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
                                           11

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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.
                                          12

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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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