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
                                      IX

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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
                                                   1-5

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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.
                                                       2-2

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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.
                                                    2-4

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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.
                                                  2-5

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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

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                          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,
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>       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
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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
                                                    3-7

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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
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(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
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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
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            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

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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

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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

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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

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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

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                                             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

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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

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                                            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

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                                            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.
                                                  7-1

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