1



40000





29000


34500.0
7778.2

27000








28000

27500.0
707.1
#02
INFLUENT
680
7000
6900
3000
7200
13000
7600
6600
12000
8900
4200
6100
6931.7
3434.0
8800
24000 .
NA
21000
19000
21000
NA
24000
22000
10000
25000
15000
18980.0
5812.2
15000
21000
NA
15000
19000
23000
35000
23000
28000
28000
25000
34000
24181.8
6720.4
#03
MID#1
11
1200
1500
400
400
1300
17
200
85
150
530
690
540.3
524.4
2600
4700
4800
NA
2900
3900
5500
6800
10000
4300
3700
7400
5145.5
728.1
4900
6700
NA
10000
8100
6000
5300
2600
4100
3700
6900
12000
6390.9
926.9

#04
MID #2
50
230
340
140
100
410
160
11
8
<50
<50
17
130.5
133.3
210
1000
160
1200
490
570
900
1400
1500
740
370
190
727.5
191.8
3500
3200
NA
4000
1200
1600
870
3200
8600
3900
5500
10000
4142.7
1112.3
#05
EFFLUENT
16
880
140
140
88
<5000
<50
5
5
8
<50
50
130.2
253.5
82
810
190
NA
320
430
200
1000
<50
390
230
78
343.6
147.9
3100
1200
NA
910
890
1100
<50
140
300
330
140
2700
987.3
487.4
% removal
02-05/02
97.6
87.4
98.0
95.3
98.3
	
99.3
99.9
100.0
99.9
98.3
99.2
98.1
3.7
99.1
96.15
	 ,
	
98.3
98.0

95.13
99.13
96.1
99.1'
99.5
98.2
0.9
79.3
94.3
— ,
93.9
95.3
95.2
99.9
99.4 .
98.9
98.8
99.4
92.1
95.9
4.0
     - Not included in Calculation of Averages or Standard Deviations

                          37

-------
The  data  are presented in  terms  of pentachlorophenol mass removal
in Table  16.  Based on the  calculated mass of pentachlorophenol
introduced to the system over  each two week experimental period,
and  assuming that all pentachlorophenol  is lost by biological
degradation,  mass removals of  >95% are consistently achievable.


            TABLE 16.  MASS  REMOVAL OF PENTACHLOROPHENOL         ''.
Week


1
2
3
4
5
6
Flow
(gpm)

0.98
1.0
2.92
3.02
5.14
5.03
Total PCP
In (Ibs)*
(#D
3.32
2.65
8.39
6.29
9.99
10.13
Total PCP
Out (Ibs)
(#5)
.178
.002
.077
.075
.533
.221
Removal
(%)

94.6
99.9
99.1
98.8
94.7
97.8
           *  Based on well  water  (#1)  analyses


 Comparison of analytical results  for  total  PCP  in  as-is  samples
, and soluble  PCP in samples that had been  filtered  to  remove any
 suspended solids confirmed that very  little if  any of the PCP in
.the as-is samples was absorbed on the filterable solids  (Table
 17) .   There  were, however,  measurable concentrations  of  PCP in
 the sludge samples (see Table 21) .  Considering the small amount
 of  sludge exiting the bioreactor,  this is not a significant
 contributor  to the removal of PCP from the  system,  as discussed
 earlier.  Similarly,  the low concentration of oil in the  effluent
 (<10  ppm)  strongly argues  against loss of PCP by extraction into
 that  phase.

 Analyses  of  the air exhausted from the bioreactor  also confirmed
 that  no detectable quantities of  pentachlorophenol were  lost by
 this  route.

 Mineralization. Chloride and TOC  monitoring of  the influent and
 effluent  produced results  that are consistent with an assumption
 that  the  bulk of the pentachlorophenol is mineralized, but
 indicate  that other contributors  to chloride and TOC  are present.
 The expected reaction would be:
        OH
    ci /_\ Cl
      !(  )|     + 5.5 02  + OH"  ---- - --- > 5 Cl"  + 6 C02  +  H2O
    Cl V-7 Cl
        Cl
                                38

-------
TABLE  17. SOLUBLE PCP/TOTAL  PCP ANALYTICAL DATA
                       PCP  (ug/L)

DAY
OF
HUN
1
2
3
4
5
6
7
8
9
10
11
12

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1^A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE PCP(tOt)
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE PCP(tot)
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/21/89 ST1-C-01
8/22/89 ST1-C-02
8/23/89 ST1-C-03
8/24/89 ST1-C-04
8/25/89 ST1-C-05
8/26/89 ST1-C-06
8/27/89 ST1-C-07
8/28/89 ST1-C-08
8/29/89 ST1-C-09
8/30/89 ST1-C-10
8/31/89 ST1-C-11
9/01/89 ST1-C-12
AVERAGE PCP(tOt)
SD(n-1)
SAMPLING POINT

#01
WELL



39000/47000




41000/37000


42000.0
7071.1



42000/40000





29000/29000


34500.0
7778.2
29000/21000








29000/28000

27500.0
707.1
#02
INFLUENT
690/680
— 17000
5200/6900
—13000
— /7200
15000/13000
5200/7600
— 16600
11000/12000
— /8900
— /4200
8800/6100
6931.7
3434.0
15000/8800
.— /24000
NA
— /21000
—/19000
21000/21000
NA
— /24000
22000/22000
— /10000
— /25000
22000/15000
18980.0
5812.2
3000/15000
—/21000
NA
— /15000
— /19000
27000/23000
— 135000
21000/23000
— /28000
28000/28000
— /25000
2000/34000
24181.8
6720.4
#03
MID #1
<50/11
— /1200
810/1500
— 7400
— /400
1800/1300
13/17
— 1200
96/85
— /150
— /530
460/690
540.3
524.4
3200/2600
— /4700
490/4800
NA
— /2900
3600/3900
4200/5500
— /6800
8900/10000
— /4300
— /3700
6100/7400
5145.5
728.1
4400/4900
— /6700
NA
— /10000
— /8100
7400/6000
— 15300
5000/2600
— /4100
3100/3700
— /6900
10000/12000
6390.9
926.9
#04
MID #2
6/50
— /230
350/340
— /140
— /100
710/410
66/160
— /11
4/8
— /<50
— /<50
<50/17
130.5
133.3
240/210
— /1000
540/160
— /1200
—7490
640/570
830/900
— /1400
1400/1500
— /740
— 1370
190/190
727.5
191.8
3200/3500
— /3200
NA '
— /4000
~/1200
2200/1600
— /870
3100/3200
•— /8600
3600/3900
— /5500
100/10000
4142.7
1112.3
#05
EFFLUENT
11/16
— /880
120/140
~/140
— /88
~/<5000
11/<50
— /5
4/5
— /8
— /<50
9/50
130.2
253.5
77/82
~/810
580/190
NA
~ 1320
350/430
330/200
— /1000
1600/<50
— 7390
—7230
100/78
343.6
147.9
3000/3100
--/1200
NA
~/910
— /89CI
810/1100
— 7
-------
or perhaps

       OH
   Cl A-A Cl
   ci
              + 5.75
->  5  Cl'  +6 CO,
+ H20
       ci
Table 18 summarizes the observed and expected changes in chloride
and  TOC calculated  on  the basis  of the  observed  decrease in
pentachlorophenol, again using the PCP values for the groundwater
rather than the influent. Chloride and TOC values were selected for
the same days. The actual analytical data are reported in Table 19
(chloride) and Table 20  (TOC).


TABLE 18. COMPARISON OF CHLORIDE & TOC CHANGES WITH PCP REMOVAL
1
1
1.
I
1
1
1
Flow PCP
(gpn)
1
3
5
change
-41.9
-34.1
. INCREASE IN j
Cl(fd) Cl(calc) !
DECREASE IN
TOC(fd) TOC(calc)
• i
i
(mg/L) j
+40.2
+37.2
-26.5 +27.2
+27.9
+22.7
+17.6 (
-25.5
-31.5
-21.0
-11.3
- 9.2
- 7.0
1
1

     fd = found (effluent - groundwater)
     calc = calculated from change in PCP, as 5C1/PCP & 6C/PCP

The concentrations of mono-,  di-,  and trichlorophenols (by SW846
Method  8270)  all  were  below  the  detection  limits  in  the
semivolatile scans of the groundwater, influent, and effluent but
the detection limits were  often quite high since pentachlorophenol
was the primary  "target"  of  the analyses.   It  is  reported that
manufactured pentachlorophenol may have contained as much as  20% by
weight of tetrachlorophenols (TCPs).  If, for example, the original
PCP concentration in the groundwater, 42 ppm, were accompanied by
20%  by  weight as- tetrachlorophenols  (which  were  not  target
analytes) , this would mean that 8.4 ppm of TCPs were present.  If*.
these tetrachlorophenol isomers degrade  as efficiently as PCP, the
8.4 ppm  would contribute 5.1 ppm  of chloride.  And if one also
assumed that all of the less chlorinated isomers (mono-, di-, and
trichlorophenols)  in the  semivolatile scan were present  at just
below their detection  limits  in the original sample,  they could
contribute an  additional  6.4  ppm of chloride.  Table  21 presents
calculated chloride yields on the basis of  these assumptions for
the groundwater sample during the 1 gpm study.  [Subsequent review
of two archived  scans of groundwater indicated TCP  contents .of
about 4% and 10% of the PCP measured.]  Other  chlorinated phenol
species that are not  reported as part  of the  semi-volatile scan
also could be present.
                               40

-------
TABLE  19.  CHLORIDE ANALYTICAL RESULTS
                  Cl  (mg/L)

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE

1
2
3
4
5
6
7
8
9
10
11
-12

8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
SD(n-1)
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B-11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/21/89
8/22/89
8/23/89
8/24/89
8/25/89 !
' 8/26/89 !
8/27/89 i
8/28789 5
8/29/89 5
8/30/89 S
8/31/89 J
9/01/89 £
ST1-C-01
ST1^C-02
ST1-C-03
ST1-C-Q4
3T1-C-05
3T1-C-06
3T1-C-07
3T1-C-08
3T1-C-09
3T1-C-10
3T1-C-11
5T1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL



14




19


16.50
3.54



14





24


19.00
7.07
38








12

25.00
18.38

#02
INFLUENT
58
48
56
48
53
46
.48
48
44 '
53 '
53
48
50.82
3.95
jt
44
29 .
44
34
40
46
NA
34
34
38
34
34
37.36
5.45
41
27
29
27
26
28
29
29
18
16 '
28
21
27.55
5.70
#03
MID#1
53
58
53
63
63
58
53
53
53 '
58
58
58
57.09
1.31
48
53
9.7 *
50
53
53
60
50
46
51
. 50
51
51.36
1.24
53
46
51
45
43
52
51
51
37
48
46
44
47.25
1.67
#04
MID #2
58
68
63
82
58
58
58
58
9.7 '
63
63
53
62.00
3.19
58
58
106 *
53
55
55
54
54
57
54
55
56
55.36
0.69
55
51
53
- 50
54
54
55
52
52
46.
46
47
51.25
1.40
#05
EFFLUENT
58
53
58
34
63
63
58
53
100
58
63
63
56.73
4.44
52
58
58
63
56
56
55
55
55
56
56
55
56.25
1.44
54
52
54
53
55
55
55
55
54
27
42
46
50.17
4.50
#14
DUPLICATE



48 (INF1)



53(EFIF)





44 (INF)









54 (EFF)




(


54 (EFF)


6 (EFF)

4 (INF)



 * - Not Included in Calculation of Average or Standard Deviation
                     .41

-------
  TABLE 20.  TOG ANALYTICAL RESULTS
               TOC  (mg/L)

DAY
OF
RUN
1
2
3
4
5
6
7
8
9
10
11
12

SAMPLE
DATE

7/24/89
7/25/89
7/26/89
7/27/89
7/28/89
7/29/89
7/31/89
8/01/89
8/02/89
8/03/89
8/04/89
8/05/89

SAMPLE
NUMBER

ST1-A-01
ST1-A-02
ST1-A-03
ST1-A-04
ST1-A-05
ST1-A-06
ST1-A-07
ST1-A-08
ST1-A-09
ST1-A-10
ST1-A-11
ST1-A-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/07/89
8/08/89
8/09/89
8/10/89
8/11/89
8/12/89
8/14/89
8/15/89
8/16/89
8/17/89
8/18/89
8/19/89
ST1-B-01
ST1-B-02
ST1-B-03
ST1-B-04
ST1-B-05
ST1-B-06
ST1-B-07
ST1-B-08
ST1-B-09
ST1-B-10
ST1-B^11
ST1-B-12
AVERAGE
SD(n-1)
1
2
3
4
5
6
7
8
9
10
11
12
8/21/89
8/22/89
8/23/89
8/24/89
8/25/89
8/26/89
8/27/89
8/28/69
8/29/89
8/30/89
8/31/89
9/01/89
ST1-G-01
ST1-C-02
ST1-C-03
ST1-C-04
ST1-C-05
ST1-C-06
ST1-C-07
ST1-C-08
&T1-C-O9
ST1-C-10
ST1-C-11
ST1-C-12
AVERAGE
SD(n-1)
SAMPLING POINT

#01
WELL

..',

79




79


79.0
0.0



82





82


82.0
0.0
80








82

81.0
1.4
#02
INFLUENT
63
65
62
64
63
62
60
57
120
65
58
59
61.6
2.8
69
72 -
70
69
68
68
NA
75
74
70
73
75
71.2
2.7
72
85
84
82
83
82
79
84
84
81
84
79
81.6
3.6
#03
MID#1
32
55
55
52
51
47
48
47
48
60
51
46
49.5
2.5
55
58
60
57
55
54
57
59
61
58
58
58
57.5
0.7
66
66
69
66
64
72
65
66
68
68
69
67
67.2
0.8
#04
MID #2
52
54
56
53
50
51
49
48
53
48
49
46
50.5
1.2
51
51
53
54
51
49
49
53
54
51
50
48
51.2
0.8
64
63
64
65
59
70
58
61
68
80
67
71
65.8
2.5
#05
EFFLUENT
56
57
66
60
61
2450
48
46
49
49
46
46
53.5
3.8
51
52
54
51
46
50
53
50
.54
50
47
48
50.5
1.4
63
61
60
56
53
68
.55
56
61
68
59
60
60.0
2.5
#14
DUPLICATE



69 (INF)



50 (EFF)





70 (INF)









49 (EFF)







64 (EFF)


60 (EFF)

82 (INF)



- Not Included in Calculation of Averages or Standard Deviations
                   42

-------
      TABLE 21.  POTENTIAL CHLORIDE CONTRIBUTIONS FROM
                 PARTIALLY CHLORINATED PHENOLS
       substance    detection limit    chloride yield
                        PPM               PPM (calc)

      2-MONOCHLORO        2               0.6
      2,4-DICHLORO        2               0.9
      2, 4,6-TRICHLORO     2               1.1
      2,4, 5-TRICHLORO    10               5.4
      TETRACHLORO        NA,  .2PCP*       5.1
        POSSIBLE NON-PCP TOTAL ..........  13 . 1
      PENTACHLORO        42 found        27.9
        GRAND TOTAL ............. . ........ 41.0

      *Estimated only,  on the basis that  PCP
       may contain as much as 20% tetra isomers.


 Removal  of other pollutants  such as  residual oil or biomass  may
 explain  why  the decreases  in TOC levels are higher than calculated
 for PCP  removal.

 Polvnuclear  Aromatic Hydrocarbon Removal

 Concentrations  of the  various  polynuclear  aromatic hydrocarbons
 (PAHs)  in  the incoming well  water were lower than anticipated  and
.below the detection limits in both the well water and the influent.
 The high detection limits for  PAHs in the  semivolatile  organics
 GC/MS scans, often in the range of 2 ppm when analyzing groundwater
 or influent for pentachlorophenol in the 10-50 ppm range, precluded
 measurements for PAHs at ppb  level, but do confirm that significant
 concentrations   of  the  various  PAHs  were  not  present  in  the
 groundwater.  Two  values  for total  PAHs  obtained    during  the
 predemonstration well  drilling  effort, 145 and 295 ppb,  would be,
 consistent with  the absence at the  indicated  detection  limits
 during the experimental portion  of the project.

 Specific PAHs were below the detection limits  in  the effluents as <
 well,  even with the detection limits  now in the range of  10-100
 ppb.  One effluent sample exhibited a single PAH component,  reported
 as 0.4 ppb of fluoranthene.  The  lack of numerical  values for PAHs
 in the well water or the influent makes it impossible to assess  the
 removal  of these chemicals by the BATS at the  MacGillis and Gibbs
 facility.

 As noted  earlier,  It  was  only  possible  to carry  out limited
 analyses,  and only  on a few sludge samples,  for pentachlorophenol
 or the  PAHs.  These  analyses, indicated  low but     detectable
 quantities of PCP and selected PAH compounds of interest,  as noted
 in Table  22.  In every case the amount  of  sludge  produced  or
 collected  was so small that  daily sampling of the sludge was  not
 practical. While not conclusive,  the limited data does suggest that

                                43

-------
accumulation  of PGP or PAHs  in the sludge  is  not a significant
contributing mechanism for the  removal of these species.


         TABLE  22.   SLUDGE ANALYSIS RESULTS

     SAMPLE     POLLUTANT             CONG
                                  (mg/kg dry)

     B-09-07S   PGP                    34
                pyrene                 15
                chrysene                5.3
                Benzo(b)fluoranthene   10
                benzo(a)pyrene          6.1
     C-05-07S   PGP                   170
                Anthracene             92
                Benzo(k)fluoranthene   74
     C-10-07S   PGP                     2.7
                Anthracene              3.0
                Pyrene                  2.5
     C-10-15S*  PGP                    18
                phenanthrene            1.9

     * This sample is "active"  sludge found
       adhering to the walls of bioreactor.


Interestingly,  monitoring of the  exhaust  air stream,  in a 4 inch
chimney in the lid over the bioreactor before and after the carbon
adsorber, indicated that some  stripping  of  polynuclear aromatic
hydrocarbons does occur, probably due to  the air bubbled through
system (Table 23). It was necessary to introduce additional air to
the stack during the monitoring to overcome the resistance of the
carbon.  Small  amounts (=< 1 ppb)  of phenol, 2,4-dimethyl phenol,
and higher molecular weight" PAHs such as fluorene and dibenzofuran,
were found occasionally in the  pre-carbon samples  but not in the
after-carbon samples.  Only naphthalene was  found to pass through
the carbon at a  detectable level (under 2  ppb), possibly by an  air
stripping "regeneration" phenomenon.
                                44

-------
     TABLE 23.  PAHS IN AIR EMISSIONS FROM  BIOREACTOR

  Test   Liquid    naphthalene   2-me naphthalene acenaphthene
  #      flow at    b.c.* a.c.*    b.c.  a.c.       b.c.    a.c.






*

#
UA,
1
2
3
4
5
b.c.
a.c.
nd
tuts uj. Ufciia
1
1
1
3
5
= before
= after
= not de
u L 	
6.5
3.8
4.6
4.6
34.6
carbon
carbon
tected
	 U
0.6
1.6
1.7
0.6
1.1
adsorber
adsorber

JP"
4
3
3
6
47



) — '
.7
.0
.7
.7
.9




nd f
nd
nd
nd
nd




0.
0.
nd
0.
2.




5
3

7
8



	 ]
nd
nd
nd
nd
nd



Polvchlorinated Dibenzo-p-Dioxins/Dibenzofurans

Historically,  there  has been  concern  about the  possibility  of
chlorinated  dibenzodioxins  in  manufactured  chlorinated  products
such  as pentachlorophenol.  Consequently  there was  some  concern
about  the  possibility  of   these  species  being  present  in  the
grounclwater. Selected samples were scanned  for the various dioxins
and furans using high, resolution GC coupled with low resolution MS.
A number  of the chlorodioxin and  furan species were found to  be
present  in  the  influent   and  in  the  effluent,   but  only  at
nanogram/liter levels except for the  octachloro- isomer (OCDD). The
2,3,7,8-TCDD isomer was  reported at  above detection  limit in  only
one sample  (62 ng/L  in  an  effluent sample) . Review of the  data
(Table 24) also discloses an increase in concentration for all the
isomers as the wastewater moves through the reactor.  The increases
may be  due  to  accumulation  of  the dioxins on the biomass, which
then is sloughed off  into the effluent.
                 TABLE 24. DIOXINS/FURANS FOUND IN. SYSTEM
   Week
      HpCDD
HpCDF
 Influent/Effluent Concentrations
          (ng/L)
HxCDD     HxCDF      OCDD     OCDF
TCDD  2378-
1
2
3
4
5
6
60/180
32/180
<4.4/4.3
—
25/62
^
<10/20
<2.8/30
-
-
2,1/7.0
*~
-* •
<2.2/8.8
-
-
-
••
—
<1. 5/4.1
. -
—
-
—
340/1100
170/910
28/42
<8.6/28 .
140/390
—
<17/23
<7.3/40 '
-
-
<4.8/12
—
„_ ~ _
> _ .
- ~ -
- - '
-
<3.2/62
    * An '-'  indicates the isomer was absent or below detection limit in
    both influent and effluent.
Some dioxin/furan  isomers  were found in the sludge in the ng/Kg
range, based on wet weights  (Table 25). Recognizing the small

                                45

-------
amount of  sludge  generated,  it  is  not considered a problem except
that the sludge may  require  disposal  as a dioxin-contaminated
material.  This would add  somewhat  to  the cost of the process.
                TABLE 25. DIOXINS/FURANS FOUND IN SLUDGE
Week
Sludge Concentrations
(ng/gm)

1
2
3
4
5
6
HpCDD HpCDF
260 46
no sample
no sample
25 3.9
<.20 <.14
23 4
HxCDD
13


1.4
<. 17
1.5
HXCDF
13


1.7
<. 12
1.7
OCDD
1900


190
0.98
140
OCDF
41


3.0
<.22
3.1
TCDD
<.054


<.088
<. 16
<.08
2378-
<.054


<.088
<. 16
<.08
Heavy Metals

While, low concentrations of arsenic and various heavy metals were
found to  be  present in  the groundwater,  these appear  to pass
through the system with little change in concentrations  (Table  26)
- with  the exception of  the first  effluent,, sample, which shows
anomalous results. The remaining data in the table are groundwater
and effluent data obtained on neighboring,  but not necessarily  the
same, day.  At the levels  encountered,  metals  are not expected to
interfere  with  the  bioreaction.  The  analytical  data  show  no
evidence for accumulation of metals on the biomass and subsequent
sloughing into the effluent.
               TABLE 26. METALS FOUND IN SYSTEM
 Week
    Concentration of Metals  (groundwater/effluent)
                    (ug/L)
As       Cu       Ni        cr       Pb      Zn
1
2
3
4
5
6
DLA
6.4/220
4.1/5.6
5.4/5.3
— /6.0
6 . 5/7 . 7
5.9/5.7
1.5
25/4400
19/37
20/23
— /19
~/23
ND/30
12
60/390
54/67
81/73
-v/60
67/71
91/87
21
ND/450
ND/8 . 0
ND/ND
— /ND
ND/23
7 . 0/ND
6.7
7.7/580
11/ND
ND/11
— /8.1
3.9/6.1
6.9/5.9
2.9
32/20,000
20/20
ND/8.0
— /13
23/30
. 20/17
5.7
 *  An '—'  indicates the analysis was not carried out; an ND
   indicates the concentration was below detection limit.
 A  DL = Detection limit
                               46

-------
Volcitile Organics

Analyses  for  volatile  organics  indicated that   few  of  these
materials  were   present  in   the  groundwater,   even   at  low
concentrations. Levels were further reduced by passage through the
treatment system, probably by  stripping.  Interestingly,  volatile
organics were not detected in  the exhaust air collected from the
reactor during the Modified Method 5 testing.

Biomonitoring

Considering the nature of the contaminants, it was  suspected that
the groundwater  could be toxic to aquatic  species. With that in
mind, biomonitoring with two different species, minnows and water
fleas, was carried out  on  the  groundwater,  the influent, and the
effluent. The results confirmed that the groundwater was toxic to
these species and that treatment removed the cause of the toxicity.
The  results  presented  as LC50 values  in  Table 27  reflect  the
percentage of  groundwater, influent,  or  effluent  that  could be
tolerated in the water used for the test before 50%  of the species
succumbed.  When 1% or even less of either groundwater or influent
water is  introduced  to the  test water,  50%  or  more of the test
species die during the  test  period.  After treatment in the BATS,
the effluent has essentially no adverse effect on either species,
even when 100% effluent is the test water.
TABLE 27. ACUTE BIOTOXICITY OF GROUNDWATER AND TREATED EFFLUENT
     Week   Flow        LCeg-Daphnia  #      LC5Q-Minnow *
        (gpm)      grdwtr  infl.  effl.   grdwtr  infl.  effl,
                          ( % wastewater/test water)
1
2
3
4
5
6
1
1
3
3
5
5
__
—
—
—
1.0
-• 0.27
0.35
0.84
0.26
0.54
0.61
0.66
100
100
100
100
100
100
__
	
—
—
0.22
0.22
0.3
1.07
0.43
0.3
0.20
0.20
100
100
100
35
100
100
# 48 hour static test at 20°C, daphnia magna
* 96 hour static test at 20°C, pimephales promelas
                                47

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                            SECTION 6

                            ECONOMICS
INTRODUCTION

The  purpose  of this economic  analysis is to   provide realistic
costs and a knowledge of the basis for their determination, so that
it is  possible to estimate the cost for systems for other sites.
The analysis is based on cost factors  developed  over the six weeks
of  operations  at  the  demonstration  site  as  well  as  other
information provided by BioTrol, Inc. for operation at other sites.
The key conclusions are based on the two weeks of operation of the
mobile  unit  operating at  5  gpm  with  an  influent  containing
approximately 30 ppm of pentachlorophenol and achieving 96% removal
of that, pollutant.


CONCLUSIONS

Operating  costs  total  approximately  $3.45/1000  gallons  when
treating approximately 7200 gallons/day at 5 gpm in a 5 gpm BATS.
The equivalent residence time is 1.8 hours.

Key components of the operating cost for the mobile unit were found
to  be  heat  and  labor.  Secondary  items  included:  nutrients,
electricity   (pumps),  and  caustic.     Related  items  such  as
permitting,  sinking  wells,   residuals disposal,  etc.  are  not-
included.
OPERATING COSTS

Cost data  were provided  by BioTrol, Inc.  for operation  of -the
mobile  unit at a flow of 5 gpm, assuming an incoming groundwater
with about 45 ppm of pentachlorophenol and a removal efficiency of
about 95%.   Operating  costs were also provided by BioTrol for a 30
gpm unit on the basis of this demonstration and other data from the
developer.  Table 28 summarizes  the  essential operating cost delta
for systems of both sizes.
                               48

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               TABLE 28. OPERATING COST OF TREATMENT
              Cost item       at 5 gpm     at 30 gpm
                                      ($/1000 gal)
nutrients
electricity
heat
labor*
caustic
0.042
0.216
1.46
1.49
0.24
0.017
0.216
1.46
0.50
0.24
                 TOTAL           3.45         2.43

            * includes operation,  maintenance,  routine
                       monitoring at $15/hr


The  estimates  do  NOT  include  operating  costs  for  oil/water
separation,  suspended solids removal, exhaust  air treatment, or
effluent polishing since these items are site and waste specific.
While carbon was  used at  the MacGillis and Gibbs site as part of
the demonstration program,  the exhaust from the reactor and the
effluent  from  the reactor  would have met  the  OSHA Permissible
Exposure Limit  (PEL)  for  naphthalene (10  ppm)  and POTW discharge
requirements (2 ppm PCP) without these controls.

In  addition,  the  cost data  do  not reflect items such  as well
drilling, obtaining permits, disposing of solid residues or other
wastes, site security, insurance, or decommissioning the site after
treatment. While  these Items are part of EPA's  list of  12 cost
categories, these costs are expected to be comparable for any above
ground system that was used to remediate a site.  In addition, these
costs - would  be   very  dependent  on  the   site  location  and
characteristics.

A more detailed  discussion of each of the cost elements included in
Table 28 is provided  in the following paragraphs.

Nutrients; Urea and  trisodium  phosphate are  added at  the same t
dosage (0.16 Ib urea  and 0.31 Ib TSP/lb PCP)  regardless of system
size.   For the pilot scale system the cost  reflects purchase of.the
ingredients at a local fertilizer supplier;  for the larger system
some economy of scale has been factored in on the assumption that
the materials   would  be  purchased   in bulk.  (Cost for  storage
facilities has not been included in the capital costs.)

Electricity;  Groundwater (or other feedwater) is delivered to the
system by a pump .external to the system; the cost to operate that
pump has not been included.  Electricity, at $0.06/kwh, is used to
pump effluent from the bioreactor and to power  the  air sparger
blower motor. The developer's calculations  indicate that variations


                               49

-------
between the requirements for a 5 gpm and a 30 gpm system appear to
be nominal.

Heat:   The amount of heat required at a particular site would be
dependent  to  some extent  on the  incoming water temperature,the
ambient  temperature  and resulting  heat  loss,   as  well  as  the
exothermicity of  the reactions  for a particular wastewater. With
the  heat  exchanger  in  use,  the  actual  temperature  difference
between influent and effluent is only about 5°F and is essentially
independent of the temperature  of  the water source except during
startup. At the MacGillis and Gibbs site during July to September
the average groundwater  temperature was  55°F (13.25°C)  because of
ambient  heating  and the  heater was  not  used.    For the cost
calculations, a 5°F difference in temperature is assumed.

Caustic; The cost for these estimates  is  based on  the caustic used
in  the demonstration  program  at  a  price  of  $2.60/gal  of  50%
solution.  For the MacGillis and Gibbs  demonstration project, total
caustic use was about 15 gal over the six weeks. Depending on the
pH and alkalinity of  the  incoming water to be treated, more  or less
caustic may be required at another site.

Labor; The vendor's experience  is that  operation  of  the 5  gpm
system requires  only about  5  hours/week  for operation,   on-site
maintenance, replenishment of nutrient  and caustic  supply tanks,
and sampling for off-site monitoring. With the larger system, it is
estimated that labor requirements could increase to 10 hours/week.

Increasing the size of the system presents few economies of scsile
except in labor,  which is very significant,  and, to a much smaller
extent, the quantity of  nutrients  that will be needed during the
course of a cleanup.

Start-up of the system requires approximately two weeks and costs
would  be  about  the  same  as two  weeks  of  operation. Clearly,,
acclimation time and costs contribute a more significant  portion of
total  operating  cost where a  system is  being  used for  a short
duration cleanup.  •

Capital Costs

BioTrol,  Inc.  provided three bases  to the  capital  cost  of  the
equipment:

   a.  A lease rate for a 5 gpm mobile unit of $2400/month, which
      would be suitable for a short term cleanup;

   b,  A purchase price of $30,000 for a 5 gpm skid mounted
      installation,  such as might be needed for long term
      treatment of a relatively low flow stream,  leachate
      from a pond, etc.;  and


                               50

-------
   c. A purchase price of $80,000 for a 30 gpm skid mounted
      installation, as might be needed for a larger aquifer.

These  capital  costs  also  do  not  include  the  equipment  or
installation costs for any pre- or post-treatment equipment nor the
cost of a  concrete pad,  building enclosure for the equipment, or
other site preparation. For the following comparisons, the  capital
costs for both the 5 gpm and the 30 gpm units have been amortized
over 10 years and  assigned a $0.00 salvage value at that time.

HYPOTHETICAL CASE  STUDIES

Using the above operating and capital  cost  figures provided by the
vendor, various  case studies  can be formulated  and conclusions
drawn as  to the time  and actual cost that would  be involved in
remedliations of specific sizes. For example, if a site is expected
to yield 1,000,000 gallons of groundwater contaminated with 45 ppm
of pentachlorophenol, and all other factors are comparable to those
in the demonstration program,  the most cost-effective scenario can
be predicted,  as  shown in Table 29.  At 5  gpm,  the demonstration
project approximates to the 0.1 MG example shown in the table.

While the  30  gpm unit would be the most  cost-effective on these
bases, short term  use  of  this  unit is probably unrealistic. Even
for  short  term  uses,  lease  of the  5  gpm mobile unit  is more
realistic than purchase of the 5 gpm unit unless other uses can be
readily foreseen for the remainder of a purchased unit's life.


Mathematically, costs can be evaluated with the following  general
equation using the appropriate operating and capital costs  for the
system size selected:

      Total Cost =  (operating cost) x (total throughput)
       1000 gal        1000                1000
                                    +
                   ( capital cost  ) x (total throughput)
                   -amortize period      throughput/day


Another way of examining  the costs  is to  assume that a Superfund
site is a large reservoir  of contaminated water. Costs can  then be
estimated on the assumption that treatment  (to a comparable  removal
level)  will be carried out at  the  site for an extended time, for
example, 5 years.  For this analysis it would  be assumed that the
equipment is 50%  amortized by the use  and has 50% salvage value at
the end of  the five years. The results  of such an  analysis are
presented in  Table 30. Of course,  this  analysis results  in the
treatment of different volumes of wastewater over the course of the
cleanup.
                                51

-------
    TABLE 29. ESTIMATED COST OF TREATING VARIOUS WASTEWATER VOLUMES*

5
System
0.1 MG 1 MG 10 MG ;
gpm skid mounted unit:
days to treat # 28 153 1.403

opereiting cost
$3.45/1000 gal $ 690 3,795 34,845
capital cost of unit @ $8.33/day 233 1,294 11^687


5





30





Total cost, $
Cost, $/lOOO
gpm mobile unit:
days to treat #
operaiting cost
lease cost ($2,
Total cost, $
Cost, $/1000
923 5,069 46,532
gallons
9.23 5.07 4.
65
DEMONSTRATION
2
$3.45/1000 gal $ 69
400/mo) 2,40
3,09
gallons j 3
8 153 1,403
0 3,795 34,845
0 12,000 112,800
0 15,795 147,645
0.90 15.80 14.




76
gpm skid mounted unit :
days to treat #
opereiting cost
capital cost of
Total cost, $
Cost, $/lOOO
17 37 243 ,'
$2.43/1000 gal 1,713 3,900 25,770
unit @ $22.22/day 378 822 5,422
2,091 4,722 31,192
gallons 20.91 4.72 3.
12
* At an assumed 45 ppm PCP concentration
# Acclimation time of about 2 weeks is included in the "days to
treat" and in capital and operating costs at the same operating cost


         TABLE 30. TREATMENT COSTS OVER 5 YEARS (1800 days)
Cost item
MG water treated
operating cost
equipment cost
total cost
Cost/1000 gal
5 gpm
skid mounted
12.96
$ 44,712
$ 15,000
$ 59,712
$ 4.61
5 gpm
mobile
12.96
$44,712
$144,000
$188,712
$14.56
30 gpm
skid mounted
77.76
$188,957
$ 40,000
$228,957
$ 2.94
An equation that can be used to estimate total cost on this  basis would
have the following form:

Cost = [BATS rate x total time x operating cost] + depreciation
                                   52

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                                SECTION 7

                               CONCLUSIONS


A mobile (trailer-mounted)  BATS with 5 gpm capacity tested at the MacGillis
and Gibbs Company  site under the Super fund SITE program demonstrated the
ability of the system to remove pentachlorophenol from groundwater.  At the
flow  selected as  optimum for the system,  5 gpm,  removal of  96+% was
achieved  and  an  effluent  with  about 1  ppm  of  pentachlorophenol was
attainable. At lower flow rates, 1 gpm and 3 gpm, pentachlorophenol removal
increased to 99+% and final concentrations down to 0.1 ppm were achievable.

Polynuclear  aromatic hydrocarbons probably were  also removed,  either by
biodegradation or by adsorption on/in the biomass but low concentrations in
the groundwater source make it impossible to reach a  firm conclusion.

Secondary pollutants such as oil, suspended solids, and even heavy metals
do  not  appear  to   interfere with   the  reaction,  at  least  at  the
concentrations present in this wastewater. Decreases  in the Total Organic
Carbon (TOC)  beyond that attributable to pentachlorophenol suggest that the
system removes other organic species as well.

Biomonitoring  demonstrated  that  acute  toxicity  present  in  the  raw
groundwater  was  essentially totally removed.  Coupled with the  measured
removal of  specific  chemical  species, this  suggests  that any  form  of
discharge -or reuse would be safe for this wastewater.

Operating cost for the BATS ranges from $3.45/1000 gal when using a 5.gpm
system to $2.43/1000 gal when using a larger (30 gpm) unit.
                                   53

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                            SECTION 8

                           BIBLIOGRAPHY


1. Bishop, J., GAINING ACCEPTANCE, Hazmat World,  June,  1989,  p.  37
ffd.

2*  Brown,  E.J.,  et  al,   PENTACHLOROPHENOL DEGRADATION:  A  PURE
BACTERIAL CULTURE AND. AN  EPILITHIC MICROBIAL CONSORTIUM,  Applied
and Environmental Microbiology, July,  1986, p. 92-97.

3. Bourguin, A.W., BIOREMEDIATION  OF HAZARDOUS WASTE, HMC,  Sept/Oct
1989, p. 16 ffd.

4. Dworkin,  D. and R.M. Shapot, INNOVATIVE REMEDIAL TECHNOLOGIES  AT
A CREOSOTE-BASED WOOD TREATMENT PLANT, presented at HAZMAT
'88, Nov. 8-11, 1988.

5.  EPA,  BIOLOGICAL' TREATMENT  OF  CHLOROPHENOLIC  WASTES,  Final
Report, Project No. 12130  EGK, June 1971.

6. EPA, METHODS  FOR CHEMICAL ANALYSIS OF WATER  AND WASTES,  U.S.
Environmental  Protection  Agency,  Environmental  Monitoring and
Support  Laboratory/ Cincinnati,  OH., EPA-600/4-79-020.   Revised
March 1983.
      *•
7. EPA, SUPERFUND INNOVATIVE TECHNOLOGY EVALUATION  (SITE)  STRATEGY
AND PROGRAM PLAN, EPA/540/G-86/001, December 1986.

8. EPA,  TEST  METHODS  FOR  EVALUATING  SOLID WASTE,  SW-846,  U.S.
Environmental  Protection  Agency,  US Government  Printing  Office,
Washington, DC, Third Edition, November 1986.

9. Finlayson,  G. ,  MICROBIAL CLEANUP OF TOXIC  WASTES MAY  PROVIDE
ALTERNATIVE SOLUTION, Occupational Health and Safety, Jan  1990,  p.
36,38,40,57.

10. Kennedy, M.S., J. Grammas and W.B. Arbuckle, PARACHLOROPHENOL
DEGRADATION  USING  BIOAUGMENTATION, Research J. Water Pollution
Control Federation, 62 #3.  227-233 May/June 1990.

11.  Lee,   L.S.,   et  al,  INFLUENCE  OF  SOLVENT  AND   SORBENT
CHARACTERISTICS ON  DISTRIBUTION OF  PENTACHLOROPHENOL IN  OCTANOL-
WATER AND SOIL-WATER SYSTEMS, Environmental Science  and Technology,
24., |5, 654-661 (1990).

                               54

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12. Lee, K.M. and H.D. Stensel, AERATION AND SUBSTRATE UTILIZATION
IN A SPARGED PACKED-BED BIOFILM REACTOR, J. Water Pollution Control
Federation,  58  #11.  1066-1072  (1986).

13.  Loper,  J.C.,  THE  FUTURE  OF BIOREMEDIATION:  PROSPECTS  FOR
GENETICALLY  ENGINEERED  MICROORGANISMS,  HMC, Sept/Oct  1989,  p.  24
ffd.

14.  Mathewson,  J.R.  and R.B.  Jones,  COMMERCIAL MICROORGANISMS,
Hazmat World, June,  1989 p. 48-51.

15.  Mueller, J.G.,  P.J. Chapman and  P.H.  Pritchard,  CREOSOTE-
CONTAMINATED   SITES-THEIR    POTENTIAL    FOR   BIOREMEDIATION,
Environmental Science and Technology, 23.  #10.  1197-1201 (1989).

16.  Nicholas,  R.B.  and  D.E.  Giamporcaro, NATURE'S  PRESCRIPTION,
Hazmat World, June 1989, p. 30  ffd.

17.  PEI  Associates,  Inc.,  REMEDIAL ALTERNATIVES REPORT FOR  THE
MACGILLIS  AND GIBBS "CO.  HAZARDOUS  WASTE SITE  IN  NEW  BRIGHTON,
MINNESOTA,  for Twin City Testing and Engineering Laboratory Inc.,
State PMN  Contract No.  13726,  Subcontract No.  1-35086, PN  3686,
April 1987.

18.  Piotrowski,  M.R., BIOREMEDIATION:  TESTING  THE  WATERS,  Civil
Engineering, Aug., 1989, p. 51-53.

19.  Rusten, . B. ,  WASTEWATER  TREATMENT  WITH  AERATED  SUBMERGED
BIOLOGICAL FILTERS,  J. Water Pollution  Control  Federation,  56  #5.
424-431  (1984).

20. Saber, D.L. and  R.L. Crawford, ISOLATION AND CHARACTERIZATION
OF FILAVOBACTERIUM STRAINS THAT DEGRADE  PENTACHLOROPHENOL, Applied
and Environmental Microbiology, Dec. 1985, p. 1512-1518.

21. Skladany, G.J.  and K.M. Sullivan,  "DECAY THEORY"  BIOLOGICAL
TREATMENT  FOR  LOW-LEVEL ORGANIC CONTAMINATED GROUNDWATER  AND
INDUSTRIAL WASTE, Superfund '87 Conference (HMCRI), Nov.  17,  1987,
Washington, D.C.                                                  /

22.  Steiert, J.G.  and  R.L.  Crawford,  MICROBIAL DEGRADATION-. OF
CHLORINATED PHENOLS, Trends  in Biotechnology, 3. #12.  1985,  p. 300-
305.

23. Stinson, M.K., W. Hahn and H.S. Skovronek.,  SITE  DEMONSTRATION
OF BIOLOGICAL TREATMENT OF GROUNDWATER  BY  BIOTROL, INC.  AT A WOOD
PRESERVING SITE IN NEW BRIGHTON, MN, Presented  at 16th Annual  EPA
Research Symposium,  Cincinnati, OH, April  3-5,  1990.
                                55

-------
24. Topp, E., R.L. Crawford,  and R.S. Hanson, INFLUENCE OF READILY
METABOLIZABLE   CARBON   ON  PENTACHLOROPHENOL  METABOLISM   BY  A
PENTACHLOROPHENOL-DEGRADING  FLAVOBACTERIUM SPECIES,  Applied and
Environmental Microbiology, Oct 1988, p. 2452-2459.

25. Torpy, M.F., H.F. Stroo,  and G. Brubaker, BIOLOGICAL TREATMENT
OF HAZARDOUS WASTE, Pollution Engineering, May 1989, p. 80 ffd.

26.  Twin  City  Testing  Corp.,  REMEDIAL  INVESTIGATION  REPORT:
MACGILLIS AND GIBBS COMPANY SITE, NEW BRIGHTON, MINNESOTA, Document
#120-86-414 for Minnesota Pollution Control Agency, June 25, 1986.

27. Valine,  S.B.,  T.J.  Chresand and D.D.  Chilcote,  SOIL WASHING
SYSTEM FOR USE  AT  WOOD  PRESERVING  SITES,  Proceedings of the 1989
Air and Waste Management Association/USEPA International Symposium,
p. 257-268,  Feb. 20-23, 1989, Air and Waste Management Association,
1989, Pittsburgh, PA.

28.  Wilson,  S.,  THE   IMPORTANCE  OF  BIOREMEDIATION,  Pollution
Equipment News, Dec., 1989, p. 67 ffd.
                                56

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                 APPENDIX A
QUALITY ASSURANCE/QUALITY CONTROL EVALUATION
                     A-l
                    '(57)

-------
                                  APPENDIX A

                 QUALITY ASSURANCE/QUALITY CONTROL EVALUATION

   BioTrol Aqueous Biological Treatment of Wood Preserving Site Groundwater


                               TABLE OF CONTENTS

Section                                                                 Page

List of Tables	  iii

1.0   INTRODUCTION		  1- 1

      1.1   CRITICAL ANALYSES	 . .	  1- 1
      1.2   DATA QUALITY OBJECTIVES  	  1- 6

            1.2.1  Data Quality Indicators	  1- 6

2 .0   ANALYTICAL QUALITY CONTROL	'	  2- 1

      2.1   COMPLETENESS 	  2- 1
      2.2   PCP/PAH (TOTAL, DISSOLVED) AND SEMIVOLATILE
             ORGANICS ANALYSIS 	:	  2- 2

            2.2.1  Holding Time 			  2-4
            2.2.2  Method Blank Results	 .. .  2-4
            2.2 .'3  Surrogate Recovery	  2- 4
            2.2.4  Precision and Accuracy	  2- 7

      2.3   CHLORIDE 		  2-9
      2..4   TOTAL ORGANIC CARBON	  2- 9
      2.5   POLYCHLORINATED DIBENZO-p-DIOXINS/DIBENZOFURANS 	  2-12
      2.6   METALS 	  2-12
      2.7   VOLATILE ORGANICS 		  2-14
      2.8   OIL AND GREASE 		  2-14
      2.9   TOTAL PHENOLICS	  2-17
      2.10  RESIDUE	  2-17
      2.11  NUTRIENTS	  2-17
      2.12  FIELD DUPLICATES 		  2-17

            2.12.1  Pentachlorophenol 	  2-18
            2.12.2  Other Analyses	 	  2-21

3.0   BIOMONITORING AND EMISSION MONITORING 	  3- 1

      3.1   BIOMONITORING	'  3- 1
      3 .2   EMISSION MONITORING		  3- 1
                                     (58)

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                 QUALITY ASSURANCE/QUALITY CONTROL EVALUATION

   BioTrol Aqueous Biological Treatment of Wood Preserving Site Groundwater


                         TABLE  OF  CONTENTS  (CONTINUED)

Section                                                                 Page

            3.2.1  Sample Collection	,	  3 - 1
            3.2.2  Sample Analysis	  3- 2

4.0   ADDITIONAL STUDIES 	'.	  4- 1

      4.1   PENTACHLOROPHENOL SAMPLING LOCATION BIAS	  4- 1
      4.2   EXTENDED PENTACHLOROPHENOL CALIBRATION STUDY 	:.  4- (5

5.0   NON-CONFORMANCES 	 	  5- 1
6.0   DEVIATIONS FROM THE QAPjP 	  6- 1

      6.1   FIELD PROCEDURES	  6- 1
      6.2   SAMPLING SCHEDULE 	  6- 2
      6.3   ANALYTICAL METHODS  	  6- 3

7 .0   AUDIT FINDINGS/RESULTS	  7- 1

      7.1   FIELD AUDIT, WATER SAMPLING 	  7- 1
      7.2   FIELD AUDIT, EMISSIONS SAMPLING 	  7- 2
      7 .3   LABORATORY AUDIT ... '.	  7- 3

8.0   CONCLUSIONS AND LIMITATIONS  OF DATA	  8- 1
                                      ii
                                    (59)

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                 QUALITY ASSURANCE/QUALITY CONTROL EVALUATION

   BioTrol Aqueous Biological Treatment of Wood Preserving Site Ground-water


                                LIST OF TABLES
Table No.
A.I
A. 2
Title
Sampling Summary: BioTrol Aqueous Treatment SITE
Demonstration Project 	 ' 	 	
Completeness Data: BioTrol Aqueous Treatment SITE
Demonstration 	 	
Page
	 1-2
	 2- 2
A.3         Method Blank Results: PGP/PAH and Semivolatile
             Organic Analyses  	 	  2- 5

A.4         Surrogate Recovery: PCP/PAH (total, dissolved) and
             Semivolatile Organic Analyses 	  2- 6

A.5         QC Summary: Precision and Accuracy - Semivolatile
             Organic Compounds	  2- 8

A.6         Method Blank Results: General Chemistry, Metals,
             Volatile Organics and Dioxin/Furan Analysis	  2-10

A.7         QC Summary: Precision and Accuracy - General
             Chemistry Analysis		  2-11

A.8         Surrogate Recovery: Dioxin/Furan Analysis	  2-13

A.9         QC Summary: Precision and Accuracy - Metals 	  2-15

A.10        Surrogate Recoveries: Volatile Organic Analysis 	  2-16

A.11        QC Summary: Precision and Accuracy - Volatile Organics ...  2-16

A.12        Field Duplicate Analysis Summary	  2-19

A. 13        Pentachlorophenol Field Duplicate Analytical Re.sults 	  2-20

A.14        Surrogate Recovery: MM5 Sample Analysis 	  3- 3

A. 15        PCP Method Comparison	  4- 4

A. 1.6        Method Precision Data for GC/MS and HPLC
             PCP Analaysis	  4- 5
                                     . iii
                                     (60)

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                                   APPENDIX
                 QUALITY ASSURANCE/QUALITY CONTROL EVALUATION
   BIoTrol Aqueous Biological Treatment of Wood Preserving Site Groundwater

                               1.0   INTRODUCTION

      As a part of the USEPA Superfund Innovative Technology Evaluation (SITE)
program, the BioTrol Aqueous Treatment System (BATS)  technology was demonstrated
at the  MacGillis  and Gibbs Superfund  site  in New Brighton, Minnesota.   This
appendix-.to the final report discusses  the results of the comprehensive quality
assurance  program associated with this  demonstration.     Included  in  this
discussion are: (1) data quality objectives  (as defined in the Quality Assurance
Project Plan), (2) analytical quality control, (3) additional  studies undertaken
during the project (including a method comparison study initiated in an effort.
to resolve an apparent discrepancy  in pentachlorophenol influent concentrations
as a  function of  sample location and  system flow  rate),  (4) non-conformances
encountered during the demonstration,  (5) deviations from  the QAPjP in field or
laboratory protocols,  (6) findings of audits conducted during  the demonstration,
and (7) conclusions and limitations of the data.

1.1   CRITICAL ANALYSES
      The primary technical objective of this SITE demonstration was to determine
the extent  of removal  of  pentachlorophenol  (PCP)  by the BioTrol  bioreactor
treatment system.   The project was also designed to obtain data on polynuclear
aromatic hydrocarbons (PAHs) removal.   Additionally, a secondary objective was
to determine the fate  and extent  of removal  of  other  semivolatile  organic
compounds, dioxins/furans,  volatile organics, metals,  oil and grease and total
phenolics.   Chloride  ion production was  determined along with  total  organic
carbon as supporting measures of pentachlorophenol degradation/destruction.  The
toxicity  reduction between  well water/influent and effluent wastestreams was
determined by conducting acute toxicity tests.  Losses from the bioreactor via
sloughed  biomass  and  exhausted air  were  monitored  by  sludge analysis  and
emissions sampling and  analysis, respectively.  Residue  and nutrient analyses
were also performed in the laboratory as system condition measurements.   Table
A.I summarizes the analyses performed,  matrices sampled,  location sampled and
frequency of sampling.  Each of these analyses will be summarized  in sections 2.0

                                      1-1
                                     (61)

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 and 3.0,  including any potential bias,  outlier  data and precision and accuracy
 data.


 1.2   DATA QUALITY OBJECTIVES

       Quality assurance objectives were quantitatively  defined in the QAPjP for

 precision,  accuracy  and  completeness  for  the  critical  measurements for  the

 project  (excluding biotoxicity).  A primary concern was the establishment  of a

 comprehensive quality assurance  program with defined objectives  to ensure  that

 the data produced during the demonstration were of known and acceptable quality,

 thus allowing an evaluation of the treatment technology and achievement of the

 project's technical objectives (the primary  objective being the determination of

 the extent of removal of POP). Overall,  analytical measurements met data quality

 objectives  with the following exceptions.


       o     High levels of PGP  in the samples  required that many semivolatile
            extracts  be  diluted prior  to analysis  by GC/MS.   As a result, a
            significant  amount  of surrogate  recovery  data was  unobtainable,
            since  the necessary dilution factors brought the surrogate compound
            concentrations  below the  detection  limit.   However,  the  available
            data suggest that overall approximately  90% of the recoveries were
            within control  limits.

       o     The high levels of  PGP  native to  the  samples also affected  the
            calculation of pentachlorophenol spike recoveries.  For half of  the
            matrix spike duplicate pairs analyzed, the sample PGP concentration
            was 6-20 times higher than the spike concentration  and  therefore
            recovery could not be determined.  The remaining available data met
            precision and accuracy objectives overall.

       o     One set of emissions samples (from the 3 gpm flow rate) had signi-
            ficantly  low surrogate  recoveries  for  the  semivolatile organic
            analysis of the MM5  sampling train,  indicating that  these results
            are biased low.  However, the sampling episodes from the 1 gpm arid
            5 gpm  flow rates, which  had normal  surrogate recoveries,  indicate
            that losses to  the  exhaust air were minimal, and that  no PCP was
            present in these emissions.

       o     Completeness objectives for sludge  (sloughed biomass) collection/
            analysis were not achieved for reasons detailed in section 6.1.


1.2.1 Data Quality Indicators:

      Quality control analyses associated with  the  data quality  indicators of

precision and accuracy include matrix replicates, matrix  spikes and matrix spike


                                      1-6
                                     (67)

-------
duplicates.   Precision,  the ability  of the  measurement system  to generate
reproducible  data,  was  calculated as  the  relative percent  difference  (RPD)
between the results of duplicate samples or  matrix spike/matrix spike duplicate
(MS/MSD) pairs using the following equation:
                % RPD -  (Rx - R,)   x 100
                         (Rj. + R2)/2
where Rx and R2 are  the results  of  the  sample and  duplicate, or the MS and MSD,
analyses.  Accuracy,  defined as the nearness  of  the  analytical result to the
"true" value, is  assessed by the analysis of matrix spikes (or  MS/MSD pairs) and
reported as percent recovery according to the  following equation:

                  % Recovery -  Ci - C0  x 100
                                  Ct
where CL — the measured  concentration  in the  spiked sample,  C0 — the measured
concentration in the unspiked sample and Ct - the known concentration of analyte
added to the sample.  The data quality  indicator of completeness is measured as
thes comparison of valid data obtained during the demonstration with the amount
of data expected:

        % Completeness - Valid data points/Expected data points x 100

      Completeness is discussed in section 2.1, and precision  and accuracy are
discussed for each of the analyses in sections 2.2-2.11.
                                     1-7
                                     (68)

-------
                        2.0   ANALYTICAL QUALITY CONTROL

       The following sections review the measure of completeness achieved for the
 project, followed by discussions of the  analytical QC results for each of the
 parameters measured.

 2.1    COMPLETENESS
       QA objectives for completeness for all critical measurements were given in
 the  QAPjP, generally as 90-95%,  and. results  are  summarized in Table A.2.  The
 data presented in this table  include the number  of samples  and duplicates
 proposed for collection in the QAPjP,  the number actually collected during the
 6-week demonstration and the number of samples analyzed.  (Sample analyses which
 may have exceeded QC criteria for surrogate recoveries are included in the totals
 given  for PGP/PAH, semivolatiles and emissions analysis).

       Almost  all  analyses  met the  QA objective  for completeness,  with the
 exception of PCP/PAHs-(total and dissolved) and sludge analyses.  The treatment
 technology was evaluated  using average  PGP concentrations  for  well water,
 influent and effluent waste streams.  The loss of eight individual data points
 does not  seriously impact  data quality or  the  achievement of  the project's
 technical objective, and as noted in Table A.2, the completeness objective  only
 fell one-two percent short of the QAPjP objective.   Sludge collection/analysis
was hindered by the type of sample collected (see  section 6.1).  Sludge  data was
used qualitatively to estimate the potential PGP loss due  to ad/absorption;  thus
data quality was not greatly impacted.

2.2    PGP/PAH (TOTAL, DISSOLVED) AND SEMIVOLATILE ORGANICS ANALYSIS
      Aqueous samples were analyzed  for PCP/PAHs  (on samples  as  collected and
after filtering),  and occasionally for full-scan semivolatile organics, by SW846
method 3510/8270.   Solid/sludge samples were  analyzed  for PCP/PAHs  by SW846
method 3550/8270,  and were phase-separated by centrifugation prior to extraction
of the solids.  Method blank data, surrogate recovery results, and precision and
accuracy data  (MS/MSD analysis) are summarized below.   In addition  to these
quality control analyses, method specified protocols  for calibration (tuning,
multi-point standard curves,  continuing  calibration standards  and  internal
standards)  were followed and met QC criteria.
                                     2-1
                                     (69)

-------
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-------
                                             TABLE A.2  (Continued)
 Notes;
 NC  =   Not a critical measurement; completeness QA objective given for guidance
 N/A =   Hot applicable

 1.      Does not include field, trip or equipment wash blanks

 2.      Aqueous matrix  includes:   well  water,  influent,  effluent,  reactor midpoints  and carbon  effluent
         samples.

 3.      One influent sample  lost  in field; one  influent, effluent and  midpoint sample  lost in lab  (due  to
         breakage).

 4.      One influent sample lost in field, one influent sample lost  in  lab (both due to  breakage).

 5.      One influent sample lost in field (breakage).

 6.      An extra duplicate was collected for this measurement parameter.   Completeness is calculated based only
         on the # of samples without the extra duplicate.

 7.      QAPJP  originally called for 2  samples/week.   An additional well water  sample was added the last 2
         weeks.

 8.      Sludge collection severely hampered by type of filter used, generating wastewater-type sludge samples.
         The limited volume  available  prevented samples being collected during weeks 2 and  3 and made a field
         duplicate  impractical  (as qualified  in the QAPP).  Completeness calculated without  including proposed
         duplicate.

 9.       Uncertainty about  the opportunity to collect  an active biomass sample was clearly documented in the
         QAPP. (Section 5.4, Table 5-5, Table 5-8, and 5.4.3.2-page 29)  A single  sample was  obtained the last
         weak of  sampling.   A completeness objective/calculation is not  appropriate given  the  nature of the
         sampling activity.

 10.     'The QAPP proposed an initial sampling episode at the start  of the project, with subsequent bioreactor
         and carbon  effluent being sampled once per test period, for a total of 8 samples.  Three consecutive
         samples  were to be taken with the first sampling episode, thus 1  sample and 2 "duplicates"; since both
         effluents were sampled there are actually 4 "duplicates".  The initial sampling episode prior to the
         start of the demonstration was not performed due to schedule constraints;  therefore only 6 samples were
         collected.  The QAPP was not fully revised to reflect this altered schedule.

 11.      This total  does include  samples  which had surrogate recoveries outside of control limits  due  to
         suspected matrix effect (see section 2.2).

12.      An extra effluent sample was analyzed for dioxins/furans.

13.      Eighteen samples were specified for collection in the QAPP; three grab samples were to be collected and
         analyzed in the laboratory as a composite (excluding  the raw well water  sample).  Following  the lab
         audit,  the decision was made to analyze each individual grab separately.- thus the actual number  of
        samples analyzed were 38 and the duplicate was actually 3 grab analyses.
                                                      2-3

                                                      (71)

-------
 2.2.1 Holding Time
       The method-specif led holding time for aqueous samples (7 days from sample
 collection to extraction and 40 days from extraction to analysis)  was exceeded
 for the influent, midpoint 1, midpoint 2, effluent  and equipment  wash samples
 from day 3 of the 5 gpm flow test (STI-C-03-02/03/04/05/13) ,  and were met for all
 other water samples.   The results  for samples exceeding hold time were not used
 in the evaluation of the bioreactor.  The method-specified holding time for solid
 matrices (14 days from sample collection to extraction) was exceeded for two of
 the sludge samples by one and five days; all samples met the analysis hold time
 of 40 days.   The elapsed time was  considered  to have minimal  impact  on data
 quality and these  data were used  in evaluating the extent of PGP removal via
 sloughed biomass.   In addition,   sludge data was used only as  a  quantitative
 estimate as previously stated.

 2.2.2 Method Blank Results
       Method blank results are summarized in Table A.3.  The only consistent lab
 contaminant detected in aqueous method blanks was bis(2-ethylhexyl)phthalate (at
 an average concentration of 22 ug/1.) Phthalates were only a target compound for
 the 19 samples (and associated field blanks)  analyzed for full-scan semivolatile
..organics.  At the detected blank levels, there  was no impact  on sample data
 quality.

 2.2.3 Surrogate  Recovery
       Seven surrogate compounds were spiked into each aqueous sample prior to the
 liquid-liquid extraction procedure.  The percent recovery ranges and comparison
 to control limits are give in Table A.4.  As discussed previously, a significant
 number  of  surrogate  recovery  data points  were  unobtainable when  dilutions
 required,  due  to high  sample   PCP  concentrations,  resulted  in  surrogate
 concentrations below the detection limit.

       Of the analyses for which surrogate recoveries were generated, an overall
 90% of the recoveries were within specified control  limits.  However,  approxi-
 mately 18% of the samples had 2 or  more surrogate  recoveries (more than one each
 of the acid and base/neutral compounds) outside control limits.  Significantly,
 two-thirds of these samples were collected from the  second bioreactor midpoint
 or the effluent, mostly from the first two weeks of the demonstration (1 gpm flow

                                     '2-4
                                      (72)

-------
                           TABLE A.3

METHOD BLANK RESULTS:   PGP/PAH AND SEMIVOLATILE ORGANIC ANALYSES
Number
Compound of Blanks
AQUEOUS MATRIX BLANKS
Diethylphthalate 22
Di-n-butylphthalate 22
Bis(2-ethylhexyl)phthalate 22
Di-n-octylphthalate 22
Phenol 22
2-Chlorophenol 22
4-Chloro-3-methylphenol 22
All other compounds 22
SOLID MATRIX BLANKS
All compounds 3

* — Also found in 2 additional blanks
No . Above Concentration Detection
Detection Range Limit
Limit (ug/L) (ug/L)

1
1
12*
1
1
1
1
0

0

at levels

34
16
13-140
17
14
16
11
- -

-.

just below the

10
10
10
10
10
10
10
10 - 50

330 - 1600
mg/kg
detection limit.
                                2-5
                                (73)

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 rate).  Factors which appear to have contributed to this matrix effect include
 the1, suspended solids in the effluent which were highest during the first part of
 the demonstration (average TSS=54 mg/1 at '1 gpm, 26 mg/1 at 3 gpm and 18 mg/1 at
 5 gpm), and  throughout the demonstration the samples  collected at the second
 midpoint  of  the bioreactor  and from the  effluent would  have been  the  most
 affected by  biological activity (including any degradation by-products)  thus
 causing a residual  microbe population  which may have  interfered with  the
 extraction or analysis.

       In addition,  the surrogate compounds d5-phenol  and  2-fluorophenol  were
 primarily affected and biased low; tribromophenol recoveries were reported both
 above and  below the  control limits and more  frequently within limits.  Similarly
 PGP concentrations did not appear to be biased low for samples with low surrogate
 recoveries -  a review of influent samples from the 1 gpm flow rate indicated that
..the average PGP concentration was higher for samples  (six  out of twelve)  with
 surrogate  recoveries below the control limits than for samples with surrogate
 recoveries within limits.

       It appears  reasonable, therefore, to  conclude  that the low  surrogate
 recoveries observed for d5-phenol and 2-fluorophenol are attributable,  at least
 in part,  to  matrix effects, particularly  for the bioreactor midpoint 2  and
 effluent samples from the first two weeks.  It is also significant that extrac-
 tion recovery/efficiency was  generally within control limits for tribromophenol
 and for spiked pentachlorophenol - which for most  samples  was the  only target
 acid extractable compound.  Therefore, given the low percentage of samples-with
 surrogates below specified  limits there is considered to be  minimal  adverse
 impact on data  quality  basing  conclusions  on average PCP  concentrations  as  a
 result of  the low-recovery for the .two surrogate compounds.   In addition,  the
 comparison study of methods SW3510/8270  and the developer's HPLC method (which
 is not  dependent on  extraction efficiency) shows PCP recovery was not adversely
 affected in any given matrix (see section 4.1).4

 2.2.4 Precision and  Accuracy
      A summary of aqueous sample MS/MSD analysis results is presented  in Table
 A.5.   The  full, complement of spiking compounds was included  for  each  MS/MSD
 analyzed although in many cases  only PCP and PAHs were the target compounds.   Due

                                      2-7
                                     (75)

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to the elevated background  level  of PGP in some of "the samples spiked, penta-
chlorophenol recoveries were not considered meaningful and are not reported if
the sample concentration was greater than 5 times the spike concentration.

      Precision measurements  for all  PGP MS/MSD  pairs  reported were within
control limits (RPD - 0-50%);  RPD values were not reported for the MS/MSD pairs
which had elevated PGP sample concentrations.   However, if precision is calcu-
lated for  these  analyses using  the observed spiked sample  concentration (as
opposed  to using  the calculated  % recoveries  to determine  the RPD),  then
additional precision data is obtained which is particularly relevant for high PCP
concentrations.  This measure of precision generates an RPD range of 0.8-17.2%
with all values within control limits.

      Matrix  spikes  could not be performed on sludge/solid samples,  due  to
limited volume.                         .

2.3  CHLORIDE
      During the  initial  stage  of the  analysis program, aqueous  samples were
analyzed for chloride by SW846  Method 9252.  After the  laboratory  audit (see
section 7.3), the method was changed to Standard Method 4Q7C for the remainder
of the program.  All samples were analyzed within the method specified holding
time of 28 days.   Method blanks (see Table A.6) were analyzed with each sample
batch, and chloride was less than the detection limit for all blanks.  Precision
and accuracy were  determined  by  the analysis of matrix  duplicates  and matrix
spikes/matrix  spike  duplicates  (see Table  A.7).      Initial and  continuing
calibration standard" analyses met applicable QC criteria.

2.4  TOTAL. ORGANIC CARBON (TOG)
      Samples were analyzed for TOG  as  collected and  after filtering (soluble
total organic carbon, STOC) by  SW846 Method 9060.   All  samples  were analyzed
within the 28 day method specified hold  time.  One method blank had a TOG valtae
of 1.4,  all others were not detected at 
-------
                                     TABLE A.6

        METHOD BLANK RESULTS:   GENERAL CHEMISTRY, METALS, VOLATILE ORGANIC,
                             AND DIOXIN/FDRAN ANALYSIS
Parameter-Matrix (units)

Chloride-Aqueous (mg/L)

Total Organic Carbon-Aqueous
  (mg/L)

DIoxins/furans-Aqueous (ng/L)
Number of
 Blanks

   28
   30
Number Above
Detec. Limit

     0
                                                           Concentration  Detection
Ranee
                   1.4
Limit
OCDD
Others
Dioxins/furans- Solid (ng/g)
Metals -Aqueous (ug/L)
Chromium
Nickel
Lead
Metals - Sludge (ug/L) <2)
Volatile Organics- aqueous (ug/L)
Methylene chloride
Others
Oil and Grease - aqueous (mg)
Residue - aqueous (mg/L)
Nutrients -Aqueous (mg/L)
Nitrate -nitrite
Ammonia
Total phosphate
Total phenolics- aqueous- (mg/L)
6
6
3

6
,6
4
2

11
11
14
17

11
12
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7
1
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(3) Four additional blanks contained
sludge, an aqueous
blank is
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applicable
just below the
       detection  limit
                                         2-10
                                        (78)

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      Precision  and accuracy for TOG was evaluated -by the analysis of matrix
duplicates and matrix spikes and measurements met QC objectives.  In addition,
QC  check standards were  analyzed  and had recoveries  ranging from 96.8-103%.
Calibration standard analyses met QC criteria.

2.5  POLYCHLORINATED DIBENZO-P-DIOXINS/DIBENZOFURANS
      Aqueous and sludge samples were analyzed for dioxins/furans by SW846 method
8280.  Sludge samples were phase separated prior to extraction by decanting the
water and only the solid fraction was analyzed.  The procedure involves a matrix
specific extraction and cleanup, followed by GC/MS analysis.  Sample extracts,
blanks and standards were  spiked prior to analysis with 13C12-1,2,3,4-TCDD as a
quantification   standard,  then  analyzed  by   selective   ion monitoring  and
identified/quantified based  on  isotope  dilution techniques.   All samples were
analyzed  within  the  method-specified holding time. of  30  days  from  sample
collection to extraction and 45 days for complete analysis.

      All samples  and,blanks were spiked prior  to extraction with labelled
(13C12-) PCDDs and PCDFs.  Surrogate recoveries are summarized in Table A. 8.  Most
compound recoveries were within control limits.   In one instance,  a sludge sample
.(STI-A-6-7) had high recovery of the labelled OCDD and OCDF surrogates (144% and
141%, respectively); the sample results reported for OCDD  (1900 ng/g) and OCDF
(41  ng/g)  may consequently  be  biased somewhat high.   For most of the other
samples  having  surrogate  recoveries  outside  of  control  limits,  the  related
congener  was not detected.   Two  sample results were  reported  as NC  (not
calculated) for  PeCDF due  to the associated surrogate being non-detected.

2.6   METALS
      Aqueous  samples  and four  sludge  samples  were  analyzed for  priority
pollutant metals by SW846  methodologies.  All samples were analyzed within the
method-specified holding times  of 28 days for mercury and 6 months for the other
metals.   Sludge samples were analyzed  "as  is" without phase separation,  and
reported as ug/g,  wet weight.

      Method blanks were digested/analyzed with each batch of aqueous and sludge
samples.    Three  of the four  lead analysis method blanks contained  lead,  at
concentrations ranging  from 1.4-3.9 ug/L.  In addition, four equipment wash

                                     2-12
                                     (80)

-------
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 blanks and one field blank also had lead detected at concentrations ranging from
 4.6-5.3 ug/1.  Lead concentrations in the samples ranged from non-detected to 11
 ug/L; one effluent sample had a concentration of 580 ug/L (all elements detected
 in this sample had much higher concentrations) .   Based on blank results, the low
 levels of lead detected in the  samples may be biased due  to the background lead
 level observed.

       Precision and accuracy for metals  analysis was determined by the analysis
 of matrix spike duplicates  (MS/MSD) and these  results are summarized on Table
 A. 9.  In addition,  laboratory control samples were analyzed and generally met QC
 criteria.

 2.7   VOLATILE ORGANICS
       Aqueous samples were analyzed  for  volatile organics by SW846 Method 8240.
 All samples were analyzed within the method-specific holding time of 14 days for
 a preserved aqueous sample (pH < 2- with hydrochloric  acid).

       Method blanks were analyzed along with the samples each day.   There were
 eleven method blanks associated with  these samples; the only detected contaminant
.was methylene chloride in 6 blanks at concentrations  ranging from 3J-29 ug/L.
 (The "J" refers to  an estimated concentration reported below the MDL of 5 ug/L.)
 Most trip,  field and equipment wash blanks (11 out  of 15) were also contaminated
 with methylene chloride  at  concentrations  ranging  from  3J-28  ug/L.   Sample
 concentrations ranged from non-detected to 48 ug/L.   One sample which required
 a 50-fold dilution due to foaming during purging had a  concentration  of  1200
 ug/L, which is equivalent to 24 ug/L prior to  accounting for the dilution factor.
 Thus,  all methylene chloride values  should be considered biased high.

       Surrogate recovery  results,  summarized  in  Table  A. 10  were all  within
 control limits. Precision and accuracy were measured by the analysis of MS/MSD
 samples; the results are  presented in Table  A.11.

 2.8   OIL AND GREASE
       Samples were  analyzed for oil and grease by SW846 Method 9070.  All samples
 were analyzed within the  method-specifled holding  time of 28 days.
                                      2-14
                                      (82)

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-------
       Precision and  accuracy were to be determined by  the  analysis of matrix
 replicates and matrix spikes; due to limited sample volume this was not always
 possible.  In addition,  QC check standards were analyzed with each sample batch
 and all recoveries were acceptable, ranging from 80-101%.

 2.9   TOTAL PHENOLICS
       Aqueous samples and sludge  samples were analyzed  for  total phenolics by
 .SW846 Method  9066.   Sludge  samples were analyzed  as  received, basically as
 aqueous samples and  reported as mg/L.'"  All samples were analyzed  within the
 method recommended hold time of  28' days.   Method  blanks  were free  from any
 contamination.  All  precision and  accuracy measurements were within control
 limits..

 2.10  RESIDUE
       Aqueous samples were analyzed for  total suspended  solids  (TSS) and total
 volatile suspended solids (TVSS) .  Sludge samples were analyzed for total solids.
 All samples were  analyzed within the 7  day method-specified  hold  time.   All
 associated method blanks had non-detected (<1 mg/L)  results.  Matrix replicate
 analyses were used to assess method precision and results were within control
'limits.

 2.11  NUTRIENTS
       Samples  were analyzed for ammonia, nitrate-nitrite, and total phosphate as
 system condition measurements.  Samples were analyzed within the 28  day holding
 times  for each of  these analyses excluding the following  samples which exceeded
 the holding time for  phosphate:  days  1 and 3 of the  1  gpm flow  test,  influent/
 effluent/equipment washes  (ST1-A-1-2/5/13, ST1-A-3-2/5/13).  All method blanks
 for these analyses were free from any laboratory contamination. Method precision
 was evaluated  by the  analysis of matrix duplicates and accuracy was  determined
 by  the analysis of matrix.spike  analyses; results are  summarized in  Table A.7.

 2.1.2   FIELD DUPLICATES
       Field duplicates were collected and analyzed at a frequency  of 5%.  As
 discussed in the QAPjP, field duplicates inherently measure the precision of both
 the collection procedure  and the analytical methodology.   When the results of the

                                     2-17
                                     (85).

-------
field duplicate analyses meet the analytical precision objectives, then both the
sampling and analysis can be considered to be within control.  If, however, the
measurements exceed the precision objectives, then it is difficult to ascertain
whether the collection procedures resulted in non-representative  samples or if
the analysis was  in  error.   A total of eight field duplicates,  analyzed for a
variety of parameters,  were  collected during the demonstration.   Table A. 13
summarizes the results of the field duplicate analyses.

2.12.1  Pentachlorophenol
      Since the measurement  of PGP was the most critical of the measurements, the
individual sample results for the field duplicate  pairs are given in Table A.13
for total and dissolved PGP.

      Of the eleven duplicate pair analyses, seven RPD values were less than the
analytical  control  limit   (RPD  0-50%).   This  indicates both  sampling  and
analytical precision were "in control.  In the cases where the analysis for total
and/or dissolved PGP exceeded the control limit, other parameters analyzed for
the sample pairs generally met the control limits.  For sample pair ST1-C-6-05/14
the RPD for total  PGP was 85.7%, but dissolved PGP  and other analyzed parameters
had RPD values within the  applicable analytical  control limits.   Similarly,
sample ST1-C-09-05 and the  duplicate had dissimilar PGP  concentrations,  but
results for TOG and chloride agreed.   For sample pair ST1-B-01-02/14 both total
and dissolved  PGP had RPD  values  outside  of control  limits,  although  the
duplicate sample dissolved  PGP concentration is suspect due  to  analysis at an
inappropriate dilution.  In addition, other parameters analyzed for this field
duplicate  pair were * generally  within  the  applicable control  limits.    This
suggests that sample collection techniques resulted in representative samples;
if differences  in PGP concentrations were a result of non-representative sample
composition this would be reflected in other analyses.  The PGP analyses which
exceeded the control  limit are more likely a result of differences  in extraction
efficiency or  analytical measurements which  were affected by  large  dilution
factors.   PGP extraction is known to be highly variable by SW846 Method 3510 and
because of this variability several field duplicates showed precision to be above
specified objectives. However, a majority of the field duplicate  pairs, as well
as MS/MSD analyses,  indicate that overall variability was in control for the
measurement system.

                                     2-18
                                      (86)

-------
                            Table A.12
                  Field Duplicate Analysis Summary
Analysis Parameter
Pentachlorophenol
Dissolved Pentachlorophenol
Chloride
Total Organic Carbon (TOG)
TOG -dissolved
Total Phenolics
Oil and Grease
Volatile Organic Compounds :
Methylene Chloride
Metals: Arsenic
Copper
Lead
Nickel
Zinc
Dioxin/furans :
HpCDD
HpCDF
OCDD
OCDF
Alkalinity
Residue - TSS
TVSS
Nutrients - Ammonia
Nitrate-nitrite
Phosphate
Total #
of Analyses
7
4
7
7-
4
1 '
3
3
1
1
1
1
1
1
1
1
1
1
4
4
2
2
2
RPD Ranges
0-200
0-195
0-61 -
1.4-9.1
0-9.2
33
0-33
0-200
5.3
12
15
20
0
45
35
44
20
1.2
3.8-40'
0-40
0-6.1
4.1-12
0-23
Analytical RPD
Control T.fm-tt
0-50
0-50
0-25
0-25
0-25
0-25
0-30
NAd)
0-20
0-20
0-20
0-20
0-20
0-30
0-30
0-30
0-30
0-20
0-20
0-20
0-20
0-20
0-20
There are no established control limits for this compound.
                               2-19
                               (87)

-------
                                     TABLE A.13

                          Pentachlorophenol  Field Duplicate

                                 Analytical Results
Sample/Duplicate ID(1)
STI-A-5-02/14
STI-A-9-05/14
STI-B-1-02/14
STI-B-9-02/14
STI-B-11-05/14
STI-C-6-05/14
STI-C-9-05/14
PGP Concentration (ug/L)
Sample      Dupl.     %
 Cone.      Cone.    RPD
 7200
  <50
 8800
24000
  230
 1100
  300
11000
<50
17000
24000
160
440
<50
41.7
0
63.6
0
35.9
85.7
200
NA
<50
15000
22000
NA
810
NA
NA
<50
200*
22000
NA
810
NA
Dissolved PCP (ug/L)
Sample   Dupl.     %
Cone.    Cone.    RPD
                   0
                  195
                   0
(1)    The last number in the sample ID relates to influent (-02), effluent (-05) and
      the field duplicate (-14).

      *  i-  Extract was not re-analyzed at an appropriate dilution
                                        2-20
                                        (88)

-------
2.12.2  Other Analyses
      One chloride field duplicate RPD value (61%) exceeded the analytical RPD
control limit;  all other chloride RPD  values  were well  within limits, again
indicating that any problem was limited to individual  sample analysis.  The one
sample pair collected as the field duplicate for total phenolics had an RPD of
33%.   One oil and grease  duplicate  analysis also had an RPD of  33%.   These
estimates of  precision are considered  to be indicative  of an overall system
(sampling and  analysis)  which is in  control,  even though the analytical RPD
values were  slightly exceeded.  Methylene chloride was the only detected compound
in the volatile organic analysis  of the field  duplicate collected (as 3 grabs
over 24 hours) for this parameter.  Due  to the background  levels encountered in
the  laboratory  for this  compound,  the high RPD can be attributable  to  lab
contamination of the  duplicate. One effluent sample collected  in duplicate for
dioxins/furans had RPD values  which exceeded the  analytical control limit for
three out  of four detected congeners.   The  duplicate pair analyses for TOG, STOC
and metals all had results Which met the precision objectives for the analysis.
                                    2-21
                                    (89)

-------
                  3.0  BIOMONITORING AND EMISSIONS MONITORING

3.1   BIOMONITORING
      Acute toxicity was determined on influent, effluent and well water samples.
The  fathead  minnow tests  were  performed  at  five  concentrations,  each  in
replicate, using a total of 20 organisms.  Controls were performed,  in replicate,
with  each test.   Survival for  the  controls was well  within the  80% survival
requirements;  in most  cases no  mortality was observed  (except  a  few tests
exhibiting 90% survival).   The water flea bioassay tests also were performed at
five concentrations, using a total of 20 organisms divided between two or four
vessels.  All control samples exhibited 100% survival.

      Reference toxicant tests were performed using cadmium chloride and sodium
pentachlorophenate.  (This latter compound could only be obtained as a technical
grade reagent since it is  no longer available from EPA.)  The replicate 48 hour
LC50 values for cadmium  chloride for the water flea were 0.08 mg/L and 0.09 mg/L.
The reported EPA ranges were 0.01-0.09 mg/L.   The replicate 96 hour LC50 values
for cadmium chloride for the minnow was 0.48 mg/L and 0.60 mg/L;  the reported EPA
ranges  were  0.10-0.41  mg/L.   The  replicate 96 hour  LC50  values for  sodium
pentachlorophenate were determined for the  minnow  to be 0.09  mg/L and 0.12 mg/L
(it was not run with the water flea).  The values referenced in the literature
indicate LC50 values ranging from 0.198-0.60 mg/L.

3.2  EMISSIONS MONITORING

3.2.1 Sample Collection
      Gaseous  samples   were  collected  from the  exhaust  in the  lid of  the
bioreactor at  locations before  (upstream)  and after  (downstream) the  carbon
adsorption system using EPA Modified Method 5 sampling procedures (SW846 Method
0010).  Pre- and post-sampling leak tests were conducted per the Method to assure
that the sampling systems were within tolerance of the leak specifications in the
method.

      EPA guidelines for acceptable results based on percent isokinetic sampling
are 100% ± 10%.  Isokinetic sampling percentages for the upstream and downstream
samples collected  during  Run 1  were 80.6% and 99.1%  respectively.   The  low

                                     '3-1
                                      (90)

-------
measured percent of isoklnetic for the upstream sample was probably a result of
turning the bioreactor fan on and off during the sampling run.   During the first
sampling run, flow measurements were made with the fan on and off to determine
impacts the fan had on flowrates.  It was decided that the fan was necessary for
isokinetic sampling;  therefore,  the booster  fan was  left on for the remaining
runs.  The percent  of isokinetic sampling maintained for all of the remaining
runs  (Periods 2 and 3) was within the acceptance criteria of 90 - 110%.

3.2.2 Sample Analysis
      Each emissions sample was comprised of the particulate  filter, XAD sorbent
trap, impinger condensate and the  probe/nozzle solvent washings. The filter and
trap were combined, spiked with phenol-d5, 2-fluorobiphenyl and anthracene-dlO
as surrogate standards, and extracted by SW846 Method  3540 (soxhlet extraction).
The  condensate  was  spiked with nitrobenzene-d5  and  .2,4,6-tribromophenol,  the
washings fraction was spiked with 2-fluorophenol  and  terphenyl-d!4 (see section
6.3); both were extracted (individually)  by  SW846 Method  3510 (liquid-liquid
separatory funnel).   The three extracts were combined prior to analysis for PGP,
PAHs and phenols by SW846 Method  8270.  Reagent blanks were prepared using XAD
and an aqueous blank and were extracted with each batch of samples.

      Four reagent blanks  were  analyzed;  one contained  11  ug of naphthalene.
Four field blanks were collected and three had naphthalene detected at 15-100 ug.
Sample concentrations of naphthalene ranged from 92-780 ug for inlet samples and
11-40 ug  at the  outlet; therefore the  outlet  levels  of  naphthalene  may  be
suspect.

      Table A. 14 summarizes surrogate recoveries achieved for the analysis of MM5
samples. All surrogate recoveries which were outside control limits were for the
samples collected during the  3 gpm flow rate period.   All  of these field samples
(inlet,  outlet,  and field blanks), along with  the associated reagent blank,  had
low surrogate recoveries for almost all compounds (average  recoveries were 16%
for the trap/filter  fraction, 14% for the condensate fraction  and 8%  for  the
washings fraction) .  All results  for these samples should therefore be considered
significantly biased low.
                                      3-2
                                     (91)

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      Three samples were collected during the 1 gpm flow rate period as a means
of  evaluating sampling  precision.   Triplicate analyses  were  not  possible,
therefore  these   three   consecutive  samples  were   the   best  alternative.
Naphthalene,  phenol and 2-methylphenol were measured in all  three  inlet samples;
the  relative  standard   deviations   (RSD)   were   27.9%,   23.4%,  and  21.7%,
respectively.  Naphthalene  was  detected in all three  outlet  samples,  with an
RSD-46%; the  elevated RSD  is  probably a  function of  the  concentration bias
discussed previously (based on contaminated reagent and field blank analyses).
Acenaphthene was detected in two of the three inlet samples,  but at levels barely
above the MDL for the compound.  Overall, the results for these analyses indicate
that  the  sampling  and   analyses  protocols  were  in-control  and  generated
representative concentrations.
                                     3-4
                                     (93)

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                            4.0  ADDITIONAL STUDIES


4.1   PENTACHLOROPHENOL SAMPLING LOCATION BIAS

      As  initial pentachlorophenol results were reported for samples collected

during the first two weeks of  the demonstration, it became apparent that there

was a significant difference between the PCP concentration in the raw well water,

and the concentration in the sample collected as the  influent.   The well sample

was collected as a grab sample from a tap in the line prior to  the groundwater

entering  the conditioning tank.  The influent samples were collected as 22 hour

composites taken from the bioreactor pre-chamber above the underflow weir where

the water entered the first cell of the bioreactor.  As additional data became

available, the difference in PCP  concentration  between  the  well water and the

influent  decreased as the flow rate increased, as shown below:


                                   Average Concentration (ug/L)
            Flow Rate               Well Water        Influent

            1 gpm                   42000             6900
            3 gpm                   34500             18300
            5 gpm                   27500             24200


Data available from grab  samples collected and analyzed by the developer (using

an HPLC method) ,  and data from  samples split with Lockheed as part of the field

immunoassay project provided additional data.  The following observations were
made.

      o  The developer  collected samples  from  a  tap  in the  line after  the
         conditioning tank, but  prior to  the water entering  the  bioreactor.
         Results indicated  a  fairly constant  sample concentration  averaging
         42000 ug/L.

      o  Samples analyzed by GC/MS (SW846 Method 8270) by EMSL-LV as part of the
         field  immunoassay project were  split  samples  of  the  composites
         collected from the bioreactor.  Results  were comparable  to the influent
         concentrations obtained by the  SITE  contract laboratory.

      o  Other analyses  -  chloride and  residue - showed a reverse trend  in
        -concentration:    the  well water concentrations were  lower than  the
         influent sample,  suggesting that some change was  occurring in-  the
         bioreactor prechamber.
                                     4-1
                                     (94)

-------
       It.was postulated that backmixing within the bioreactor,  from one chamber
 to the preceding chamber,  could be occurring. Thus, the PGP concentration of the
 "influent" would decrease as wastewater from midchamber in the bioreactor, having
 a lower PGP concentration after undergoing biodegradation, mixed with and diluted
 the  incoming groundwater.  Likewise, chloride and residue concentrations would
 be higher within the cells of the bioreactor due to degradation by-product and
 sloughed biomass,  respectively, and  would therefore increase  the "influent"
 concentrations after mixing with the incoming groundwater.

       To   determine   whether  the  variation  between   the  influent  sample
 collected/analyzed by the developer and the composite influent sample collected
 from the bioreactor pre-chamber could be due to differences in methodology versus
 sample location and to document how the methods compared, as well as to determine
 if the developer's  data could be used in support of the other  demonstration data,
 the  following steps were taken:
       1.  Compared the developer's sample results  (HPLC) with the  SITE contract
          lab sample results (SW8270) for high flow rate influent and effluent
          samples where  possible.   Also determine what,  if any, QC/validation
          data the.developer had available  for the HPLC method.
      2.  Have  the SITE  contract  lab  re-analyze  several  of  their  composite
          influent samples (low and high flow rate) by SW8270 to evaluate hold
          time effect.
      3.  Have  the SITE  contract  lab  re-analyze several  developer  influent
          samples (low and high flow rate) by SW8270 to compare methodology.
      4.  Have the developer re-analyze several of their influent grab samples
          by HPLC to evaluate hold time effect.
      5.  Have  the developer  re-analyze  several of  the  composite  influent
          samples by HPLC to compare methodology.
      6.  Have each lab analyze the standard used  for calibration by the other.

Eight samples (four each from the low and high flow tests) were chosen for re-
analysis by both labs; two were to be performed in duplicate.  By re-analyzing
the samples which were also being sent to the other lab, data  would be comparable
from within the same analysis time  frame,  and  in  addition,  information on the
effects of holding  time would be generated.  Results of this  study are discussed
below.
                                     4-2
                                     (95)

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       Holding Time:    The re-analysis  of samples  by both  laboratories
       provided inconclusive results.    Twenty reanalyses,  total,  were
       performed with a majority of the  re-analyzed  values  lower  than the
       original sample concentrations; however,  the percent decrease ranged
       from 4.7-100%.  (A few re-analysis sample concentrations  actually
       increased.)    The  results indicated  that the  effect  of  compound
       degradation  over time was unpredictable.

       Method Comparison:   Regardless of the effect of hold time on the
       samples,  since both laboratories  were re-analyzing samples at the
       same time, the results could be used to  compare  the GC/MS  and HPLC
       methods used.    Table  A. 15  presents the  re-analysis  values  of
       composite samples (collected from the bioreactor pre-chamber) re-
       analyzed by both laboratories.  Six of the eight analysis pairs had
       RPD  values less  than 50 percent (the SW8270 precision  criteria for.
       MS/MSD pairs for pentachlorophenol).

       Each laboratory also analyzed the  other's analytical  standard.  The
       SITE contract  laboratory analyzed the 38.4 ppm standard used by the
       developer at  25.0  and 26.0  ppm   (average  66.4% recovery).   The
       developer analyzed  the 2.0 ppm standard  used by the SITE  contract
       lab  at 1.8 and 2.1 ppm (average 98% recovery).

       The  average  of  the 8270  values  compared to the HPLC  data  were
       approximately  35% lower.   The GC/MS method used the 3510  extraction
       procedure, which is known to  exhibit  fair  to moderate  extraction
       efficiency for PGP.  The  SITE contract  lab MS/MSD recoveries, while
       highly variable (65-204%), also suggest PCP recovery efficiency was
       biased low.    Therefore  it appears  the  two  different method are
       comparable, that extraction efficiency causes  the GC/MS analysis to
       be biased low, and  that HPLC methodology may be more accurate for
       PCP  concentrations above  1 PPM.

       Precision:   Several samples were analyzed  in  duplicate  by  both
       laboratories.  The precision estimates  are presented in Table A.16.
       In general,  the HPLC duplicate analyses performed by the developer's
       lab  showed  excellent  agreement   (maximum RPD -  12).    The GC/MS
       analyses  performed  by  the SITE contract lab were also  within  QC
       limits,  meeting the method criteria for precision  for pentachlo-
       rophenol, RPD  s50%,  in 7  out of 8  anlayses.  The  larger RPD for the
       SITE  contract  lab  result was  primarily a  function  of variable
       extraction efficiency.


The results  of these analyses  indicated that the  lower-than-expected  influent
concentrations for  the composite samples  collected from the bioreactor prechamber
during the  demonstration, specifically  during  the 1 gpm and  3  gpm flow rates,
were probably due to the suspected backmixing as opposed to method bias.'  (See
reported concentrations in the  Technical Evaluation Report)   In general,  the

extraction/analysis method used  for the analysis of the well water demonstration
                                     4-3
                                     (96)

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                                    TABLE A.15

                               FCF Method Comparison
                                        Concentration.  ug/L
                          SW846-3570/8270
Sample Date                 Re-Analysis                 HPLC Re-Analysis        RPD


7/26/89                    ND(4J)                       ND (<500)

7/27/89, dupl.           3400,  5600                     5700,  5700              24*

8/01/89, dupl.           2900,  --                      3700,  3300              19*

8/03/89, dupl.           6-100,  5500                     8400,   --                37*

8/24/89                  18000                          37900                   71

8/26/89, dupl.           33000, 35000                   37300,  37500            9.5*

.8/28/89, dupl.           28000, 15000                   33400,  33600            44*

8/29/89                  9700                           35800                   115




* -   RPD value calculated using  the average concentration^ ) of the duplicate pair
                                      4-4
                                      (97)

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  samples,  SW846  Method 3510/8270,  did appear  to achieve somewhat lower absolxite
  recovery  (60-70%) when compared  to  the HPLC  method.

       Well water PCP  concentrations analyzed by GC/MS were similar to BioTrols
  influent  PCP concentrations  analyzed by HPLC when a  correction for  a 65%
  extraction efficiency was performed.

        The QA data from the study indicated  that the developer's results could
  be  used  to  support  the demonstration   data,  and  that the  well water  PCP
  concentrations were more representative of the actual "influent" concentration.

  4.2   EXTENDED PENTACHLOROPHENOL  CALIBRATION STUDY
       Many sample extracts for PCP, particularly the well water and the influent,
  required analyses at multiple dilutions to bring the PCP concentration within the
  calibration range of  the  analysis.   Time constraints resulted in  a  number of
  samples with reported PCP concentrations which exceeded the calibration range;
  the highest concentration standard analyzed was 160 ng/uL which, for a one liter
  sample extracted and concentrated to one milliliter, is equivalent to a sample
 concentration of 160  ug/L.  After reviewing the sample and calibration data, it
.was felt that the actual linear range of PCP analysis extended beyond 160 ng/uL.
 Therefore, three studies were performed to determine the actual linear range of
 PCP.  Standards were analyzed at eight concentrations for the tests:  20, 50, 80,
 120, 160,  200, 250 and 300 ng/uL.   The first two tests used all eight points, the
 third excluded the 20 ng/uL standard.  (The routine laboratory calibration range
 for PCP is 50-160 ng/uL.)  The average response factors  and relative  standard
 deviations were  calculated for all eight  standards (20-300  ng/uL)  and a second
 time  excluding  the  lowest  concentration standard  (since  PCP has  a  method
 detection limit  of 50 ug/L).   The results are summarized below:

                           20-300 ng/uL                 50-300 ng/uL
           Test           RF          %RSD            RF          %RSD
           1 •            0.1183       41.8              0.1316       26.4
           2              0.1168       29.9              0.1257       20.8
           3              NA          NA                0.1310       13.4

 where the  response factor (RF) - area PGP/area internal standard x concentration
 internal  standard/concentration PCP.  The method requirement for linearity  for

                                      4-6
                                     (99)

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a compound designated as a calibration check compound (CCC), which PGP is not,
is an RSD <;30.0%.   If this criteria is applied to the PCP results for the seven-
point  calculations,   then the  %  RSD  all  meet  the  linearity  requirement.
Therefore, it was  determined that pentachlorophenol was  linear within 50-300
ng/uL, and  almost all  sample  data  did  indeed fall within  this range,  and
therefore was determined to be useable for calculating process efficiency.
                                     4-7
                                    (100)

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                             5.0   NON-CONFORHANCES


      Most  analytical QC. results,  including  blank  analyses,  precision  and

accuracy data,  surrogate  recovery results and  QC  check sample results,  were

discussed in  detail  in previous  sections  (2.2  through 2.11) of  this  review.

Therefore,  nonconformances regarding QC analysis .results which did not meet QC

criteria have  already been discussed.  However, a few additional non-conformances
are presented below.


      o   Dioxin/furan extraction was to be performed on a phase-separated solid
          sample of the sludge.   Percent solids were to have been determined in
          this phase-separated sample  to  allow the calculation of dry-weight
          concentrations.   Percent solids were  not  performed and  dipxin/furan
          results for the  sludge  were reported as wet-weight concentrations.
          Corrective Action:   None possible.

      o   Trip blanks  were often  received  (at the field and/or at the lab)  with
          air  bubbles.
          Corrective Action:   Document on Chain-of-Custody.   (This problem was
         not  encountered  with the samples.)
                                     5-1
                                    (101)

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                         6.0  DEVIATIONS FROM THE QAPjP

       In some instances the procedures  and methods  referenced in the  QAPjP for
 use during the BioTrol demonstration project were modified or changed in response
 to physical constraints of the system, field requirements/limitations, laboratory
 needs  and/or EPA concerns.  These deviations are listed below; each includes in
 parentheses  the QAPjP section reference and page number which applies.'

 6.1   FIELD  PROCEDURES
       Samples for biotoxicity testing were to be collected as composites.   Due
 to  the limited  hold  time,  and large volume requirements,  these samples  were
 actually collected  as grab  samples  (5.4, pg.  32).

       Total  organic carbon  (TOG) samples were to be  preserved  with hydrochloric
 acid to a pH of less than 2.  At the laboratory's request, the  preservative  used
 was changed  to sulfuric acid  (5.4, pg.  16)  in  order to accommodate  their  TOG
 analyzer.

       Samples to be analyzed for dissolved parameters (TOG and PCP/PAHs) were to
 be  filtered  in the  field prior to preservation; time constraints in  the field
 required  that samples for  dissolved  PCP/PAHs be filtered  in the laboratory.
 (Dissolved TOG samples were  filtered in  the field, preserved and then shipped to
 the lab.) (5.4,  pg. 28).

       Oil and grease  samples of the bioreactor midpoints could not be  obtained
 by direct immersion of the sample bottle;  the Teflon suction  line of  the auto-
 sampler was  used to collect a sample (no  equipment wash blank was collected)
 (5.4,  pg. 27).

       Samples for total phenolics and volatile organic compounds analysis were
 to be taken as three grabs over 24 hours and composited in the laboratory prior
 to analysis.   Instead, each individual grab sample was analyzed separately for
volatile organics,  and samples for total phenolics were collected as a field
 composite. (A measured volume was collected, preserved, poured  into  a sample
bottle and refrigerated.  During the day, two more volumes  were collected,
                                      6-1
                                     (102)

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 preserved and added to the bottle which was then shipped as  a composite  of the
 three grab aliquots.)  (5.4,  pg.  27).

       The sample numbering system was modified to include two additional  sample
 identifiers.   The  last  digit(s)  of the  sample  number specifies the • discreet
 ssimple location (e.g.,  influent,  sludge).   Field  replicates were assigned a
 sample point number "-14" (e.g.,  STI-A-9-1-14).  An additional sludge sample was
 collected from the  walls of  the bioreactor  (not proposed in  the  QAPjP) and was
 assigned a sample number "-15".  [5.4, page  35]

       Sludge  samples were to be collected at the  bioreactor  filter  location on
 a weekly basis.  The  type  of filter utilized (described as  a  felt sock bag
 fitter) hindered the collection of a true sludge sample.  Volume was limited, and
 the sludge was collected as a composite  by combining samples  obtained each  time
 the filter was  changed.  [5.4, pg.  29]

       Emissions  monitoring was originally planned to take place during  system
 start-up,  and once during each of the three  test periods.  At the  time the QAPjP
 was approved, it was no longer feasible  to sample during the start-up period and
 most  references  in  the QAPjP to this proposed sampling were  omitted.  However,
 Table 5-5, an overall  sampling  summary  for the  project, [5.4,  pg.  8]  still
 (incorrectly) specified a total of four  samples .(plus samples for precision) at
 each  sample point.  Only three were collected (plus  samples for precision), one
 for each'  flow rate  test.

 6.2   SAMPLING SCHEDULE
      Seven more trip blanks (TB)  than originally  proposed were collected.  The
 raw well water was grab sampled once/week for all  parameters  including volatile
 organics  on a  different  day  than  planned, necessitating one additional TB per
week.  An additional TB was also required when the field blank was collected and
 sent  for analysis.

      As a result of the field audit, an equipment wash blank for dissolved TOG
was added  to the sampling plan on a weekly basis,  beginning with week 4.
                                     6-2
                                    (103)

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       As a result of concerns expressed during the EPA audit of  the  procedure
 used by laboratory for biotoxicity  testing,  the  raw well water was  added  for
 biotoxicity testing on a weekly basis  (in  addition to the influent/effluent
 samples proposed).

       An additional sludge  sample was  obtained the  last  week  of sampling by
 collecting scrapings from the side walls of the bioreactor.  This sample, STI-C-
 10-15,  was analyzed for PCP/PAHs.

 6.3    ANALYTICAL METHODS
       Total phenolics were cited in the  QAPjP as analysis method SW846  9065;  the
 laboratory actually used  SW9066 which is an automated application of the same
 procedure.  (5.5, pg. 11).

       During the EPA audit of  the laboratory performing chloride  it was agreed
 to change the procedure referenced for chloride analysis, SW9252,  to the Standard
 Methods  procedure 407C. (5.5,  pg. 10).

      Metals determinations require the analysis of a laboratory control sample
 (LCS), often a known solution provided by EPA with  statistically determined 95%
 confidence  limits.  The lab performing metals used an NBS standard for the LCS,
 and has established an acceptance criteria for the  analysis of ±15% of the true
 value.  (5.7, pg. 4).

      Sludge samples were expected to be a very  wet solid sample.  A wastewater
 type sample was  actually  obtained.   The sample was  treated "as-is"  for total
 phenolics and metals as proposed in the  QAPjP, and  results  were  calculated on a.
 wet-weight basis.  Samples for dioxin and PCP/PAH analysis were separated into
 phases and  the solid phase was extracted.  Total solids were used to calculate
 dry-weight results for PCP/PAH; dioxins were reported as wet weight.  (5.4,  pg.
 29).

      Samples for  semivolatile analysis  (full  scan  or  PCP/PAHs   only)  which
exhibited  low surrogate  recoveries of  d5-phenol  and 2-fluorophenol  were  re-
analyzed to confirm  results.  However, due to  time constraints, this re-analysis
                                     6-3
                                     (104)

-------
was discontinued after it was determined that the re-analysis was confirming the
original results. (5.7, pg.2).
                                    6-4
                                   (105)

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                          7.0  AUDIT FINDINGS/RESULTS

       A series of audits were conducted  in the field and of the  laboratories
 involved with this BioTrol SITE demonstration project.  The findings and results
 of the audits and corrective actions  taken in response to any concerns noted
 during the audits  are  summarized below.

 7.1   FIELD AUDIT, WATER SAMPLING
       An audit  of  the  water sampling operations  was conducted by  an EPA
 contractor on July 26-27, 1989.  The audit rating was satisfactory.  A few issues
 were  identified and prompt corrective action was taken to resolve these  issues.

       Prior to the audit, it had been noted during the first few days of sampling
 that the dissolved oxygen meter was not functioning properlyl'and steps were taken
 to  obtain  an additional D.O.  meter.   Dissolved oxygen was a system condition
 measurement, not a critical measurement.  One day's worth of measurements were
 lost  (and the two prior day's measurements were suspect). While waiting, for the
 new meter to arrive on site, dissolved oxygen measurements were taken using the
 Winkler titration method. After  receiving a new D.O.  meter, problems were still
 encountered-with calibration, and  the  decision was made .to .continue using the
 Winkler method for dissolved oxygen determinations.

      A  second  item  of concern noted  by  the auditor was the manner in which
 samples  were labelled for shipment.   A question arose as to whether  or not
 samples which were preserved with acid to pH <2 required shipment as corrosive
 material.  After shipments made according to DOT regulations were unsuccessful
 and, after evaluating the regulations,  the following procedure was implemented.
 The samples were not  considered corrosive and were shipped via regular overnight
 carrier.    All  samples  were  preserved  to  a  pH <2 without  over-acidifying
 (generally only a few drops of acid per several hundred milliliters of sample).
Bottles  were sorbent wrapped,  bubble  wrapped,  packed  with  ice,  placed  in  a
plastic bag and shipped in a cooler.

      A third issue  noted on  the audit corrective action form  involved field
filtration of samples for dissolved TOG.  The field  filtration kit erroneously
                                     7-1
                                     (106)

-------
 included an organic-based filter paper and consequently inorganic-based filter
 paper was promptly obtained and substituted.

 7.2   FIELD AUDIT,  EMISSIONS SAMPLING
       An audit of the emissions monitoring MM5 sampling protocols was conducted
 by an EPA contractor on August 2-3, 1989.  The audit  rating was satisfactory.
 One issue  was raised concerning  the representativeness of  the  MM5 samples.
 Previously, a memorandum  from Guy Simes dated July 20,  1989  raised  the issue of
 isokinetic sampling.  As  a result,  the sampling team obtained a 4" PVC  pipe to
 attach to  the BioTrol  reactor  exhaust for MM5  sampling.   This  was  done to
 increase duct size  as required by the method.   In  order to measure  the velocity
 of both  the reactor exhaust and carbon filter  exhaust,  an exhaust  fan attached
 to the reactor lid needed  to be turned on.  Once this decision was made, an issue
 of representativeness was raised.   Without  the fan running  it was  evident that
 no vacuum was pulled on the reactor bed, nor were there leaks in the system.  It
 was also obvious that since the fan increased the flow in the  reactor outlet, the
 extra air flowing through the system resulted from system leaks.  Leaks into the
 exhaust flow would produce a non-representative sample.  Without the exhaust fan
 operating,  sample  flow in the  exhaust outlet would  be almost  impossible to
 measure and the exhaust for the  carbon bed filter  had no measurable flow.  This
 presented a problem for obtaining isokinetic samples in the  reactor exhaust and
 for obtaining a sample at  all in the carbon filter exhaust. All parties involved
 were  in  agreement  that isokineticity  was non-critical because there were no
 particles in the reactor exhaust.  Not being able to obtain a measurement of the
 carbon bed  filter emission,  however,  would have presented a problem  if  it was
 decided to turn off the  exhaust  fan.  It was determined that representativeness
 of the sample was not a problem providing no significant PGP or PAH concentration
 existed in  the dilution air.  In order to do  a mass balance of the system all
 that was needed was a total PGP/PAH concentration regardless of whether  or not
 it was diluted.  After close examination of the calculations used to  determine
PGP/PAH concentration in air emissions, all involved parties were satisfied with
the decision to keep the exhaust fan operating. It was therefore  decided that
sampling should take place only while the exhaust fan was operating.  Additional
concerns about pulling a  vacuum on the reactor or if  operating the  fan upset
reactor operations  proved to be  negligible.
                                     7-2
                                     (107)

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 7.3   LABORATORY AUDITS
       Audits of the three laboratories involved with the analysis of the BioTrol
 demonstration samples were conducted by EPA contractors.  Two audit ratings were
 satisfactory and one was rated conditional.

       On August  4,  1989 an audit  was  conducted of  the  laboratory  performing
 PGP/PAH analysis, full scan semivolatile organics, volatile  organics arid metals
 analysis.  The audit  rating was  satisfactory.   During the audit, the volatile
 compositing  procedure  described  in  the  QAPjP  was  changed.    Rather  than
 compositing the three grabs collected over 24 hours into a single sample prior
 to analyses,  each  of the  grabs  was to be  analyzed separately  as a discrete
 sample.

       The August 7,  1989 audit  covered the analyses  of  total  organic carbon,
 dissolved organic carbon, oil and grease,, residue and alkalinity.  A conditional
 rating was assigned.   The major concern noted involved the procedure being used
 for distillation in the oil and grease  method,  a modification of the  reference
 method  SW9070.     The  laboratory  responded  to  the  concern  by   providing
 documentation of the  distillation temperature  and  by  performing  duplicate
.analyses comparing  the modified procedure  and the referenced method.   Based on
 these determinations,  which indicated that data quality was  not compromised by
 the variation,  a change in audit rating was  requested.  To date, a final audit
 report and rating have not been received.

       A  final audit was conducted August 14-15, 1989  covering  the analysis  of
 dioxins/furans,   chloride,   phenolics,  ammonia,   phosphate, nitrate-nitrite,
 biotoxicity,  and the MM5 sampling  trains  for PCP/PAHs.   The audit rating  was
 satisfactory.  Minor  concerns were  noted regarding the biotoxicity method,  and
 the shipment of MM5 samples.
                                     •7-3
                                     (108)

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                   8.0  CONCLUSIONS AND LIMITATIONS:OF DATA


      As noted throughout this Appendix, most of the data generated during the

BioTrol SITE demonstration can be used in its current form with the exceptions

noted below.  Process efficiency was most representative when determined using

well water contaminant concentrations,  as opposed to bipreactor influent sample

concentrations.  The additional study performed on PGP influent concentrations

supports the use of these well water sample  concentrations which were similar to

data obtained by the developer in an independent collection/analysis program.


      Data  which  have limitations  include  the  following;  however,  these

qualifications to  the data did not preclude the ability to adequately evaluate
the treatment technology.

      o   Emissions  samples collected  during  the  3 gpm flow rate  period were
          significantly biased low.  However, sampling during the  1  gpm and 5
          gpm flow rates indicated that losses to  the exhaust air were minimal
          and that  PGP was  not present  in  these emissions,  therefore  mass
          balance  calculations were not affected.

      o   Sludge samples were  not the wet solids expected,  but rather an almost
          aqueous  wastewater type  sample.   Analyses  performed on  the samples
          were either reported on an as-is,  wet weight basis (which could easily
          be converted to  dry weight) or on a phase-separated sample.   Samples
          were phase-separated for  PGP/PAH  by centrifugation  and  reported on a
          dry-weight  basis,  and by  decanting  for dioxins/furans.    Without
          percent  moisture on  the solids obtained after decanting, overall mass
          balances can only be estimated for dioxins.
                                     8-1

                                     (109)

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