Surfactant Injection for Ground
Water Remediation:
State Regulators' Perspectives
and Experiences
U.S. Environmental Protection Agency
Technology Innovation Office (5102W)
EPA 542-R-95-011
December 1995
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Preface
This report is based on a series of interviews with State regulators involved in the review and
approval of applications for demonstrations or applications of surfactant technologies for the
remediation of contaminated ground water. Treatment of aquifers contaminated by non-aqueous
phase liquids (NAPLs) by traditional pump-and-treat systems has proven impracticable in many
instances. State regulators, researchers, and engineers are working on innovative solutions to this
problem. This report focuses on identifying specific technical issues, non-technical problems,
training, and technical or policy needs that would contribute to improving the use of in situ
surfactant enhancements. The goal of the study was to identify barriers and describe successes in
gaining State regulatory approval, in order to promote understanding among the various
stakeholders vital to developing this important technology.
The Technology Innovation Office gratefully acknowledges the assistance of the following
individuals who gave their time and consideration to this project: Gary Beyer, Texas Natural
Resources Conservation Commission; Duane Mortensen, Utah Department of Environmental
Quality; George Nicholas and Greg Zalaskus, New Jersey Department of Environmental
Protection; Jim Shaw, Pennsylvania Department of Environmental Protection; Randall Thomas,
Kentucky Department for Environmental Protection, Federal Facility Oversight Unit; Susan
Timm, Central Valley Regional Water Quality Control Board, California Environmental
Protection Agency; Mark Walker, Colorado Department of Health and Environment; and
Jonathan Williams, U.S. EPA, Region 10. Dr. Candida West of the Subsurface Protection and
Remediation Division of the National Risk Management Research Laboratory was essential to
the project, as well as the various investigators and researchers in the area of surfactant
technologies who dedicate their considerable resources to the search for innovative solutions to
the nation's hazardous waste remediation problems.
Walter W. Kovalick, Jr., Ph.D.
Director
U.S. EPA Technology Innovation Office
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The information in this document has been funded by the United States Environmental
Protection Agency under contract number 68-W2-0004 to Environmental Management Support,
Incorporated. It has been reviewed by the Agency and has been approved as an EPA document.
The opinions expressed herein are those of the authors and do not necessarily represent those of
the U.S. Environmental Protection Agency. Any mistakes are attributable to the authors and not
those interviewed. Mention of trade names does not constitute endorsement nor recommendation
for use.
Comments or questions regarding this report should be directed to:
Rich Steimle
Technology Innovation Office (5102W)
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
703-308-8800
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Surfactant Injection for Ground Water Remediation:
State Regulators' Perspectives and Experiences
This is a report on a series of interviews
conducted with eight State regulatory
representatives regarding the use of
surfactants for in situ ground water
remediation. The interviews were a follow-up
to a analysis conducted last year by the
Environmental Protection Agency's
Technology Innovation Office (TIO). In the
previous study, TIO identified State
regulations and policies concerning the
injection of surfactants, co-solvents, or
nutrients into contaminated ground water for
remediation. The present study examined
procedures used in States that have reviewed
proposals for surfactant demonstrations to
identify specific technical issues, non-
technical problems, training, and technical or
policy needs that would contribute to
improving the use of in situ surfactant
enhancements. The goals of the study are to
identify barriers and describe successes in
gaining State regulatory approval, and make
recommendations to future applicants that
may improve their chances for approval. TIO
sponsored a meeting of several principals
involved in ongoing surfactant demonstra-
tions on September 20, 1995, in Kansas City,
Missouri.1 Participants in the meeting
addressed issues of regulatory barriers and
other problems. This information is included
in this report where appropriate.
Surfactant Demonstration Report and
State Regulation Study
In April of 1995, TIO conducted an in-
vestigation to identify research, demonstra-
tions, and field applications of in situ
surfactant enhancement technologies to
remove contaminants from soils and ground
water at hazardous waste sites.2 Information
was collected from computerized databases,
such as Dialog Information Services, EPA
technology databases (VISITT, ATTIC),
Technology Needs
Traditional pump-and-treat systems
have proven impracticable in many
instances for treating non-aqueous
phase liquids (NAPLs) in aquifers.
NAPLs have very low solubility in
water, leading to very slow rates of
removal by pumping. NAPLs tend
to exist in pockets at the subsurface
location to which they have
migrated. New technologies are
being developed to improve
removal efficiency through
mobilization or solubilization of
these pockets.
Superfund Innovative Technology Evaluation
Profiles, and the Department of Energy's
Office of Technology Development Program
Reports. This information was supplemented
with telephone interviews with selected
representatives of federal agencies, academic
research centers, and hazardous waste
remediation consulting firms to identify
ongoing or planned demonstrations and
commercial applications of surfactant
technologies. A separate investigation of
applicable State regulations identified a
number of additional sites where surfactant
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use has been reviewed, approved, or
implemented.3
Method
State ground water contacts in each of the
States where surfactant demonstrations or
applications had been identified were sent a
letter inviting them to participate in the study.
A questionnaire directed toward gathering
information on the process used to review
surfactant applications was included (see
appendix). The letter explained the purpose of
the study and asked for their participation in a
half-hour interview. The questionnaire
included questions regarding the site, the
length of application review, the most
important technical information contained in
the proposal, technical deficiencies (if any),
non-technical problems that caused delays,
suggestions for improving the review and
approval process, and the potential benefit of
training or guidance on surfactant chemistry
and processes. Following the letter, each state
contact was called and a telephone interview
scheduled at their convenience. Interviews
were completed with State representatives in
Alaska, California, Colorado, Kentucky, New
Jersey, Pennsylvania, Texas, and Utah.
Interview Summaries
Each of the eight interviews conducted by
EPA are summarized below. In some cases,
specific information about the site where
surfactant use has been approved or is under
consideration is included, as well, to provide
a context for understanding the State
regulator's perspective. In addition, each of the
items in the questionnaire is addressed to the
extent possible for each State respondent.
Alaska
Jonathan Williams of EPA Region 10
provided information regarding the use of a
surfactant as a sequestering agent for iron-
fouling problems with a ground-water
remediation system at an oil refinery in Kenai,
Alaska. The Region was asked for their
approval after the Alaska Division of
Environmental Conservation had already
reached a decision to approve the project. The
process was fairly informal, and was not very
lengthy. The State reviewed the work plan and
surfactant chemistry. They were convinced
that the system was well contained and that
the surfactant being used was harmless. The
State informed the company that an
Underground Injection Control (UIC) program
review and approval also would be needed.
The Regional UIC staff did not see the need to
issue a permit in this situation.The surfactant
was being used only in the area of the
pumping wells to increase the effectiveness of
recovery of spilled petroleum.
Mr. Williams was unsure of the efficacy of the
surfactant in solving the problem. He also felt
that technical guidance would be valuable.
Guidance should describe the different
sequestering agents available, their strengths
and weaknesses, and what could happen if
they could not be recovered.
California
In California, ground-water remediation is
regulated by a number of Regional Water
Quality Control Boards and the Department of
Toxic Substances Control, part of the
California Environmental Protection Agency.
The contact we interviewed in the Central
Valley Regional Water Quality Control Board
has been involved in planning for an in situ
surfactant remediation at the Department of
Energy's Lawrence Livermore National
Laboratory. The proposed project will be
conducted at the Livermore Site 300
Superfund site, about 50 miles east of San
Francisco.
The site is characterized by channel deposits
underlain by thick sandstone and claystone
deposits. There are four primary
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hydrogeologic units: a shallow isolated,
perched water bearing zone; an unsaturated
perching horizon; a claystone aquitard; and a
deep uncontaminated regional aquifer. The
site is contaminated with high levels of
volatile organic compounds (VOCs),
specifically trichlorethene (TCE). TCE, mixed
with a silicone-based lubricant (TBO), was
used as a heat exchange media in military
production. The plume is relatively
concentrated near the source area. Researchers
believe that the perched zone represents a
good opportunity to test innovative
technologies.
The proposed surfactant injection will be used
to initially solubilize the contaminants,
followed by phase focusing on mobilization.
The project should provide proof of the
concept, as well as the opportunity to
demonstrate a separation technology.
Preliminary partition tracer tests were
conducted in November 1995; the appropriate
surfactant will be selected in January 1996,
and the surfactant test is planned for March
1996. Participants include the Department of
Energy, Lawrence Livermore National
Laboratory, California's Department of Toxic
Substances Control, the Central Valley
Regional Water Quality Control Board, U.S.
EPA Region 9's Hazardous Waste
Management Division, the EPA Subsurface
Protection and Remediation Division of the
National Risk Management Research
Laboratory (formerly R.S. Kerr
Environmental Research Laboratory), and
researchers from the University of Oklahoma.
In our interview with Susan Timm of the
Central Valley Regional Water Quality
Control Board, we learned that LLNL had not
made a formal application to the State, but had
contacted RPMs involved at the site more than
six months ago to begin discussions of the
project. The State has been pleased with the
level of interaction and is quite interested in
the possibility of using a perched area for a
demonstration of surfactant technology.
According to the State of California, the most
important technical information they need
from the other parties includes certainty of
hydrogeologic control (both surfactant and
tracers), and the understanding the interaction
of the surfactant with the contaminant and the
media. The State also must be convinced that
the monitoring system is adequate to answer
these questions.
In California, surfactant proposals would be
reviewed using procedures established for
other types of remedies, which are based on
modeling, empirical data, and technical
knowledge. The Department of Toxic
Substances Control also has regulations for
underground injection of hazardous waste that
may result in a need for a permit (This has not
been at issue for the present project, as it is a
Superfund site). Also, for the LLNL project, a
public meeting was held as part of the
CERCLA process, but citizen concerns
focused on the overall cleanup rather than on
the small section where surfactants are
proposed.
State regulators in California are aware of the
potential benefits of surfactants, but concerned
about hydrologic control and possible
reactions with other contaminants. Although
this project has not yet been conducted, she
said that the State would probably require
further action (probably pump-and-treat) if no
results are gained from the surfactant project.
Ms. Timm thought that both training and
guidance from EPA would be of benefit. A
number of people in the State office who
haven't been involved in following surfactant
research would be very interested to learn
more. She recommended that training also
focus on the private sector. This is especially
important because private parties are the
source of technology decisions, state
regulators do not generally propose specific
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solutions due to liability concerns, but do give
final approval.
Colorado
The Colorado Department of Health and
Environment has reviewed one proposal for a
surfactant remedy at a petroleum facility in
Loveland, Colorado. This was a corrective
action for a leaking underground storage tank
site, and the remedy was rejected. However,
Mark Walker, whom we talked to, explained
that in Colorado, the facility can be
reimbursed for any technology that is
demonstrated as technically and economically
feasible. In this case, the State not only had to
approve the project, but literally to pay for it.
The proposal review process took from four to
six months, and consisted of review of the site
assessment documents and corrective action
plan to remediate a gasoline leak from the
leaking underground storage tank. The State's
concerns in this case focused on the chemical
makeup of the surfactant, which was a
proprietary product. The State requested a
sample of the surfactant that was analyzed by
a State laboratory. They found two problems:
the surfactant itself contained hazardous
components (e.g., benzene, toluene) and the
laboratory had a problem in quantifying the
surrogates. This was considered problematic
in that it would mask detection of the
contaminant at the point of compliance.
The State encouraged the applicant to conduct
a pilot scale test that compared the surfactant
to a clean sample, a sample contaminated with
diesel fuel, and a fourth sample with both
diesel fuel and the surfactant, and analyze for
total petrol HCs. Finally, the contaminant
source was largely in the soil rather than the
ground water, and the State was concerned
with the idea of cleaning the soil by moving
the contaminant into ground water.
Alternatives that addressed removing the
contaminant directly from the soil were not
Technology Description (1)
The application of surfactants can
enhance remediation by increasing
contaminant mobility and solubility
to improve pump-and-treat
performance; by decreasing the
mobility of contaminants to prevent
their migration; and by speeding
the rate of biodegradation of
contaminants in soil.
Surfactants increase contaminant
removal by increasing the apparent
solubility of the contaminant in
water which improves the mass
removal per pore volume. They
may also be used to reduce
interfacial tension between the
water and the contaminant. This
requires greater surfactant
concentrations than those needed
for increasing solubility, but results
in direct mobilization of NAPLs,
which may allow them to be
extracted more efficiently.
However, if uncontrolled,
increasing the mobility of the
NAPLs also increases the risk of
increasing the contaminant plume.
considered.
Other technical issues of concern include the
need for very good hydrologic control as
demonstrated by monitoring wells, slug tests,
and flow direction, as well as adequate
confidence in the ability to detect problems at
the point of compliance. It would be
preferable that there be no immediate
downgradient receptors.
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Mr. Walker was quite interested in the
possibility of training or guidance on a
national level. He suggested that EPA should
be involved in conducting research to
determine which surfactants are best in
particular situations. Guidance should focus
on an impartial test of surfactant reliability
and performance. The State would also be
interested in EPA guidance on "how clean is
clean." Training should be modeled on a
recent workshop called the Strategic Technical
Exchange Workshop. In this training,
instructors, regulators, and the regulated
community met together and in break out
sessions to discuss specific techniques.
Pennsylvania
Jim Shaw discussed the State of
Pennsylvania's experience in reviewing and
approving a pilot study to evaluate the use of
surfactants for remediating PCBs at the
Delmont Site in Westmoreland County. The
State received a work plan and MSDS
(Material Safety Data Sheets) sheets from the
company with toxicity information on the
proposed surfactant. The information
submitted was adequate, but delays were
caused since this was the first such proposal
and the State did not have procedures in place
to review it. Eventually, the information was
reviewed by a hydrologist, an aquatic
biologist, and a toxicologist. Mr. Shaw said
that he coordinated with the Bureau of Water
Quality to find the proper staff. Another
problem involved proprietary information
regarding the surfactant itself; however, this
was overcome by the MSDS information.
According to State staff, there are no
legislative or public barriers to the use of
surfactants in Pennsylvania. Proposals are
reviewed on a case-by-case basis; and
approval is determined on the basis of
technical merit. It is possible that future
proposals would also be reviewed by State
UIC staff as well.
Pennsylvania has recently enacted new
cleanup legislation that should make the
remediation process easier at a number of
sites. The law incorporates generic remedies,
background levels, and the development of
site-specific standards as options. Each region
in the State will have responsibility for sites in
that area. Review of proposals will be
contingent on the availability of technical
resources and management priorities, but there
is a requirement for a 60-90 day turnaround on
remedial projects. Mr. Shaw thought the effect
of the new legislation would be to make it
easier to implement innovative technologies.
State staff in Pennsylvania would benefit from
a conference or training course on surfactants.
Mr. Shaw noted that it was difficult to locate
staff with familiarity with the topic. The best
approach would be a series of regional
conferences provided by EPA. Guidance on
how to implement surfactant demonstrations,
focusing on the process and options, also
would be helpful.
Kentucky
The Department of Energy's Paducah Gaseous
Diffusion Plant has numerous contaminated
areas (200 potential release sites or solid
waste management units). TCE used for
cleaning metal and machinery parts has been
identified in ground water plumes both to the
northwest and northeast of the site. (Other
contaminants include the radionuclide
technetium-99, uranium, PCBs, chromium,
and other substances in both soil and ground
water.)
The Commonwealth of Kentucky approved a
proposal for a surfactant demonstration to
facilitate removal of TCE in a small area
(about 200 square yards). Although there were
no specific permit requirements or regulations
that were applicable to the site, DOE
submitted a work plan to EPA for review
under UIC regulations. Kentucky's Division of
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Waste Management has an arrangement for
technical support from the University of
Kentucky, where their Federal Facility
Oversight Unit is located. Therefore, even
though this was the first such request,
technical staff were available to review the
proposal within three to four weeks.
One problem identified by Randall Thomas of
the Federal Facility Oversight Unit was that
DOE was not convinced that the State was
supposed to review and approve the proposal.
If DOE had involved the State earlier in the
process, a better working relationship most
likely could have been established. Also, by
the time the Federal Facility Oversight Unit
became involved, DOE had strict time
schedules to initiate the demonstration. The
contractor doing the work was willing to work
for free in order to show DOE their
capabilities, but delays would have made this
impossible.
The proposal contained no major technical
difficulties and approval was granted initially
based on technical merit. However, the
contractor did not want to disclose much
information about the surfactant. The
compound initially proposed contained a
hazardous waste component and later a
different surfactant was substituted. The
Commonwealth also was concerned with
mobilizing the DNAPL (dense, non-aqueous
phase liquid), since this may result in DNAPL
moving deeper into the aquifer.
Unfortunately, the demonstration did not turn
out as planned. The contractor was unable to
recover all of the surfactant, some of which
either moved downgradient or was bound up
in the matrix. Mr. Thomas identified a number
of possible reasons: they did not pump
aggressively enough; there was not enough
geologic testing in advance of the
demonstration; and possibly they used the
wrong surfactant. In spite of these problems,
Mr. Thomas remains enthusiastic about using
surfactants to enhance pump-and-treat
remedies. The Commonwealth would like
DOE to try again, and DOE has not ruled out
this possibility.
Mr. Thomas also noted that training for both
the regulators and the regulated community is
essential. People need knowledge about the
process and how to use it; however, he
thought it may be too early in the
development of the technology for EPA to
provide guidance.
Utah
A number of remedial projects are ongoing at
Hill Air Force Base in Utah. Surfactant-based
technologies will be included as three of eight
field demonstrations in one project led by
researchers from the University of Oklahoma
at Operable Unit 1 (OU1). A project at OU2 is
being conducted by researchers from the
University of Florida and the U.S. EPA
Subsurface Protection and Remediation
Division of the National Risk Management
Research Laboratory in Ada, Oklahoma. Both
projects were discussed in the State regulator's
interview.
Hill AFB is designated as a Superfund site.
Other partners in the projects include U.S.
EPA, Region 8; the Utah Department of
Environmental Quality; and Hill AFB. The
purposes of the studies are to evaluate
innovative remediation technologies for the
removal of NAPL or constituents in NAPL
from saturated and unsaturated soil; and to
conduct treatability studies of these
technologies for remediating LNAPL
contamination. For the OU1 project, field
demonstrations will be executed inside a test
cell constructed to hydraulically isolate the
investigation area and minimize migration of
fluids from the cell. Participants hope to make
preliminary assessments of the long term
effectiveness of the technology and to develop
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basic cost factors that can be used for cost
estimates for full scale application.
Technology Description (2)
Cationic (positively charged)
surfactants have been shown to
improve the capacity of soil to sorb
hydrophobic organic contaminants,
such as polyaromatic hydrocarbons
(PAHs). Other research suggests
that low concentrations of
surfactants may be useful for
enhancing in situ biodegradation of
hydrophobic pollutants.
Our interview was with Duane Mortensen of
the Utah Department of Environmental
Quality, and with one of his staff members
who is a State Project Manager at Hill AFB.
The application was reviewed in six months.
The most important technical information
included in the proposal from the State
perspective was information regarding the
expected effectiveness of the technology (e.g.,
as demonstrated through treatability studies),
how well the containment system was
designed, and the type of chemical to be used.
The State Ground Water Quality Protection
Rule specifies levels equal to Maximum
Contaminant Levels (or, in some cases where
ground water has not been impacted by
contamination, specified percentages of
MCLs) as a standard for the concentrations of
injectant. A State applicable or relevant and
appropriate requirements (ARAR) waiver
would be necessary for full remediation.
While there were no technical deficiencies in
the application, appropriate regulatory
requirements of EPA's Treatability Study
Guidance had to be addressed in the work
plan. No UIC permit was required as this is a
CERCLA site; however, one would be needed
at a RCRA site. Approval of projects are
based on technical merit, and state regulators
suggested there were no institutional barriers,
at least for Superfund sites. They did note that
it would be more complicated for a RCRA
site. Also, so far, no one has proposed using a
proprietary product for use as the surfactant.
The State noted that they would need enough
informa-tion on the chemical properties of the
proposed surfactant to ensure public safety.
Since this is a CERCLA site, a certain level of
public involvement is required. The local
Community Working Group and South Weber
Landfill Coalition have been very active and
involved in the overall project. So far, local
citizens have not been overly concerned with
treatability studies, but they would be very
concerned if the Record of Decision (ROD)
called for injecting some-thing with hazardous
constituents. They also have concerns
regarding the overall cleanup strategy at the
site.
Finally, State regulators noted the impor-tance
of having very good communication and
coordination with all the parties involved.
They have had several meetings with the
Universities, EPA, and the Air Force that have
helped keep the projects moving by keeping
everyone informed. They suggested that
others become more familiar with the State's
administrative process to facilitate approval of
demonstration proposals. Researchers
involved in the projects agreed with these
conclusions. In particular, they recommended
that keeping the regulators involved
throughout the process, developing work
plans, and familiarizing researchers with the
regulatory process are all essential steps.
New Jersey
At Picatinny Arsenal, TCE was used for years
as a degreasing solvent and has contaminated
a sand and gravel aquifer. The site was
recently listed as a Superfund site and a pump-
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and-treat system was installed as an interim
remedy. The water table is 10 feet below the
surface, and a lower confining unit 10 to 15
feet thick is another 40 feet from the water
table, making the site ideal for a small scale
field test.
Laboratory research indicated that a nonionic
surfactant, Triton X-100, may increase the
desorption rate of TCE from soil and organic
materials to ground water. This theory was
field tested by researchers from the U.S.
Geological Survey (USGS), the University of
Virginia, and the Army. The preliminary
results from the field test completed in March
1995 support the laboratory research. The
work will be incorporated into the site
Remedial Investigation/Feasibility Study (RI/
FS) and used in selection of final remedies.
The USGS designated the site as a research
site, and the University of Virginia has a grant
from EPA to conduct research on the site. The
State of New Jersey has granted the Army a
permit to discharge to ground water. State
regulators were brought into the process up to
a year prior to beginning the field test.
According to the researchers, the State was
willing to let the project go forward because
the field test was being conducted within the
capture zone of the existing pump-and-treat
systems. Modeling studies showed that all but
5% of the ground water is being captured by
the existing system.
Any discharge to ground water in New Jersey,
whether it is clean water discharged from a
treatment system or chemical surfactants
injected/infiltrated into an aquifer, would be
regulated by the New Jersey Water Pollution
Control Act (N.J.S.A. 58:10A). Two sets of
regulations from this Act directly apply to
discharges to ground water. They are: 1) the
New Jersey Pollutant Discharge Elimination
System (N.J.A.C. 7:14A) and, 2) the New
Jersey Ground Water Quality Standards
(N.J.A.C. 7:9-6).
The New Jersey Pollutant Discharge
Elimination System (NJPDES) regulations
focus on the operational aspects of a discharge
to ground water. They outline requirements
for obtaining and maintaining permits for
discharge to ground waters or surface waters
of the State. These regulations also specify
procedures for public comment/public notice,
and requirements for constructing and
operating treatment works. The New Jersey
Ground Water Quality Standards (NJGWQS)
focus on the classification and quality of
ground water. These regulations deal with
aquifer classifications, exceptions to aquifer
classifications, ground water quality criteria,
calculation of ground water criteria,
identification of practical quantitation levels,
and anti-degradation policies. Discharge limits
contained in a NJPDES discharge to ground
water (DGW) permit would be obtained from
specified ground water quality criteria (or
guidance provided to calculate criteria)
contained in the New Jersey Ground Water
Quality Standards.
Under CERCLA Section 121 "Cleanup
Standards"; federal, state, and local permits
are not required for the portion of any removal
or remedial action conducted entirely on-site.
However, also under Section 121 is the
requirement for remedial actions to at least
attain legally applicable or relevant and
appropriate federal and state standards,
requirements, criteria, or limitations (i.e.,
ARARs), unless such requirements are
waived.
The State of New Jersey does not waive
requirements, and ARARs must be met at
publicly-funded and Federal CERCLA sites.
ARARs include the Technical Requirements
for Site Remediation, N.J.A.C. 7:26E-6.1(b)3,
which require a responsible party to meet the
equivalent of a permit's conditions; however,
a permit number is not issued nor is a permit
fee required. The surfactant injection project
at Picatinny must meet the equivalent
8
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requirements that the Department would set
for any request for a permit to inject to ground
waters of the State. The NJDEP utilized a
"Permit by Rule" approach to facilitate the
surfactant injection project while meeting
regulatory requirements.
At the NJDEP, contaminated sites are
identified, assessed, scored, and ranked.
Depending on the ranking and the regulatory
program, the site is assigned to a Bureau
which appoints a case or site manager to
handle the case. For sites with substantial
ground water and soil contamination, a full
case team is usually assigned. A full case team
consists of the case manager, a technical
coordinator (responsible for evaluating soil
data, QA/QC, and related technical issues),
and a geologist. The case team operates as a
unit under the direction of the case manager.
For discharges to ground water, the purpose of
a NJPDES permit is to ensure the protection
of human health and ecological receptors.
However, NJDEP modified its NJPDES
regulations in September 1994 to ease the
administrative permitting requirements for
certain discharges to ground water. These
include discharges related to pilot studies,
aquifer testing, or other discharges to the
ground related to monitoring, engineering, or
design needs.
The following approach would likely be
followed at the NJDEP to allow surfactant
injection to be considered and implemented.
As with any proposal to test a specified
remedial approach, a responsible party or their
consultant should inform the NJDEP case
manager that they would like to evaluate the
feasibility of surfactant injection. The case
manager would require submittal of a proposal
outlining the details and nature of a requested
discharge. This proposal should provide all
technical data to allow the Department to fully
review it, including where will the discharge
occur, what is the nature of the discharge,
expected concentrations, flow rates, duration
of the discharge, static ground water flow
velocities and directions, health and safety
provisions, sampling/monitoring plans).
As discussed above, for pilot studies or
aquifer tests, NJPDES regulations now
authorize using a "permit by rule" for a
discharge to the ground. The permit by rule is
simply a letter and no public noticing
procedures are required. Adequate monitoring
of the discharge, ground water quality, and
hydraulic conditions would be required
through whatever regulating mechanism or
oversight document is driving the remedial
work, not as part of the permit by rule. The
permit by rule would include effluent limits
based on specific criteria found in the Ground
Water Quality Standards for the aquifer
classifications receiving the discharge.
Discharges occurring outside the limits of a
capture zone must meet "anti-degradation
limits" (as discussed in Section 7:9-6.8 of the
NJGWQS). These limits are designed to
prevent any further degradation of ground
water quality from a regulated discharge.
Higher discharge limits may be allowed, on a
case by case basis, if the discharge is
occurring within the limits of hydraulic
capture, or if the Department determines it is
appropriate to issue a Classification Exception
Area (CEA). For a full scale system, a formal
NJPDES-DGW permit would be issued,
except for on-site discharges at CERCLA
sites, in which case a "Permit Equivalent"
would be issued. Currently, submittal of
formal application forms is not necessarily
required for Permit Equivalents for a
discharge to ground water.
Training on surfactant chemistry and
processes would be beneficial for future
decision making; however, New Jersey has
drastically cut back on training due to
resource limitations, and staff would be able
to attend only if training is offered free of
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charge. Guidance would also be helpful in
integrating information on surfactants, and
should focus on State concerns and how these
can be mitigated.
Texas
EPA has identified one completed
demonstration of surfactant technology for
hazardous waste remediation in Texas. "In
Situ Remediation Technology Status Report:
Surfactant Enhancements" describes a pilot
test of use of a surfactant to facilitate removal
of carbon tetrachloride at the Corpus Christi
Dupont site in 1993. The demonstration
showed positive results. No current projects in
Texas have been identified; however a number
of companies are looking into the technology,
and a pilot project is being considered at
Kelley Air Force Base.
Gary Beyer of the Texas Natural Resources
Conservation Commission's Federal Facilities
Team, discussed some of the technical
information requirements and regulatory
requirements for conducting a demonstration.
His office deals with corrective actions under
the RCRA program. The time to review a
proposal for a Corrective Measures Study
would likely be about one month. A Class 5
UIC well permit would be required, but could
be obtained from within their office. The most
important technical data for the proposal
would be hydrogeological data explaining
recovery and chemical solubility data on the
surfactant. A surfactant containing hazardous
constituents would not be likely to be
approved.
Pilot studies can be approved under the State
Risk Reduction rules through a letter permit as
part of the normal corrective action process.
No public hearing would be required for a
pilot study. However, a full Corrective
Measures Investigation under RCRA does
include a public participation requirement.
The proposal would be reviewed by staff
hydrogeologists and toxicologists. The
requirement for an injection permit would be
the main regulatory issue.
There would be a good deal of interest in
training on surfactant use, especially for
remediation of TCE. The State's Innovative
Technology Program has offered vendor
presentation days that have regulators become
familiar with the technology. Because of
travel restrictions, training or a workshop in
Austin would be the best venue. Written
guidance would also be welcome.
Conclusions and Recommendations
The survey of state regulators indicated that
there is a great deal of variety in approaches
and procedures relevant to gaining approval
for demonstrations of surfactant technology.
For this reason, it is difficult to make
generalizations about how states can best be
approached. As demonstrated by the projects
discussed in the report, it is clear that
opportunities do exist. Typically, proposals
have been reviewed on a case by case basis
and rejected or approved on the basis of
technical merit. However, the states are not
monolithic. Different agencies within the
states may be responsible or involved in
reviewing a surfactant application, and some
effort may be involved in determining which
State office has regulatory jurisdiction.
Moreover, the technology is still in a
relatively early stage of development for use
in remediating hazardous waste, and states are
doing their best to keep up. Many questions
remain about the technology itself, such as:
• Which surfactants should be considered
for particular contaminants?
• Will geochemical interactions with other
contaminants be a factor?
• How can you ensure the surfactant will
not remain in the matrix? and
• How do you know when you've been
successful?
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Given these caveats, it is possible to draw
some conclusions based on experiences.
Time Required to Review Proposal
None of the states included in the survey had
a specific procedure in place for reviewing
proposals for surfactant projects. Most states
have more general procedures for review and
approval of pilot projects or demonstrations of
innovative technologies, and these may
require a broad range of time. In general,
researchers or others proposing a
demonstration should plan from one to six
months for state review of surfactant
proposals. States where pilot studies can be
approved and permits issued by rule or letter
are likely to take less time.
In some cases review of proposals was
delayed because of the need to locate
appropriate experts for the review within the
state office and because of the need to
coordinate among state offices. Types of
experts who are likely to be involved in the
state review include: hydrogeologists,
toxicologists, and possibly others. Suggestions
for reducing the amount of time required for
state review included knowledge of the
regulatory process by those preparing
proposals and adequate technical information
included in the submission (see below).
Training, technical support, or a national
directory of experts might also be useful.
Format and Technical Information
Requirements
The survey identified state concerns about the
toxicity of the surfactant, masking effects,
transfer of contaminants from soil to ground
water, satisfactory hydrologic control, and
adequate monitoring to ensure that processes
taking place in the subsurface are understood.
In particular, state regulators need to be
convinced that use of surfactants will not
make the situation worse, that NAPLs are not
mobilized without being recovered, and that
the surfactant itself can be recovered or
remediated.
Information that should be included in the
proposal includes:
• A detailed work plan for conducting the
project including objectives,
• Comprehensive site characterization
information (including water levels and
monitoring well data),
• Background information on laboratory
studies or other field demonstrations
showing the efficacy of the proposed
approach,
• Demonstration of hydrologic control over
the test site to ensure that surfactant will
not be lost, nor NAPLs simply moved
further into the matrix,
• Surfactant chemistry and contaminant
geochemical interactions, and
• Demonstrated monitoring capabilities.
Barriers to Approval
Underground Injection Control (UIC)
regulations are not applicable at Superfund
sites and appeared generally not to be
considered a serious problem in States that
have approved surfactant demonstrations.
Permits were not typically required for pilot
tests, and the UIC staff were simply kept
informed of the surfactant activities. However,
UIC permits may well be required for full
remediation or even for pilot studies at RCRA
or private sites. There are also differences in
regulatory requirements based on whether the
site is regulated under RCRA or CERCLA,
and whether it is a Federal Facility, a
Superfund, State, or private party lead. There
appear to be fewer restrictions at a Superfund
site.
In some states, water quality standards would
prohibit use of surfactants that contain Safe
Drinking Water Act-listed constituents at
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concentrations above the MCL. Waiver of
state ARARs may be needed for large scale
implementation at a Superfund site. Public
disapproval has not generally been a problem
for small scale demonstrations, but it could
become a concern for larger remedial efforts.
Training and Guidance Needs
Seven of the eight individuals interviewed
recommended training in surfactant use and
processes for state staff. Most also mentioned
that the public needs training as well. The
preferred format was a series of regional
workshops that would be close enough to state
capitals to minimize travel costs, and that
would include researchers, regulators, and the
regulated community.
Guidance on surfactant use would also be
welcome, especially as a substitute or addition
to training, but some of those interviewed
admitted that it may be too early in the
development of the technology for EPA to be
able to write useful guidance.
Recommendations
Researchers or others interested in gaining
state approval for a surfactant pilot test or
demonstration project should consider the
following recommendations based on lessons
learned by previous proposals:
• All relevant parties should be brought into
the process early and kept informed of
project progress. Communications with all
partners, and especially state regulators, is
critical to the process.
• Researchers and others proposing
surfactant demonstration or remediation
projects need to be well versed in the
regulatory process, and should become
familiar with the state's regulatory and
administrative procedures. This will
frequently determine whether or not
specific permits are needed, and the
specific format the proposal should take to
facilitate approval.
• Surfactants about which considerable
chemical data is known and those that do
not contain hazardous constituents are the
most likely to be approved. The use of
proprietary products will make approval
more difficult in most cases.
• EPA should consider developing training
or technology transfer workshops for state
staff and the public sector.
As the technology for surfactant
enhancements develops, more is learned about
which surfactants are least harmful and most
efficient, and cost and performance data
become available, the approval process in the
states can be expected to improve.
Notes
1 "Workshop on In Situ Surfactant Use",
sponsored by U.S. Environmental Protection
Agency, Technology Innovation Office,
Kansas City, Missouri, September 1995.
2 "In Situ Remediation Technology Status
Report: Surfactant Enhancements", U.S.
Environmental Protection Agency,
Technology Innovation Office, Washington,
DC, EPA542-K-94-003.
3 EPA's Technology Innovation Office will
publish the results of this study in early 1996.
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Appendices
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State Regulators' Interviews
Surfactant Injection for Ground Water Remediation
List of Participants:
STATE NAME
AK Jonathan Williams
U.S. EPA, Region 10
1200 Sixth Street (WD132)
Seattle, WA 98101
CA Susan Timm
Central Valley Regional Water Quality
Control Board
3443 Routier Road, Suite A
Sacramento, CA 95827
CO Mark Walker
Colorado Department of Health and
Environment (HMWMD-RP-B2)
4300 Cherry Creek Drive, So.
Denver, CO 80222-1530
KY Randall Thomas
Federal Facility Oversight Unit
14 Reilly Road
Frankford, KY 40601
NJ George Nicholas
NJ Dept. of Environmental Protection
Division of Publicly Funded Site
Remediation (CN 413)
Trenton, NJ 08625
PA Jim Shaw
Dept. of Environmental Protection
Bureau of Land Recyclying & Waste
Management
400 Market Street (14th Floor)
P.O. Box8471
Harrisburg, PA 17105
TX Gary Beyer
Texas Natural Resources
Conservation Commission
P.O. Box 13087, Capital Station
Austin, TX 78711-3087
UT Duane Mortensen
UT Dept of Environmental Quality
168 N. 1950 W., 1st Floor
Salt Lake City UT 84114
SITE
Refinery on Kenai
Penninsula (UST Site)
Lawrence Livermore
National Laboratory
1 site where surfactants
being used at an UST
site
DOE Paduaka
Gaseous Diffusion
Plant
Picatinny Arsenal
HillAFB
PHONE
206-553-1369
Fax 553-1280
916-255-3057
Fax 255-3015
303-692-3449
Fax 759-5355
502-564-4797
Fax 564-5096
609-292-8427
Fax 292-0848
717-783-9475
Fax 787-0884
512-239-2361
Fax 239-2346
801-536-4172
Fax 359-8853
INTERVIEW
Aug. 31
Aug. 31
Aug. 29
Sept. 6
Sept. 6
Aug. 28
Sept. 6
Sept. 12
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State Regulator's Interview Guide
Barriers and Successes in Demonstrating Surfactant Injection
for Ground Water Remediation
Introduction
This is a follow-up to a survey EPA conducted last year aimed at determining what State regulations and policies are
concerning the injection of surfactants, co-solvents or nutrients into contaminated ground water for remediation. At this
time, we are interested specifically in procedures used in your state for reviewing proposals for surfactant injection
demonstrations. EPA is aware of about half a dozen current surfactant demonstrations. EMS has been employed to
assist them in conducting interviews with key state regulators who may have been involved in reviewing and approving
such proposals. The goal of these interviews is to identify recommendations for future applicants that may improve the
efficacy of approval.
1. Are you the appropriate persons to discuss the details of the proposal for surfactant use within your state?
a. If not, whom should we contact?
Name Phone No.
Fax No.
[Thank you for your assistance]
2. What is the name and location of the site?
3. Can you give me the time frame during which the application was reviewed by the State?
From: To:
4. What would you consider the most important technical information in the proposal?
5. Were there major technical deficiencies in the application? Yes: No:
a. Could you describe these briefly?
b. Did you request additional information from the applicant? Was this adequate?
6. Were there other, non-technical problems that caused delays?
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a. If so, how do you think these problems can best be addressed?
b. Who would be in the best position to change things?
7. Do you have any suggestions about how the application approval process can be speeded up?
8. Do you believe that training on surfactant chemistry and processes would be beneficial for future decision-making
related to permitting decisions?
If yes, what recommendations do you have?
9. Do you think guidance for specific surfactant applications is needed?
10. Are there other technical or policy options that could be addressed nationally that you feel would contribute to
improving the use of in situ surfactant enhancements in your State?
Thank you for your time. You will be given the opportunity to review our report and recommendations before they are finalized.
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