EPA/540/R-04/507
June 2007
Electrochemical
Technologies (ECRTs) - In
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Contaminated Marine
Sediments
Innovative Technology Evaluation Report
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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Notice
The information in this document has been funded by the U.S. Environmental Protection Agency
(USEPA) under Contract Number 68-COO-179 to Science Applications International Corporation
(SAIC). It has been subjected to the Agency's peer and administrative reviews and has been
approved forpublication as an EPA document. Mention of trade names or commercial products does
not constitute an endorsement or recommendation for use.
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Foreword
The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting
the Nation's land, air, and water resources. Under a mandate of national environmental
laws, the Agency strives to formulate and implement actions leading to a compatible
balance between human activities and the ability of natural systems to support and nurture
life. To meet this mandate, EPA's research program is providing data and technical support
forsolving environmental problems today and building a science knowledge base necessary
to manage our ecological resources wisely, understand how pollutants affectour health, and
prevent or reduce environmental risks in the future.
The National Risk Management Research Laboratory (NRMRL) is the Agency's centerfor
investigation of technological and management approaches for preventing and reducing
risks from pollution that threaten human health and the environment. The focus of the
Laboratory's research program is on methods and their cost-effectiveness for prevention
and control of pollution to air, land, water, and subsurface resources; protection of water
quality in public water systems; remediation of contaminated sites, sediments and ground
water; prevention and control of indoorair pollution; and restoration of ecosystems. NRMRL
collaborates with both public and private sector partners to foster technologies that reduce
the cost of compliance and to anticipate emerging problems. NRMRL's research provides
solutions to environmental problems by: developing and promoting technologies that protect
and improve the environment; advancing scientific and engineering information to support
regulatory and policy decisions; and providing the technical sup port and information transfer
to ensure implementation of environmental regulations and strategies at the national, state,
and community levels.
This publication has been produced as part of the Laboratory's strategic long-term research
plan. It is published and made available by EPA's Office of Research and Development to
assist the user community and to link researchers with their clients.
Sally Guiterrez, Director
National Risk Management Research Laboratory
in
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Abstract
This Innovative Technology Evaulation Report summarizes the results of the evaluation of
the Electrochemical Remediation Technologies (ECRTs) process, developed by P2-Soil
Remediation, Inc. (in partnership with Weiss Associates and Electro-Petroleum, Inc.). This
evaluation was conducted between August 2002 and March 2003 in cooperation with the
Washington State Departmentof Ecology (Ecology). The ECRTs demonstration consisted
of an evaluation of ECRTs' process to utilize a DC/AC current passed between an electrode
pair (anode and cathode) in sediment in order to mineralize organic contaminants through
an ElectroChemicalGeoOxidation (ECGO) process, or complex, mobilize, and remove metal
contaminants deposited at the electrodes through the Induced Complexation (1C) process.
The demonstration of the ECRTs process was conducted at the Georgia Pacific, Inc. (G-P)
Log Pond located along the Whatcom Waterway in Bellingham Bay, Bellingham,
Washington. This demonstration was designed to assess and evaluate the ability of the
ECRTs process to reduce concentrations of mercury, PAHs, and phenolic compounds.
For the demonstration project, Weiss Associates, (Emeryville, CA) installed, operated, and
removed the ECRTs pilot test equipment from the Log Pond site. Faulk Doering,
electrochemical processes (ECP; Stuttgart, Germany) provided oversightand consultation
for the system installation and operation. Installation of pilot study infrastructure involved
placing 9 anode (steel plates) and 9 cathode (graphite plates) electrodes, in two parallel
rows, into the sediments.
The G-P Log Pond is a marine e m bay me nt that served as a former log storage and hand ling
area and receiving waterforfacility effluent and stormwater runoff. The ECRTs projectarea
was designated as an approximately 50-feet (ft) by 50-ft area within a pre-characterized
area of the G-P Log Pond known to contain elevated concentrations of mercury, phenolics,
and PAHs. However, based on results from a preliminary survey, mercury was identified
as the most ubiquitous and consistently elevated contaminant relative to Washington State
Sediment Management Standards (SMS) Sediment Quality Standards (SQS) and Cleanup
Screening Levels (CSL) which are used in Puget Sound to determine impacted sediments
that require remediation under State law.
The primary technical objective of the demonstration was to determine whether there was
a significant trend in the reduction of sediment mercury concentrations over the period of
the demonstration. Reference area samples were collected for comparison to determine
whether treatment differed from natural attenuation. The experimental design was based
IV
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upon significant mercury reduction from baseline to a post-treatment sampling event. The
primary objective is not associated with a percent reduction but instead the primary
objective is to determine a statistically significant negative trend over time. Samples of the
cap material and the underlying native material were used to evaluate potential migration
of all contaminants, including mercury (primary objective), PAHs, and phenolics.
An assessment of the sediment chemistry results indicated a less than anticipated
performance due in part to system operational problems encountered during the course of
the demonstration. Electrical readings collected by the technology's sponsor indicated a
steady degradation of system performance throughout the duration of the demonstration,
resulting in an early shutdown of the system prior to completion of the planned test period.
In addition, when the electrodes were removed from the test plot, it was evident that the
connections between the electrical supply and anode electrode plates had completely
corroded to the point that a viable contact had not been maintained.
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Contents
Notice ii
Foreword iii
Abstract iv
Tables viii
Figures ix
Abbreviations and Acronyms x
Acknowledgments xii
Executive Summary ES-1
1.0 Introduction 1-1
1.1 Background 1-1
1.2 Brief Description of the SITE Program 1-3
1.3 The SITE Demonstration Program and Reports 1-4
1.4 Purpose of the Innovative Technology Evaluation Report (ITER) ... 1-4
1.5 Technology Description 1-4
1.6 Key Contacts 1-5
2.0 Technology Applications Analysis 2-1
2.1 Key Features of the Electrochemical Remediation Treatment
Process 2-1
2.2 Operability of the Technology 2-3
2.3 Applicable Wastes 2-3
2.4 Availability and Transportability of Equipment 2-3
2.5 Materials Handling Requirements 2-4
2.6 Site Support Requirements 2-4
2.7 Limitations of the Technology 2-4
2.8 ARARS for the Electrochemical Remediation Treatment Process ... 2-5
2.8.1 CERCLA 2-5
2.8.2 RCRA 2-5
2.8.3 CAA 2-7
2.8.4 CWA 2-7
2.8.5 SDWA 2-7
2.8.6 OSHA 2-8
2.8.7 State and Local Requirements 2-8
VI
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Contents (Cont'd)
3.0 Economic Analysis 3-1
3.1 Introduction 3-1
3.2 Conclusions 3-4
3.3 Factors Affecting Estimated Cost 3-4
3.4 Issues and Assumptions 3-4
3.4.1 Site Characteristics 3-4
3.4.2 Design and Performance Factors 3-4
3.4.3 Financial Assumptions 3-5
3.5 Basis for Economic Analysis 3-5
3.5.1 Site Preparation 3-6
3.5.2 Permitting and Regulatory Requirements 3-6
3.5.3 Capital Equipment 3-7
3.5.4 Startup and Fixed Costs 3-7
3.5.5 Labor 3-8
3.5.6 Consumables and Supplies 3-9
3.5.7 Utilities 3-10
3.5.8 Effluent Treatment and Disposal 3-10
3.5.9 Residuals Shipping and Disposal 3-10
3.5.10 Analytical Services 3-11
3.5.11 Maintenance and Modifications 3-11
3.5.12 Demobilization/Site Restoration 3-12
4.0 Demonstration Results 4-1
4.1 Introduction 4-1
4.1.1 Project Background 4-1
4.1.2 Project Objectives 4-2
4.2 Field Activities 4-3
4.2.1 Pre-Demonstration Activities 4-3
4.2.2 Sample Collection and Analysis 4-5
4.3 Performance and Data Evaluation 4-9
4.3.1 Primary Objective 4-9
4.3.2 Secondary Objectives 4-14
5.0 Other Technology Requirements 5-1
5.1 Environmental Regulation Requirements 5-1
5.2 Personnel Issues 5-1
5.3 Community Acceptance 5-2
6.0 Technology Status 6-1
6.1 Previous Experience 6-1
6.2 Ability to Scale Up 6-1
7.0 References 7-1
VII
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Tables
Table Page
2-1 Federal and State ARARS for the ECRTs Process 2-6
3-1 Cost Estimates for Full-Scale Application of the ECRTs Technology 3-3
3-2 Weiss Associates Labor Costs 3-8
3-3 Electrical System Component Costs 3-9
3-4 Estimated Electrode Disposal Costs 3-10
3-5 Estimated Analytical Costs 3-11
3-6 Estimated Sediment Monitoring Costs 3-12
4-1 Summary of Demonstration Objectives & Methods of Evaluation 4-4
4-2 Mercury Concentrations in Test Plot Sediment Horizon (mg/Kg) 4-10
4-3 Mercury concentrations in Extended Zone Sediment Horizon (mg/Kg) .... 4-25
4-4 Mercury concentrations in sediment cap samples 4-26
4-5 Summary of Mercury Analyses for Post-Demonstration Electrodes 4-27
VIM
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Figures
Figure Page
1-1 Site Location Map 1-2
2-1a Schematic of CS Grade Graphite Electrode 2-2
2-1 b Schematic of Mild Carbon Steel Plate Electrode 2-2
3-1 Hypothetical Site Diagram 3-2
4-1 Spatial and Temporal Distribution of Mercury in Test Plot Sediment Horizon 4-11
4-2 Average Mercury Concentrations in Test Plot Sediment Horizon 4-12
4-3 Average Naphthalene Concentrations in Test Plot Sediment Horizon 4-15
4-4 Average Naphthalene Concentrations in Extended Zone Sediment Horizon. 4-15
4-5 Average 2-Methylnaphthalene Concentrations in Test Plot Sediment Horizon 4-16
4-6 Average 2-Methylnaphthalene Concentrations in Extended Zone Sediment
Horizon 4-16
4-7 Average Acenaphthalene Concentrations in Test Plot Sediment Horizon . 4-17
4-8 Average Acenaphthalene Concentrations in Extended Zone
Sediment Horizon 4-17
4-9 Average Fluorene Concentrations in Test Plot Sediment Horizon 4-18
4-10 Average Fluorene Concentrations in Extended Zone Sediment Horizon .. 4-18
4-11 Average Fluoranthene Concentrations in Test Plot Sediment Horizon ... 4-19
4-12 Average Fluoranthene Concentrations in Extended Zone Sediment Horizon 4-19
4-13 Average 4-Methylphenol Concentrations in Test Plot Sediment Horizon . 4-20
4-14 Average 4-Methylphenol Concentrations in Extended Zone
Sediment Horizon 4-20
4-15 Average Mercury Concentrations in Test Plot Cap 4-22
4-16 Average Mercury Concentrations in Test Plot Native Material 4-22
4-17 Average Mercury Concentrations in Extended Zone Sediment Horizon .. 4-23
4-18 Average Mercury Concentrations in Reference Zone Sediment Horizon .. 4-24
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Abbreviations and Acronyms
AQCR Air Quality Control Regions
AQMD Air Quality Management District
ARARs Applicable or Relevant and Appropriate Requirements
BL Baseline
CAA Clean Air Act
CERI Center for Environmental Research Information
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CSL Cleanup screening level
CV Coefficient of variance
DC/AC Direct Current/Alternating Current
DGPS Differential global positioning system
ECGO ElectroChemicalGeoOxidation
Ecology Washington State Department of Ecology
ECRTs Electrochemical Remediation Technologies
ft2 Square feet/square foot
GC/MS Gas chromatography/mass spectroscopy
G-P Georgia-Pacific Corporation
G&A General and administrative
HPAHs High molecular weight polycyclic aromatic hydrocarbons
HSWA Hazardous and Solid Waste Amendments
ICP Inductively coupled plasma spectroscopy
ITER Innovative Technology Evaluation Report
Int Intermediate
JARPA Joint Aquatic Resources Permit Application
LCS Laboratory control sample
LPAHs Low molecular weight polycyclic aromatic hydrocarbons
LOS Level of significance
LCL Lower confidence limit
MSS Marine Sampling Systems
MS/MSD Matrix spike/matrix spike duplicate
MDL Method detection limit
mg/kg Milligrams per kilogram
MLLW Mean lower low water
MTCA Model Toxics Control Act
NAAQS National Ambient Air Quality Standards
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Abbreviations and Acronyms (Cont'd)
NCR National Oil and Hazardous Substances Pollution Contingency Plan
NPDES National Pollutant Discharge Elimination System
NRMRL National Risk Management Research Laboratory (EPA)
NSCEP National Service Center for Environmental Publications
ND Non-detectable, not detected, less than detection limit
OSHA Occupational Safety and Health Administration
ORD Office of Research and Development (EPA)
OSC On-scene coordinator
O&M Operation and maintenance
OC Organic carbon
PAHs Polynuclear aromatic hydrocarbons
PCB Polychlorinated biphenyl
PPE Personal protective equipment
PO Primary objective
POL Practical quantitation limit
PQA Pre-Quality Assurance Plan Project Agreement
PVC Polyvinyl chloride
POTW Publicly owned treatment works
QAPP Quality assurance project plan
QA/QC Quality assurance/Quality control
RPD Relative percent difference
RFP Request for proposal
RPM Remedial project manager
RCRA Resource Conservation and Recovery Act
R&D Research and development
RSD Relative standard deviation
SAIC Science Applications International Corporation
SARA Superfund Amendments and Reauthorization Act
SMS Washington State Sediment Management Standards
SQS Sediment quality standards
SVOCs Semi-Volatile Organic Compounds
SOP Standard operating procedure
SW-846 Test methods for evaluating solid waste, physical/chemical methods
SWDA Solid Waste Disposal Act
SITE Superfund Innovative Technology Evaluation
TER Technology Evaluation Report
TOC Total organic carbon
TPH Total petroleum hydrocarbons
TRPH Total recoverable petroleum hydrocarbons
TSCA Toxic Substances Control Act
TSD Treatment, storage, and disposal
UCL Upper confidence (or control) limit
USEPA United States Environmental Protection Agency
VOC Volatile organic compound
WAC Washington Administrative Code
yd3 Cubic yards
XI
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Acknowledgments
This report was prepared under the direction of Mr. Randy Parker, the EPA Technical
Project Manager for this SITE demonstration at the National Risk Management
Research Laboratory (NRMRL) in Cincinnati, Ohio. Dr. Scott Beckman of Science
Applications International Corporation (SAIC), Hackensack, NJ, served as the SITE work
assignment manager for the demonstration project. Mr. Tim Hammermeister (SAIC,
Bothell, WA) provided project oversight for evaluation study design, field survey
implementation, and data reporting. Mr. Joe Evans (SAIC) provided QA oversight in
conjunction with Mr. Hammermeister for evaluation study design and data reporting.
The demonstration project required the services of individuals from several companies
and agencies including Georgia-Pacific (G-P), Marine Sampling Systems (MSS),
Washington State Department of Ecology (Ecology), and Weiss Associates. Chip
Hilardes, Field Services Manager for G-P (Bellingham, WA), provided site access,
logistical support, and use of G-P facilities for sample processing and equipment
storage. Bill Jaworski of MSS (Purdy, WA) provided and operated the sampling vessel
for collecting sediment cores and conducting voltage probe measurements. Brad
Helland of Ecology (Bellevue, WA), provided technical oversight of the technology
developers. Joe lovenitti, Don Hill, and Bill Mcllvride of Weiss Associates (Emeryville,
CA) served as logistical and technical contacts for the developer Dr. Faulk Doering, of
P2-Soil Remediation, Inc. (Stuttgart, Germany).
This report was prepared by Scott Beckman, Joe Evans, Tim Hammermeister, Maureen
Goff, and Joseph Tillman of SAIC. Ms. Rita Schmon-Stasik served as the SAIC QA
coordinator for data review and validation. Tim Hammermeister, John Nakayama, Chris
Hunt, Pete Heltzel, Mike Johnson, Ruth Otteman and Maureen Goff, all of SAIC,
conducted field sampling and data acquisition efforts.
XII
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Executive Summary
This report summarizes the results of the evaluation
of the Electrochemical Remediation Technologies
(ECRTs) process, developed by P2-Soil
Remediation, Inc. (in partnership with Weiss
Associates and Electro-Petroleum, Inc.). The
Superfund Innovative Technology Evaluation (SITE)
demonstration of the ECRTs process was conducted
at the Georgia Pacific, Inc. (G-P) Log Pond located
along the Whatcom Waterway in Bellingham Bay,
Bellingham, Washington. The demonstration was
designed to assess and evaluate the ability of the
ECRTs process to reduce concentrations of mercury,
PAHs, and phenolic compounds.
Overview of Site Demonstration
The ECRTs Demonstration project consisted of an
evaluation of ECRTs' process to utilize DA/AC
current passed between an electrode pair(anode and
cathode) in sediment in order to mineralize organic
contaminants through an
ElectroChemicalGeoOxidation (ECGO) process, or
complex, mobilize, and remove metal contaminants
deposited at the electrodes through the Induced
Complexation (1C) process. Installation of a pilot
study infrastructure involved placing 9 anode (steel
plates) and 9 cathode (graphite plates) electrodes, in
two parallel rows, into the sediments. Each electrode
row was approximately 30 feet long. The distance
between the anode and cathode sheet electrode
rows was approximately 30 feet. Electricity was
supplied, in parallel, to each individual electrode
plate.
The G-P Log Pond is a marine embayment that
served as a former log storage and handling area and
receiving water for facility effluent and stormwater
runoff. The ECRTs project area was designated as
an approximately 50-feet (ft) by 50-ft area within a
pre-characterized area of the G-P Log Pond known to
contain elevated concentrations of mercury,
phenolics, and PAHs. However, based on results
from a preliminary survey, mercury was identified as
the most ubiquitous and consistently elevated
contaminant relative to Washington State Sediment
Management Standards (SMS) Sediment Quality
Standards (SQS) and Cleanup Screening Levels
(CSL) which are used in Puget Sound to determine
impacted sediments that require remediation under
State law,
The actual treatment area used to evaluate the
technology's effectiveness was a 20-ft by 30-ft zone
located between the electrode arrays. With the
exception of the Port of Bellingham's Shipping
Terminaldockon the Whatcom Waterway adjacentto
the test plot, there were no structures within the
project area. The mudline elevations within the test
plot ranged from approximately -4 to -8 feet Mean
Lower Low Water (MLLW). Log Pond sediments with
elevated chemical concentrations and woody debris
measured approximately 5 to 6 ft thick between
underlying native material and a cap of clean sand
from regional maintenance dredging projects. The
area was capped in late 2000 and early 2001 with
clean capping material as part of a Model Toxics
Control Act (MTCA) interim cleanup action. Cap
thickness within the sediment treatment
demonstration area ranged from 0.5 to 1 foot in
thickness. The formal SITE demonstration of the
ECRTs system was conducted from August 2002
(Baseline Survey prior to installation) until March
2003 (Post-Demonstration Survey). The
performance of the ECRTs processwas evaluated by
collecting sediment cores from within and adjacent to
the electrode array and from 'reference' stations
ES-1
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located within the log pond but beyond the influence
of the ECRTs electricalfield. Intermediate monitoring
events were conducted in November 2002 and
December 2002 during the active ECRTs
demonstration period. A third monitoring event
scheduled for February 2003 was canceled due to
system operational concerns.
The primary technical objective of the demonstration
was to determine whether there was a significant
trend in the reduction of sediment mercury
concentrations over the period of the demonstration.
Reference area samples were collected for
comparison to determine whether treatment differed
from natural attenuation. The experimental design
was based upon significant mercury reduction from
baseline to a post-treatment sampling event. The
primary objective is not associated with a percent
reduction but instead the primary objective is to
determine a statistically significant negative trend
over time. Samples of the cap material and the
underlying native material were used to evaluate
potential migration of contaminants. Samples were
submitted for analysis of mercury, PAHs, and
phenolic compounds. In addition purse seining and
infauna inumeration studies were conducted to
determine the effect of the process on the native fish
and wildlife. There was some concern that the
ECRTs system would have a negative effect on
electrosensitive marine life.
Conclusions from this SITE Demonstration
Formal statistical analyses were used to evaluate the
critical mercury data. The overall conclusions
reached from these statistical analyses are as
follows:
• An inferential statistical evaluation was
performed to determine if there was any
decreasing trend in contaminant mercury
concentrations over time. The statistical
analysis showed thatthere was no significant
decreasing trend over time. Concentrations
of mercury remained relatively heterogeneous
but unchanging in the test plot during the
duration of the demonstration. Therefore
remediation results of the technology were
not readily apparent from mercury
concentration determinations obtained from
the test plot and the primary objective
regarding mercury reduction was not
achieved.
• Spatial and temporal plots of mercury from
the contaminated sediment horizon in the test
plotsupportthe inferential statistical analysis.
No significant changes in mercury
concentration (from a remedial perspective)
can be discerned from the spatial distribution
over time.
• Operational problems with the ECRTs
process may be responsible for the lack of a
significant reduction in mercury levels in the
test plot. Electrical readings collected by the
technology's sponsor indicated a steady
degradation of system performance
throughoutthe duration of the demonstration.
In addition, the connections between the
electrical supply and anode plates had
completely corroded to the point that a viable
contact had not been made. Therefore, it is
uncertain exactly how long (and to what
extent) the ECRTs process was fully
functional and operational.
Additional conclusions may be drawn from the
evaluation of the ECRTs process, based on extensive
analytical data supplemented by field observations.
These include:
• Plots were generated for naphthalene,
2-methyl naphthalene, acenaphthalene,
flourene, flouranthene, and 4-methylphenol.
All other SW-846 method 8270 compounds
were at concentrations too low to be able to
observe any possible decrease due to
technology remediation. The compounds
noted above show no apparent decrease in
concentration The ECRTs technology
demonstration was therefore unsuccessful at
reducing organic compounds through
mineralization. Overall it is believed that
because of problems encountered by the
developer for this demonstration that there
was no significant effect on hazardous
compound concentrations. The collected
data suggest that there were no significant
decreases in any of the compounds analyzed
ES-2
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at the G-P log pond site.
Vertical migration of contaminants (e.g.
induced complexation and mobilization of
mercury) was important to assess because
possible decreases in concentration in any of
the different horizons (sediment, cap, or
native material) could be due to vertical
migration of contaminants rather then actual
remediation. There was, however, no
significant decrease or increase in
contamination for any of the contaminants of
concern within the test plot for the
contaminated horizon, the cap material, and
the native material, confirming that the
technology had no effect on contaminant
migration.
In orderto determine the extentof the zone of
influence of the ECRTs process, spatial
measurement of electric potential and also
changes in compound concentrations outside
the immediate area of influence, designated
as the treatment plot were monitored.
Collected data indicated that there was no
significant decrease in contaminant
concentrations outside the immediate
treatment plot.
Benthic infauna effects and behavioral effects
on electro-sensitive fish were monitored as
part of the demonstration. There was no
outward evidence that the ECRTs system
was having an adverse impact on the local
benthic community (i.e. sterile substrate).
It appears that some mercury did adhere to
the cathode surfaces during the
demonstration. However, based on the
analytical results and visual assessments of
the electrodes, the relative quantity of
mercury plated to the cathodes was limited,
not readily recoverable (from a remedial
perspective), and may be an artifact of the
sediment in direct contact with the electrode
plates. It also does not appear that mercury
was mobilized to the extent that enriched
sediments near the electrodes.
Based upon review of data quality indicators,
it appears the critical data generated during
thefinal sampling and analysis post-treatment
event for the demonstration met
QAPP-specified criteria. These data are
therefore considered suitable without
qualification for use in evaluating the project
objectives.
The estimated cost to implement an
approximate 2,500 ft2 ECRTs treatment
system, extending to a five foot depth to treat
mercury-contaminated sediments over a six
month period is approximately $385,500,
including a 5% technology fee assessed by
P2 Soil Remediation.
ES-3
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Section 1.0
Introduction
This section provides background information about the
Superfund Innovative Technology Evaluation (SITE)
Program, discusses the purpose of this Innovative
Technology Evaluation Report (ITER), and describes the
Electrochemical Remediation Technologies (ECRTs)
process. Key contacts are listed at the end of this section
for inquiries regarding additional information about the
SITE Program, this technology, and the demonstration site.
1.1 Background
The Eletrochemical Remediation Technologies (ECRTs)
process was developed by P2-Soil Remediation Inc. P2-
Soil Remediation Inc. formed a partnership with Weiss
Associates and ElectroPetroleum, Incorporated to apply the
technology to contaminated sites. The ECRTS process was
evaluated for the treatment of marine sediments
contaminated with mercury, polycyclic aromatic
hydrocarbons (PAHs), and phenolic compounds. The
demonstration of the ECRTs was conducted at the Georgia
Pacific, Inc. (G-P) Log Pond in Bellingham Bay,
Washington. The G-P Log Pond pilot project consisted of
a demonstration of ECRTs, which utilizes an DC/AC
current passed between an electrode pair (anode and
cathode) in sediment. Remediation of the sediment was to
be accomplished by either the mineralization of organic
contaminants through the ElectroChemicalGeoOxidation
(ECGO) process, or by use of the Induced Complexation
(1C) process to complex, mobilize, and remove metal
contaminants plated to the electrodes, as described in
Section 1.5. The pilot study was designed to evaluate the
ability of the ECRTs process to reduce concentrations of
mercury, PAHs, and phenolic compounds.
The G-P Log Pond is a marine embayment located
adjacent to the Whatcom Waterway navigation channel in
Bellingham Bay, a well-established heavy industrial land
use area with a Maritime shoreline designation (Figure
1-1). The ECRTs project area was an approximately
50-feet (ft) by 50-ft area within the G-P Log Pond in
Bellingham Bay. The actual treatment area used to
evaluate the system's effectiveness was a 20-ft by 30-ft
zone within the test area as described in section 4. With the
exception of the Port of Bellingham's Shipping Terminal
dock on the Whatcom Waterway next to the site, there are
no structures in the project area. The test plot location has
existing mudline elevations ranging from approximately -4
to -8 feet Mean Lower Low Water (MLLW). Log Pond
sediments measure approximately 5 to 6 ft thick, and are
contaminated with various contaminants including mercury,
phenols, PAHs, PCBs and wood debris. The area was
capped in late 2000 and early 2001 with an average of
seven feet of clean capping material as part of a Model
Toxics Control Act (MTCA) interim cleanup action. Cap
thickness within the proposed in situ sediment treatment
demonstration area is reported by Anchor Environmental,
L.L.C. in the project JARPA Permit as approximately 0.5
feet. The integrated remediation and habitat restoration
project was performed as an interim Remedial Action as
part of an Agreed Order between G-P and the Washington
State Department of Ecology (Ecology) in compliance with
the State Model Toxics Control Act (MTCA; Chapter
173-340 WAC; RCW70.105D). Approximately 43,000yd3
of clean cap/restoration material from regional maintenance
dredging projects were placed within the Log Pond. The
total placed thickness ranged from approximately 0.5 feet
along the site perimeter to 1.0 feet within the interior of the
project area. The restoration project produced 2.7 acres of
shallow subtidal and 2.9 acres of low intertidal habitat, all
of which had previously exceeded the Sediment
Management Standards cleanup criteria (Anchor 2001 b).
1-1
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Figure 1-1. Site Location Map
RA
1-2
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Two prospective candidate sites within the Log Pond,
designated A and B, were originally considered for project
implementation. Data from these two areas indicated that
the contaminant concentration ranges found in samples
from Site A made this location better suited to conducting
the ECRTs pilot study. In comparing sediment chemistry
data from Sites A and B, average mercury concentrations
in Site A exceeded those of Site B by a factor of 63.
Average low molecular weight polycyclic aromatic
hydrocarbons (LPAHs) and high molecular weight PAHs
(HPAHs) in Site A exceed those of Site B by a factor of 112
and 17, respectively. However, based on results from a
preliminary survey, mercury was identified as the most
ubiquitous and consistently elevated contaminant relative
to Washington State Sediment Management Standards
(SMS) Sediment Quality Standards (SQS) and Cleanup
Screening Levels (CSL) which are used in Puget Sound to
determine impacted sediments that require remediation
under State law. A debris survey indicated that buried
logs/pilings were not likely to be encountered within Site A,
with the exception of sporadic riprap located at the base of
the bulkhead along the west edge of the site. In addition,
Site A was a subtidal location (-4 to -8 MLLW) that was
accessible by small boat, whereas Site B was an intertidal
location with access limited by variable tidal stages.
1.2 Brief Description of the SITE Program
The SITE Program was created in order to develop,
demonstrate, and establish the commercial potential of
innovative technologies for treating wastes found at
Superfund and other hazardous waste sites across the
country. Through SITE Demonstrations, USEPA acquires
the performance and cost data necessary to properly
consider innovative technologies in the remedial action
decision-making process. If tested successfully, these
technologies become alternatives to less attractive, more
costly forms of remedial action.
The SITE Program is a formal program established by
EPA's Office of Solid Waste and Emergency Response
(OSWER) and Office of Research and Development (ORD)
in response to the Superfund Amendments and
Reauthorization Act (SARA). The SITE Program promotes
the development, demonstration, and use of new or
innovative technologies to clean up Superfund sites across
the country.
The objective of the Demonstration Program is to develop
reliable performance and cost data on innovative
technologies so that potential users can assess the
technology's site-specific applicability. Technologies
evaluated are either available commercially or close to
being available for full-scale remediation of Superfund
sites. SITE demonstrations usually are conducted at
hazardous waste sites under conditions that closely
simulate full-scale remediation conditions, thus assuring
the usefulness and reliability of the information collected.
Data collected are used to assess:
1. the performance of the technology;
2. the potential need for pre- and
treatment of wastes;
3. potential operating problems; and
4. the approximate costs.
post-
The demonstration also provides opportunities to evaluate
the long-term risks and limitations of a technology.
Existing and new technologies and test procedures that
improve field monitoring and site characterizations are
explored in the CSCT Program. New monitoring
technologies, or analytical methods that provide faster,
more cost effective contamination and site assessment
data, are supported by this program. The CSCT Program
also formulates the protocols and standard operating
procedures (SOPs) for demonstration methods and
equipment.
The Technology Transfer Program disseminates technical
information on innovative technologies in the
Demonstration and CSCT Programs through various
activities. These activities increase awareness and
promote the use of innovative technologies for assessment
and remediation at Superfund sites. The goal of
technology transfer is to develop interactive communication
among individuals requiring up-to-date technical
information.
The U.S. Environmental Protection Agency's (EPA)
Superfund Innovative Technology Evaluation (SITE)
Program was established by EPA's Office of Solid Waste
and Emergency Response and the Office of Research and
Development (ORD) in response to the 1986 Superfund
Amendments and Reauthorization Act, which recognized
a need for an "Alternative or Innovative Treatment
1-3
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Technology Research and Demonstration Program." The
SITE Program is administered by ORD National Risk
Management Research Laboratory in the Land
Remediation and Pollution Control Division (LRPCD),
headquartered in Cincinnati, Ohio. The SITE
Demonstration Program encourages the development and
implementation of: 1) Innovative treatment technologies for
hazardous waste site remediation, and 2) Monitoring and
measurement.
In the SITE Demonstration Program, the technology is
field-tested on hazardous waste materials. Engineering
and cost data are gathered on the innovative technology so
that potential users can assess the technology's
applicability to a particular site. Data collected during the
field demonstration are used to assess the performance of
the technology, the potential need for pre- and
post-processing of the waste, applicable types of wastes
and waste matrices, potential operating problems, and
approximate capital and operating costs.
1.3 The SITE Demonstration Program and
Reports
In the past technologies have been selected for the SITE
Demonstration Program through annual requests for
proposal (RFP). EPA reviewed proposals to determine the
technologies with promise for use at hazardous waste
sites. Several technologies also entered the program from
current Superfund projects, in which innovative techniques
of broad interest were identified for evaluation under the
program. Once the EPA has accepted a proposal,
cooperative arrangements are established among EPA, the
developer, and the stakeholders. Developers are
responsible for implementing and operating and/or
maintaining their innovative systems at a selected site, and
are expected to pay the costs to transport equipment to the
site, operate and/or maintain any equipment on-site during
the demonstration, and remove the equipment from the
site. EPA is responsible for project planning, sampling and
analysis, quality assurance and quality control, preparing
reports, and disseminating information.
Usually, results of Demonstration Programs are published
in three documents: the SITE Demonstration Bulletin, the
Technology Capsule, and the ITER. The Bulletin describes
the technology and provides preliminary results of the field
demonstration. The Technology Capsule provides more
detailed information about the technology, and emphasizes
key results of the field demonstration. The ITER provides
detailed information on the technology investigated, a
categorical cost estimate, and all pertinent results of the
field demonstration. An additional report, the Technology
Evaluation Report (TER), is available by request only. The
TER contains a comprehensive presentation of the data
collected during the demonstration and provides a detailed
quality assurance review of the data.
For the ECRTs G-P Log Pond Demonstration, there is a
SITE Technology Bulletin, Capsule, and ITER; all of which
are intended for use by remedial managers for making a
detailed evaluation of the technology for a specific site and
waste. A TER is submitted as verification documentation.
1.4 Purpose of the Innovative Technology
Evaluation Report (ITER)
This ITER provides information on the ECRTs process for
treatment of marine sediments contaminated with mercury,
PAHs, and phenolics. This report includes a
comprehensive description of this demonstration and its
results. This ITER includes a comprehensive description
of this demonstration and its results and is intended for use
by EPA remedial project managers, EPA on-scene
coordinators (OSCs), contractors, and other decision-
makers carrying out specific remedial actions. The ITER is
designed to aid decision-makers in evaluating specific
technologies forfurtherconsideration as applicable options
in a particular cleanup operation.
To encourage the general use of demonstrated
technologies, the EPA provides information regarding the
technology applicability to specific sites and wastes. The
ITER includes information on cost and desirable site-
specific characteristics. It also discusses advantages,
disadvantages, and limitations of the technology.
Each SITE demonstration evaluates the performance of a
technology in treating a specific waste matrix. The
characteristics of other wastes and other sites may differ
from the characteristics of the treated waste. Therefore, a
successful field demonstration of a technology at one site
does not necessarily ensure that its applicability at other
sites. Field demonstration data may require extrapolation
for estimating operating ranges in which the technology will
perform satisfactorily. Only limited conclusions can be
drawn from a single field demonstration.
1-4
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1.5 Technology Description
The ECRTs Demonstration project consisted of a
demonstration of ECRTs' process to utilizes an DC/AC
current passed between an electrode pair (anode and
cathode) in sedimentto attemptto eithermineralize organic
contaminants through an ElectroChemicalGeoOxidation
(ECGO) process, or complex, mobilize, and remove metal
contaminants deposited at the electrodes through the
Induced Complexation (1C) process as described below.
ElectroChemicalGeoOxidation: According to the
developer, by using a low voltage, low amperage
proprietary coupled DC/AC current, an induced polarization
field is created within the sediment. The sediment acts as
a capacitor, discharging and charging electricity resulting
in redox reactions, which cause desorption of the
contaminants from the sediments and mineralization of the
organics in the matrix. Empirical evidence indicates that
reaction rates are inversely proportional to grain size, such
that ECRTs remediate faster in finer-grained materials
typically found at contaminated sediment sites. The
sediment-pore water system can be considered an
electrochemical cell. In an electrochemical cell, reactions
only occur at the electrodes and comprise anodic oxidation
or cathodic reduction. However, in sediment, in addition to
the local electrode reactions, redox reactions occur
simultaneously at any and all interfaces within the
sediment-water-contaminant system at the pore scale. The
reaction partners for oxidations and reductions are
simultaneously generated by water hydrolysis.
Empirical ECRTs field remediation data of rapid
mineralization of organic contaminants including phenolic
compounds and PAHs (and enhanced mobilization rates
for metals) suggest that the secondary current released via
sediment electrical discharges provides the activation and
dissociation energy for the ensuing redox reactions.
Additionally, it is suspected that trace metals in the
sediment may act as catalysts, reducing the activation
energy required for the redox reactions. The quantification
of these energy releases remains to be completed. Since
the redox reactions are occurring at the pore scale, the
ECRTs system pH is stabilized in the neutral range.
Induced Complexation: According to the developer,
metals remediation may be achieved when redox reactions,
created by the same low voltage/amperage current
described above, desorb the contaminants from the
sediment and create ionic metal complexes that are
significantly more mobile. These more mobile ions move
readily to the electrodes, are electrically contained by the
induced direct current, and are migrated to the electrodes
where they are chemically deposited. Following treatment,
the electrodes are removed and disposed, orthe deposited
metals are recycled.
For the demonstration project, Weiss Associates,
(Emeryville, CA) installed, operated, and removed the
ECRTs pilot test equipment from the Log Pond site. Faulk
Doering, electrochemical processes (ECP; Stuttgart,
Germany) provided oversight and consultation for the
system installation and operation. Installation of pilot study
infrastructure involved placing 9 anode (steel plates) and 9
cathode (graphite plates) electrodes, in two parallel rows,
into the sediments. Each electrode row was approximately
30 feet long. The distance between the anode and cathode
sheet electrode rows was approximately 30 feet. Electricity
was supplied, in parallel, to each individual electrode plate.
1.6 Key Contacts
Additional information regarding the ECRTs process and
the SITE program are available from the following Sources:
EPA Project Manager
Randy Parker
U.S. EPA National Risk Management Research Laboratory
26 W. Martin Luther King Jr. Dr.
Cincinnati, OH 45268
(513)569-7271
E-mail: parker.randy@epa.gov
Technology Developer Contacts
Falk Doering
Electrochemical Process, L.L.C.
Burghaldenweg 51,
Stuttgart, Germany
D.70469
+49(0)711.859146
E-mail: stgt@ecp-int.com
Dr. J. Kenneth Wittle
Electro-Petroleum, Inc.
996 Old Eagle School Road
Wayne, PA 19087
(610)687-9070
E-mail: kwittle@electropetroleum.com
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Joe lovenitti
Weiss Associates
5801 Christie Avenue
Suite 600
Emeryville, California 94608
(510)450-6141
E-mail: ili@weiss.com
Information on the SITE Program is available through the
following on-line information clearinghouses:
The SITE Home page (www.epa.gov/ORD/SITE)
provides general program information, current
project status, technology documents, and access
to other remediation home pages.
The OSWER CLU-ln electronic bulletin board
(http://www.clu-in.org) provides information on
innovative treatment and site characterization
technologies while acting as a forum for all waste
remediation stakeholders.
Technical reports may also be obtained by writing to
USEPA/NSCEP, P.O. Box 42419, Cincinnati, OH 45242-
2419, or by calling (800) 490-9198.
1-6
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Section 2.0
Technology Applications Analysis
This section addresses the general applicability of the
Electrochemical Remediation Treatment (ECRTs) process,
developed by P2-Soil Remediation, Inc. (in partnership with
Weiss Associates and Electro-Petroleum, Inc.) to sites
having sediments contaminated with organic compounds,
metals, or both. The analysis is based on results from, and
observations made during, the SITE Program
Demonstration, and from additional information received
from Weiss Associate (the technology lessee that was
responsible for installing, operating, and maintaining the
ECRTs pilot test equipment at the Bellingham Bay G-P Log
Pond site). The results of this SITE Demonstration are
presented in Section 4.0 of this report. Weiss Associates
had the opportunity to discuss the applicability, other
studies, and performance of the technology in Appendix A.
2.1 Key Features of the Electrochemical
Remediation Treatment Process
There are three key features comprising the ECRTs
process. These include the following:
* Electrodes
* DC/AC Converters
* Auxiliary Equipment
Each of these components is discussed in the following
paragraphs.
Electrodes
The electrodes are typically installed as two parallel lines
of electrodes that are installed outside of the contaminated
area to be treated. The electrodes can consist of either
horizontal plates or pipes, or vertical pile sheets or pipes.
(the raw materials are shipped to the site, and then
modified). The electrode array installed at the G-P Log
Pond site consisted of steel and graphite sheets that were
electrically continuous. Each electrode row was
approximately 30 feet long and about 30 feet apart from
one another. Figures 2-1 a and 2-1 b illustrate the design
specifications for the anode (graphite) sheets and cathode
(steel) sheets, respectively. Weiss Associates estimated
weights for the steel and graphite electrodes used for the
Demonstration as 240 Ibs each and 120 Ibs each,
respectively.
The most important aspect of the ECRTs technology is the
design of the electrode array network (i.e., the number,
depth, and row length of electrodes) required for optimum
treatment. The depth of installation is dictated by the
thickness of the contaminant zone. For the Demonstration
performed at the G-P log pond, metal and graphite vertical
pile sheets were used as electrodes. The electrode array
installed for the Demonstration consisted of two 30 foot
long parallel rows of electrodes placed about 30 feet apart.
The depth of treatment extended from the top of a clean
cap (0.5 - 1 ft thick) to the bottom of a 5-6 ft thick
contaminated zone. The maximum sediment volume
treated was therefore approximately 30ftx30ftx5ft =
4,500 ft3 (167 yd3). Using a standard conversion of 1.3
tons/yd3 of sediment, roughly 220 tons of contaminated
sediment was targeted for treatment during the
Demonstration.
DC/AC Converters
P2 Soil Remediation owns the proprietary DC/AC
converters used to power the ECRTs system, and leases
the use of the converters. At least one of these DC/AC
converters, which are 480 Volt and 3 phase, are required
to powerthe ECRTs system. Forthe Demonstration at the
G-P Log Pond, a total of three DC/AC converters were
used. Each of the three power supplies powered three
anode sheets and three cathode sheets.
2-1
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3/8" Holes for
Attachment of 3/4" Holes for
Electric Wire Attachment of
Pulling Rope
7/8"
wide
3/8" Holes for
Attachment of
Electric Wire 3/4" Holes for
Attachment of
l Pulling Rope
7/8"
wide
A A
I
2'6"
GROUND TO
SHARP EDGt
PLAN VIEW CROSS-SECTION
VIEW
PLAN VIEW CROSS-SECTION
VIEW
Figure 2-1 b. Schematic of Mild Carbon Steel Plate Electrode.
Figure 2-1 a. Schematic of CS Grade Graphite Electrode.
Auxiliary Equipment
Auxiliary equipment for marine application of the ECRTs
technology may consist of a variety of electrical-related
equipment and supplies. Forthe Demonstration at the G-P
Log Pond, the following auxiliary equipment included the
following:
A resistor of about 3.5 Q was required to drive the
minimum voltage.
Epoxy sealant
Electrical meter
Shut-off-switch
Marine gauge (10-12 awg) stranded wires that
were double insulated as underwater pump cable
It should be noted that the standard field array in soil
consists of standardized 16 mm2 copper cables.
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2.2 Operability of the Technology
The ECRTs technology can be applied to soil and
sediments both in situ and ex situ. Ex situ application
would include treatment in a soil heap, which was reported
done at a site in Enns, Austria (HazTECH News, 2001).
In many cases both organic and inorganic compounds are
targeted by the ECRTs technology. When two different
types of contaminants are encountered (i.e., metals and
organics), the ECRTs system must be operated in two
different voltage and amperage domains. One domain
induces 1C for mobilizing metals and a second domain
induces ECGO for mineralizing organic contaminants to
inorganic components.
For sediment application of the ECRTs, there are two
surveys that should be conducted before installing and
operating the ECRTs system. The first is a debris survey
for determining the suitability of the site for installing the
ECRTs system components. During the Demonstration,
this survey involved advancing a pointed pole into the
sediment until refusal to determine whether any large
objects (e.g..sunken logs, pilings, etc), were submerged in
the sediment. This type of survey requires the services of
a pontoon boat.
The second survey typically required is a cathodic
protection survey, since there are typically structures in the
vicinity of contaminated sediments. Forthe Demonstration,
the Port of Bellingham required cathodic protection for
structures in the vicinity of the demonstration site to ensure
that those structures would not be susceptible to corrosion
during operation of the ECRTs. Weiss Associates provided
oversight of a contractor (Norton Corrosion Inc.), who
conducted the survey.
Initially P2 Soil Remediation is involved in system startup
by activating the DC/AC converters and adjusting and
optimizing the operating parameters.
There are specific operations and maintenance O&M
activities associated with the ECRTs system. These
include:
1. Assuring DC/AC Converter Working Status - This
is performed by looking at the meter indicating the
availability of three phase power, reading the amp
meter to determine availability of the required
amperage, and the voltmeter as to the availability
of the required voltage.
2. Making Oscilloscope Readings - performed weekly
for two channels: voltage and amperage.
3. Conducting Trouble Shooting - performed when
the Ground Fault Interrupter Switch (GFIS) has
tripped and it requires resetting, and when other
fuses have tripped requiring replacement
4. Restarting the DC/AC converter.
Generally speaking, no regulated waste streams are
produced.
2.3 Applicable Wastes
The technologies (ECGO and 1C) have been reported by
the developer as effective in unsaturated and saturated
zones in sediments for metals and organics, including free-
phase organics, except that separate groundwater
treatment is generally necessary for dissolved organics.
ECRTs' are reported as suitable for all soil types, especially
clay or silt. Specific contaminant types mentioned in case
study examples for ECGO have included TPH, BTEX,
PCE, TCE, VC, PAHs, phenols, and PCBs. For 1C, the
metals arsenic, chromium, copper, lead, nickel, and zinc
have been specified. The developer has also inferred
ECRTs to be effective on radionuclides.
2.4 Availability and Transportability of
Equipment
The ECRTs process can theoretically be implemented
anywhere that an electrode array can be installed, which
would include any location that can be accessed by
equipment needed to install the electrode sheets (e.g., a
crane).
Because the ECRTs uses proprietary DC/AC converters,
they are available for lease from P2 Soil Remediation only.
The availability of the DC/AC converters could therefore be
an issue if the numbers are limited and units are being
used elsewhere. In the specific case of the Demonstration,
three DC/AC converters were used, one of which was
shipped from Europe.
In knowing that the electrode sheets used for the
Demonstration would have to penetrate a stiff sediment
cap, graphite material suitable for driving with a
vibrohammerwas required for the Demonstration. Weiss
Associates conducted research into the material
specifications most suitable for constructing the graphite
electrode sheets. Due to a discrepancy between the type
of graphite available in Europe versus the type of graphite
available domestically a graphite plate test was conducted
on Union Carbide CS-grade graphite produced in West
Virginia. The test involved using a vibrohammer to
2-3
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determine the driving capability of the domestically-
produced graphite priorto procuring and installing graphite
sheets at the demonstration site. Thus, for marine
applications, the suitability of the electrode sheets
(especially graphite) may require investigation.
2.5 Materials Handling Requirements
During the Demonstration, the electrode plates were placed
in position by a mobile heavy lift crane with extended beam
and a vibrohammer that was operated from the adjacent
pier. The pier was evaluated for bearing load capacity to
determine if the crane could be supported. Therefore,
contaminated areas that are offshore may have to employ
a barge to mobilize a crane.
Each electrode row (e.g., anode sheet electrode line) was
approximately 30 feet long. The distance between the
anode and cathode sheet electrode lines was
approximately 30 feet. The total time of system installation
was three days. Buoys were attached to each electrode for
locating them from the surface once installed. An
underwater camera was used to confirm proper placement
into the sediment at the time of installation.
A forklift was also used during the Demonstration to move
components from the shipping truck to the pier and crane.
2.6 Site Support Requirements
Site facilities are required to store and secure various
components of the ECRTs system prior to and during
treatment. Site facilities at the Demonstration site
consisted of a shed and rented fencing to secure the area
around the shed. The Port of Bellingham's Shipping
Terminal Dock, having a load bearing capacity for
supporting a crane with an extended beam, was an
advantage for installing the electrode plates during the
Demonstration. Thus, such a pier may be a site support
requirement in certain marine applications.
Prospective sites must also be suitable for arranging for
fixed or portable electrical power. Electricity is essential, as
it is used to power the ECRTs treatment process. The
developer has reported that typical current consumed when
using their Direct Current technology to treat soil byECGO
ranges from 0.2 kWh to 3 kWh per ton of soil. Power
consumption for metals remediation by 1C is slightly higher
(Doering, et. al.,).
It should also be noted that electrical power is also required
for operating rental equipment and supplying power to an
on-site trailer. At remote sites, a generator could be used
to powerthe ECRTs system. Generatorsize would depend
on the size of the project, however 5 to 10 kW is the
minimum size requirement.
A water source may be necessary for certain ECRTs
applications. For one particular application of the ECRTs
technology at a heaped soil pile an irrigation system was
installed to humidify the soil (HazTech News, September
13 & 27, 2001). A water source may also be needed for
occasional decontamination activities.
2.7 Limitations of the Technology
The soil particle surface area and the soil to water ratio are
key parameters in determining the technologies'
effectiveness. Therefore, the soil or sediment grain size is
a potential limitation of the technology. Reaction rates are
reported to be inversely proportional to grain size, such that
ECRTs systems remediate faster in clays and silts than in
sands and gravels (Doering, et. al., 2000).
Depth and placement is limited only by the installation
technology.
According to the developer, the precipitation of metals onto
the electrodes is non-selective. If different metals compete
for precipitation, then the rate of precipitation of prospective
metals is governed by the relationship between their
different equivalent weights. The more metals competing
for precipitation results in greater decrease in precipitation
rate (F. Doering writeup, p. 33, no date). Therefore, sites
containing many metals may be more difficult or take
longer to remediate.
Use of the technology in marine environments can present
additional challenges. During the Demonstration several
system perturbations occurred which eventually lead to
stopping the project. One of the most substantial problems
was corrosion of the electrode leads. Although the
electrical wire leads were within a double insulation, the
insulation material was cracked due to movement of the
sea nearthe shoreline. Electrical readings collected by the
technology's sponsor indicated a steady degradation of
system performance throughout the duration of the
Demonstration, resulting in an early shutdown of the
system priorto completion of the planned test period. In
addition, when the electrodes were removed from the test
plot, it was evident that the connections between the
electrical supply and anode electrode plates had
completely corroded to the point that a viable contact had
not been maintained.
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2.8 ARARS for the Electrochemical
Remediation Treatment Process
This subsection discusses specific federal environmental
regulations pertinent to the operation of the ECRTs
process, including the transport, treatment, storage, and
disposal of wastes and treatment residuals. These
regulations are reviewed with respect to the demonstration
results. State and local regulatory requirements, which
may be more stringent, must also be addressed by
remedial managers. Applicable or relevant and appropriate
requirements (ARARs) include the following: (1) the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA); (2) the Resource Conservation
and Recovery Act (RCRA); (3) the Clean Air Act (CAA); (4)
the Clean Water Act (CWA); (5) the Safe Drinking Water
Act (SDWA), and (6) the Occupational Safety and Health
Administration (OSHA) regulations. These six general
ARARs, and state requirements for the G-P Log Pond site,
are discussed in the following subsections. Specific
ARARs that may be applicable to the ECRTs process are
identified in Table 2-1.
2.8.1 CERCLA
The CERCLA of 1980 as amended by the Superfund
Amendments and Reauthorization Act (SARA) of 1986
provides for federal funding to respond to releases or
potential releases of any hazardous substance into the
environment; as well as to releases of pollutants or
contaminants that may present an imminent or significant
danger to public health and welfare or to the environment.
As part of the requirements of CERCLA, the EPA has
prepared the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) for hazardous substance
response. The NCP is codified in Title 40 CFR Part 300,
and delineates the methods and criteria used to determine
the appropriate extent of removal and cleanup for
hazardous waste contamination. SARA states a strong
statutory preference for remedies that are highly reliable
and provide long-term protection. It directs EPA to do the
following:
use remedial alternatives that permanently and
significantly reduce the volume, toxicity, or the
mobility of hazardous substances, pollutants, or
contaminants;
select remedial actions that protect human health
and the environment, are cost-effective, and
involve permanent solutions and alternative
treatment or resource recovery technologies to the
maximum extent possible; and
avoid off-site transport and disposal of untreated
hazardous substances or contaminated materials
when practicable treatment technologies exist
[Section 121(b)].
In general, two types of responses are possible under
CERCLA: removal and remedial actions. Superfund
removal actions are conducted in response to an
immediate threat caused by a release of a hazardous
substance. Many removals involve small quantities of
waste of immediate threat requiring quick action to alleviate
the hazard. Remedial actions are governed by the SARA
amendments to CERCLA. As previously stated, these
amendments promote remedies that permanently reduce
the volume, toxicity, and mobility of hazardous substances
or pollutants.
The ECRTs process could possibly be part of a CERCLA
remedial action since the volume and mobility of the
contaminants of concern are intended to be reduced.
Remedial actions are governed by the SARA amendments
to CERCLA.
On-site remedial actions must comply with federal and
more stringent state ARARs. ARARs are determined on a
site-by-site basis and may be waived under six conditions:
(1) the action is an interim measure, and the ARAR will be
met at completion; (2) compliance with the ARAR would
pose a greater risk to health and the environment than
noncompliance; (3) it is technically impracticable to meet
the ARAR; (4) the standard of performance of an ARAR
can be met by an equivalent method; (5) a state ARAR has
not been consistently applied elsewhere; and (6) ARAR
compliance would not provide a balance between the
protection achieved at a particularsite and demands on the
Superfund remedial project manager (RPM) for other sites.
These waiver options apply only to Superfund actions
taken on-site, and justification for the waiver must be
clearly demonstrated.
2.8.2 RCRA
RCRA, an amendment to the Solid Waste Disposal Act
(SWDA), is the primary federal legislation governing
hazardous waste activities. It was passed in 1976 to
address the problem of how to safely dispose of the
enormous volume of municipal and industrial solid waste
generated annually. Subtitle C of RCRA contains
requirements forgeneration, transport, treatment, storage,
and disposal of hazardous waste, most of which are also
applicable to CERCLA activities.
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Table 2-1. Federal and State ARARs for the ECRTs Process.
Process
Activity
Waste Charac-
terization
Waste
Processing
Storage of
auxiliary
wastes
Determination
of cleanup
standards
Waste
disposal
ARAR
RCRA: 40 CFR
Part 261 (or the
state equivalent)
RCRA: 40 CFR
Part 264 (or the
state equivalent)
CAA: 40 CFR
Part 50 (or the
state equivalent)
RCRA: 40 CFR
Part 264
Subpart J (or the
state equivalent)
RCRA: 40 CFR
Part 264
Subpart I (or the
state equivalent)
Local
RCRA: 40 CFR
Part 262
CWA: 40 CFR
Parts 403 and/or
122 and 125
RCRA: 40 CFR
Part 268
Regulation
Description
Standards apply to
the identification and
characterization of
wastes.
Standards apply to
treatment of wastes
in a treatment facility.
Regulations govern
toxic pollutants,
visible emissions and
particulates.
Regulation governs
the standards for
tanks at treatment
facilities.
Regulation covers
the storage of waste
materials generated.
Standards apply for
treatment of
sediments.
Standards that
pertain to generators
of hazardous waste.
Standards for
discharge of
wastewater to a
POTW or to a
navigable waterway.
Standards regarding
land disposal of
hazardous wastes
General Applicability
Chemical and physical properties of waste
determine its suitability for treatment by
attenuated anaerobic dechlorination (i.e.,
the types of organic and metals
contaminants present and the grain size of
the soil/sediment determine suitability).
Standards apply to treatment of wastes at a
treatment facility (i.e., there are
requirements for operations, record
keeping, and contingency planning)
Any off-gas venting (i.e., from buildup of
VOCs, etc.) must not exceed limits set for
the air district of site. (Not likely to occur
since the) target contaminants are either
semi-volatile or non volatile).
Storage tanks for liquid wastes (e.g.,
decontamination waste) must be placarded
appropriately, have secondary containment
and be inspected daily.
Potential hazardous wastes remaining after
treatment (i.e., contaminated electrodes)
must be labeled as hazardous waste and
stored in containers in good condition.
Containers should be stored in a
designated storage area and storage
should not exceed 90 days unless a
storage permit is obtained.
Remedial actions for sediments are
required to meet local requirements ( e.g.,
the State of Washington sediment quality
standard for mercury is 0.41 mg/Kg).
Potential hazardous waste generated by
attenuated anaerobic dechlorination is
limited to drill cuttings, well purge water,
PPE, and decontamination wastes.
Applicable and appropriate for any
decontamination wastewater generated
from process. Discharge of wastewater to
a POTW must meet pre-treatment
standards; discharges to a navigable
waterway must be permitted under NPDES.
Applicable for off-site disposal of auxiliary
waste (e.g., excess sediment sample).
Specific Applicability
to ECRTs Process
Chemical and physical analyses
must be performed to determine if
waste/contaminants are suitable for
the ECRTs.
Not likely applicable to the ECRTs,
since the process not normally
conducted at treatment facilities.
Only applies to staged treatment.
When treating SVOCs and metals,
particulate emissions may contain
regulated substances. In such a
case, standards for monitoring and
record keeping apply.
If storing non-RCRA wastes, RCRA
requirements may still be relevant
and appropriate.
Applicable for RCRA wastes;
relevant and appropriate for non-
RCRA wastes.
In the case of the G-P Log Pond
the primary cleanup objective was
based on the Washington State
Sediment Management Standards.
Generators must dispose of wastes
at facilities permitted to handle the
waste. Generators must obtain an
EPA ID number prior to disposal.
No specific applicability to the
ECRTs unless groundwater
treatment specified as part of
cleanup criteria. Standards may
apply to wastewater generated from
decontaminating sediment cores
and electrode sheets that are
removed at the end of treatment.
Hazardous wastes must meet
specifictreatment standards priorto
land disposal, or be treated using
specific technologies.
2-6
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The Hazardous and Solid Waste Amendments (HSWA) of
1984 greatly expanded the scope and requirements of
RCRA. RCRA regulations define hazardous wastes and
regulate their transport, treatment, storage, and disposal.
These regulations are only applicable to the attenuated
anaerobic dechlorination process if RCRA defined
hazardous wastes are present. Hazardous wastes that
may be present include contaminated soil cuttings and
purge water generated during well installation and
development, and the residual wastes generated from any
groundwater sampling activities (e.g., PPE and purge
water). If wastes are determined to be hazardous
according to RCRA (either because of a characteristic or a
listing carried by the waste), essentially all RCRA
requirements regarding the management and disposal of
this hazardous waste will need to be addressed by the
remedial managers.
Wastes defined as hazardous under RCRA include
characteristic and listed wastes. Criteria for identifying
characteristic hazardous wastes are included in 40 CFR
Part 261 Subpart C. Listed wastes from specific and
nonspecific industrial sources, off-specification products,
spill cleanups, and other industrial sources are itemized in
40 CFR Part 261 Subpart D. RCRA regulations do not
apply to sites where RCRA-defined wastes are not present.
Unless they are specifically delisted through delisting
procedures, hazardous wastes listed in 40 CFR Part 261
Subpart D currently remain listed wastes regardless of the
treatment they may undergo and regardless of the final
contamination levels in the resulting effluent streams and
residues. This implies that even after remediation, treated
wastes are still classified as hazardous wastes because
the pre-treatment material was a listed waste.
For generation of any hazardous waste, the site
responsible party must obtain an EPA identification
number. Otherapplicable RCRA requirements may include
a Uniform Hazardous Waste Manifest (if the waste is
transported off-site), restrictions on placing the waste in
land disposal units, time limits on accumulating waste, and
permits for storing the waste.
Requirements for corrective action at RCRA-regulated
facilities are provided in 40 CFR Part 264, Subpart F and
Subpart S. These subparts also generally apply to
remediation at Superfund sites. Subparts F and S include
requirements for initiating and conducting RCRA corrective
action, remediating groundwater, and ensuring that
corrective actions comply with other environmental
regulations. Subpart S also details conditions under which
particular RCRA requirements may be waived for
temporary treatment units operating at corrective action
sites and provides information regarding requirements for
modifying permits to adequately describe the subject
treatment unit.
2.8.3 CAA
The CAA establishes national primary and secondary air
quality standards for sulfur oxides, particulate matter,
carbon monoxide, ozone, nitrogen dioxide, and lead. It
also limits the emission of 189 listed hazardous pollutants
such as vinyl chloride, arsenic, asbestos and benzene.
States are responsible for enforcing the CAA. To assist in
this, Air Quality Control Regions (AQCR) were established.
Allowable emission limits are determined by the AQCR, or
its sub-unit, the Air Quality Management District (AQMD).
These emission limits are based on whether or not the
region is currently within attainment for National Ambient
Air Quality Standards (NAAQS).
The CAA requires that treatment, storage, and disposal
facilities comply with primary and secondary ambient air
quality standards. The most likely air emissions that would
be anticipated with Harding ESE's technology would be
VOC emissions generated during drilling activities. These
potential emissions would typically be very low
concentrations and are easily monitored.
2.8.4 CWA
The objective of the CWA is to restore and maintain the
chemical, physical and biological integrity of the nation's
waters by establishing federal, state, and local discharge
standards. If treated water is discharged to surface water
bodies or Publicly Owned Treatment Works (POTW), CWA
regulations will apply. A facility desiring to discharge water
to a navigable waterway must apply for a permit under the
National Pollutant Discharge Elimination System (NPDES).
When a NPDES permit is issued, it includes waste
discharge requirements. Discharges to POTWs also must
comply with general pretreatment regulations outlined in 40
CFR Part 403, as well as other applicable state and local
requirements.
Since Harding ESE's attenuated anaerobic dechlorination
process is in situ and purge water generated during the
demonstration was discharged back to the aquifer material
(in accordance with MaDEPsite procedures), CWA criteria
did not apply for this demonstration.
2.8.5 SDWA
The SDWA of 1974, as most recently amended by the Safe
2-7
-------
Drinking Water Amendments of 1986, requires the EPA to
establish regulations to protect human health from
contaminants in drinking water. The legislation authorized
national drinking water standards and a joint federal-state
system for ensuring compliance with these standards.
2.8.6 OSHA
CERCLA remedial actions and RCRA corrective actions
must be performed in accordance with the OSHA
requirements detailed in 20 CFR Parts 1900 through 1926,
especially Part 1910.120, which provides forthe health and
safety of workers at hazardous waste sites. On-site
construction activities at Superfund or RCRA corrective
action sites must be performed in accordance with Part
1926 of OSHA, which describes safety and health
regulations for construction sites. State OSHA
requirements, which may be significantly stricter than
federal standards, must also be met.
If working at a hazardous waste site, all personnel involved
with the installation and implementation of a treatment
process are required to have completed an OSHA training
course and must be familiar with all OSHA requirements
relevant to hazardous waste sites. Workers on hazardous
waste sites must also be enrolled in a medical monitoring
program. The elements of any acceptable program must
include: (1) a health history, (2) an initial exam before
hazardous waste work starts to establish fitness for duty
and as a medical baseline, (3) periodic examinations
(usually annual) to determine whether changes due to
exposure may have occurred and to ensure continued
fitness for the job, (4) appropriate medical examinations
after a suspected or known overexposure, and (5) an
examination at termination.
For most sites, minimum personal protective equipment
(PPE) for workers will include gloves, hard hats, steel-toe
boots, and Tyvek® coveralls. Depending on contaminant
types and concentrations, additional PPE may be required,
including the use of air purifying respirators or supplied air.
For an in situ dechlorination process, noise levels would
potentially be high only during drilling activities involving the
operation of a drill rig or Geoprobe®. During these
activities, noise levels should be monitored to ensure that
workers are not exposed to noise levels above a time-
weighted average of 85 decibels over an eight-hour day.
If noise levels increase above this limit, workers will be
required to wear hearing protection. The levels of noise
anticipated are not expected to adversely affect the
community, but this will depend on proximity to the
treatment site.
2.8.7 State and Local Requirements
State and local regulatory agencies may require permits
prior to implementing an in situ technology and/or for
specifically treating sediments. Most federal permits will be
issued by the authorized state agency. Since the ECRTs
technology was implemented on marine sediments in situ,
appropriate permits were required. For example, a Joint
Aquatic Resource Permits Application (JARPA) was
required by the U.S. Army Corps of Engineers (COE) for
conducting construction work in or near the water. JARPA
can be used to apply for Hydraulic Project Approvals
(HPAs), Shoreline Management Permits, Water Quality
Certifications, and COE Section 404 and Section 10
permits. For the Demonstration project, the JARPA
application was completed prior to the SITE Program's
involvement. SITE Program personnel were additionally
required to obtain a scientific collection permit for
conducting fish community samples.
It should be noted that permitting fees are commonly
waived for government-conducted research type projects,
such as SITE demonstrations. However, For construction
projects (including remediation) the JARPA is mandatory.
If remediation is conducted at a Superfund site, federal
agencies, primarily the USEPA, will provide regulatory
oversight. If off-site disposal of contaminated waste is
required, the waste must be taken to the disposal facility by
a licensed transporter. With respect to the Demonstration,
both steel and graphite sheets were wrapped in plastic
drum liners, placed in shipping crates, and sent to a
disposal/recycling facility in Wisconsin.
Forthe Demonstration, the primary cleanup objective was
based on the Washington State Sediment Management
Standards (SMS). Based on results from a preliminary
survey, mercury was identified as the most ubiquitous and
consistently elevated contaminant relative to Washington
State SMS, Sediment Quality Standards (SQS) and
Cleanup Screening Levels (CSL) which are used in Puget
Sound to determine impacted sediments that require
remediation under State law. For mercury, the SQS and
CSL are 0.41 mg/Kg and 0.59 mg/Kg, respectively.
2-8
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Section 3.0
Economic Analysis
3.1 Introduction
The purpose of this economic analysis is to estimate costs
for commercial treatment of marine sediments
contaminated with mercury and SVOCs utilizing an in situ
Electrochemical Remediation Treatment (ECRTs) process,
developed by P2-Soil Remediation, Inc. Weiss Associates
of Emeryville, CA installed, operated, and maintained the
ECRTs pilot test equipment at the Georgia Pacific, Inc.
(G-P) Log Pond located along the Whatcom Waterway in
Bellingham Bay, Bellingham, Washington. The G-P Log
Pond is a marine embayment that served as a former log
storage and handling areaas well as a receiving water
basin for facility effluent and stormwater runoff.
The Demonstration at the G-P Log Pond was conducted
between October 2002 and January 2003. The treatment
area of the G-P Log Pond was known to contain elevated
concentrations of mercury, phenolics, and PAHs. Of these
contaminants, mercury was determined as the most
adversely contaminant affecting the sediments per State of
Washington sediment management standards. Treatment
of mercury was by Induced Complexation (1C), which
according to the developer, enhances mobilization of
metals in soils and sediments. Treatment of organic
compounds in sediments was by
ElectroChemicalGeoOxidation(ECGO), which according to
the developer, mineralizes organic contaminants to their
inorganic components.
The electrode array installed for the Demonstration
consisted of two 30 ft long parallel rows of electrodes
placed about 30 feet apart. The depth of treatment
extended from the top of a clean cap (0.5-1 ft thick) to the
bottom of a 5-6 ft thick contaminated zone. The maximum
sediment volume treated was therefore approximately 30
ftx30ftx5ft = 4,500 ft3 (167 yd3). Using a standard
conversion of 1.3 tons/yd3 of sediment, roughly 220 tons of
contaminated sediment was targeted for treatment during
the Demonstration. This volume and mass is considered
a pilot-scale sized application of the ECRTs technology.
For this economic analysis, a hypothetical site having
characteristics similar to the G-P log pond site was used to
estimate full-scale costs (Figure 3-1). As shown in this
figure, there is a fairly large zone of contaminated
sediments that are partially obstructed by two piers
comprising a boat slip. These structures would inhibit
dredging of sediment, even if permitted. Therefore an in
situ remedy, such as the ECRTs process, maybe
appropriate for such a scenario. The two electrode lines
(anode and cathode) could be installed outside of the piers
to treat an approximate 50 ft x 50 ft area. Based on an
electrode spacing similar to that used for the
Demonstration, the electrode array at the hypothetical site
is shown to consist of 14 anode sheets and 14 cathode
sheets. Assuming the sediment contamination extends to
five feet below the sediment surface, approximately 12,500
ft3 (~ 460 yd3) of sediment would need to be treated. This
correlates to about 600 tons of sediment affected by the
ECRTs process, nearly three times that amount targeted
during the Demonstration.
Costs associated with implementing the ECRTs technology
at this hypothetical site have been broken down into 12
cost categories that reflect typical cleanup activities at
Superfund sites. They include:
1) Site Preparation
Permitting and Regulatory Activities
3) Capital Equipment
4) Start-up and Fixed
5) Labor
6) Consumables and Supplies
7) Utilities
8) Effluent Treatment and Disposal
9) Residuals Shipping, & Disposal
0) Analytical Services
11) Maintenance and Modifications
12) Demobilization/Site Restoration
3-1
-------
SCALE
Cathode
Electrodes
(Steel)
Anode
Electrodes
(Graphite)
Contaminated
Sediments
Figure 3-1. Hypothetical Site Diagram.
Table 3-1 presents a categorical breakdown of the
estimated costs for implementing the ECRTs technology at
this hypothetical site over the duration of six months. As
with all cost estimates, there are associated factors, issues,
and assumptions that caveat specific cost values. The
major factors that can affect estimated costs are discussed
in subsection 3.3. The issues and assumptions made
regarding site characteristics are incorporated into the cost
estimate. They are discussed in subsection 3.4.
The basis for costing each of the individual 12 categories
in Table 3-1 is discussed in detail in subsection 3.5. Much
of the information presented in that subsection has been
derived from observations made and experiences gained
from the SITE demonstration. Other cost information has
been acquired through records obtained from the State of
Washington Department of Ecology and Department of
Natural Resources (both of which contracted Weiss
Associates), information gathered from the Weiss
Associates web site (www.weiss.com), and subsequent
discussions with Weiss Associates.
It should be emphasized that the cost figures provided for
economic analyses are typically "order-of-magnitude"
estimates, generally + 50% / -30%.
3-2
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Table 3-1. Cost Estimates for Full-Scale Application of the ECRTs Technology.1
Cost Category
Units
Unit Cost Extended Cost
1. Site Preparation
Baseline Survey (debris)
Cathodic Protection Survey
Site Facilities (Shed and Fencing)
Shipment of System Components 3
Utility hookup
2. Permitting & Regulatory Activities
Permits
Studies and Reports
3. Capital Equipment
Graphite Plates
Steel Plates
Digital Storage Oscilloscope
4. Startup & Fixed
Treatability Study
Graphite Plate Testing
System Installation
Leasing of Proprietary Converters
System Operation Services
P2 Soil Remediation Technology Fee
5. Labor
Weiss Associates 4
Sediment Sampling (4 events)
Electrode Sampling (1 event)
Boat Operator/Coring Tubes
6. Consumables and Supplies
Electrode components5
7. Utilities (Electricity) 6
8. Effluent Treatment & Disposal
9. Residuals & Disposal
Spent Electrodes 7
Contaminated Solids
10. Analytical Services
Mercury in Sediment (SW846 7471A)
Mercury in Electrodes (SW846 7471A)
SVOCs in Sediment
Total Solids
Metals in Sediment
Sample Shipments
11. Maintenance & Modifications 8
12. Demobilization/Site Restoration
Removal of Electrodes 9
Shipment of Proprietary Converters
Total Estimated Project Cost
P2 Soil Remediation Technology Fee (5% of total project cost)
Total Estimated Cost
1 Based on treatment of an approximate 12,500 ft3 of sediment (~ 460 yd3).
, Cost value totals in column are rounded to three significant digits.
3 Includes shipment of proprietary converters from Europe.
Weiss Associates labor costs listed in Table 3-2.
Includes items listed in Table 3-3.
° Electrical cost based on rate of $0.10/kW-hr.
' Based on disposal cost estimates presented in Table 3-4.
Costs consist mainly of specialized services required for sampling
Costs consist mainly of subcontractor fees for a crane and diversl
1
1
1
1
1
0
0
14
14
1
1
1
1
1
1
5%
950
160
20
4
31,700
NA
NA
NA
48
28
48
40
10
8
4
1
1
Each
Each
Each
NA
Each
Each
Each
Each
Each
Each
Fixed
Fixed
Fixed
Fixed
Fixed
of total project
Hours
Hours
Hours
Event
kW-hr
NA
NA
Drums
Each
Each
Each
Each
Each
Each
Event
Fixed
Fixed
$4,360
$5,200
$1,200
$2,100
$26,900
$0
$0
$552
$106
$900
$50,000
$4,080
$17,300
$4,500
$11,700
$4,360
$5,200
$1,200
$2,100
$26,900
$0
$0
$7,728
$1,484
$900
$50,000
$4,080
$17,300
$4,500
$11,740
cost (see totals below)
$100
$60
$60
$5900
$3,150
$0.10
NA
$10,100
$0
$35
$35
$260
$7.00
$85
$100
$12,880
$15,000
$1,600
$95,000
$9,600
$1,200
$23,600
$3,150
$3,170
$10,100
$0
$1,680
$980
$12,480
$280
$850
$800
$51,500
$15,000
$1,600
$/Cateqory2 % of Total
$39,760 10.8
$0
$10,1112 2.7
$87,620
23.8
$129,400
$3,150
$3,170
$0
$10,100
$17,070
35.1
0.9
0.9
2.9
4.6
$51,520
$16.600
$368,182
$18,500
$388,500
14
4.5
100
marine sediments and are detailed in Table 3-6.
o remove electrodes from sediments
3-3
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3.2 Conclusions
(1) The estimated cost to implement an approximate
50 ft2 ECRTs treatment system, extending to a five
foot depth to treat mercury-contaminated
sediments over a six month period is
approximately $388,500, including a 5%
technology fee assessed by P2 Soil Remediation.
(2) The largest cost components for the six-month
application of the ECRTs technology at a site
having characteristics similar to the G-P Log Pond
site are 1) Labor (35.1 %) and 2) Startup & Fixed
(23.8 %), together accounting for approximately
59% of the total cost. The other major costs, as
estimated, include Maintenance & Modifications
(14 %), Site Preparation (10.8%).
(3) The cost of implementing the ECRTs technology
may be less or more expensive than the estimate
provided in this economic analysis depending on
several factors. Such factors may include the
depth and areal extent of the contaminated
sediment, the contaminant concentration levels,
the length of treatment the level of site preparation
required, the number and size of electrodes
needed to be installed, and the level of process
monitoring required by a regulatory agency.
3.3 Factors Affecting Estimated Cost
There are a number of factors that could affect the cost of
treatment of mercury-contaminated sediments using the
Weiss ECRTs technology. The contaminant distribution
pattern will also affect the design of the electrode array
required to attain a sufficient area of ECRTs technology
coverage to treat the contaminants to acceptable levels. It
is apparent that the number of cathodes (steel plates) and
anodes (graphite plates) required for the electrode array,
and the number of samples required for characterizing
sediments have very significant impacts on treatment
costs.
3.4 Issues and Assumptions
This section summarizes the major issues and
assumptions used to estimate the cost of implementing the
ECRTs technology at full-scale. In general, the
assumptions are based primarily on billing records and
other information provided by the Washington Department
of Ecology and Department of Natural Resources, and
observations made during the Demonstration.
3.4.1 Site Characteristics
Site characteristics are an important consideration for
deciding whether the ECRTs technology is an appropriate
remedy fortreating contaminated sediments at a particular
site. First and foremost, application of the technology relies
on passing a low voltage electrical current through a zone
of contaminated soil or sediment. For this reason, the
contaminated area at the site must be well defined. In
addition, the area to be treated must be surveyed for debris
or other obstacles that could hinder installation of the
electrodes (the electrodes are driven into the sediment).
The first general assumption for the economic analysis is
that the prospective site has already been characterized as
to the extent of contamination. Thus, site characterization
costs are not included. The site characteristics used forthe
prospective site are assumed similar to the demonstration
site with respect to contaminant type and geology. The
water depth, however, is set at ten feet for the entire area
treated.
The following specific assumptions have been made
regarding the site characteristics of the hypothetical site.
1. The site is located close to shore in a sheltered
bay; and thus easily accessible by a small boat.
2. Contaminated sediment occurs at about 10 feet
belowmean sea level (msl) and extends from the
water/sediment interface to five feet below. This
well defined area enables the proper placement of
the ECRTs electrode array.
3. Contamination at the site consists primarily of
mercury, ranging in concentration from 1.0 to 500
mg/kg dry weight (similar to concentrations
detected at the demonstration site). The mercury
contaminated sediment is situated primarily in the
0 to 5 foot zone below the sediment surface.
4. Debris is minimal, as confirmed by a preliminary
survey. As a result, installation of the electrode
array will not be adversely affected.
5. Sediment is composed primarily of silt, therefore
the fine grain size is conducive to fairly rapid
treatment by the ECRTs process.
6. Unlike the Demonstration, research-oriented data
collection (e.g., benthic and fish community
samples to monitor for negative environmental
affects) is not required and thus not costed.
3.4.2 Design and Performance Factors
Basic ECRTs components include the following:
* Power Supply: DC/AC converters: 480 Volt, 3
phase; (Two were used forthe Demonstration)
>• Power Lines: Standardized 16mm2coppercables,
if required; and,
3-4
-------
> Electrodes: either horizontal plates or pipes, or
vertical pile sheets or pipes (the raw materials are
shipped to the site, and then modified).
The most important aspect of the ECRTs technology is the
design of the electrode array network (i.e., the number,
depth, and row length of electrodes) required for optimum
treatment. The depth of installation is dictated by the
thickness of the contaminant zone. For the Demonstration
performed at the G-P log pond, metal and graphite vertical
pile sheets were used as electrodes.
The following assumptions are made regarding the
electrode array installed at the hypothetical site.
1. Due to the larger area treated, the electrode array
will consist of 14 anodes (graphite sheets) and 14
cathodes (steel sheets), as opposed to the nine
anodes and nine cathodes installed at the G-P Log
Pond. However, both anode and cathode sheets
will be the same dimensions as those used during
the Demonstration (the anode graphite plates were
measured to be 72 inches long, 31 inches wide
and % to1 inches thick; the cathode steel plates
were measured to be 60 inches long, 36 inches
wide and % inches thick).
2. The steel and graphite sheets are installed to the
bottom of the contaminated sediment layer, 20 feet
below msl and five feet into the sediment. As was
the case during the Demonstration, a vibrating
head hung from a crane is used for installation.
3. All sheets will be spaced about 1/4 ft apart. The
distance between anode and cathode rows will be
approximately 45 ft.
4. The treatment duration is assumed to be six
months, which is similar to the originally planned
treatment duration for the Demonstration of
approximately 6/4 months.
3.4.3 Financial Assumptions
All costs are presented in Year 2002 U.S. dollars (unless
otherwise noted) without accounting for interest rates,
inflation, or the time value of money. Insurance and taxes
are assumed to be fixed costs lumped into the specific
costs under the "Startup and Fixed" category.
3.5 Basis for Economic Analysis
In this section, each of the 12 cost categories that reflect
typical clean-up activities encountered at Superfund sites,
are defined and discussed. Combined, these 12 cost
categories form the basis for the detailed estimated costs
presented in Table 3-1. The labor costs are grouped into
a single labor category (subsection 3.5.5).
3.5.1 Site Preparation
Site preparation includes activities necessary for preparing
the site for installing the ECRTs treatment system
components. Included in this setup phase is the non-labor
costs for conducting preliminary surveys and testing for
determining the suitability of electrode installation, setting
up a temporary trailer, shipping the system components
from the vendor storage facility to the site, and conducting
electrical setup and connections. Each of these site setup
cost components is discussed in the following paragraphs.
3.5.1.1 Baseline Surveying of Debris
A survey was conducted by a consultant, prior to the site
program demonstration project, to determine the extent of
large woody debris (i.e., sunken logs, pilings, etc). This
survey involved advancing a pointed pole into the sediment
until refusal to determine whether any large objects were
submerged in the sediment. This preliminary survey
should be conducted to determine suitability of the site for
installing the ECRTs system components.
Weiss Associates utilized a local contractor, Anchor
Environmental, to conduct the wood log debris survey. The
actual cost of this survey was reported to be approximately
$4,360 (Weiss Associates, July 2001). This total cost
included labor and materials, including the cost of renting
a pontoon boat.
Prior to the demonstration, it was necessary for SITE
Program personnel to mark (spray paint) the locations of
sampling transects on the adjacent bulkhead, pier, and
pilings. The level of effort was negligible, and not included
as part of this cost estimate, but necessary for proper
placement of the electrodes. Weiss Associates installed
two sections of PVC pipe vertically into the log pond
(visible from the surface) to provide additional visual
reference points for placing the electrodes in parallel.
3.5.1.2 Cathodic Protection Survey
The Port of Bellingham required cathodic protection for
structures in the vicinity of the demonstration site to ensure
that those structures would not be susceptible to corrosion
during operation of the ECRTs. Weiss Associates provided
oversight of a contractor (Norton Corrosion Inc.), who
conducted the survey. The cost provided by Weiss
Associates for this service was approximately $5,200.
3.5.1.3 Site Facilities
Site facilities are required to store and secure various
components of the ECRTs system prior to and during
treatment. Site facilities at the Demonstration site
consisted of a shed and rented fencing to secure the area
around the shed. Weiss associates costed the shed at
$953 and 100 feet of fencing at $225. Therefore, for this
3-5
-------
cost estimate, total cost for site facilities is estimated at
about $1,200.
3.5.1.4 Shipment of System Components
After the preliminary survey has cleared the way for
installing the ECRTs treatment system, the components of
that system must be shipped to the site. One of the major
system components of the ECRTs process are the
proprietary converters (i.e., transformers). For the
Demonstration, Weiss Associates used three converters for
operational flexibility. Two of the converters were shipped
from Europe and one was shipped from a domestic site.
For a pilot-scale system installed for the Demonstration,
Weiss has indicated that one converter would normally
suffice, but for larger sites two or more converters would be
necessary.
Forthis cost estimate, an assumption will be made that two
proprietary converters will be required for the full-scale
ECRTs system at the hypothetical site. The cost to ship
the two converters one way, including customs fees, was
approximately $1,600.
Besides the proprietary converters, other ECRTs system
components are also shipped to a site (e.g., the raw
materials used for constructing the electrodes). Materials
and components such as these were delivered to the site
by truck. Per review of Weiss Associates invoices to the
State of Washington DNR, approximately $500 was spent
on shipping supplies to the site. Forthis cost estimate this
same cost will be used for shipping components, with the
assumption that the additional electrodes and materials
required for the hypothetical site will not add any
substantial shipping costs. Thus, the total shipment costs
would total to an estimated $2,100.
3.5.1.5 Utility Hookup
The primary utility service typically required for
implementing the ECRTs technology is electricity.
Electricity is essential, as it is used to power the ECRTs
treatment process, and also is needed for specific site
activities. At the demonstration site, Weiss Associates
procured the services of an electrical contractor for
providing the 480V power supply, and for running extra DC
cable lengths required by relocation of the ECRTs'
converters 300 feet from the original planned location. The
cost for these system hookup services, up to and including
system installation, was approximately $26,900.
It should be noted that electrical power is also required for
operating rental equipment and supplying power to an on-
site trailer. At remote sites, a generator could be used to
power the ECRTs system. Generator size would depend
on the size of the project, however 5 to 10 kW is the
minimum size requirement.
3.5.2 Permitting and Regulatory Requirements
3.5.2.1 Permitting Requirements
Several types of permits may be required for implementing
a full-scale remediation. The types of permits required will
be dependent on the type and concentration of the
contamination and the regulations covering the specific
location.
Since the ECRTs technology was implemented on marine
sediments in situ, appropriate permits were required. For
example, a Joint Aquatic Resource Permits Application
(JARPA) was required by the U.S. Army Corps of
Engineers (ACOE) for conducting construction work in or
near the water. JARPA can be used to apply for Hydraulic
Project Approvals, Shoreline Management Permits, Water
Quality Certifications, and ACOE Section 404 and Section
10 permits. For the Demonstration project, the JARPA
application was completed prior to SITE Program
involvement.
In addition to the Hydraulic Project Approval (HPA)
acquired via JARPA, SITE Program personnel were
required to obtain a scientific collection permit for
conducting fish community samples. This permit cost $15
plus one hour of labor.
It should be noted that permitting fees are commonly
waived for government-conducted research projects, such
as SITE demonstrations. For construction projects
(including remediation), however, the JARPA is
mandatory. The JARPA application process helps define
which permits are required. No permits are currently
required for sediment sampling.
The total cost of acquiring licenses and permits for
installing the ECRTs system for the Demonstration was
listed by Weiss Associates at about $270. Due to this
insignificant amount, permitting related costs for this cost
estimate are considered negligible.
3.5.2.2 Other Regulatory Requirements
The costs incurred for ultimately receiving approval from
the regulatory agency to install the treatment system would
include the preparation of site characterization reports, the
design feasibility study for the treatment system, and
meetings with regulators for discussing comments and
supplying related documentation for acquiring approval for
installing and implementing the treatment technology.
Depending upon the classification of the site, certain RCRA
requirements may also have to be satisfied as well. If the
site is an active Superfund site, it is possible that the
technology could be implemented under the umbrella of
existing permits and plans held by the site owner or other
3-6
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responsible party. Certain regions or states have more
rigorous environmental policies that may result in higher
costs for permits and verification of cleanup. Added costs
may result from investigating all of the regulations and
policies relating to the location of the site; and for
conducting a historical background check for fully
understanding the scope of the contamination.
Due to the very site-specific nature of these costs, an
assumption will be made that sufficient pre-existing site
information exists. As a result, no further costs regarding
site characterization will be included in this economic
analysis.
3.5.3 Capital Equipment
Because the ECRTs technology utilizes leased proprietary
converters and the components comprising the electrode
array are mostly consumable items, there is essentially little
capital equipment associated with the technology.
However, capital equipment for this cost estimate are the
steel and graphite electrode sheets that are custom made
for this application and an oscilloscope that was needed
during the Demonstration to monitor the ECRTs system.
Graphite plates were purchased at $552 each and steel
plates were purchased at $106 each. Therefore 14
graphite plates and 14 steel plates would cost $7,728 and
$1,484, respectively. An oscilloscope (60 MHz Digital
Storage) was purchased for $900. Total estimated cost of
capital equipment is therefore approximately $10,112.
3.5.4 Startup and Fixed Costs
Startup and fixed costs typically include service-oriented
costs that are typically incurred before the actual treatment
process is initiated, and are a one time non-recurring costs
throughout the treatment duration. Based on information
provided by Weiss Associates and the State of Washington
DOE and DNR, startup costs for full scale application of the
ECRTs technology would include: 1) initial treatability
testing; 2) graphite plate testing; 3) installation of the
ECRTs electrode array; 4) rental of a proprietary power
system; 5) System Operation services; and 6) Licensing
fees assessed by P2 Soil Remediation.
3.5.4.1 Treatability Testing
It should be noted that Weiss Associates typically does not
conduct either bench- or pilot-scale treatability studies.
Pilot-scale studies may be conducted as requested by the
client or to assess the ECRTs system's performance when
unusual site conditions occur. The cost of these studies
can range from $30,000 to $300,000, depending on the
goals of the pilot-scale study and site complexity.
For the full-scale application of the ECRTs system at the
hypothetical site, an assumption will be made that some
form of initial treatability testing will be conducted in order
to justify proceeding with a 6-month treatment. The cost
will be estimated at $50,000, which is near the lower cost
range provided by Weiss Associates.
3.5.4.2 Graphite Plate Testing
Weiss Associates conducted research into the material
specifications most suitable for constructing the graphite
electrode sheets. Due to a discrepancy between the type
of graphite available in Europe versus the type of graphite
available domestically a graphite plate test was conducted
on Union Carbide CS-grade graphite produced in West
Virginia. The test involved using a vibrohammer to
determine the driving capability of the domestically-
produced graphite priorto procuring and installing graphite
sheets at the demonstration site. The actual cost of this
graphite plate test was reported to be approximately $4,080
(Weiss Associates, July 2001). This cost included
purchasing and shipping a test electrode to Weiss
Associates, purchasing miscellaneous
equipment/materials, preparing the sheet for testing,
shipping the prepared sheet for testing at a construction
yard, and interpreting/reporting the results.
3.5.4.3 System Installation
Installation of the ECRTs electrode array included the use
of subcontractors to provide a crane and vibrohammer.
Buoys were attached to each electrode for locating them
appropriately from the surface, once installed. An
underwater camera was used to confirm proper placement
into the sediment at the time of installation.
Each electrode row (e.g., anode sheet electrode line) was
approximately 30 feet long. The distance between the
anode and cathode sheet electrode lines was
approximately 30 feet. The total time of system installation
was three days. Weiss Associates has indicated the cost
for installing the ECRTs system at the Demonstration site
to be approximately $17,300.
3.5.4.4 Proprietary Power Rental
P2 Soil Remediation owns the proprietary converters used
to power the ECRTs system, and leases the use of the
converters. The approximate cost for this lease during the
Demonstration was $4,500.
3.5.4.5 System Operation Services
During the Demonstration, there was basically two types of
services utilized by Weiss directly related to the operation
of the ECRTs system. Initially P2 Soil Remediation is
involved in system startup by activating the AC/DC
converters and adjusting and optimizing the operating
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parameters. The cost for this optimization service for the
Demonstration was approximately $4,060. In addition,
Weiss Associated acquired the services of two local
electrical contractors for assisting with the operation of the
ECRTs system. These itemized costs were approximately
$5,650 and $2,030, respectively. Therefore, the total cost
of system operation services is estimated at approximately
$11,740.
3.5.4.6 P2 Soil Remediation Technology Fee
For using the ECRTs proprietary process P2 Soil
Remediation assesses a technology fee on the licensee.
Weiss Associates has indicated that this fee typically costs
5-10% of the total project cost. For this cost estimate, an
assumption will be made that the licensee fee will be a
fixed cost of 5% of the total project cost, or $18,500 as
noted in Table 3-1.
Based on the aforementioned tasks, the total startup and
fixed costs for the hypothetical full-scale ECRTs is
estimated to be approximately $87,620 plus the $18,500.
It should be noted that the P2 Soil Remediation technology
fee was waived for the Demonstration.
3.5.5 Labor
Included in this subsection are the core labor costs that are
directly associated with the ECRTs technology. Labor
costs for the Demonstration were substantial, comprising
well over half of the total cost incurred. It should be noted
up-front that the labor costs provided in the section have
been calculated using "loaded" hourly rates. Loaded hourly
rates typically include base salary, benefits, overhead, and
general and administrative (G&A) expenses.
Travel, per diem, and standard vehicle rental have not
been included in this section, nor are they incorporated into
any labor values.
Much of the labor for the Demonstration was provided by
Weiss Associates personnel. Other laborthat was used for
the Demonstration, or would be used for a full-scale
remediation, was subcontracted. Therefore, this section
has been subdivided into two subsections. The first
subsection addresses the cost of labor as provided by
Weiss Associates and the second subsection provides
other labor costs that would not typically be provided by
Weiss Associates.
3.5.5.1 Weiss Associates Labor Costs
Weiss Associates used a variety of professional disciplines,
and management and technical support for conducting the
pilot-scale Demonstration. The specific labor categories
used by Weiss Associates included the following:
* Principle II
* Principle Geologist
* Senior Associate
* Senior Project Hydrogeologist
* Field Operations Manager
* Geological Technician n
* Technical Assistant
* Contracts Manager
* Clerical Support
Weiss Associates broke their labor costs incurred during
the demonstration into the eight task categories, which are
shown in Table 3-2 along with the approximate labor costs
for each of the categories.
Table 3-2. Weiss Associates Labor Costs
Task Category
1. Procurement and Electrode Preparation
2. Kickoff Meeting / Pre-Remediation Monitoring
3. System Installation
4. System Startup
5. Management of Pilot Test and Reporting
6. Review Monitoring Data to Optimize
System Performance
7. Project Shutdown
8. System Demobilization
Total
Cost1
$15,000
$5,600
$16,000
$3,700
$18,000
$12,000
$5,900
$19,000
$95,000
1 Values rounded to two significant digits.
According to Weiss Associates, these costs are not
representative of a typical remediation project. Pilot project
laborcosts are higherdue to more intensive monitoring and
analysis of the system. Full-scale remediation operational
costs could be much lower or higher than $95K for 6
months, depending on project size and complexity. Weiss
Associates do not break these costs out separately for
full-scale projects, which are performed on a fixed-fee
basis.
Taking into account that the ECRTs system was operated
for approximately three months and that the
aforementioned cost values are the best estimates
available, these Demonstration labor costs will be
considered as suitable estimates for of a full-scale system
that would operate for six months.
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3.5.5.2 Other Labor Costs
In addition, there are also labor costs that would be
incurred by other entities, besides Weiss Associates.
Examples include the labor incurred during baseline
surveys (debris and cathodic protection), installation of the
ECRTs treatment system, and periodic sediment sampling
activities. With respect to the surveys and system
installation activities, subcontractor labor costs were
included in a lump sum subcontractor fixed cost (see Site
Preparation and Startup and Fixed Costs).
As a result, the only labor costs that can be adequately
estimated, otherthan the Weiss Associates laborcosts, are
those incurred forsediment sampling. Sampling of marine
sediments during the Demonstration was conducted by
SAIC, the EPA SITE Program contractor.
As previously discussed, an assumption has been made
that the contamination at the hypothetical site has been
fully characterized prior to installation of the ECRTs
system. During the Demonstration pilot study, sediment
samples were collected from ten locations within the test
plot; five from the extended zone of influence (adjacent to
the test plot), and five remote reference locations.
Samples were collected on four occasions including a
baseline survey prior to the Demonstration, two
intermediate monitoring events, and the final
post-demonstration event.
For a full-scale application at the hypothetical site, a
sampling scheme for collecting treatment verification
samples, similarto the one used during the Demonstration,
can be employed. Because sediments can commonly be
re-worked, there would still be the need to collect baseline
samples just prior to installation of an ECRTs electrode
array. After establishing a true pretreatment baseline, two
intermediate sampling events would be conducted (i.e.,
after a month of treatment and after 3 months of treatment),
followed by a post-treatment event just prior to removal of
the ECRTs system (i.e., 6 months or more after system
startup). Thus, there would be a total of four sampling
events. These four events are summarized as follows.
1.
2.
3.
4.
Pre-Treatment (Baseline)
1st Intermediate -1 month
2 Intermediate - 3 months
Post-Treatment - 6 months
It should be noted that during the Demonstration six
samples were collected within each individual core. This
was done because there were different sediment horizons
at the Bellingham Bay site. As a result, each sample
collected for the Demonstration represented a separate
sediment horizon. Since an assumption has been made
that there is only one sampling horizon at the hypothetical
site, sub-sampling of each 10 foot long core would not be
required. Because the sediment contaminants consist of
mercury and SVOCs, each core would be homogenized
and represent a single sample point.
For this cost analysis, it will be assumed that a four-person
sampling team can mobilize to the site, setup, sample the
10 locations, ship the samples to an outside laboratory, and
demobilize in two 12-hour days. Therefore, each of the
four sampling events would incur 112 hours of labor (i.e.,
2 days x 4 people x 12 hours + 16 hours mob/demob = 112
hours). At$60/hr, a labor cost of $6,720 would be incurred
for sediment sampling each event; thus the total labor cost
of sediment sampling over the entire four-event treatment
period is estimated at $26,880.
A boat operator, coring equipment, core tubes, and DGPS
will also be required forsediment sample collection. The
cost forthe sampling vessel equipped with sediment coring
and DGPS navigational equipment would cost
approximately $2200/day. The cost for pre-cleaned core
tubes is estimated at $150/tube, which are not considered
re-usable as they are destroyed during processing.
Therefore, an additional cost of $5,900 per sampling event
is estimated for the sampling platform and related
equipment; thus the total cost for the entire four-event
treatment period is estimated to be $23,600, not including
boat transit time to and from the site.
In addition to sampling sediments, during the
Demonstration, the actual electrodes were sampled and
analyzed for mercury. This was conducted to estimate and
compare the mass of mercury collected on the electrodes
to sediment measurements for calculation of total mercury
remediation. The metal sheets were sampled by scraping
with a stainless steel chisel, and collecting the scraped
powder in sample jars. For the graphite sheets, a 1/4 inch
diameter plug was drilled and used as a sample. The
electrode samples were treated as a soil sample and
digested via the same method (SW-846 method 7471).
For a full-scale remediation, this type of sampling is
assumed necessary to verify that mercury did indeed
accumulate onto the electrodes. This would be a one time
occurrence. Forthis cost, an assumption will be made that
two people could sample all 28 electrodes in one 10-hour
day. Thus, at the same $60/hr rate, the estimated labor
cost would be $1,200 for this task.
3.5.6 Consumables & Supplies
The electrode array is primarily constructed of locally-
purchased components. The majority of these components
can be considered consumable items, as they are
purchased as dedicated equipment that is typically
customized for the specific site application. Weiss
Associates provided a cost for the pilot-scale electrical
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system components that were itemized in their cost
estimate. These costs are provided in Table 3-3.
It should be noted that the $3,150 cost value for the
electrode array supplies may be low for a full scale system,
since the electrode supply cords will need to be longer for
reaching 14 anodes and 14 cathodes of equal spacing.
However, the difference is assumed minor for this cost
estimate. It should also be mentioned that other
miscellaneous supplies typically would be needed for such
a project (e.g., sample core tubes), however due to their
direct association with other cost aspects, these supply
costs are included within the labor cost category.
Table 3-3. Electrical System Components Costs.
ITEM
Wire, 12awg 1
Wire, 8 awg 1
125 A Cable
Cord, 8 awg
Misc. Electrical
Epoxy Sealant
Meter, kW Hr
Shut-off-Switch
Insulation Mat.
Safety Supplies 2
Thermal Printer
QTY
250ft
300ft
1 roll
60ft
1
1
1
1
1
1
1
UNIT COST
$1.00/ft
$3.00/ft
$100/Ea
$0.23/ft
$500
$200
$200
$100
$240
$250
$400
Total
ITEM COST
$250
$900
$100
$13.80
$500
$200
$200
$100
$240
$250
$400
$3,150 3
I Wire is marine grade
Includes signs,FPE, etc.
3 Total rounded to three significant digits.
3.5.7 Utilities
The main utility required for the ECRTs treatment system
is electricity. At the Bellingham Bay site the electrical
hookup and service were provided by G-P. The electricity
provided the AC/DC current that passed between the
electrode pair (anode and cathode). The developer has
reported that typical current consumed when using their
Direct Current technology to treat soil and by ECGO ranges
from 0.2 kWhto 3 kWh perton of soil. Power consumption
for metals remediation by 1C is slightly higher (Doering, et.
al.,).
Although, actual records for electrical usage were not
obtainable for the shortened 8-week operational period
during the Demonstration, Weiss Associates did provide an
electrical usage cost estimate of $3,170 in their cost
proposal. This estimate was based on a rate of $0.10/kW-
hr and assumed that the ECRTs system would be
operational for six months.
It should be noted that electricity cost can vary greatly
depending on geographical location.
Other utilities that may add nominal costs to a remediation
project are communications and lavatory facilities. During
the Demonstration, Weiss Associates passed on certain
utility type costs to the Department of Ecology. These
included pager, cell phone, and photocopier usage costs
and rental of a laptop. These costs are not included in this
cost estimate.
3.5.8 Effluent Treatment and Disposal
For this technology there is no effluent. Therefore, it is
assumed that there will be no effluent treatment and
disposal expense. Disposal of small amounts of
decontamination wastewater generated from cleaning
sampling equipment is considered negligible and not
included in this cost estimate.
3.5.9 Residuals Shipping and Disposal
During the Demonstration, the primary residual generated
by the ECRTs process was the spent electrodes. Due to
the nature of the process, mercury is deposited on the
electrodes. As a result the electrodes must either be
processed following treatment to remove hazardous
mercury or disposed of as hazardous waste. Although
Weiss Associates has indicated that the mercury plated on
the sheets could potentially be recovered and recycled
(thus rendering the sheets reusable), this was not done for
the Demonstration. This was likely due to the poor
condition of the electrodes upon removal.
SITE demonstration personnel used a stainless steel chisel
to scrape off material accreted to the surface of the steel
plates and used a hole-cutting drill bit to collect solid plugs
from the graphite plates as samples. Following this
processing of electrodes, both steel and graphite sheets
were wrapped in plastic drum liners and given back to
Weiss Associates. G-P incurred the cost of disposing of the
electrodes. Weiss Associates costed the disposal of their
electrodes in their SOW, based on an estimated weight of
the electrodes (Table 3-4).
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Table 3-4. Estimated Electrode Disposal Costs.
ITEM
Electrodes 1
Shipping 2
DOT-approved
shipping crates
QTY
2.9 tons
1
5
UNIT COST
$2,500/ton
$1,300/trip
$300/Ea
Total
ITEM COST
$7,250
$1,300
$1,500
-$10,100
I Include steel and graphite plates, and plated mercury.
2 From Seattle, WAlo Union Grove, Wl.
Weiss has provided the approximate weights for the steel
and graphite electrodes as 240 Ibs each and 120 Ibs each,
respectively. However, in their SOW, they estimated that
the 18 electrodes with plated mercury would weigh about
1.88 tons. Since the hypothetical site utilizes a total 14
steel and 14 graphite electrodes, proportionately the total
weight of these 28 electrodes and plated mercury would
correlate to about 2.9 tons. The disposal cost was quoted
at $2,500/ton, thus the estimated disposal cost is $7,250.
Assuming that this tonnage could still be shipped in one trip
in 5 DOT-approved shipping crates, the total disposal cost
of the electrodes is approximately $10,100.
Other than the electrodes, the other waste stream was
excess sediment samples. G-P took responsibility for
properly disposing of excess sediment. The cost of
sediment disposal is not included in this cost estimate.
3.5.10 Analytical Services
Although the demonstration site contained both organic
and inorganic contaminants, mercury was of prime interest
since its concentrations were consistently above
quantitation limits and were found to be less variable within
the test location. During the pilot-scale Demonstration of
the ECRTs treatment system, the SITE Program performed
four separate sediment sampling events between August
2002 and March 2003. Six samples were collected from
each sediment core including three separate vertical
composite samples from the contaminated horizon (i.e.,
top, mid, and bottom third of material between the cap and
native material); one composite over the length of the
contaminated horizon (i.e., equivalent to compositing the
three vertical samples together); one cap sample; and one
native material sample. Select samples were either
submitted for analysis of mercury, PAHs, phenolic, and
sediment conventional analyses (organic carbon, total
solids, and grain size distribution), or archived (frozen).
The level of testing required to substantiate successful
treatment at full-scale site (i.e., at the hypothetical site) is
assumed to be significantly scaled down from the SITE
Demonstration sampling plan. The ECRTs technology at
the demonstration site was planned to attain the treatment
goals within QV2 months but was discontinued after eight
weeks. For this cost analysis, a treatment period of six
months is assumed and the four-event sampling schedule
discussed previously (see 3.5.5.4) will be considered of
adequate frequency to monitorthe treatment effectiveness.
Although the site owner or the site owner's contractor
would likely collect these samples, the state or local
regulatory agency may require independent analysis of the
samples by an outside laboratory (especially for final
post-treatment samples). It will also be assumed that for
the four-event monitoring schedule there will be four
analytical parameters. These parameters include mercury,
PAHs, total solids (which is a requirement of the Puget
Sound Estuary Program), and metals. These parameters
are either deemed essential or are believed to provide the
most useful information regarding the technology
effectiveness.
Table 3-5 provides an estimate for the cost of analytical
samples using the four-event sampling scenario. This
estimate assumes that the only analyses requiring
MS/MSD QA analyses are mercury and SVOCs, the
primary contaminants.
Table 3-5. Estimated Analytical Costs.
Analysis
Samples
per event
# of Events
Total Sediment
Samples
Electrode Samples
Cost/Sample
Total Cost
Mercury
12*
4
48
28
$35
$2,660
SVOCs
12*
4
48
—
$260
$12,480
Total
Solids
10
4
40
—
$7
$280
Metals
10
1
10
—
$85
$850
* Includes one MS and one MSD analysis.
Typical mercury analysis cost, along with percent-moisture
for dry-weight calculation is approximately $35. The
resulting total of 76 sediment/electrode samples, analyzed
for total mercury at an estimated $35 per sample, would
cost $2,660. The resulting total of 48 PAH analyses (using
the method used during the demonstration) would cost an
estimated $260 per sample and total approximately
$12,480. The 40 Total Solids analyses estimated at $7
each, would total $280. Total Metals analyses estimated
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at $85 each, would total $850. Thus, total analytical costs
are estimated at approximately $16,270.
Assuming that one laboratory would conduct all four
analyses, two overnight sample shipments are estimated
for each sampling event (i.e., one per sampling day).
Conservatively assuming the eight shipments would cost
$100 each, total sample shipping costs would total $800.
Total analytical services costs (including shipping costs) for
the 6-month treatment scenario is thus estimated at
$17,070.
3.5.11 Maintenance and Modifications
According to Weiss Associates general maintenance
activities associated with the ECRTs system includes
checking and recording electrical parameters, adjusting
equipment operation, and tracking chemical data analysis.
With respect to the operational performance of the ECRTs
system, oscilloscope readings are routinely performed
weekly for two channels: voltage and amperage. If the
system ground fault interrupter switch (GFIS) trips, it
requires resetting. Tripped fuses require replacing. If
either maintenance or modification of the actual ECRTs
electrode array system is required, the system is powered
down using a sequential protocol by an ECRTs-trained
technician.
The tracking of chemical data was conducted by the SITE
Program for the Demonstration, but for a full-scale
remediation the cost would typically be incurred by the site
owner. Sampling activities for monitoring sediment
contaminant concentrations can thus be categorized as
maintenance and would constitute the largest cost
component of this category. As previously mentioned, due
to the research-oriented nature of SITE project evaluations,
monitoring costs are relatively high (i.e., there were a total
of six sampling events planned for the Demonstration at
Bellingham Bay). Forthe hypothetical site discussed in this
economic analysis, four sampling events are assumed and
would occur over a 6-month treatment period.
The labor cost incurred for tracking chemical data (i.e.,
sampling activities) has been discussed in subsection
3.5.5., however, more significant costs include the
specialized services required to collect marine sediments.
Table 3-6 presents the actual costs for monitoring
sediments during the Demonstration for each sampling
event. These costs are assumed to be similar to the
hypothetical site scenario with the exception that the
number of sampling days per event forthe hypothetical site
has been halved from four to two in order to account forthe
decreased number of discrete samples collected.
Table 3-6. Estimated Sediment Monitoring Costs.
Cost Item
Mob/Demob. 1
Coring Services 2
DGPS Positioning 3
Core Tubes 4
Crew Per Diem 5
Cost/Unit
$4,250 (fixed)
$2,075/Day
$200/Day
$145/tube
$200/Day
No. Of
Units
NA
2
2
24
3
Total Cost Per Event
Total Cost for Four Events
Extended
Cost
$4,250
$4,150
$400
$3,480
$600
$12,880
$51,500
1 For the Demonstration, a boat was trucked from near Tacoma, WA
to Bellingham Bay. Similarcosts are assumed forthe hypothetical site.
, Includes daily use of boat, deck hands, and coring equipment.
I DGPS = Differential Global Positioning System.
Includes both materials and labor to decontaminate core tubes.
Per Diem cost includes two crew members..
As shown in Table 3-6, the specialized services required
for conducting marine sediment sampling is estimate to
cost $12,880 per event and total to an estimated $51,500
for all four events.
In addition to tracking chemical data, the SITE Program
also conducted voltage probe measurements during the
Demonstration to determine the spatial extent of the zone
of influence of the ECRTs (a secondary objective of the
Demonstration). This monitoring involved probing the
sediment bottom with a custom designed 3" diameter pole
with a con-shaped tip, charged with a current. The
treatment area was probed for changes in voltage. This
type of monitoring was more research oriented and would
not typically be conducted fora remediation project. Thus,
costs for this specialized monitoring are not considered.
3.5.12 Demobilization/Site Restoration
Demobilization and Site restoration are performed at the
conclusion of the treatment project. Although site
restoration can be an ongoing activity related to certain
remediation technologies, for the ECRTs technology it is
assumed that site restoration will consist primarily of
removing the electrodes from the sediment bottom and
either shipping the used components back to a storage
facility for maintenance or properly disposing them.
Weiss Associates subcontracted a crane for removing the
electrodes from the sediment via the pier, and has
indicated that the cost of this operation to be $15,000. The
majority of these costs consisted of subcontractor fees for
a crane and divers to remove the electrodes from the
sediments (the divers were on standby to aid with electrode
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removal, but were not needed). After they were removed,
photographs were taken of the electrodes and each was
identified and labeled.
In addition to the electrode removal cost, an assumption
will be made that the proprietary converters will be shipped
back for the same cost as they were delivered, which was
$1,600. Thus, the total cost Demobilization/Site Restoration
is estimated at $16,600.
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Section 4.0
Demonstration Results
4.1 Introduction
This section summarizes information on the performance
and effectiveness of the ECRTs process, as evaluated by
the SITE Program. The SITE Program was created in
order to develop, demonstrate, and establish the
commercial potential of innovative technologies fortreating
wastes found at Superfund and other hazardous waste
sites across the country. Through SITE Demonstrations,
USEPA acquires the data necessary to properly consider
innovative technologies in the remedial action
decision-making process. If tested successfully, these
technologies become alternatives to less attractive, more
costly forms of remedial action. The general study design
and basis for the data collection efforts are detailed in the
Quality Assurance Project Plan for the ECRTs Puget
Sound Site Demonstration (SAIC 2002a) and the technical
memoranda dated March 7, 2003, "Sampling and analysis
of electrodes upon removal following the ECRTs
Demonstration Project at the G-P Log Pond, Bellingham,
I/I/A"(SAIC 2003).
4.1.1 Project Background
The Electrochemical Remediation Technology (ECRTs)
process, developed by P2-Soil Remediation, Inc. for the
treatment of marine sediments contaminated with mercury,
PAHs, and phenolic compounds was tested during this
demonstration. The demonstration of the ECRTs process
took place at the Georgia Pacific, Inc. (G-P) Log Pond
located adjacent to the Whatcom Waterway navigational
channel in Bellingham Bay, Washington. The ECRTs
process utilizes a DC/AC current passed between an
electrode pair (anode and cathode) in sediment. According
to the developer, remediation of the sediment is
accomplished by either the mineralization of organic
contaminants through the ElectroChemicalGeoOxidation
(ECGO) process, or by use of the Induced Complexation
(1C) process to complex, mobilize, and remove metal
contaminants plated to the electrodes. The pilot study was
designed to assess and evaluate the ability of the ECRTs
process to reduce concentrations of PAHs, phenolic
compounds, and mercury.
Pre-demonstration data were collected to determine the
relative concentrations and variability of the contaminants
noted above. A test plot area was established as a
potential location for the ECRTs treatment. A reference
area was established to determine natural attenuation of
the contaminants of concern over the course of the
treatment period. Results of this sampling effort for both
the test plot and reference area locations are presented in
a separate report (SAIC 2002b) and discussed in Section
4.2.1. In summary, elevated concentrations for
contaminants of concern were detected in both the test plot
and reference area locations. Mercury and phenolic
compounds were detected in comparable concentrations at
both the test and reference area locations. PAH
concentrations were higher in the test plot than the
reference location. In addition, concentrations for most of
the contaminants of concern, with the exception of
mercury, were highly variable and often below method
detection and/or quantitation limits. Mercury
concentrations were consistently above quantitation limits
and were found to be less variable within the test location,
however, overall mercury concentrations were still
considered to be heterogeneous. Therefore, while the
demonstration included testing for all contaminants of
concern, as noted above, mercury was the only
contaminant considered critical for purposes of the
demonstration and for purposes of preparing a statistical
experimental design in relation to the project primary
objective. PAH concentrations below method detection
and/or detection limits and higher PAH concentrations in
the test plot (test and reference plots are not comparable)
precluded an inferential test of treatment effectiveness.
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Primary and secondary objectives associated with all
parameters are presented in section 4.1.2.
The ECRTs designated project area was approximately a
50-foot (ft) by 50-ft plot within the G-P Log Pond.
Installation of ECRTs infrastructure involved placing 9
anode (steel plates) and 9 cathode (graphite plates)
electrodes, in two parallel rows, into the sediments. Each
electrode row was approximately 30 feet long. The distance
between the anode and cathode sheet electrode rows was
approximately 30 feet. Electricity was supplied, in parallel,
to each individual electrode plate. The actual area for
sample collection was a 20-ft by 30-ft zone located within
the treatment plot, to allow a 5-foot buffer zone between
sampling locations and the installed electrodes.
4.1.2 Project Objectives
The primary goal of the SITE Program is to develop reliable
performance and cost data on innovative, field-ready
technologies. A SITE Demonstration must provide detailed
and reliable data so that potential technology users have
adequate information to make sound judgements regarding
an innovative technology's applicability to a specific site,
and to be able to compare the technology to other
conventional technologies. This section presents the goals
and objectives for the ECRTs demonstration.
In accordance with QAPP Requirements for Applied
Research Projects (EPA,1998), the technical project
objectives for the Demonstration were categorized as
primary and secondary. Primary objectives are those goals
that support the developer's specific claims for the
technology demonstrated. These objectives are usually
evaluated using both descriptive and inferential statistical
analyses. Secondary objectives are also in support of
developer claims, however, the data analysis associated
with these objectives are considered less rigorous. Critical
data support primary objectives, and non-critical data
support secondary objectives. Primary objectives required
the use of quantitative results to draw conclusions
regarding technology performance. Secondary objectives
pertain to information that is useful, and did not necessarily
require the use of quantitative results to draw conclusions
regarding technology performance.
4.1.2.1 Primary Technical Objective
The primary technical objective was to determine whether
there was a significant trend in the reduction of mercury
over the period of the demonstration. A reduction
percentage of 50% with a confidence level of being able to
statistically determine this reduction set at 90% was used
to better determine the number of samples needed from
each sampling event. The primary objective was not
associated with a percent reduction, but instead, the
primary objective was to determine a statistically significant
negative trend overtime.
4.1.2.2 Secondary Objectives
Several additional project objectives were associated with
the evaluation of the ECRTs process at the G-P Log Pond.
These secondary objectives were defined as having an
important role in determining the potential applicability and
suitability of the technology for marine sediments. Ancillary
data collected to achieve these goals are described below:
Determine the rate of organic compound
mineralization (i.e. reduction) by the collection and
analysis of test plot samples for PAHs/SVOCs
during multiple sampling events;
Assess potential vertical migration of contaminants
through the evaluation of data from samples
collected over discrete depth intervals and
analyzed for PAHs/SVOCs and mercury;
Determine the extent of the zone of influence of
the ECRTs process through the spatial
measurement of electric potential and collection of
contaminated samples outside the immediate area
of the test plot;
Track natural attenuation changes in contaminant
concentrations by sampling/analysis of a reference
area located outside the ECRTs's zone of
influence;
Evaluate possible environmental effects of ECRTs
including benthic infauna effects and possible
behavioral effects on sensitive fish by a series of
measurements (e.g., benthic infaunal sampling,
purse seining, and underwater video);
Evaluate potential contaminant flux across the
water-sediment interface by the evaluation of cap
chemistry;
Evaluate migration of mercury towards electrodes
by determining the mass of mercury collected on
electrodes at the end of the demonstration;
Determine field scale costs to implement the in-situ
sediment technology in marine sediments (results
are presented in Section 3).
4.1.2.3 Data Types
Several different data types were identified to meet the
primary technical objective and secondary objectives
described above. Data needs included sediment
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chemistry, biological data, and otherdata such as electrical
field measurements, cost information, and calculation of the
mercury mass adhered to the electrodes at the end of the
demonstration. These data were then classified as being
critical (data needed to meet primary objective) or
non-critical (data needed to meet secondary objectives).
Table 4-1 summarizes the evaluation method forthe critical
primary objective and the non-critical secondary objectives.
4.1.2.4 Project Schedule
The ECRTs demonstration was originally scheduled to
operate for a six-month period; from September 2002 until
February 2003. The demonstration period was scheduled
based upon ecological constraints of being able to operate
the process within the WDFW'fish window", designated for
the protection of migrating salmonids. The demonstration
period forthe ECRTs project actually ran from September
19, 2002 to March 17, 2003, however the effective
operating phase of the ECRTs electrodes was significantly
less due to operational problems associated with
maintaining electrical connections to the system. The
demonstration period was to incorporate several data
collection efforts to monitor and assess the ECRTs
performance including a baseline, final, and three
intermediate sampling events. The third intermediate
sampling event was canceled due to operational difficulties
with the ECRTs system. The dates of the data collection
efforts and major project milestones were as follows:
Field Event
Pre-demo. sampling
Baseline sampling
ECRTs installation
ECRTs process initiation
1st Intermediate sampling
2nd Intermediate sampling
Process termination
3rd Intermediate sampling
ECRTs removal
Post-demo, sampling
Date(s) of Event
May 29-31 , 20021
August 1 9-22, 20022
Sep. 17-18,2002
Sep. 19,2002
November 1-5, 20023
Dec. 9-13,2002
March 17,2003
Cancelled4
April 1, 2003
March 18-21 /April 1-2, 20035
1 Pre-demonstration sampling conducted to verify contaminant concentrations at the
demonstration site and provide data to develop the study design. Potential
reference locations were also investigated, but data was not included forthe ECRTs
evaluation.
2 Baseline sampling was conducted prior to the installation of the ECRTs system
largely due to schedule and logistical constraints.
3 The first intermediate sampling event was originally scheduled to commence two
weeks following the installation and initiation of the ECRTs process. Equipment
issues related to the power supply delayed the initiation of the demonstration
project.
4 This sampling effort was canceled due to the termination of the ECRTs process.
5 The post-demonstration sediment sampling effort was conducted in March prior to
the removal of the electrodes. The electrodes were sampled subsequent to their
removal in April.
4.2 Field Activities
This section describes the various data collection efforts
that were conducted prior to, during, and following the
ECRTs demonstration project. The results of the
Pre-demonstration activities are discussed relative to their
implication on the study design developed for evaluating
the ECRTs process. The results for all other data
collection efforts are discussed in Section 4.3. Detailed
descriptions of the sampling methods are provided in the
project QAPP (SAIC 2002a).
4.2.1 Pre-Demonstration Activities
In May 2002, pre-demonstration characterization sampling
and analysis was conducted. The pre-demonstration
sampling and analysis was designed to accomplish two
main objectives: 1) to delineate and characterize the
contaminant levels, including the vertical distribution of
contaminants, in the area designated as the test plot; and
2) to determine the location of a reference (no-treatment)
area to be monitored during the demonstration.
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Table 4-1 . Summary of Demonstration Objectives & Methods of Evaluation.
Objective
Description
Method of Evaluation
Primary Objective (Critical)
Objective 1
Determine whether or not there is a decreasing
trend in mercury concentration over duration of the
demonstration.
The rate parameter will be estimated and a 90% confidence
interval around the rate parameter will be constructed. The
confidence interval will be used to determine if there is a
statistically significant decreasing trend.
Secondary Objectives (Non-Critical)
Objective 2
Objective 3
Objective 4
Objective 5
Objective 6
Objective 7
Objective 8
Objective 9
Objective 10
Determine the rate of organic compound
mineralization.
Assess potential vertical migration of contaminants
Determine the extent of the zone of influence of
the ECRTs.
Assess the zone of influence for the
demonstration.
Track natural attenuation changes in contaminant
concentrations.
Evaluate possible environmental effects of ECRTs
including benthic infauna effects and possible
behavioral effects on sensitive fish.
Evaluate potential contaminant flux across the
water-sediment interface.
Evaluate migration of mercurytowards electrodes.
Determine field scale costs to implement the
in-situ sediment technology in marine sediments.
Collection and analysis of test plot samples for
PAHs/SVOCs.
Evaluation of data from samples collected over discrete
depth intervals including the cap and native material and
analyzed for PAHs/SVOCs and mercury.
Spatial measurement of electric potential.
Taking core samples outside the immediate area of the test
plot.
Sampling and analysis of a reference area (control plot)
outside the ECRTs zone of influence.
Biological monitoring including benthic infaunal sampling and
purse seining
Evaluation of cap chemistry.
Determining the mass of mercury collected on electrodes at
the end of the demonstration.
Details are provided in the economic analysis (Section 3.0).
Core samples were collected from six locations within the
test plot area and were analyzed as composites of the
material below the cap and above the native material (i.e.
the contaminated sediment horizon). Additionally several
cores were analyzed by collecting separate samples from
up to three distinct intervals determined by dividing the
contaminated sediment horizon evenly into thirds (top,
middle and bottom). Results for detected parameters,
concentration ranges and applicable SMS CSL limits are
presented in the demonstration QA Project Plan (SAIC
2002a).
The sediment conventional parameters analyzed included
total solids, total organic carbon (TOC), total sulfides, and
grain size distribution. Total sulfide concentrations ranged
from 2.8 mg/kg in native material to a high of 1870 mg/kg
within the contaminated horizon. The percentage of TOC
was consistently lower in the cap and native material
horizons (0.12 to 0.43%) than in the contaminated horizon
(4.75 to 19.2%). The grain size distribution of the cap and
native material samples consisted mostly of medium to
coarse sand, whereas the contaminated horizon consisted
primarily of fines (silt and clay). The visible difference in
grain size composition, as well as texture, consistency, and
color were the distinguishing factor for discerning the
horizons during core processing. The analytical results for
conventional and chemical parameters verified that visual
observations were adequate for distinguishing the sediment
cap, contaminated sediment horizon, and native material.
The SMS metals analyzed included arsenic, cadmium,
chromium, copper, lead, mercury, silver, and zinc. Mercury
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is the primary contaminant of concern for metals at the G-P
Log Pond Site. Mercury was detected at concentrations
ranging from 1.02 to 456 mg/kg dry wt., exceeding the
Cleanup Screening Level (CSL) of 0.59 (mg/kg dry wt.) in
all samples from the contaminated horizon. In general,
mercury concentrations were higher in the upper sediment
horizons.
Numerous semi-volatile organic compounds (SVOCs) (e.g.
4-methylphenol, acenaphthalene, fluorene) were detected
at concentrations exceeding SMS criteria in the
contaminated horizon. SVOCs, however, were not found
in the cap or native material samples at concentrations
exceeding SMS criteria. In general, SVOCs below method
detection and/or detection limits and higher SVOCs in the
test plot (test and reference plots are not comparable)
precluded an inferential test of treatment effectiveness,
therefore, SVOCs were considered non-critical for
purposes of the demonstration.
Multiple locations were evaluated to ascertain the location
of a suitable area for the reference plot for the pilot study.
Core samples were obtained from areas of similar cap
thickness relative to the test plot, and visible comparisons
were made to cores collected from the test plot. Those
having geophysical characteristics similarto cores from the
test plot were composited and sent for analysis, along with
samples analyzed to assess vertical heterogeneity.
Concentrations of mercury in the chosen reference areas
were more variable than in the test plot but were still
considered to be relatively similar. The average mercury
concentration in composited cores over the entire depth
strata was around 5 mg/kg dry wt. but concentration in one
vertical horizon was as high as 456 mg/kg dry wt.,
suggesting that this area also had high concentrations of
mercury, comparable to those in the test plot. As with the
test plot, PAH and phenolic concentrations were highly
variable and at much lower concentrations. Additional
sampling during the demonstration provided more definitive
concentrations of contaminants, however, the preliminary
pre-demonstration data suggested that reference area
locations would provide insight as to the potential for
natural attenuation compared to active remediation via the
ECRTs process.
4.2.2 Sample Collection and Analysis
The collection of representative samples during the
Demonstration was vitally important to the achievement of
project objectives. Environmental samples were collected
to examine the following relative to the ECRTs process:
changes in contaminant concentrations and potential
mobility, benthic infaunal community changes, effects on
the fish community structure, the size and relative strength
of the electric field, and to monitor for possible behavioral
effects on electro-sensitive fish.
Sediment sampling activities were conducted during the
baseline, intermediate and final events for chemical
analyses. Non-critical data types including sediment grabs
for benthic infauna analyses, purse seining for fish
community identification and enumeration. Electrical field
measurements were collected during the baseline and
intermediate events, but several measurements were
discontinued due to operational limitations of the ECRTs
process and cost-saving measures.
Underwater video transect for observing fish behavior was
originally proposed as a monitoring technique, but was
discontinued as not feasible because of the limited visibility
within the Log Pond. The underwater video was used to
examine the installation of the electrodes, to ensure the
electrodes were all placed below the sediment surface.
A voltage probe to determine the extent of the electric field
generated by the ECRTs was originally part of the
demonstration field-monitoring plan but was not executed
as part of the evaluation at the request of the Developer
because of the proprietary nature of the voltage
measurements. Due to cost implications relative to overall
project objectives; the benthic flux (contaminant mobility at
the sediment-water interface) evaluation was removed from
the project scope priorto the baseline data collection effort.
Therefore, no samples were collected specifically for
determining potential benthic flux.
4.2.2.1 Sampling Platform and Positioning
Field sampling efforts involving sediment core collection
and electric field measurements were conducted using the
R/V Nancy Anne, owned and operated by Marine Sampling
Systems of Burly, WA. The R/V Nancy Anne is specially
designed and equipped for collecting sediment cores
including a powerwinch, a bow-mounted A-frame, custom
vibracorer, vertical core storage, and a core-cutting stand.
Biological monitoring (purseseining, underwatervideo, and
benthic grabs) was conducted using a small open vessel
equipped with an outboard motor operated by SAIC
personnel. The small sampling vessel is equipped with a
processing table for handling seining nets and a power
davit for deploying the benthic grab sampler.
Navigation and positioning was accomplished using
Differential Global Positioning System (DGPS), which
provided accurate positions (±2 meters in real-time) with a
rapid positional update (e.g., every 3 seconds or less). The
DGPS employs a receiver which tracks and times signals
emitted by satellites orbiting the earth, a Coast Guard
reference beacon located in the vicinity of the survey area,
and a shipboard receiver. The receiver deployed at the
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Coast Guard reference beacon (horizontal control point)
was used to correct for Selective Availability (SA) (satellites
emit an encrypted signal designed to degrade the accuracy
for non-military users by dithering the time code embedded
in the signal). This receiver calculates position based on
the satellite signals and compares the calculated position
to the known position at the horizontal control point. A
positional offset of correction factor is calculated and
transmitted to the shipboard GPS receiver, which applies
the correction factor to calculate the corrected vessel
position. All station coordinates were recorded by latitude
and longitude to the decimal minute.
To ensure the accuracy of the system, several survey
control points were used from previously surveyed
locations including a pierface, dock, and piling, of which all
were accessible by the sampling vessel. A DGPS reading
was taken twice daily, before and after sampling activities,
at the control point, and compared to the surveyed
coordinates. The position reading and surveyed
coordinates were within a plus or minus two-meter
accuracy.
Additionally, sampling locations within the test plot,
"reference marks" were painted on the pier and bulkhead
located adjacent to the test plot. Markings were made
during baseline sampling in order to provide a visual
reference point for subsequent sampling events. These
were compared with real-time GPS readings and plotted
target sampling locations, graphically displayed on the
shipboard navigation computer. While not exact, this
provided sufficient accuracy for returning to the same
location for all subsequent sampling events and for
placement of the electrode array. It should be noted that
GPS positioning at sea is less accurate than continuous
readings collected from a stable land-based location, due
to the inherent difficulties of maneuvering and positioning
a floating sampling platform to a precise location or
maintaining a stationary position on a water surface
influenced by wind, wave action, currents, and tide. Three
taglines, connecting the vessel to the bulkhead and pier
were used to maintain the boats position while sampling.
The use of traditional anchors or spuds was not practical
due to the resultant damage to the sediment cap and
potential disruption to sampling locations.
Vertical positioning was determined using the depth
sounder on the sampling vessel. A lead-line (weighted
measuring tape) was used to measure from the water
surface to the mudline to confirm the depth sounder
reading and to provide a correction factor (if needed).
Adjustments to the recorded depth due to tidal stage was
made using tidal prediction software loaded onto the
navigational system. Adjustment factors used based on
tidal prediction software was corroborated during
post-processing using the actual tidal elevation
observations recorded by the National Ocean Services
(NOS) Cherry Point tide gauge.
4.2.2.2 Sediment Sampling
Sediment samples included composites, as well as
samples collected from distinct intervals in order to assess
vertical distribution of contaminants. Based upon visual
inspection, three distinct intervals (i.e. top, middle, and
bottom) were subdivided and sampled over the length of
the contaminated sediment layer. Samples of the overlying
cap and underlying native material were collected and
analyzed as well. The QA Project Plan provided details on
the protocols for both critical and non-critical sampling,
frequency of collection for all parameters, sample
processing procedures and sample custody and handling
procedures (SAIC 2002a).
Sediment samples were collected from within the test plot
in support of the primary objectives, and from outside the
test plot (extended zone of influence) and from within the
reference plot in support of secondary objectives. All
sediment samples were collected using a vibracoring
system capable of obtaining cores to one foot below the
proposed dredging prism. The vibracorer consists of a
core barrel attached to a power head. Aluminum core
tubes equipped with a stainless steel "eggshell" core
catcher inserted in the core barrel were used to retain
material. The vibracore was lowered into position on the
bottom and advanced to the appropriate sampling depth.
Once sampling was complete, the vibracore was retrieved
and the core liner removed from the core barrel. The core
sample was examined at each end to verify that sufficient
sediment was retained for the particular sample. The
condition, and quantity of material within the core was then
inspected to determine acceptability.
To verify whether an acceptable core sample was collected
the following criteria had to be met:
> target penetration depth (i.e., into native material)
was achieved;
> sediment recovery of at least 65% of the
penetration depth was achieved; and
> sample appeared undisturbed and intact without
any evidence of obstruction or blocking within the
core tube or core catcher.
The percent sediment recovery was determined by dividing
the length of material recovered by the depth of core
penetration below mudline. If the sample was deemed
acceptable, overlying water was siphoned from the top of
the core tube, and each end of the tube was capped and
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sealed with duct tape.
All cores were processed on board the sampling vessel
(initial sectioning to ease handling) and at a shore-based
processing facility (extrusion, documentation, and sample
collection foranalysis). Sediment cores were processed in
the same order as collected in order to minimize storage
time. Each section comprising a core sample was carefully
cut into two sections using a depth-calibrated circular saw
(only the aluminum tube is cut). Care was taken to
preserve the integrity of the core section stratums by
processing sections in order from top (e.g., mudline) to
bottom (native material). Once the core was split open, a
mark was made to delineate cap, the sediment horizon (the
target zone), and underlying native sediment sections.
Sediment samples were collected from the test plot, the
reference plot and the extended zone of influence during
the baseline, each of two intermediate events, and the final,
post-treatment event. Six samples were collected from
each sediment core for mercury analysis, total solids, and
total organic carbon (TOC). These included one composite
collected overthe length of the contaminated horizon from
between the native material and the cap; three vertical
composite samples collected from three discrete intervals
(top, middle, bottom) overthe length of the contaminated
horizon; one cap sample; and one native material sample.
Six samples were collected for SVOCs as noted above for
mercury analysis, with the three discrete intervals initially
placed in archive. Subsequent funding, provided by
Ecology, allowed for the archived samples to be analyzed
in May 2003.
Representative aliquots of sediment were sub-sampled
over the entire length of a respective horizon, using
decontaminated stainless steel spoons, in order to
generate a composite sample for chemical and
conventional analysis. Sediment was collected from the
center of the core that had not been smeared by, or in
contact with the core tube. The sediment sub-samples
were placed in a decontaminated stainless steel bowl, and
mixed until homogenous in texture and color
(approximately two minutes). After all sediment for a
composite sample was collected and homogenized,
representative aliquots were placed in the appropriate
pre-cleaned sample containers for analysis. Samples of
the cap material and the underlying native material were
collected in a similar manner.
The vertical distribution of contaminants was used to
evaluate deposition patterns of chemical concentrations
(baseline), and potential vertical migration of contaminants
due to the ECRTs process (post-baseline sampling
events). Based upon visual inspection, three distinct,
equivalent intervals were subdivided and sampled overthe
length of the objective sediment layer (top, bottom, and
middle). Distinct layers of cap, contaminated sediment
horizon, and native material were easily recognizable within
each core.
4.2.2.3 Benthic Infauna Sampling
Two biological parameters, the benthic invertebrate and
fish communities, were proposed for monitoring to
determine whether the operation of the ECRTs system
would have any adverse effects on nearby biota. The
monitoring of both of these parameters was considered
discretionary in terms of the success of the ECRTs
process. The primary goal of monitoring benthic
invertebrates and fish was to provide qualitative
observations as to potential impacts to biota. The
monitoring approach was designed to provide a minimal
line of evidence of biotic conditions, with a scope that could
be expanded if warranted.
The benthic infauna sampling methods were consistent
with the methods used for monitoring the Log Pond Cap
and Puget Sound Estuary Program (PSEP) protocols
(PSEP 1987). Conventional parameters (sediment grain
size and TOC) were analyzed at each location in
conjunction with benthic infauna analysis. The TOC and
grain size data were collected from three cores in the test
plot, and the zone of influence; howeverthe TOC and grain
size data were collected separately for the benthic grab
co-located with the OMMP benthic station.
Benthos samples were collected before sediment chemistry
samples in order to attain undisturbed site conditions.
Three replicate benthos samples were collected at each
proposed station using a 0.1 m2 van Veen grab sampler for
a total of 15 benthic infaunal samples per sampling event.
To verify that a sample was not disturbed during retrieval,
the van Veen grab sampler was inspected according to the
following PSEP criteria:
Sampler is not overfilled,
Overlying water is present (e.g., no leakage),
Sediment surface is relatively flat (e.g., no
evidence of disturbance or winnowing), and
The following minimum penetration depths are
achieved:
> 4-5 cm for medium-coarse sand
> 6-7 cm for fine sand
> > 10 cm for silts and clays
Once a sample was deemed acceptable, a description of
the collected material was recorded in logbooks by the
project scientist, including such information as penetration
depth, color, texture, odor, and biological structures or any
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other notable features. Overlying water was carefully
siphoned off and poured through a 1.0 mm sieve to retain
any organisms siphoned from the sample. The material
collected on the screens were transferred into plastic
sample jars and preserved in 10% formalin. Samples were
later preserved with a 70% ethanol, 5% glycerine, and 25%
water solution for long-term storage.
Benthic infauna samples were collected from five locations
within the log pond: three locations within the
demonstration site, one location near the boundary of the
anticipated area of influence, and one location outside the
area of influence. The far-field sampling location was
selected to coincide with a sampling location used as part
of the OMMP monitoring. Three replicate samples were
collected at each location. Samples were collected on two
occasions including a baseline (August 19, 2002) and a
mid-demonstration (January 10, 2003) sampling event.
Because the mid-demonstration sampling event took place
(January 10, 2003) about the same time that the ECRTs
process was terminated, a post-demonstration sampling
event was deemed unnecessary.
Formal benthic community analysis—identification and
enumeration of organisms to the species level—was not
performed. Laboratory analysis of benthic samples was
not warranted for the ECRTs demonstration, and the
preserved samples remain in archive. Following
completion of the Demonstration, archived benthos
samples were transferred to the U.S. EPA.
4.2.2.4 Fish Community Monitoring
Three monitoring methodologies were originally proposed
to monitor the fish community: seining, underwater video,
and acoustical tracking. The underwater video and
acoustical tracking methods were dropped from further
consideration due to cost-saving measures. Underwater
video was also hindered by low water clarity at the site for
observing such highly mobile organisms as fish. The fish
community was monitored to assess whetherthe operation
of the ECRTs results in: 1) changes in community
structure; 2) changes in fish behavior; and 3) serves as an
"attractive nuisance" for electro-sensitive fish.
The Log Pond fish community was monitored on three
separate occasions using a 15' x 150' purse seine. Three
locations were seined twice each during each sampling
event. Seining was conducted for the baseline and two
intermediate sampling events. The third intermediate
sampling event was canceled due to the inoperable
condition of the ECRTs system. Fish monitoring was not
conducted during the post-demonstration sampling event
due to cost-saving measures and the fact that the second
intermediate event was close to the time period that the
ECRTs became totally inoperable (late January).
The qualitative fish surveys were conducted using purse
seines to ascertain the general community structure (based
on species presence and relative abundance) of fish
populations in proximity to the ECRTs test site. Particular
attention was paid to evaluate whetherthe ECRTs served
as an "attractive nuisance" based on the relative presence
and abundance of potentially electro-sensitive fish (e.g.,
spiny dogfish). Three locations within the G-P Log Pond
were selected for fish community monitoring, one in the
vicinity of the demonstration site, and two outside the
influence of the ECRTs. Each location was seined twice,
during both the low and high tidal cycles for each sampling
event.
The 150 foot long by 15 foot deep purse seine was fitted
with 1/4-inch mesh, floats, leadline, rings, and purseline.
The seine was deployed from the bow of the boat, with one
end of the seine firmly anchored while the boat moved
quickly in reverse in a tight circle. The ends of the net were
joined together and then the lead line is "pursed" creating
a closed bag. The net was then lifted onto the boat and
fish were removed for processing.
At the completion of each purse seine, fish were removed
and transferred into a live tank for processing. The
demersal fish were identified and measured;
measurements were from the tip of the nose to the end of
the tail. Once 30 fish of one species were measured from
the set, all remaining fish of that species were counted but
not measured. Fish were also examined for any signs of
external lesions or parasites. Great care was taken to
avoid excessive mortality by minimizing fish handling,
processing each catch as quickly as possible, and carefully
returning each specimen to the water. Demersal
invertebrates were identified to species, counted,
measured where appropriate to indicate carapace length,
and sex determined on appropriate species (e.g., crabs).
4.2.2.5 Benthic Flux Monitoring
One concern of conducting an in situ remediation pilot
project was the potential to impair overlying water quality
through the mobilization of contaminants. Potential
contaminant flux across the sediment-water interface was
therefore identified as a secondary objective forthe ECRTs
demonstration project. This transport mechanism is
interest due to potential compromising of the existing cap,
exposure of ecological receptors to contaminants, and loss
(reduction) of contaminants by a mechanism different to
those claimed by the ECRTs proponents. Three types of
contaminant flux monitoring were considered: 1) In situ
benthic flux monitoring using the Benthic Flux Sampling
Device (BFSD); 2) Sequential Batch Leachate Testing
4-8
-------
(SBLT); and 3) sediment cap monitoring of bulk
concentrations. Each method provides a varying degree of
direct measurement of the relative mobility of
contamination through the cap material and into overlying
water. In each case a different matrix is evaluated,
therefore preventing a direct comparison between data
types and their subsequent interpretation. Quantitative
methods (e.g. benthic flux chambers, and sequential batch
leachate testing) to determine the potential contaminant
flux across the water-sediment interface, however, were
deemed beyond the scope of the demonstration project.
Sediment cap monitoring was therefore chosen due to the
fact that it was already included as part of the cost of the
demonstration. As part of the current study design, the
cap material was analyzed for contaminants of concern at
each location. Increases in contaminant concentrations at
the test site, in lieu of similar increases at the reference
location, would indicate that the ECRTs demonstration
resulted in the upward migration of contaminants.
4.2.2.6 Electrical Field Monitoring
The areal extent of influence of the ECRTs system on site
sediments was to be determined by measuring the in situ
voltage at the site. The voltage measurements were to be
collected using a custom-built voltage probe which was
designed, built, and operated by Marine Sampling Systems
(MSS). The voltage probe design and operation was
approved by Weiss Associates as a sufficient methodology
for measuring the in-situ electrical field. However,
subsequent concerns by Weiss Associates regarding the
proprietary nature of the electrical field resulted in
cancelling collection of this data.
4.2.2.7 Electrode Sampling - Mercury Mass Calculation
Upon completion of the demonstration, material was
sampled from the electrodes at the time of their removal.
The objective of the data collection effort was to provide
supplemental evidence that mercury present in the test plot
sediments was mobilized and plated to the electrodes via
ionization and mobilization during the ECRTs
demonstration. Samples were collected directly from the
electrode plates prior to installation (time zero) and
following the demonstration to evaluate whether mercury
had migrated towards the in situ electrodes. In addition,
sediment samples were collected from any material found
clinging to the surface of the electrode at the time of
removal.
All powersupplies were disconnected from the system prior
to commencing any removal activities. Electrodes were
removed from the sediment using a truck-mounted
construction crane parked on the Port of Bellingham dock,
west of the test plot. A pontoon boat, operated by Wilder
Environmental, facilitated the electrodes removal from the
Log Pond surface. Buoy lines attached through two holes
drilled in the top of the electrodes were used to locate and
remove each respective electrode. Once the buoy lines
were suitably rigged to the crane's hook block, the
electrodes were hoisted from the sediment using a slow,
constant force to minimize strain on the buoy lines and
prevent sloughing of material from the electrode's surface.
Once the electrode cleared the water's surface and had
been adequately secured to prevent excessive movement
(i.e. swinging or spinning), the electrode was marked to
indicate which surface faced the test plot (interior surface)
and which surface faced away from the test plot (exterior
surface). The electrode was then checked for mercury
vapor and bagged with heavy-duty polyethylene drum
liners to minimize the potential for loss of material. Once
secure on the dock, samples of any material loosely
adhered to the electrodes surface were collected by SAIC
staff. Each electrode was identified by its respective array
(A = anode or C= cathode) and numbered sequentially
(1,2,3...9) from south to north (e.g. A-1 and C-1 were the
electrodes closest to the catwalk/electrical junction boxes).
Once the sediment samples had been collected, the
electrodes were transported to the processing facility for
further examination and sample collection. The remaining
electrodes did not have sufficient quantity of sediment
adhering to their respective surfaces to constitute a viable
sample.
Each electrode was photographed and visually examined
at the processing facility. Observations and measurements
were recorded and the general condition of the electrical
connection was carefully examined and recorded in the
field notebook.
4.3 Performance and Data Evaluation
This subsection presents a summary of the performance
data obtained during the demonstration sampling and
monitoring over a period of several months. A good portion
of the results are presented in tabular or graphical form.
These were computer-generated graphs from
demonstration data in order to provide easier data
interpretation. Evaluation of these data are included in the
narrative and complete data, including a discussion of
Quality Assurance measures, are available in the Technical
Evaluation Report (TER), which is unpublished but
available upon request from EPA.
4.3.1 Primary Objective
As previously stated, the primary technical objective was to
determine whether there was a significant trend in the
4-9
-------
reduction of mercury in the test plot over the period of the
demonstration that is attributable to the ECRTs process.
For assessing this objective, composite samples from the
contaminated sediment horizon were collected from the
test plot during several sampling events, including a
baseline event before operation of the ECRTs process.
Figure 4-1 (Mercury Concentrations by Event: Test Plot -
Sediment Horizon) presents a spatial representation of
mercury concentrations in the test plot sediment horizon
over the course of the Demonstration. In addition, the
figure depicts the study plots, sampling locations, and
electrode placement. Figure 4-2 is a graphical plot of the
average mercury concentrations in the contaminated
sediment horizon from the test plots. Table 4-2 is also
included and shows the data used to plot Figure 4-1 and
Figure 4-2. The sediment horizon was the contaminated
portion of the test plot, treated as part of this
demonstration. As previously mentioned, on top of this
contaminated sediment horizon was a "cap material" which
was used as a partial treatment of the G-P Log Pond. (A
temporary fix or interim measure taken until a more
permanent solution could be found.) Below the sediment
horizon is the "native material". Samples were taken at ten
different locations within the sediment horizon, the cap
material, and the native material. Samples in the sediment
horizon were obtained at three different vertical strata and
additionally composite cores of the entire depth were also
acquired. Composite cores of the sediment horizon were
obtained to determine the primary objective associated with
mercury concentration reductions. These same samples
were used to determine SVOC concentration reductions.
Samples were taken at three different vertical strata and
above and below the sediment horizon in order to account
for possible contaminant migration. Data forthese samples
will be discussed in subsequent paragraphs, included in
this section. Mercury composite cores in the sediment
horizon were considered critical as they were used to
evaluate the primary project objective. Samples were
taken over a period of approximately 6 months.
Technology operation was not constant over this time
period, as explained previously, but sampling sessions
were timed to anticipate optimum operational periods.
Table 4-2. Mercury Concentrations in Test Plot
Sediment Horizon (mg/Kg).
Grid
Number
T1
T2
T3
T4
T5
T6
T7
T8
T9
T10
Avg.
SD
CV
90% UCL
90% LCL
SAMPLING EVENT
Baseline
116
319
141
145
304
262
31.6
48.1
71.6
126
156
104
0.66
205
108
1st Int.
—
304
115
49.9
113
121
—
32.9
82.3
116
117
82.6
0.71
207
27
2nd Int.
—
80.2
146
63.4
172
121
135
47.4
60.8
168
110
48
0.44
163
58
Final
33.9
154
125
164
64.0
93.7
149
41.9
98.1
111
103
46
0.45
116
90
4-10
-------
w
•/v
Georgia Pacific
Log Pond
ECRT Demonstration Site
Georgia Pacific Log Pond
ECRT Demonstration Test Plot
Mercury per Sampling Event
Inverse-Distance Weighting Predicted Values
SH - Composite
10 20 30 40 50 Fe<
Nerjarivp Flprirnrlp<;
Positwe Electrodes
• 1 Meter BathymetricContours
IDW predicted
Mercury Concentration
flB 0-0.41 ( 005)
H 0.59-2(>CSU
['~| 2-5
| | 5-10
I I 10-50
[ | GO- 100
I | mn-ifin
I I15D-2DO
: 2DO • 250
^•250-300
•i 300 - JJO
Monitoring Event 2
IDWinterpolationa created using Gpatial Analyst with de^ult parameters.
a values are rorgrapntc presentaiion only ana should not oe usearor map calculations.
Data projected to UTM NAD 1983, Zone 10 and rotated to 313 degrees
Figure 4-1. Spatial and Temporal Distribution of Mercury in Test Plot Sediment Horizon
4-11
-------
200 ~
180 -
160 ~
140
120
100 _
80 _
60 _
40 _
20 -
I
, Test Plot SH
Concentration Trend
156 Average Mercury
(10) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
\ ' '
\ 10 30
Baseline Sampling
(Aug. 20-22,2002)
I
50
I i 1
70 \ 90
IE 1 Sampling
(Nov. 1-4,2002)
I I
110\ 130
IE 2 Sampling
(Dec. 11-13,2002)
I
150
I 1
170 190//
Final Sampling
(March 18-20,2003)
^210
Days
Figure 4-2. Average mercury concentrations in test plot sediment horizon.
4-12
-------
Upon initial observation of Figure 4-2 it might appear that
the mercury trend was decreasing over the 6 month
operational period if, only average concentrations were
considered. This same figure, however, shows the
standard deviation bars around the average and as noted
from these bars, concentrations from 10 sampling points
within the 20 by 30 foot test area were very heterogeneous.
Therefore, even though at first glance there may appear to
be a decreasing trend, this trend should not be considered
significant when standard deviations around the average
concentrations are also included. An inferential statistical
evaluation was therefore performed to determine whether
or not there was a significant decreasing trend in mercury
concentration in the test plot. This is explained in the
subsequent paragraphs, which provide the detailed
equations and resulting conclusions.
Statistical Model
Mercury concentration data were generated through
assays of soil specimens taken from 10 test plot locations.
The test plot locations were sampled on 4 separate
occasions as follows:
Sampling Event
Baseline
Event 1
Event 2
Final
Date
August 21, 2002
November 5, 2002
December 13, 2002
March 19,2003
where Yy is the natural logarithm of the Hg concentration in
mg/kg, u is the mean intercept, T, is the effect (or intercept
effect) of the 1th test plot fori = 1,2 10, (3 is the slope, ty is
the elapsed time in days for the 1th test plot and j* sampling
event for j = 1,2,3,4, and ey is the normally distributed error
term with zero mean and variance o2. Do note that:
tf1 = 0 days for Baseline monitoring
t|2 = 76 days for Event 1 monitoring ,
tjg =114 days for Event 2 monitoring ,
t|4 =210 days for Final monitoring .
This
model as constructed recognizes that the concentrations
can vary across test plots, but the model does require that
the single slope or decay rate is common to all test plots.
Also observe that the decay rate is given by A = -(3 and that
the concentration half-life is given by:
The null hypothesis of no effect or of no removal is written
as:
These dates were used as single point estimates based
upon actual sampling events that occurred over a period of
a few days. This sampling approach specified a total of 40
mercury concentration measurements. A total of 37
measurements, however, were realized because 3 values
were not obtained: the single measurement for Event 1 for
test plot T7 and both measurements for Events 1 and 2 for
test plot T1 .
The first order decay rate model was assumed for the
change in Hg concentrations within a test plot. Written
symbolically, that model is:
with c being the initial concentration, A being the decay
rate, t being the elapsed time and Hgt being the Hg
concentration at time.
With taking natural logarithms, we write the statistical
model for the Puget Sound Demonstration test plot as:
The slope coefficient (3 was estimated using maximum
likelihood. The estimate was -0.00129 with a standard
error of 0.001023 with 26 degrees of freedom. This point
estimate of the slope (3 is equivalent to an estimate of the
concentration half-life of 1.47 years. The estimates of (3
and standard error, nonetheless, yield a 2-tailed critical
value of 0.219. Because the critical value is greater than
0.10, we reject the null hypothesis, at the 90% level.
This statistical analysis shows the decreasing trend in
mercury concentration over time was not significant.
Concentrations of mercury remained relatively
heterogeneous but unchanging in the test plot during the
duration of the demonstration. Based on the statistical
analysis, the ECRTs process was not effective in reducing
mercury concentrations over time in the test plot.
Therefore, the primary objective regarding mercury
reduction was not achieved.
4-13
-------
The statistical analysis of the ECRTs process performance
is also supported by an examination of the spatial and
temporal changes in mercury concentration from the
contaminated sediment horizon of the test plot (see Figure
4-1). The figure depicts the spatial distribution of mercury
from the contaminated sediment horizon within the test
plot, as well from an extended zone outside of the effects
of the ECRTs electrical field. All four sampling events are
presented. The plots depict some changes in the spatial
distribution of mercury. However, from a remedial and
performance perspective, these differences are
insignificant. It is important to note that no location during
any of the post-baseline sampling events came close to the
site's mercury cleanup screening level (CSL) of 0.59 mg/kg
dry wt.
Operational problems with the ECRTs process may be
responsible forthe lack of a significant reduction in mercury
levels in the test plot. Electrical readings collected by the
technology's sponsor (Weiss) indicated a steady
degradation of system performance throughout the duration
of the demonstration, resulting in an early shutdown of the
system prior to completion of the planned test period. In
addition, when the electrodes were removed from the test
plot, it was evident that the connections between the
electrical supply and anode plates had completely corroded
to the point that a viable contact had not been made.
Therefore, it is uncertain exactly how long (and to what
extent) the ECRTs process was fully functional and
operational. Since the performance of the system is totally
dependant on the effectiveness of the electrical
connections and resultant electrical field, the ECRTs
process should have a monitoring protocol to identify and
quickly rectify any problems associated with electrical
current distribution and field propagation.
4.3.2 Secondary Objectives
Objective 2 forthe demonstration was to determine the rate
of organic compound mineralization (PAHs and phenols).
This was evaluated by analyzing for SVOCs from ten
sample locations collected within the test plot. Both
discrete intervals and composite test plot cores, which
included the entire depth of the test plot, were collected.
This was a secondary objective because SVOC
concentrations were not considered to be significantly high
enough, and exhibited high variability, in baseline samples
to statistically determine a quantitative rate parameter for
a potential decrease. SVOC concentrations for the
compounds that were at high enough concentrations to plot
the data over the course of the demonstration are
presented in Figures 4-3 through 4-14. Data are presented
for both the test plot and the extended zone of influence.
These plots include concentrations over the period of the
demonstration for naphthalene, 2-methylnaphthalene,
acenaphthalene, flourene, flouranthene, and 4-
methylphenol. All other SW-846 method 8270 compounds
were at concentrations too low to be able to observe any
possible decrease.
As noted some of these graphs are similar to the mercury
graphs, which show a potential decrease in average
concentrations, however, because of the heterogeneity of
compound concentrations in the test plot, these decreases
are not considered significant when standard deviations are
also included in the evaluation. (Standard deviation bars
are included as part of the graphs.) These compounds
show no apparent decrease in concentration. This would
confirm previous conclusions about the process and its
inability during this demonstration to significantly reduce
concentrations of inorganic compounds through ionization
and mobilization due to operational problems.
The ECRTs technology demonstration was also
unsuccessful at reducing organic compounds through
mineralization. Overall it is believed that because of
problems encountered by the developer for this
demonstration that there was no significant effect on
hazardous compound concentrations. The data suggest
that there were no significant decreases in any of the
compounds analyzed at the G-P log pond site.
4-14
-------
800 _
Days
• Test Plot SH
Concentration Trend
264 Average Naphthalene
(10) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
Legend
\ 10
\
Baseline Sampling
(Aug. 20-22, 2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-3. Average naphthalene cocnetrations in test plot sediment horizon.
1600 -l
1400 -
Days
Note: The Standard Deviation
upper limit of 2336 is off the scale.
Legend
1 Ext. Zone SH
Concentration Trend
899 Average Naphthalene
(5) Concentration in mg/Kg
(No. Of Values averaged)
Baseline Sampling
(Aug. 20-22,2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-4. Average naphthalene concentrations in extended zone sediment horizon.
4-15
-------
400 _.
Q)
Q) 300 _
^
^~
C
|j 200 -
I "»-
\
<
)
»
50.9
^ '
H
i <
I I 1 1
Days -> \ 10 30 50 70
\
1
' (7)
1 <
k <
\ ' "
Legend
Test Plot SH
Concentration Trend
m 50.9 Average 2-Methylnaphthalene
(10) Concentration in mg/Kg
(No. Of Values averaged)
9 Standard Deviation Range
40.8 33 •
(9) (10) T
b A
\ 90 110\ 130 150 170 190/210
\
\ ._ . „ .. IE 2 Sampling Final Sampling
Baseline Sampling nil, i 2™S» (Dec. 11-13,2002) (March 18-20, 2003)
(Aug. 20-22,2002) (NOV- n"^' iwi>
Figure 4-5. Average 2-methylnaphthalene concentrations in test plot sediment horizon.
900 -
800 -
700
600
500 _
Note: The Standard Deviation
upper limit of 2873 is off the scale.
Legend
fi
Extended Zone
Concentration Trend
Days
959 Average 2-Methylnaphthalene
(10) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
Baseline Sampling
(Aug. 20-22,2002)
Final Sampling
(March 18-20,2003)
Figure 4-6. 2-methylnaphthalene concentrations in extended zone sediment horizon.
4-16
-------
40 _
Concentration (mg/kg)
->• ro GJ
o o o
1 1 1
Days ->•
Legend
Test Plot Sed. Horizon
Concentration Trend
m 1.98 Average Acenaphthalene
(10) Concentration in mg/Kg
(No. Of Values averaged)
T Standard Deviation Range
A 1-98 2.00 V||7
• (10. .(7, ."
V ff ff
\ 10 30 50 70 \ 90 110\ 130 150 170/
1.5
(10) A
V
I I
190 210
\ \ • /
\ IE 1 Sampling IE 2 Sampling ...
Baseline Sampling (Nov. 1-4,2002) (Dec. 11-13,2002) ru h « ?n SriU
(Aug. 20-22,2002) (March 18-20,2003)
Figure 4-7. Average acenaphthalene concentrations in test plot sediment horizon.
80-
70-
60 _
^ 50-
C
J5 40_
C
O 30_
20 _
10-
Days -^>-
4
(
t
1
37
K
\ '
Legend
Extended Zone SH
Concentration Trend
A 37 Average Acenaphthalene
(5) Concentration in mg/Kg
(No. Of Values averaged)
T Standard Deviation Range
\ -
3.3
\ I I I I \ I I \ 1 1 ' 1 / 1
\ 10 30 50 70 \ 90 110\ 130 150 170 190 /210
\ |p . ea_n|in_ IE 2 Sampling Final Sampling
Baseline Sampling ™ i!T?S?« (Dec. 11-13,2000) (March 18-20), 2003
(Aug. 20-22, 2002) (Nov' 1-4' 2002)
Figure 4-8. Average acenaphthalene concentrations in extended zone sediment horizon.
4-17
-------
60° -
400-
200 -
Days ->•
• 71.9 57.9
T^_ ,7,
Legend
Test Plot Sediment Horizon
Concentration Trend
A 71 .9 Average Fluorene
(10) Concentration in mg/Kg
(No. Of Values averaged)
9 Standard Deviation Range
54.1
41.7
(10) A
I I I 1
I I I II II I ' I / I
\ 10 30 50 70 \ 90 110\ 130 150 170 190 / 21C
Baseline Sampling n!L1 M& (Dec^Ts'X ,Ma^S%3
(Aug. 20-22, 2002) (Nov. 1-4, 2002) (March 18-20), 2003
Figure 4-9. Average fluorene concentrations in test plot sediment horizon.
1600 -I
1400
1200-
1000 _
I
800 _
600 _
400 -
200 -
Days
Legend
. Ext. Zone Sediment Horizon
Concentration Trend
633 Average Fluorene
(5) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
Baseline Sampling
(Aug. 20-22,2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-10. Average fluorene concentrations in extended zone sediment horizon.
4-18
-------
800 _
o Concentration (mg/kg)
CO
ro -^ o>
| § § §
<
<
i
\
,<"> • (?) J '
Legend
— Test Plot SH
Concentration Trend
A 140 Average Fluoranthene
(10) Concentration in mg/Kg
(No. Of Values averaged)
T Standard Deviation Range
10
»)
J J
1
\ i i i ' \ ' ' \ '
\ 10 30 50 70\ 90 110 \ 130
\ \
\ .... IF •) Ramnlirv
9S.4 —
(10) < >
<»
•
I ' I / I
150 170 190 /210
Q i; c«r«r»iipi« Samplincj /rtor* 11 1*1 9nn9\ Final SampliriQ
DaS6lln6 oampllny fNnv 1-4 9009^ vL/cc. i i-io, £\j\j£.) ^MarpJi 1ft 90 9fi(Y^\
(Aug. 20-22, 2002)
Figure 4-11. Average f luoranthene concentrations in test plot sediment horizon.
1600 -l
1400
1200'
1000 _
800 _
600 _
400 -
200 -
Days
\ Note: The average value of 3800 and standard
^ deviation upper limit of 10,100 are off the scale
\
30
Baseline Sampling
(Aug. 20-22,2002)
Legend
- Ext. Zone SH
Concentration Trend
' Estimated Trend
ft 120 Average Fluoranthene
(5) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
50
\
130
70 \ 90 110\
^ IE 2 Sampling
IE 1 Sampling (Dec. 11-13, 2002)
(Nov. 1-4,2002)
I
150
170
I
190
210
Final Sampling
(March 18-20,2003)
Figure 4-12. Average fluoranthene concentrations in extended zone sediment horizon.
4-19
-------
1600 -
1400 ~
1200-
§> 1000 _
.§ 800 _
c
o
O 600
400 -
200 -
Days ~ ^
<
<
<
»
<
B80 __^ .. — — " -—
(10)
^^
t
<
I
1
(
1 (
1
»
989
(»)
>-
1000
»
»
>
Legend
^~ Test Plot Sediment Horizon
Concentration Trend
• 880 Average 4-Methylphenol
(10) Concentration in ug/Kg
. (No. Of Values averaged)
1 Standard Deviation Range
1
)
1
)
\ 1 1 1 1 \ 1 1 , 1 1 ' 1 / 1
\ 10 30 50 70 \ 90 110\ 130 150 170 ^90/2K
\ ic * c r IE 2 Sampling Final Sampling
Baseline Sampling nL, iTmran (Dec. 11-13,2002) (March 18-20, 2003)
(Aug. 20-22,2002) l ° n-*'zuu^
Figure 4-13. Average 4-methylphenol concentrations in test plot sediment horizon.
^ 1000 _
•^ 800 _
^ 600 _|
400 -
200 -
Days ->•
r
10
r
30
\
50
70
r
90
110X
\
130
150 170
190 /210
Baseline Sampling
(Aug. 20-22, 2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-14. Average 4-methylphenol concentrations in extended zone sediment horizon.
4-20
-------
Objective 3 was evaluated in order to assess vertical
migration of contaminants (e.g. induced complexation and
mobilization of mercury). This was proposed since
possible decreases in concentration in any of the different
horizons (sediment, cap, or native material) could be due
to vertical migration of contaminants rather then actual
remediation. There was, however, no significant decrease
in contamination for any of the contaminants of concern
within the test plot for the contaminated horizon, as noted
previously. Nonetheless, vertical migration was shown by
plotting concentrations of mercury in each of the separate
horizons including the cap material and native material.
Figures 4-2, 4-15 and 4-16 show no significant changes in
concentration of mercury within the three previously
defined vertical horizons; not only confirming that the
technology had no effect on mercury migration but also
showing that contaminants did not appear to significantly
move within the specified horizons. This is not unexpected
since the lack of a significant electrical field would have not
significantly mobilized mercury. These plots were not
generated for the SVOCs as there appeared to be no
significant information that could be gained from plotting
these additional data.
Objectives 4 and 5 were evaluated to determine the extent
of the zone of influence of the ECRTs through spatial
measurement of electric potential and also track changes
in compound concentrations outside the immediate area of
influence, designated as the extended zone. The extended
zone (area immediately outside the designated test plot)
was considered as an area of influence that may also show
treatment effects of the demonstration. Figure 4-17
presents summary data for mercury concentrations from
the Extended Zone. Based upon this figure, there appears
to be no significant decrease in mercury concentration due
to the ECRTs treatment technology. A decrease in the
extended zone would not be expected, however, because
of a lack of an effective electrical field even in the test plot.
In addition, data from the extended zone of influence for
the previously noted SVOCs are included in figures 4-3
through 4-14. These also show no evidence of significant
decrease for any of the noted compounds.
Voltage probe measurements were taken during the early
phase of the Demonstration as a method for evaluating the
spatial extent of the zone of influence of the ECRTs
system. The voltage measurement data were not evaluated
as part of this report due to their proprietary nature and as
such no conclusions concerning these data are presented
in this report. These data, however, were evaluated and
discussed between Weiss Associates, Ecology, and
USEPA at the time of their collection.
Objective 6 was intended to track natural attenuation
changes (if any) in contaminant concentrations by sampling
and analysis of a reference area located outside the
ECRTs' zone of influence. Figure 4-18 shows collected
mercury data over the period of the demonstration for the
reference plot. This figure shows no significant change in
mercury concentration over the period of the
demonstration. The reason for obtaining data from the
reference plot was to show that if there was a decrease in
concentration of mercury in the test plot, then it would be
necessary to show that this decrease was not due to
natural attenuation. Since there was no significant
decrease in mercury concentration in the test plot over the
period of the demonstration, there was no decrease
expected in the reference plot. This is shown to be true by
graphing the data overthe duration of the demonstration in
a similar fashion as the graph for the test plot data. No
similar graphs are constructed forthe SVOC data because
there was no concentration decrease in the test plot forthe
analyzed compounds and therefore no natural attenuation
was anticipated.
Objective 7 evaluated possible environmental effects of
ECRTs including benthic infauna effects and possible
behavioral effects on sensitive fish. Qualitative
observations made at the time the samples were being
sieved, indicated the clean sediment cap had been readily
colonized by numerous polychaetes, amphipods, and
mollusks. Samples collected during the active
demonstration appeared to have the same relative
abundance and composition, based solely on a visual
assessment, as samples collected during the baseline
sampling event. There was no outward evidence that the
ECRTs system was having an adverse impact on the local
benthic community (i.e. sterile substrate). Since the
ECRTs process was not properly functioning, it cannot be
concluded that the process, if properly operating, would
have no adverse impact on the benthic infauna and
sensitive fish.
4-21
-------
7_
Days
Legend
• Test Plot Cap
Concentration Trend
I 1.64 Average Mercury
(10) Concentration in mg/Kg
(No. Of Values averaged)
Baseline Sampling
(Ajg. 20-22, 2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-15. Average mercury concentrations in test plot cap.
6
5 _
Days
4 _
3 _
2 _
1 _
t
^
i
<
^^^
kO.H> ^^ ^— "
>(» ^
K-"^ —
1 4
1
1.34
1 <
Legend
Test Plot Native Material
Concentration Trend
9 0.50 Average Mercury
!(9) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
10.68 0.62
^ (9) ("I
I n
\ 1 1 1 1 i 1 1 \ 1 1 ' 1 / 1
-> \ 10 30 50 70 \ 90 110\ 130 150 170 190/210
\ 1=10.^11- IE 2 Sampling /
Baseline Sampling ,w™ iT™?» (Dec. 11-13,2002) Final Sampling
(Aug. 20-22,2002) INOV' n~*' •"*"' (March 18-20,2003)
Figure 4-16. Average mercury concentrations in test plot native material.
4-22
-------
240
200 _
160 _
120 J
80 -\
40 -
Days
10 30
50
90
\
130
Legend
1 Extended Zone SH
Concentration Trend
76 Average Mercury
(10) Concentration in mg/Kg
(No. Of Values averaged)
Standard Deviation Range
T
\
150 170 190 /210
Baseline Sampling
(Aug. 20-22,2002)
IE 1 Sampling
(Nov. 1-4,2002)
IE 2 Sampling
(Dec. 11-13,2002)
Final Sampling
(March 18-20,2003)
Figure 4-17. Average mercury concentrations in extended zone sediment horizon.
4-23
-------
i
8
I
40 "I
35
30
25-
20 _
15 _
10 -
5 -
I
Legend
, Reference Zone SH
Concentration Trend
9.7 Average Mercury
(5) Concentration in mg/Kg
(No. Of Values averaged)
.Standard Deviation Range
Days
\ 1
\ 10
\
\
\
Baseline Sampling
(Alia. 20-22.2002}
I
30
I
50
I I
70
90
IE 1 Sampling
(Nov. 1-4,2002)
I \ I
110\ 130
\
IE 2 Sampling
(Dec. 11-13,2002)
I
150
1
170
I / 1
190 / 210
Final Sampling
(March 18-20,2003)
Figure 4-18. Average mercury concentrations in reference zone sediment horizon.
Table 4-3 provides the species list for the seining efforts.
Shiner perch were the most abundant species at each
location during the baseline event and first intermediate
event, with the exception of the open water location in
October. Shrimp were the most abundant species at
each location during the January sampling event. The
species list observed during the demonstration
monitoring was consistent (albeit a subset) with the
species observed in beach seines conducted in July and
August, 2000 (Anchor Environmental 2000). No fish
considered to be electro-sensitive such as the spiny
dogfish, the spotted ratfish, or pacific lamprey, were
observed during any of the seining or sampling events.
In addition, no fish kills or erratic fish behavior were
observed at any time during the operation of the ECRTs
system.
Objective 8 was to evaluate potential contaminant flux
across the water-sediment interface. The cap material
was analyzed for contaminants of concern at each
location. Table 4-4 summarizes the mercury
concentrations for each sampling event and study area.
On average, the sediment cap had a minor increase in
mercury concentrations from baseline to post-
demonstration. However, these results were not
consistent, as seven of the twenty locations monitored
during the demonstration exhibited a net decrease in
mercury concentrations. The largest net change in
mercury concentrations was at sampling point T5,
located towards the center of the test plot. Since slight
increases were observed at the test plot location, the
extended zone, and reference area, it does not appear
that these increases were a result of contaminant
mobility. It is likely that the nominal changes in the
mercury concentrations in the cap material are due to the
4-24
-------
physical disruption of the cap from the large number of
cores collected from the site. Incidental mixing of the cap
with underlying sediments having elevated mercury
concentrations may have occurred from material clinging
to, and sloughing from, the outside of core tubes during
Table 4-3 Fish and macroinvertebrate species present
extraction. The relative larger concentration changes at
single locations are indicative of the higher mercury
concentration in the underlying sediments.
Sampling Event
Baseline
First Intermediate
Second Intermediate
Third Intermediate4
Baseline5
Date
9/6/02
10/22/02
1/9/03
Canceled
Canceled
South Log Pond1
shiner perch
dungeness crab
bay pipefish
Shiner perch
dungeness crab
Starry flounder
herring
Bay pipefish
shrimp
dungeness crab
n/a
n/a
Mid-Log Pond2
shiner perch
No catch
Dungeness crab
shrimp
n/a
n/a
North Log Pond3
shiner perch
starry flounder
staghorn sculpin
dungeness crab
Shiner perch
shrimp
n/a
n/a
Bold typeface indicates most abundant species.
n/a: not applicable
1: The South Log Pond site coincided with the location of ECRTs electrode array, seining was conducted between the eastern shoreline and the
electrode array to avoid entanglement with buoys and buoy-lines used to mark the underwater location of individual electrodes.
2: The mid-Log Pond location was in open water adjacent to Whatcom Waterway.
3: The North Log Pond location was adjacent to the pier and bulkhead along the northern shoreline to best simulate conditions similar to the
ECRTs location, but outside its area of influence.
4: The third intermediate monitoring event was canceled since the ECRTs system was completely inoperable by late January.
5: The post-season fish monitoring was deemed unwarranted by project stakeholders and was canceled as a cost-savings measure.
4-25
-------
Table 4-4: Mercury concentrations in sediment cap samples
Test Area
T1
T2
T3
T4
T5
T6
T7
T8
T9
T10
Mean
Baseline
2.31
0.55
0.65
7.72
1.72
0.39
0.30
2.63
0.05
0.04
1.64
Monitoring
Event 1
-
7.34
.57
0.26
0.82
0.11
0.30
0.20
0.07
0.10
1.09
Monitoring
Event 2
-
-
-
1.11
2.55
0.24
0.2
0.19
0.28
0.05
0.66
Post-
Demonstration
-
0.24
0.69
2.13
15.30
0.20
1.21
0.74
0.15
0.11
2.31
Mean
2.31
0.40
0.67
3.37
5.10
0.23
0.60
0.94
0.16
0.08
1.46
Net change1
-
-0.31
0.04
-5.59
13.58
-0.19
0.91
-1.89
0.1
0.07
0.75
Extended Area
XI
X2
X3
X4
X5
Mean
Reference
Area
Rl
R2
R3
R4
R5
Mean
0.06
0.04
2.1
0.07
0.04
0.46
0.08
-
0.03
0.06
0.06
0.06
0.19
0.09
0.2
0.11
0.03
0.12
0.15
0.09
0.06
0.06
0.04
0.08
0.68
0.15
0.44
0.09
0.03
0.28
0.28
-
0.03
0.06
0.36
0.18
0.78
2.27
0.93
0.3
0.02
0.52
0.14
0.06
0.04
0.18
0.05
0.09
0.43
0.64
0.92
0.14
0.03
0.41
0.16
0.08
0.04
0.09
0.13
0.10
0.72
2.23
-1.17
0.23
-0.02
0.40
0.06
0.06
0.01
0.12
-0.01
0.03
Notes:
-: data not 9ollected either due to insufficient quantity of cap material in core sample, or core was not collected during a given sampling event.
1:.Change in mercury concentration (mg/kgdry wt.) from Baseline to Post-Demonstration sampling event, with the exception of Station R2,
where cnange is Irom Event 1 to Post-Demonstration. r ° r
Objective 9 evaluated migration of mercury towards the
electrodes. Due to the methodology of electrode sample
collection, a direct comparison between the anode and
cathode results was not practical. The graphite plugs may
understate the total mercury concentration on the anodes
due to relatively low surface to volume ratio of electrode
material. The mercury concentrations for the cathodes
(surface scrapings) are therefore more representative of
material directly adhered to the electrode surface.
The surface scrapings, could be best described as a
powdery material comprised mainly of the oxidized surface
of the steel plates (i.e.rust). The purpose for collecting any
sediment clinging to the electrodes at removal was to
provide an indication of the mercury concentrations of
material in direct contact with the electrodes. If mercury
was being mobilized and concentrated, then the sediments
in direct contact with the electrodes should be enriched in
mercury relative to the contaminated sediment sampled
from the test plot. Due to the relative particle size, the
sediment samples consisted of a surface to volume ratio
greater than the graphite plugs (anodes) but less than the
surface scrapings (cathodes). Table 4-5 provides a
summary of the analytical results for the electrode
sampling.
4-26
-------
Table 4-5 Summary of Mercury Analyses for Post-Demonstration Electrodes
Sample ID
Date Collected
Sample Matrix
Sample Type
Mercury (mg/kg dry wt.)
Anodes1
FIN-GO-PM-A
FIN-GO-PM-B
FIN-A1-PM-D
FIN-A2-PM-B
FIN-A3-PM-A
FIN-A4-PM-E
FIN-A5-PM-B
FIN-A6-PM-C
FIN-A7-PM-A
FIN-A8-PM-D
FIN-A9-PM-C
4/2/2003
4/2/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
graphite
graphite
graphite
graphite
graphite
graphite
graphite
graphite
graphite
graphite
graphite
time-zero
time-zero
solid plug
solid plug
solid plug
solid plug
solid plug
solid plug
solid plug
solid plug
solid plug
0.01 U
0.01 B
0.01 U
0.03
0.01 U
0.14
0.01 B
0.01 U
0.01 B
0.01 U
0.01 U
Cathodes'
FIN-SO-PM-A
FIN-SO-PM-B
FIN-C1-IS-B
FIN-C2-IS-C
FIN-C3-IS-B
FIN-C3-IS-C
FIN-C3-ES-D
FIN-C3-ES-E
FIN-C4-IS-B
FIN-C4-ES-C
FIN-C5-IS-D
FIN-C6-IS-C
FIN-C7-IS-A
FIN-C8-IS-B
FIN-C9-P
M-C
4/4/2003
4/4/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
4/2/2003
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
steel
graphite
time-zero
time-zero
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
surface scrape
solid plug
0.01 U
0.01 U
4.05
15.4
11
23.8
10.6
16
13.1
8.56
3.5
10.7
3.28
10.5
0.02 B
4-27
-------
Sediment Samples'1
FIN-A2-S
FIN-A8-S
FIN-C1-S
FIN-C2-S
FIN-C3-S
FIN-C4-S
FIN-C5-S
FIN-C7-S
FIN-C8-S
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
4/1/2003
sediment
sediment
sediment
sediment
sediment
sediment
sediment
sediment
sediment
plate surface
plate surface
plate surface
plate surface
plate surface
plate surface
plate surface
plate surface
plate surface
Mercury (ing/kg
Dry Wt.)
25.9
0.94
0.28
0.15
10.1
3.73
1.35
5.07
2.86
Total
Solids (%)
66.6
31.7
81.8
85.9
56.2
70.5
76.6
47.1
52
Notes:
1: FIN-GO-PM-A and FIN-GO-PM-B represent samples of electrode material collected prior to installation and archived until
the demonstration was complete; samples from the graphite anodes were collected using a 1" diameter hole-cutting drill
bit the entire 'plug' was submitted for analysis.
2: FIN-SO-PM-A and FIN-SO-PM-B represent samples of electrode material collected prior to ECRTs installation; time-zero
samples were collected using a hack saw to remove a representative piece of material; post-demonstration samples were
scraped from the surface of the electrodes and were representative of the electrode surface exposed to the sediment; the
designations 'IS' and 'ES' within the sample ID indicate 'interior surface' and 'exterior surface' of the electrode in relation to
the test plot, i.e. the interior faced the test plot and array of anodes; the sample for FIN-C9-PM-C was collected using a drill
bit as described in Note 1 above since it was a graphite electrode used as a cathode.
3: Sediment samples consisted of the material tnat was loosely adhered to the electrodes at the time of removal. Due to
the limited amount of sediment adhering to the electrodes samples were composited from material collected over the
entire length of the respective electrodes. Sufficient material for analysis was not available on all electrodes; samples
were collected when feasible. The purpose of these samples are to assess the relative concentration of mercury in
sediments in direct contact with the electrodes.
Qualifiers:
U: The compound was analyzed for, but was not detected ("non-detect") at or above the MRL/MDL
B: The result is an estimated concentration that is less than the MRL but greater than 10%, indicating a possible matrix
interference in the sample.
Mercury concentrations ranged from 0.01 (U) to 0.14 mg/kg
dry wt, on the graphite anodes which was no different than
the time-zero samples (undetected at 0.01 mg/kg dry wt),
with the exception of detected concentrations on A2 (0.03
mg/kg dry wt) and A4 (0.14 mg/kg dry wt). The two
sediment samples collected from the anode surfaces had
higher mercury concentrations ranging from 0.94 to 25.9
mg/kg dry wt, than measured directly from the electrode.
The collection of surface scrapings from the graphite
anodes was not practicable, as there were no visible
accretions of material plated to the anode surfaces. Based
on these findings it does not appear that appreciable
quantities of mercury migrated towards the ECRTs anodes,
with the possible exception of A4.
Mercury was detected on 12 of 13 cathode samples
submitted, with concentrations ranging from 3.28 to 23.8
mg/kg dry wt on the steel plate electrodes. A graphite
electrode that was placed in the cathode array during the
demonstration had a mercury concentration estimated at
0.03 mg/kg dry wt. These concentrations were higher than
both the time-zero steel plates (0.01 U) and sediment
adhering to the cathodes (0.15 to 10.1). At the time of
removal the steel plate was reduced (black surface), with
minor accretions (salt deposits) of solids in areas where the
plates protruded above the mudline. Once exposed to the
air, all of the steel plates oxidized and were covered in a
thin layer of rust by the time (<24 hours) the surface
scrapings were collected. Based on these data, it appears
that some mercury did adhere to the cathode surfaces
during the demonstration. However, based on the
analytical results and visual assessments of the electrodes,
the relative quantity of mercury plated to the cathodes was
limited, not readily recoverable (from a remedial
perspective), and may be an artifact of the sediment in
direct contact with the electrode plates. It also does not
appear that mercury was mobilized to the extent that
enriched sediments near the electrodes, as the highest
mercury concentrations measured during the
demonstration were located elsewhere in the test plot.
4-28
-------
Section 5.0
Other Technology Requirements
5.1 Environmental Regulation
Requirements
State and local regulatory agencies may require permits
prior to implementing the in situ ECRTs process. Most
federal permits will be issued by the authorized state
agency. If the ECRTs process is implemented on marine
sediments in situ, appropriate permits are required. For
example, for the demonstration a Joint Aquatic Resource
Permits Application (JARPA) was required by the U.S.
Army Corps of Engineers for conducting construction work
in or near the water. In addition, SITE Program personnel
were required to obtain a scientific collection permit for
conducting fish community samples.
If remediation is conducted at a Superfund site, federal
agencies, primarily the U.S. EPA, will provide regulatory
oversight. If off-site disposal of contaminated waste
(contaminated electrodes) is required, the waste must be
taken to the disposal facility by a licensed transporter.
Section 2 of this report discusses the environmental
regulations that may apply to the ECRTs process.
5.2
Personnel Issues
The numberof personnel required to implement the ECRTs
process is dependent on the size of the treatment system
and the time desired forthe installation. System installation
activities are usually conducted by the licensee of the
ECRTs process. The licensee would in most all cases
uses subcontracted specialized services to install the
system.
During installation activities at a remediation site, the site
remediation contractor (such as Weiss Associates) would
be responsible for ensuring that installation of system
components are conducted in accordance with design
specifications. These activities would require the services
of at the developer and several contractors. At a minimum,
an electrical contractor and a contractor equipped with
heavy equipment (e.g., crane) are anticipated a minimum
requirements. Marine applications of the ECRTs process
may require specialized services.
Personnel are also required forsediment sample collection
and monitoring. During the demonstration sampling
events, a specialized vessel equipped with DGPS was
required. Personnel present during sample collection
activities at a hazardous waste site must have current
OSHA health and safety certification.
For most sites, PPE for workers will include steel-toed
shoes or boots, safety glasses, hard hats during
installation operations, and chemical resistant gloves.
Sampling marine sites from a pontoon boat requires safety
floatation vests.
Depending on contaminant types, additional PPE (such as
respirators) may be required. For example, respiratory
protective equipment may be needed when VOCs are
measured in the breathing zone exceeding predetermined
levels. During the marine sediment sampling events
performed during the demonstration, respirators were not
required based on off-gas monitoring at the well heads.
Noise levels would be a short-term concern during
vibracoring operations. Thus, noise levels should be
monitored for such equipment to ensure that workers are
not exposed to noise levels above the time weighted
average of 85 decibels over an 8-hour day. If this level is
exceeded and cannot be reduced, workers would be
required to wear hearing protection and a hearing
conservation program would need to be implemented.
5-1
-------
5.3 Community Acceptance
The short-term risk to the community from implementing
this technology is minimal when the ECRTs process is
implemented in situ. For marine applications, such as the
demonstration, the level of environmental disturbance of a
site would be dependent on the type of marine species
potentially affected and would in most all instances require
some sort of benthic monitoring. For example, for the
demonstration project a series of measurements were
conducted to evaluate the possible environmental effects
of the ECRTs process on the marine environment. These
measurements included benthic in faunal sampling, purse
seining, and the use of underwater video cameras.
Otherthan noise generated during drilling vibrohammering
of the electrodes during system installation, noise
disturbance is not anticipated. The benefits of site
remediation would offset these minor disturbances. Most
marine applications would be conducted just off the
shoreline in industrial areas (e.g., shipyards) and thus
would not create additional concern to the community.
5-2
-------
Section 6.0
Technology Status
6.1 Previous Experience
P2-Soil Remediation, Inc., the electrochemical remediation
company that developed the ECRTs process has been
established since 1979 and has been reported to have
remediated over 2 million metric tons of soils, sediments,
and groundwater (Mcllvride, W.A., F. Doering, et. al., April
2003). The demonstration conducted at the G-P Log Pond
is believed to be the first application of the ECRTs process
to marine sediments in situ.
The technology developer works with and licenses its
ECRTs process to environmental engineering and
consulting firms, such as Weiss Associates. Past reported
experience using the ECRTs process includes treatment of
500 tons of PAH-contaminated silty soil in Enns, Austria;
and treatment of elemental and methyl mercury-
contaminated silt in Union Canal, Scotland (Mcllvride,
W.A., F. Doering, et. al., April 2003).
As of April 2003, other than the demonstration at the G-P
Log Pond, funded ECRTs projects are reported to include
remediation/treatment of metals or organics at the following
sites:
PCB-contaminated soil and sediment at an Upland
New York Site,
Mercury-contaminated soil at the Y-12 plant in Oak
Ridge, TN,
PAH-contaminated sediments in Lake Superior,
MN.
Elemental mercury in clay soil at an NPL site.
6.2 Ability to Scale Up
Based on the nature of the technology, theoretically there
is no limit to the areal extent of application, since the
technology can be applied in modules. The areal extent of
this ECRTs SITE Demonstration is considered a pilot-scale
application of the technology, due to the limited area of
treatment. The Demonstration "pilot-scale" area is not
considered to be a typical remediation.
6-1
-------
Section 7.0
References
Anchor Environmental. 2001a. Completion Report: Interim
Remedial Action Log Pond Cleanup/Habitat Restoration.
Prepared for Georgia-Pacific West, Inc., Bellingham, WA.
Prepared by Anchor Environmental, L.L.C., Seattle, WA.
April 13, 2001.
Anchor Environmental. 2001 b. Appendix C: Operations,
maintenance and monitoring plan: Interim Remedial Action,
Log Pond Cleanup/Habitat Restoration. Prepared for
Georgia-Pacific West, Inc., Bellingham, WA. Prepared by
Anchor Environmental, L.L.C., Seattle, WA. May 29,2001.
Bingham, Clothier, and Matthews, 2001 (Sec. 4 reference)
Doering, et. al., no date, Electrochemical Remediation
Technologies for Soil and Ground Water Remediation.
Mcllvride, W.A., F. Doering, et. al., April 2003.
Electrochemical Remediation Technologies for Metal and
Organic Remediation in Soil, Sediment, Sludge, and
Ground Water. Presented at the 4th Symposium on the
Hydrogeology of Washington State, April 8-10, 2003 -
Tacoma, Washington.
SAIC. 2003. Sampling and analysis of electrodes upon
removal following the ECRT Demonstration Project at the
G-P Log Pond, Bellingham, WA. Memorandum dated
March 7, 2003, from Tim Hammermeister and John
Nakayama of SAIC, Bothell, WA to Randy Parker of
USEPA, Cincinnati, OH, and Brad Helland of Ecology,
Bellevue, WA.
SAIC. 2002a. Quality Assurance Project Plan: ECRT
Puget Sound SITE demonstration, Predemonstration
characterization of sediments. Prepared for USEPA,
National Risk Management Laboratory, Cincinnati, OH.
Prepared by SAIC, Bothell, WA and Twin Falls, ID.
Septembers, 2002.
SAIC. 2002b. Technical memorandum data report for
ECRT Puget Sound site demonstration predemonstration
characterization of sediments, dated July 3, 2002.
Prepared for USEPA SITE Program, Cincinnati, OH and
Washington Department of Ecology, Northwest Regional
Office, Bellevue, WA. Prepared by SAIC, Bothell, WA.
Washington Department of Natural Resources. Sole
Source Contract/Amendment Justification Checklist for
Architectural/Engineering Contract.
Weiss Associates, Proposed Budget for Bellingham Bay
ECRT Project.
Weiss Associates, Invoices submitted to the Washington
Department of Ecology and Department of Natural
Resources; RE: ECRT project at Bellingham Bay.
Weiss Associates, June 19, 2001. Draft Work Plan for
Electrochemical Remediation Technologies Treatment
Demonstration Pilot - Log Pond, Bellingham Bay, Puget
Sound. Prepared for Anchor Environmental, L.L.C.
Weiss Associates, July 13, 2001. Letter from J.L. lovenitti
to Timothy Goodman of the Washington DNR; RE:
Financial data and reports - A/E Contract No. AE 086.
Weiss Associates, October 29, 2003. E-mail from William
Mcllvride (Weiss Associates) to SAIC RE: Answers to cost
questions.
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