United States
                      Environmental Protection
                      Agency   	
 Hazardous Waste Engineering
 Research Laboratory
 Cincinnati OH 45268
                      Research and Development
 EPA/540/S2-86/002  Mar. 1987
&EPA           Project  Summary
                      Systems  to  Accelerate  In  Situ
                      Stabilization   of  Waste   Deposits
                       In situ systems to accelerate the stabili-
                      zation of waste deposits have  been pre-
                      sented as alternatives to  containment,
                      isolation  or excavation as methods for
                      remediation of uncontrolled waste sites.
                      In situ applications involve three essential
                      elements: selection of a chemical or bio-
                      logical agent (reactant) which  can react
                      with and stabilize the waste, a method for
                      delivery of the reactant to the deposit and
                      a method for  recovery of the reaction
                      products or mobilized waste. The most
                      promising applications for in situ treatment
                      methods  are for spill or plume types of
                      contamination, where the  contaminants
                      are relatively evenly distributed and pref-
                      erably in liquid form. Delivery of reactants
                      to solid, heterogeneous, low permeability
                      deposits  will  be  more difficult.  In situ
                      methods  may find particular application
                      when used in combination with other
                      remedial measures, for example, removal
                      of the source material and in situ treatment
                      of the plume.
                       Four reactant  categories have been
                      examined:  biodegradation, surfactant-
                      assistant flushing, hydrolysis, and oxida-
                      tion.  Of  these,  biodegradation  and
                      surfactant-assisted flushing appear most
                      promising as in situ treatment techniques.
                      For any treatment technique, the potential
                      toxicity of the applied reactant and any in-
                      termediate  compounds or by-products
                      must be carefully evaluated. Furthermore,
                      the potential for undesirable reactions with
                      other contaminants present  must be stud-
                      ied  (e.g., oxidation of phenol with hydro-
                      gen peroxide may also oxidize chromium
                      (III) to  the  more  toxic  hexavalent
                      chromium).
                       Methods of delivery of reactants based
                      upon  gravity  include  surface  flooding,
                      ponding, surface spraying,  ditching, and
                      subsurface infiltration beds and galleries.
                      Forced injection (pumping) may also be
                      used.  Permeability is an important  con-
                      sideration in selecting the delivery system.
                      Gravity delivery methods require a per-
meability of the soil/waste medium in the
range 10~1 cm/sec to 10~3 cm/sec (280
to 2.8 ft/day).  Forced injection is most
effective at a permeability in the range of
10~1 cm/sec to 10"" cm/sec  (280 to
0.28  ft/day); below this permeability
limit a potential application of forced
injection for reagent  delivery  coupled
with electro-osmosis for recovery may
exist.  Additionally, gravity systems
should be  considered  only  when  the
waste  deposit  lies in the unsaturated
zone and when the depth to the bottom
of the deposit is less than 5 meters  (16
feet). Otherwise, forced injection should
be considered.
  Recovery systems using gravity include
open  ditching  and buried drains,  and
pumped methods include wellpoint  and
deep well systems. Basically, the same
limitations that apply to delivery systems
are also true for recovery systems. Gravity-
induced recovery works best when  the
water table is wrtnin 5 meters (16 ft) of the
surface. For depths in the range of  0-8
meters (0-26 ft),  well  points can also
be considered.  Depths greater than  the
suction limit (about 8 meters or 26 ft in
practice) will require the use of down-hole
pumps for recovery.
  This Project Summary was developed
by EPA's Hazardous Waste Engineering
Research Laboratory, Cincinnati, OH, to
announce key findings of the research pro-
ject that is fully documented in a separate
report of the same title (see Project Report
ordering information at back).

Introduction
  This project represents Phase I of a two
phase scope of work to document  the
feasibility of engineered approaches to
treating subsurface  waste  deposits
through the application of in situ methods.
Phase I concentrated on applications of
available technology and  examined  the
limitations imposed on their use by site

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and  waste  specific  characteristics.  A
future  phase of the project, Phase II, is
expected to undertake  bench scale or pilot
studies to expand the  data base available
to potential  users of in situ methods.

Procedure
  The  six part program of investigation
consisted of a literature review, a defini-
tion of the capabilities and limitations of
delivery, recovery and treatment technolo-
gies, visits to sites where remedial activi-
ties were underway, a  definition of impor-
tant site and waste characteristics, and an
evaluation of remedial technologies. The
available data were evaluated to determine
classes of organic chemicals amenable to
treatment by various potential in situ treat-
ment  methods. Potential  delivery and
recovery systems for these  treatment
agents were then evaluated with respect
to site  hydrogeologic characteristics. The
guidance  manual which  was  developed
identifies combinations  of  delivery/
recovery technologies and  reagents that
have a reasonably  high or clearly low
probability of success for in situ treatment
of hazardous waste.

Results and  Discussion
  Systems to accelerate stabilization of
waste deposits will require (1) selection of
delivery/recovery methods  for the  treat-
ment technology compatible  with site
characteristics and the waste deposit set-
ting, and (2) selection of a suitable treat-
ment technology that will be compatible
with waste  composition and  site char-
acteristics.

Delivery/Recovery Systems
  The  selection of the most appropriate
delivery/recovery methods and systems
requires a thorough understanding of the
waste deposit site characteristics. The site
must be  defined  with respect to  the
configuration of the waste  deposit (areal
extent  and  vertical   depth),  hydrologic
characteristics (surface and subsurface) of
the waste deposit, and surface and sub-
surface geohydrologic characteristics of
the  materials  surrounding the  waste
deposit.

Delivery Methods
  The  matrix for selection of  delivery
methods is presented  in Table 1. The table
shows  the  forced  delivery  method is
applicable for all conditions. The choice of
a gravity delivery method is more depend-
ent on the listed parameters.  The listed
parameters  indicate  differences in  site
characteristics that would warrant selec-
tion  of one  delivery method(s) over the
                                    2
others. These  parameters were selected
for the following reasons:
• Average Permeability  of the  Waste
  Deposit.
  Permeability will dictate the flow char-
  acteristics of  the deposit. If the per-
  meability of the deposit is high, then
  low net pressure and short time dura-
  tions would be required for a solution
  to pass through the deposit.  Low per-
  meability means  the  deposit  is not
  easily drainable and  would  require
  higher pressure nnd longer time dura-
  tion for a solution to move through the
  deposit. Gravity methods are  most
  effective for highly  permeable waste
  deposits.
• Depth to the Waste Deposit.
  Engineering judgement is the basis for
  selecting between gravity and forced
  delivery methods at each specific site.
  If the depth is too great, then gravity
  delivery  will lengthen the time for a
  solution to  travel to the deposit,  or
  extensive excavation may be required
  to obtain effective gravity delivery. A
  reasonable maximum depth for gravity
  delivery is judged to be about 5 meters
  (15 feet).
• Waste Deposit Covered by an Imper-
  meable Layer.
  For  the  forced  delivery method this
  parameter has no bearing, although for
  gravity delivery methods it will have a
  significant  impact.  For  example,
  flooding and spray irrigation cannot be
  utilized  as  delivery  methods if the
  surface of the deposit is topped by an
  impermeable layer of soil or synthetic
  material.
• Topography.
  Topographic considerations will limit, in
  part, the extent of applicability of grav-
  ity flow methods.  For  example, on a
  steep slope flooding or ponding delivery
  methods cannot be  utilized. However,
  topograhpy will not affect the forced
  delivery methods(s).
•  Infiltration Rate.
  Gravity delivery at the deposit surface
   is most effective for deposits with high
   infiltration rates. Infiltration rate has no
   bearing  in forced delivery systems.
  In general, gravity delivery methods are
  effective when the waste deposit is
  situated in the unsaturated zone  with
  shallow permeable  overburden,  and
  depth to the deposit is limited to 15 feet
  with permeability greater than  10  3
  cm/sec.
   For waste deposits covered by thick
  overburdens of significant depth (more
  than 5  meters) the  forced  delivery
   method will  be most effective.  For
   waste deposits having a permeab
   lower than  10  4  cm/sec  a forcetl
   method utilizing electro-osmosis could
   be employed for solution injection into
   the  deposit.  In  general, the  forced
   method should be highly effective for
   waste deposits within a permeability
   range of 10 ' cm/sec to  10  4 cm/sec.

Recovery Methods
  Table 2 indicates the applicability  of
various recovery methods for different site
characteristics.  Only  two  parameters,
depth to recovery zone and composite
permeability, are considered in the matrix.
Although other parameters such as  trans-
mission and storage may play an important
role  in designing  woll  or well  point
systems, these two parameters are the
most appropriate guide for the preliminary
selection of recovery methods.  It should
be noted that the recovery of injected solu-
tion will be from the saturated zone (water
table aquifer) and normally the recovery
method(s) will be installed beyond the
boundary of the waste deposit. However,
when a recovery method is installed within
the waste deposit, the composite perme-
ability of the waste deposit should be con-
sidered  in selecting the recovery method.
The parameter, depth to recovery zone, is
chosen  because gravity methods are
practical beyond  a  5 meter depth
vacuum well points are also effective  to
a 5 to 8 meter depth. The permeability will
dictate  the drainage characteristics and
thereby control the selection of recovery
(dewatering) methods.
  In general, gravity  recovery methods are
suitable for a shallow recovery zone (depth
to water table from the surface should not
be more than 5 meters). For a deeper
recovery zone, forced recovery methods
must be employed.
  The two basic treatment concepts eval-
uated are in  situ waste  destruction by
biodegradation,  hydrolysis  or  chemical
oxidation, and surfactant-assisted flushing
to mobilize the contaminants and facilitate
further in situ  treatment or recovery fol-
lowed by above-ground treatment. Poten-
tial applications of  these  methods  to
various  classes of organic contaminants
are presented  in Table 3.

Biological Renovation  of  Waste
Deposits
  Aerobic and anaerobic bacteria,  fungi,
actinomycetes, algae and  cyanophytes
(blue-green algae) have all been shown
capable of degrading many classes  of
organic chemicals. These microbes include
natural  microbial populations, ada
microbial cultures and potentially  bi

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\ible J.
Delivery
Methods
Matrix for Delivery Methods
Location of the deposit Thickness of
in relation to existing Contamination overlying
groundwater table starts at impermeable
layer
Unsatu-
rated
GRAVITY
1. Flooding
2. Ponding
3. Surface
Spraying
4. Ditches
5. Infiltration
Galleries
6. Infiltration
Bed
FORCED
1. Injection
Pipes

X
X
X

X
X

X


X

Partially
Saturated

if
if
NA

if
if

if


X

Sur- Sub-
Saturated face surface 0

NA
NA
NA

NA
NA

NA


X


X
X
X

NA
NA

NA


X"'


X
X
X

X
X

X


X


X
X
X

X
X

X


X

<1.5m
OS ft!

NA
X
NA

X
X

X


X

>1.5m
OS ftl

NA
NA
NA

NA
X

X


X

Topography
{Slope/
flat

X
X
X

X
X

X


X

0-3%

X
X
X

X
X

X


X

Infiltration
Rate
cm/hr
(inches/hrl
Hydraulic Conductivity
cm/sec Ift/dayi
.1-.2 .06-. 7 <06 10~' -10~3
>3% I.3-S>I.15-.3I<0.15 1280-2.81

NA
NA
if

X
X

NA


X


X
X
X

X
X

X


X


X
X
X

X
X

X


X


NA
if
NA

X
X

X


X


if
X
if

X
X

X


X

12.8-0.28)

NA
if
NA

if
if

if


X

Depth to Bottom
of the
Waste Deposit
Meters /ft)
10.28-0.0003) K16I

NA
NA
NA

NA
NA

NA


X<2>


X
X
X

X
X

X


X

5-12
116-40)

if
if
if

if
X

X


X

O40I

NA
NA
NA

NA
NA

NA


X

  X = Applicable
 LE = Less Effective
 NA = Not Applicable
 (J) = May need combined gravity and forced del/very.
 (2) = Applicable with electro-osmosis.
Table 2. Matrix for Recovery Methods
Recovery
Methods Depth To Groundwater


0-5 m
(0-16 ft)
h.
CAVITY:
Open Ditches X
and Trenches
Porous Drains X
FORCED:
Wellpoint X
Deep Well NA
Vacuum Well X
Point
Electro- X
osmosis
X = Applicable
LE = iess Effective
NA - Not Applicable


5 -12m
(16-40 ft)

NA

NA

X
X
X

X






>12 m
O40 ft)

NA

NA

NA
X
NA

X




Hydraulic Conductivity
>10'1 -10~3
cm/sec
O280-2.8
ft/day)

X

X

X
X
NA

NA




10-3-10~4
cm/sec
(2.8-0.28
ft/day)

LE

LE

LE
LE
X

NA




10-4-10~7
cm/sec
(0.28-0.003
ft/day)

NA

NA

NA
NA
LE

X




 gineered microbial strains. Once the extent
 of  the  contamination and  its  chemical
 characterization have been determined,
 the proper microorganisms (or groups of
 microbes)  may  be identified and deve-
 loped. The identification of the proper
 agents for waste site renovation is based
 upon past experience, laboratory screen^
 ing, and onsite pilot-scale tests.
  To date,  aerobic  bacteria such as pseu-
 domonas have been most commonly used
 for in situ biodegradation of contaminants.
 These organisms  can potentially com-
 pletely convert the organic compounds to
 C02 and water,  and do not  produce  H2S
-at methane as reaction products. However,
    lerobic  bacteria are important for the
biodegradation of pesticides and halogen-
ated organics. Organic contaminants that
have been successfully treated by biode-
gradation include phenols, gasoline and
other petroleum products, methylene chlo-
ride, alcohols and acetone.
  In the process of designing the microbial
waste treatment system, one must deter-
mine the oxygen, emulsifier (if the wastes
are insoluble) and fertilizer requirements
for optimum waste treatment rates. Micro-
bial agents require  the maintenance  of
sufficient concentrations  of  nitrogen,
phosphorus and trace elements, and a pH
range that will support their growth. The
levels of these factors at the  site  should
be determined during the site investiga-
tion; the need for additional fertilizers or
buffers required  to  support microbial
growth can then be identified.
  Biological  renovation  of  subsurface
waste deposits poses problems relating to
oxygen supply, temperature, permeability
and  accessibility  not encountered  with
surface disposal sites. Injection wells may
be established into and below the waste
site  to deliver a fertilizer  and  oxygen
supply. Oxygen  sources would  include
injectable solutions of peroxides, oxygen-
charged water produced by ozonation, or
direct  sparging of  air into the  ground
water.  Recovery wells or trenches should
be situated  at points peripheral to  or
downgradient of the waste deposit. Flow
patterns established  between injection
and recovery wells should be planned to
aid  in  confining the  waste during the
renovation  process. In this way ground
water plumes that may be migrating from
the site can be renovated as well.

Application of Hydrolysis to Waste
Deposit Stabilization
  Hydrolysis is a chemical reaction involv-
ing the cleavage of a molecular bond by
reaction with water. The rates of hydroly-
sis for some compounds can be  acceler-
ated by altering the solution pH, tempera-
ture, solvent composition, or by introduc-
ing  catalysts. For  in  situ treatment,
alternation of pH, particularly raising the
pH (base-catalyzed hydrolysis), is the most
promising approach. The range of chem-
ical  classes potentially treated by  base-
catalyzed  hydrolysis includes amides,
esters,  carbamates,  organo-phosphorus

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Table 3.
          Potential Applications of Treatment Methods to Waste Contaminants
         Chemical                  Bio-
            Class
                                degradation
Hydrolysis
                                                            1'1
Oxidation121
  Water
Flushing131
Surfactant
Flushing131
Aliphatic Hydrocarbons
Alky I Ha /ides
Ethers
Halogenated Ethers
    and Epoxides
Alcohols
Glycols/Epox/des
Aldehydes, Ketones
Carboxylic Acids
Amides
Esters
Nitriles
Amines
Azo Compounds,
    Hydrazine Derivatives
Nitrosamines
Thiols
Sulfides, Disulfides
Sulfonic Acids, Sulfoxides
Benzene & Substituted Benzene
Halogenated Aromatic
    Compounds
Aromatic  Nitro Compounds
Phenols
Halogenated Phenolic
    Compounds
Nitrophenolic Compounds
Fused Polycyclic Hydrocarbons
Fused Non-Aromatic Polycyclics
Heterocyclic Nitrogen
    Compounds
Heterocyclic Oxygen
    Compounds
Heterocyclic Sulfur
    Compounds
Organophosphorus Compounds
Carbamates
Pesticides
111
121
131
   Based upon calculated half-lives for base catalyzed at pH 9 to 11.
   Based on oxidation of chemicals in water and wastewater by H202-
   Based upon aqueous solubility and octanol/water partition coefficient IKOW).
+  = can be used                    ?   = futher research needed
-  = cannot be used                 -? = probably cannot be used
+ ?  = probably can be used
 compounds, pesticides  and  herbicides.
 Base-catalyzed hydrolysis has been suc-
 cessfully used for treatment of surface
 spills of acrylonitrile and pesticides.
   The primary design concern for imple-
 mentation  of base-catalyzed  hydrolysis
 within a waste deposit will be the produc-
 tion and maintenance of high pH (9 to 11)
 conditions  with saturation or high mois-
 ture content  in the  waste  deposit. For
 shallow subsurface or surface  deposits,
 surface application of lime,  sodium  car-
 bonate or sodium hydroxide followed by
 surface application  of   water  may  be
 appropriate. For deeper deposits, subsur-
 face delivery or injection  of alkaline solu-
 tions may be required.
                                          Potential for In Situ Oxidation of
                                          Waste Deposits
                                            The potential application of three oxi-
                                          dants  (ozone,  hydrogen  peroxide,  and
                                          hypochlorites)  to  waste  deposits  was
                                          evaluated. Although in widespread use in
                                          surface  water treatment  applications,
                                          significant  problems may preclude their
                                          effective implementation as in situ treat-
                                          ment agents for waste deposits.
                                            Hypochlorite reacts  with organic com-
                                          pounds as  both a chlorinating agent and
                                          an oxidizing agent. Documentation on the
                                          effectiveness of hypochlorite as an oxidiz-
                                          ing agent for organic materials is extreme-
                                          ly limited. Hypochlorite additions may lead
                                          to production of undesirable chlorinated
                                  by-products (e.g., chloroform) rather than
                                  oxidative degradation products. Therefore
                                  the use of  hypochlorite for in situ treat-
                                  ment  of organic  wastes  is not  recom-
                                  mended.
                                    While ozone is an  effective oxidizing
                                  agent for many organic  compounds  in
                                  wastewater treatment applications, its rel-
                                  atively rapid decomposition rates in aque-
                                  ous systems, particularly in the presence
                                  of certain chemical contaminants or other
                                  agents which catalyze its decomposition
                                  to oxygen,  preclude its effective applica-
                                  tion to  subsurface  waste deposits.  The
                                  half-life of  ozone in ground water is less
                                  than one-half hour. Considering that fir""
                                  rates of water through waste deposits I

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1 likely to be on the order of inches/hour or
 less, it is unlikely that effective oxidant
 doses of ozone can be delivered outside of
 the immediate vicinity of the point of appli-
 cation. Successful use of ozone for in situ
 chemical oxidation is unlikely. However,
 ozonation has been used successfully to
 supply oxygen for microbial biodegrada-
 tion, and to  chemically oxidize complex
 organics  in a surface reactor to simpler
 compounds that are more readily biode-
 gradable. This use of ozone as a supple-
 mentary  treatment  for  biodegradation
 seems promising.
   Hydrogen peroxide is a weaker ozidizing
 agent than ozone; however, its stability in
 water is considerably greater. Since de-
 composition of hydrogen peroxide to ox-
 ygen may be catalyzed by iron or certain
 other  metals, effective delivery of hydro-
 gen peroxide throughout an entire waste
 deposit may  be difficult or impossible
 because  of the relatively low transport
 velocities achievable in waste deposits.
 Prior to consideration of hydrogen perox-
 ide as an in situ treatment method, it will
 be necessary to investigate the stability (or
 rate of decomposition) of hydrogen perox-
 ide in the specific waste deposit matrix.
 Hydrogen peroxide may also be used as an
 oxygen source for microbial biodegrad-
 ation.
Surfactant-Assisted  Flushing  or
Sofubilization of Wastes
  Flushing or mobilization of wastes can
serve two purposes: to promote the recov-
ery of wastes  from the  subsurface  for
treatment on the surface, or to solubilize
adsorbed compounds in order to enhance
the rate  of other in situ treatment tech-
niques (such as biodegradation or hydro-
lysis). Flushing or mobilization using water
alone may be sufficient for relatively solu-
ble compounds such as phenols; however,
the use of surfactants will be required for
significant solubilization of insoluble (hy-
drophobic) compounds.
  Surfactants (surface active agents) are
a class of natural and synthetic chemicals
which promote the wetting, solubilization,
and emulsification of various types of or-
ganic chemicals.  A simple approach  to
evaluating the potential use of surfactants
in organic waste recovery involves consid-
eration  of  the aqueous solubility  or
octanol-water  partition coefficient,  K0w
Surfactants would be most effective  in
promoting the mobilization  of  organic
compounds of  relatively low water solu-
bility and high Kow  values.
   Laboratory tests suggest that surfac-
 tants may enhance the recovery of sub-
 surface gasoline leaks by groundwater
 pumping,  and promote the mobilization of
 crude oil  and PCBs from soils. However,
 certain environmental factors may reduce
 the in  situ effectiveness of surfactants.
 These include precipitation of the surfac-
 tant by groundwater with high  TDS  or
 alkaline earth cation concentrations (Ca,
 Mg); reduction of surfactant effectiveness
 due to nonoptimal pH or temperature;  or
 adsorption of the surfactant by soil par-
 ticles, negating its solubilizing properties.
 Nevertheless, the use of surfactants either
 alone (to flush otherwise insoluble organ-
 ics) or in  combination with other treat-
 ments  (to solubilize the waste materials
 and thereby promote biodegradation) is a
 promising avenue for further research.

 Selection and Evaluation of Sys-
 tems  for Treatment  of Specific
 Waste Problems
   Before  final  selection  of delivery/
 recovery  and treatment  methods, the
 following  steps  must be undertaken for
 each site:

Initial Site Evaluation -
  In this phase the following information
is obtained for each site:
 •  Extent and nature of the waste deposit;
 •  Site soil characteristics such as  por-
   osity and permeability, and uniformity;
 •  Surface drainage characteristics of the
   site;
 •  Groundwater table location and ground-
   water flow direction and velocity;
•  Field permeability testing of the waste
   deposit and host materials;
•  Surface infiltration rate;
•  Soil, waste deposit and groundwater
   samples  collection  and  laboratory
   analyses.

Identification  of Feasible Methods
  Based on the  field investigations  and
laboratory testing, feasible treatment and
delivery/recovery methods commensurate
with the  treatment requirements,  are
identified  using the matrices in Tables 1
through 3. These feasible methods are
carefully evaluated based on engineering
judgement to narrow down the choices for
the field demonstration program.

Bench Scale  Tests
  Bench scale tests may be necessary to
demonstrate the effectiveness of a given
treatment  method for a specific combina-
tion of chemical contaminants and waste
deposit matrix.
Field  Demonstration Program
  A field demonstration program for the
selected feasible methods is undertaken
to  evaluate  the  effectiveness  of the
methods and to generate design informa-
tion, such as ditch spacing and well spac-
ing required for proper delivery and re-
covery of the treatment agent.

Design and Economic Evaluation
of  the Effective  Methods
  Based on the field demonstration pro-
gram, alternate delivery/recovery systems
are developed and a cost evaluation is per-
formed. Based on cost and effectiveness
analysis,  final  selection of a  delivery/
recovery system was  made  for subse-
quent implementation.


Conclusions and
Recommendations
  To accelerate stabilization of waste piles
or deposits using a combination of chem-
ical or biological reagents and  delivery/
recovery  systems  involving  gravity or
forced methods of injection, a great deal
more information based upon specific field
experimentation must be assembled.
  Each in situ application will resemble a
research effort which must be customized
to the site and waste characteristics. The
essence of a successful application of an
in situ method  is the performance of a
treatability study designed to account for
the peculiarities of the waste and treat-
ment reagent combination as well as the
unique geohydrological characteristics of
the site. Since treatability studies cannot
exist for the generalized case, almost all
conclusions to  be drawn from the liter-
ature survey were necessarily based upon
engineering judgement. Verification of
hypotheses by reference to documented
field experience was not feasible in most
situations.
  A major constraint on the feasibility of
in situ treatment is the degree of homo-
geneity of the waste deposit. Subsurface
deposits contained in drums or within non-
uniform formations which impede the flow
of waterborne reagents cannot be con-
sidered  as realistic candidates for in situ
treatment. The experience that  exists
strongly suggests that the greatest in situ
success will be with a  plume or a spill
situation rather than with a source deposit
itself.
  The full report was submitted  in fulfill-
ment of Contract No. 68-03-3113, Task
37-2 by JRB Associates under the spon-
sorship  of the U.S. Environmental Protec-
tion Agency.

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