United States
Environmental Protection
Agency
Superfund
Office of
Solid Waste and
Emergency Response
PB95-963510
EPA/540/R/94/079
9355.4-18
November 1994
WORK PLAN
FOR
BIODEGRADATION OF POLYCHLORINATED
BIPHENYLE (PBCS)
AT
A SUPERFUND SITE

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PB95-963 510
EPA540/R-94/079
9355 .4-18
WORK PLAN
FOR
BiodtfradAtioR of Polychlorinatad Biphanyls (PCBs)
at
a Supvrfund Sit*
GENERAL MOTORS CORPORATION
Massana, M«v York
OITOX / I I DO S f * M S, ' ' I * C.
11919 Dairy Aatifor*
Sugar Land, T* ??«?•
(713) 240-0112

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Chief. Waste and Toxic Substances Branch
Office of Regional Counsel
U. S. Environmental Protection Agency
Room 437 - 26 Federal Plaza
New York, New York 10278
Att: 6. M. Foundry Attorney
Director, Division of Solid and Hazardous Waste
New York State Oept. of Environmental Conservation
Room 207 - 50 Wolf Road
Albany, N. Y. 12233
Mr. Randy Hart
St. Regis Mohawk Health Service
Consunlty Building
St. Regis Mohawk Reservation
Hogansburg, N.Y. 13655
U. S. Environmental Protection Agency
Region II
Woodbridge Avenue
Building 209
Edison, New Jersey 08817
Att: Ms. Diana Messina '
Mr. DarreH Swe redo ski
Sr. Sanitary Engineer
Division of Solid and Hazardous Waste
New York State Department of
Environmental Conservation

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TECHNICAL SUMMARY OF THE DETOX, INC.
BIOLOGICAL PCB DISPOSAL PROCESS
BACKGROUND
On December 17, 1982, Detox, Inc. (formerly "Biotechnology") reouested
approval froti EBfc legion VI to dispose of FCBs usinq its biological degradation
process. The process was used in 1981 to treat pentachlorophenol (PCP)
contaminated wastes in soil to less than 1 ppm at a site located at Conroe,
Texas. The process utilizes a method for acclimating a naturally occuring
species of microbes that have a natural tendency far degrading small amounts
of FCBs to metabolize FCBs in wastes containing relatively higher PCB
concentrations. The microbes metabolize FCBs by attacking the chlorine
atoms and ultimately reducing the molecule to cell protoplasm, water,
carbon dioxide (aerobic degradation) or methane (anaerobic degradation),
and salts. Enzymes are added when necessary to ensure contact between non-
soluble FCBs and the microbe. Also, a catalyst is added to increase the
rate of the degradation process.
Detox claims FCBs are not toxic to these microbes. It is expected that the
higher chlorinated FCBs take longer to degrade than the less chlorinated
isomers. Seme heavy metals, such as hexavalent chromiim, are toxic to the
microbes* Each waste material must be examined to determine if the process
may be applied. The process cannot be used on wastes containing material
toxic to the microbes unless the toxic material is removed. Higher PCB
concentrations reportedly require longer time .periods than lower concentrations
with the sane nvanber of microbes because the rate of degradation is constant.
The higher the PCB concentration in a waste, the greater the time required
to degrade the waste with the same amount of microbes. The tine period for
PCB degradation can be shortened by introducing more microbes into the waste.
Onoe the microbes are applied to a PCB waste, continuation of the process
is ensured by the presence of sufficient oxygen, moisture, nutrients, and
proper pH, Adjustment of pH or the addition of moisture, oxygen or
nutrients may be reauired during the degradation period.
Fbr sludge^, aeration may b^ all that is required depending on the condition
of the lagoon <«g., oxygen"levels nay differ depending on light penetration,
depth of the lagoon, temperature, presence of other bacteria^ wind
. turbulttne*). per dry waste materials, the surface nay require the addition
M of moisture, or soil may need to be further aerated by looeehing the soil
After the source of FCBs is depleted, the microbial population dies out
and becomes an energy source for naturally occuring organians. The process
is essentially the same as that used in municipal treatment plants except
this process uses microbes that can survire in an otherwise toxic environment.
A proposed decision to approve the Detox process was made on June 1, 1984.
A press release was issued opening a 30-day content period. No contents
were received during the comment period.

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2
DEMONSTRATION PROTOCOL FOR ALTERNATE TECHNOLOGIES UNDER 40 CFR 761.60(e)
The FCB regulations require that alternative methods for PCB disposal nust
be show* capable of achieving a level of performance equivalent to PCB
incineration or high efficiency boilers, and that the method does not present
an unreasonable risk to human health or the environment. The "level of
performance" for alternate technologies has been established as reducing
the PCB concentration to below 2 parts per million (ppn). This concentration
is generally the state-of-the-art for a quantitative measurement by standard
OC-MS analytical techniques. PCB samples containing less than 2 ppn PCBs
would be regarded ast' containing non-detectable PCB concentrations, and the
method used to achieve this result would therefore be judged equivalent to
the performance of an incinerator. The rationale is discussed in more
detail in the October 21, 1983, Federal Register (page 48988) on the Vulcanus
I and II draft ocean incineration permit (copy attached).
Alternate technology demonstrations are required to show the ability of the
process to reduce the FCB concentration below 2 ppm and to be cannerically
applicable without risk of injury to huteri health in the environment. To
meet these demonstration requirements. Detox performed a bench scale test
and then a field demonstration of its process using PCB contaminated wastes.
DETOX BENCH SCALE DEMONSTRATION
To demonstrate the process, EPA required a bench scale test using a PCB con-
taminated sludge. The bench test consisted of placing one kilogram samples
of PCB contaminated sludge into three, two-liter erlenmeyer flasks. Each
flask was sampled for PCB concentration before the addition of microbes and
nutrients. The FCB concentration before the introduction of microbes was
approximately 150 ppn. Mr was bubbled through the samples to maintain
aerobic conditions* A florisil trap was placed on the air exhaust line to
absorb any FCBs released into the air.
wa» approved	4,	test began
in March IS^iml'was concluded in July 1983. ' SairtJiaa.of 1(!>0 »1. volune were
withdrawn throughout the test period and sent to lTO^laiwwrtory''located at
Houston, Texas for analysis of total FCBs in sanples containing sediment and
water. The test set-up was inspected by EPA during the test period. Between
the period of March 30, 1983 and July 13, 1983, the PCB concentration drqpped
to less than 1 ppn. Analysis of the florisil trap shewed less than 0.5 ug PCBs.
Samples of flask #2 were analyzed cm 3/30/83, 5/3/83, 5/20/B3, 6/3/83, and
7/13/83. Based on the analytical results, the bench scale test demonstrated
that the biological process is capable of destroying PCBs to less than 2
ppn without detectable PCB air emissions from the sludge. Also, the qas
chromatograms showed no new chlorinated organic compounds formed during
the degradation process.

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The next phase was to oonduct a field test which would demonstrate that
the process will work under ambient conditions. On August 8, 1983, Detox
submitted a request to oonduct a field demonstration. Included was a
field demonstration plan that outlined project objectives, scope of work
and schedule of performance. The field demonstration was approved by CPA
on September 13, 1983, and begun September 22, 1983. The demonstration
was concluded in December 1983. It was conducted on the Heame Utilities
property located at Heame, Texas. The project consisted of placing less
than 500 lbs. of FCB contaminated sludge into a non-leaking "bio-reactor"
open to anbient air. FCB transformer oil was added to the FCB sludge to
raise the total FCB poncentration to approximately 2000 ppm. An inpellar
drive device in the bio-reactor ensured mixing of the sanple and that
aerobic conditions would be maintained. Microbes and nutrients were
added to the reactor after a sanple was taken of the material.
EPA was present at the beginning and the end of the test to collect split
satples of the sludge before the microbes were introduced into the FCB
sludge. EPA observed the test set up to ensure it was in accordance with
the test plan, and observed the sanple collection by Detax. Satples taken
be Detox throughout the test period were hand delivered to NUS laboratories
located at Houston, Texas. Detox claimed that chain of custody was maintained
in collection and delivery of the sarrples from Detox to NUS laboratories.
The analytical results showed a significant reduction in FCB concentration
with final sample results as low as 0.12 ppn.
DISCUSSION Of RESULTS
The Detox demonstration projects showed that the biological FCB disposal
method is capable of destroying FCni to below 2 ppn, and has a practical
field application potential without harm to human health or- the environment.
Some of the duplicate saqo&e 'analytical, results show a range in FCB
lfc™»nt e«tSiMion. However,: thi total' picture
of the resulted the bench and field demonstrations showed a,definite
trend in the reduction of FCB concentrations in the sliidfcp Naples.
The air exhaust simple results in the bench scale test showed no detectable
PCBs. This ensured that the reduction in the FCB	mm not due
to air dispersion, and that use of this technology in the field would not
result in harm to health or the environment by air dispersion. Ambient
air. sampling was not conducted at the field demonstration because of the
results of the bend) scale test, and because the field donbnstration did
not utilise a heat source which could volatalise the FCBs, or use an air
dispersion device for aeration of the sanple material which could result
in asperation of FCBs.

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4
Copies of the final report were sent to the state agencies for comment on
February 27, 1984. Hie Arkansas Department of Pollution Control and Ecology
(ADPC&E) canmented that the approval should require site-specific evaluation
before granting permission to proceed with PCB disposal. Itie proposed PCB
approval requires a complete report evaluating the site including *raste
analyses for EPA review. Each potential PCB disposal site would require
written approval by the legion VI Regional Administrator before disposal
could begin. Due to the wide variety and characteristics of contaminated
PCB wastes, it was felt necessary to require site specific approvals to
continue to collect more data on the performance of this relatively new
technology under different conditions.
/
CONCLUSION
The bench scale and field tests demonstrated the ability of the Detox
biological PCB disposal process to degrade FCBs to below 2 ppn without
endangering human health or the envirorment due to air dispersion, and
that the process is adaptable for commercial use.

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J UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
?	REGION VI
f	INTIHFIKST TWO BUILDING. 1101 ELM STREET
DALLAS. TEXAS 7S270
August 15, 1984
Mr. Thomas A. D*rd«$t President
Detox Industries, Inc.
Four Sugar Grove, Suite 210
4800 Sugar firove Blvd.
Stafford, Texas 77477
Dear Nr. Dardas:
This letter responds /to the application submitted by Detox Industries
requesting approval by the Regional Administrator of the U.S. Environmental
Protection Agency, Region VI for the use of Its biological disposal method
for the destruction of polychlorinated b1phenyls (PCBs) in Region VI States.
EPA hereby grants the requested approval subject to the enclosed conditions
and based upon the results of a demonstration Detox conducted on PC8
contaminated wastes. Split samples were collected by EPA before and after
the test period.
Section (6)(e) of the Toxic Substances Control Act (TSCA) requires EPA to
control the disposal of PCBs. EPA promulgated regulations 1n Title 40 Code
of Federal Regulations, Part 761 to implement Section (6)(e). These regula-
tions provide that disposal of PCBs in concentrations of SO parts per million
or greater shall be by methods approved by the Regional Administrator of
the EPA Region 1n which the method 1s to be used. Detox has requested by
Its application of 12/17/82, that Its PCB biological disposal method be
approved 1n accordance with EPA PCB disposal regulations.
Violation of 40 CFR Part 761 or any condition Included as part of this
approval may subject Detox to enforcement action under the appropriate
statute and/or termination, revocation or modification of the approval.
Furthermore, receipt of evidence that (1) a misrepresentation of any material
.fact,v|i|,liMii.|iili^1ii aiy Otto* submittal; (2)all relevant facts,lia*e not
been disclosed; (I) the nature of the disposal process has substantially
ftom effective date of this approval; or, (4) Detox 1s found to
be non-compliance with Its approval cohdltlons shall constitute sufficient
cause for revocation or modification of this approval.
This approval shall fee affective upon receipt of this latter.
Sincerely yours.
Dick Mhittington, P.E. '
Regional Adminlstrator
Enclosure

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Conditions for PCB Disposal by the Detox Industries
Biological Degradation Technology
Before disposal of any PCBs by the Detox biological disposal Method,
except for up to a 3 gallon sample for testing or demonstrating the
process, Detox and the owner of the PCB waste material (applicant) shall
make written request to the EPA Region VI Regional Administrator for
approval to dispose of PCBs. A copy of the notification shall be sent tc
the appropriate State and local officials. PCBs in concentrations at or
over 500 parts per million (ppm) are required to be incinerated by the PCB
regulations. For sites with PCB concentrations of 500 ppm or greater, Detox
and the applicant shall request from the Regional Administrator an exemption
from the Incineration requirements of 40 CFR 761.70.
Detox nay test or demonstrate the ability of Its process to degrade an ap-
plicant's PCB waste without IPA approval on one sample not to exceed
three gallons. Disposal of the sample after testing 1s completed shall
be according to applicable federal and/or State regulations. EPA may
request additional information or add additional requirements to complete
Its evaluation of the disposal project. Detox and the applicant must
receive written approval from the Regional Administrator before disposal
can begin. The Regional Administrator may add other conditions to the
approval that are not 1n this general approval.
Detox and the applicant shall attach to the written request a report which
shall contain the following information:
(a).	A report detailing the extent of surface and sub-surface
PCB contamination in soil and/or presence or movement In the
groundwater, and Identification of hazardous wastes which
may be present as defined by 40 CFR Part 261 of the Resource
Conservation and Recovery Act (RCRA). This report shall
Include • "Background" section describing how the PCB
contamination occured and showing the range lit concentration
of PCBs (and hazardous wastes 1f present), and the total
contaminated waste volume. This report thai 1 bt compiled
from reprcsentatlve samples trm the waste material and
•naljrzod according to methods acceptable to IPA.
(b).	A waste disposal plan showing the following:
(1). How access shall be controlled during the disposal period.
* (2). A runoff/run-on control plan showing how potential losses
of PCBs from the contaminated area shall be controlled.
(3). If groundwater contamination exists, what are the plans
for groundwater decontamination, groundwater monitoring,
and/or remedial action for groundwater decontamination/
control after disposal is completed. If groundwater
is not contaminated, ho« the groundwater will be protected
from PCB contamination.

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2
(4).	The approximate length of time required for PCB disposal,
and the expected level of treatment the biological
process 1s expected to achieve. Included In this
part shall be a discussion of the number of expected
microbial applications; types of organisms to be used;
nutrient applications; type and amount of emulslfler to
be applied^ If any; soil type and conditions such as pH;
and what factors are expected to influence the disposal
process, either positively or negatively, to achieve final
treatment.
(5).	A proposal for monitoring and reporting the progress
during the PCB disposal. Periodic reporting shall be
required based upon the length of time projected for
PCB disposal. Monitoring of the project shall be
required to ensure that the waste materials are properly
handled during the disposal process.
4
(6).	A Quality Assurance (QA) Plan shall be submitted
detailing the sampling plan, sampling protocols,
and the Analytical Quality Assurance/Quality Control
(QA/QC) during the disposal period. The name, address,
and contact person for the analytical laboratory shall
be submitted. EPA may disapprove the proposed laboratory.
(7).	A contingency plan showing where the PCB contaminated
waste will be taken for proper final disposal 1f the
PCB concentration Is not reduced to below 2 ppm.
(c). A plan for final disposition of the wast* material. This
plan shall show where the treated waste shall be sep$Jf moved
from the original site of contamination. Whether or not the
waste material Is planned to bo moved, closure pianrand
post closuro plan shall bo submitted for the sito of
contamination.
2. PCBs shall be treated to a concentration loss than2 parts permllllon
(ppm). Detox or tho applicant may request a different final level of
treatment by providing justification to the Regional Administrator.
Failure to meet tho 2 ppm PCB concentration may require removal to a
hazardous waste landfill approved to receive such wastes 1n accordance
with RCftA, Subtitle C; a landfill approved pursuant to TSCA Section 6(e)
to receive PCB wastes: or, an Incinerator approved to receive PCB wastes
pursuant to TSCA Section 6(e).

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3
3.	Detox and the applicant shall Identify and obtain all required state,
local, and federal permits, approvals, and/or authorizations before
disposal can begin.
4.	Records and data shall be Maintained on the proceedings at each disposal
site. Data shall Include; (a), the name and address of the company or
Individual for whom the service was performed; (b)t name and telephone
number of contact person for the company; (c), the location and dates
service was performed; (d), the amount of PCB waste treated; (e), a copy
of the gas chromatograph and/or data record from analysis of representative
samples taken before, during, and after PCB disposal.
EPA may require additional samples and analyses for PCBs or for the
presence of other chemical compounds to ensure that the required level
of disposal has been achieved or that the site does not pose a threat
to human health or the environment. The documents must be compiled
within 60 days of the completion of the project, and copies kept at one
central location where the data shall be available for inspection by
authorized representatives of the Environmental Protection Agency and
State regulatory agencies. Such documents shall be maintained and
accessible to EPA for at least 10 years (one copy to bt kept by Detox,
and one copy by the applicant).
S. Detox and the applicant shall notify State and local officials In
writing of the proposed PCB disposal project. If the project 1s
approved by the Regional Administrator, Detox and the applicant
^projtct1* ,#ca1 ®ff1c1,1t in ******* cf
•;• Anjruted for PCI transport, storage, or disposal sb|11
not be used for an* other purpose unless decontamination of the can-
ta1 ner compl ler wlth 40 CFK- 761.79.
7.	All *£1 articles, equipment, and containers shall ba properly marked
according to 40 CFR 761.45.
8.	Detox and theIppllcant's personnel safety requirements and procedures
for ©nslte PCB handling, storage, transport, and disposal shall comply
with OSHA requirements.
9.	The conditions of this authorization are not severable, and If any
provisions of this authorization, or any applications of any provision,
1s held invalid, the remainder of this authorization shall be held to be
entirely invalid.

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9/30/16
I.
OPERATIONAL PLAN TO BIOLOGICALLY
fttfif M«ii m CTff
TKJbA* JPWB9 UR
yg9lt9^ 9fr1fS*l»ff
OXTOX IWDUSTRIXS, IMC. ("Detox"} proposes to construct a 24* high and
/
56' disaster opan steel' tank to which 300,000 gallons, aore or lass,
of KB contaainated sludgas and/or soils will ba gatharad from an
agisting 350,000 gallon capacity lagoon located en propartf ownad by
Ganaral Motors Corporation locatad in Hassans, Haw York. Such sludgas
and/or soils shall ba traatad in phases of 300,000 gallons ainiaua at
the site in tha tank. Its purpose is to reduce the PCB contaaination
level of the above aaterial to less than 2 ppa to ba reported en an
"as received" basis or any higher level concentration agreed to by OTA
Region 21. Said tank will be the property oC Betas and will be
reaoved at the expense of Detox within one (1) year of coapletioc if
theproject.
ffWt ft Wfffcl
The work to be performed consists of the following taskst
2.1 Detox will place into the tank (bioraactor) approxiaately 300,000
gallons of contaminated sludge frosi the CM lagoon. A •iaiauai of
a two-foot freeboard will be aaintained to prevent any
overflowing.

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2.2	A aixing (i.a., diffusion) device will be placed into the tank to
ensure aixing of the sludge.
2.3	After twenty-four hours of aixing, two one-quart samples will be
S
taken, coded, sealed and properly stored with chain-of-custody
foras for transaittal to a third party laboratory for PCS
analysis to be reported on an "as received" basis. These saaples
will represent the background "untreated" saaples.
/
2.4	Detox's proprietary nutrients will be added to start the PCB
biodegradation process. Detox's aicroorganisas will then be
innoculated into the aixture. (Tiaely addition of nutrients and
aicroorganisas will be aade by Detox to ensure the rate of
degradation.)
2.5	Two one-quart saaples will be reaeved froa the tank for total KB
analysis each- Monday during the biodegradation process. These
saaples will be treated exactly as is Task 2.3. Al* saaples will
bo seat to a third party laboratory for total PCt analysis to be
reported on an "as received* basis.
2.6	All saaples will be secured in the presence of a 6M
representative designated in writin« by CM.
2.7	All saaples shall be treated by Detea with a bioeide designated
in writing to GN for the purpose of destroying Detox's
proprietary aicroorganisas. The quantity of said bioeide added
to each saaple shall be prescribed in such writing.

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IX.
MASTS DESCRIPTION
pgSWPTIQW
300,000 gallon*, aore or lass, of sludge coataaiaatad with polychloriaatad
biphaayla (PCBs) 1b ascaaa of 2 ppa to a dapth of approxiaataly aix (6) faat
-(plua an uadataraiaad aaouat of aiailarly coataaiaatad aoil baaaath tha
aludga to a dapth of approxiaataly forty (40) faat) eoataiaad ia aad uadar a
330,000 galloa capacity lagooa locatad at tha Gaaaral Motors Corporation,
Caatral Foundry Division, Massaaa Plaat ia Massaaa, Maw fork as iadicatad ia
tha attachad sita plan. Said Matarial shall aot iaeluda any objact
axcaadiag oaa (1) iaeh ia diaaatar.

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2.8	Tasks 2.4 through 2.7 will be repeated until the PCB
contaaination level of the saaples has boon reduced to tha
greater aaount of 2 ppa or such higher concentration level as aay
be acceptable to SPA Region IX.
2.9	After the PCS contaaination level has bees reduced is accordance
with Task 2.8 above, the tank contents will be reaoved to a
location on the GM property as designated by 6M not further than
500 feet froa the original lagoon.
Performance Schedule:
tased on past projects conducted by Detox involving siailar
contaainated sludges* the project is estiaated to be coapleted within
a sis-aonth period.
Materials (sludges mad/ot soils) to be treated shall be aeasured on
thetoasia of tapat as fellowst
<*) Sladeea - voloae shall be aeasured with a flow-aeter designed
to quantify the aaount of through-put.
(b) Soils - voluae shall be aeasured froa an elevation benchmark
through each phase of escavation.

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ZIZ.
SAMPLING PROCEDURES
P*QP9$ED PROTOCOL
SwUnq |pHi»} St»g«
1.	Proa the bioreactor and under the proper cha in-o f-custod;, two
oae-guart split spiplas of contaminated aaterial will be taken
randoaly aftar twenty-four hour* of aising. These aaaplaa will
be analysed by a third party laboratory for total KSa by Gas
Chroaatograph (GC) to aatablish an analytical banchaark for
parforaanca evaluation. The concentration levels of PCBs in
saaples are to be reported on an "as received" basis.
SvUfgytnt	5t»'/•. _
Ml fffPlfiM
3.	nil saaples taken in steps 1 and 2 above shall be taken in the
presence of a CM representative designated in writing to Oetos
and shall be transaitted to the laboratory pursuant to chain of
custody procedures designated by CPA Region ZZ.

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f
MASSENA SITE PLAN
«•••

*
SAST ANSA
ACTIVJI
/
»WJp#l«»OiAt
r
t9.0D0.D09 QAk.
LAQOON
L
RTH ARIA



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IV.
MUtLYTXCAL PROCEDURES
Saaplaa will ba analyiad in accordanca with SPA Mathod 1080, "Organochlorina
*
Pasticidaa and PCBi, in Vast Mathods for Evaluating Solid tfaata , SW (46, 2d
Bdition, July 1982".
Analytical raaults Hill ba raportad on an "aa racaivad" baaia. 6N ahall pay
tha coat of analyaia. Tha third party laboratory hirad by 6M auat ba
aceaptabla to Dates and IPA. All laboratory raporta ahall ba dalivarad to
CM and Satox aaparataly by tha laboratory. In addition, tha laboratory
ahall dalivar all gaa chroaata graaa to Datos.

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V.
DATA REPORT MG/R4C0RDKEEFIKG
Detox Industries plans to keep rieordi of the following:
*
1.	Daily* - Records of bioreactor temperature
-	L09 of activities
—	Operational paraaeters
—	Visitors
—	Weather
—	Shutdowns, spills, accidants
—	Motifications
2.	Weekly* - Saaple description, location, chain-of-custody
-	Third party laboratory results (notification)
* All records/books (on sitaj open to GM and iPA inspection.

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VI.
SPILL FRZVXKTIOM
Spill prevention is directly addressed by the following considerations:
1.	the process will be applied in a manufactured open steel tank.
Rupture of these standard tanks is considered relatively non-
existent.
2.	k containment bera is to be constructed completely around the
process facility to act as an impediment to any extraneous flow
of material created in an emergency situation.
3.	Should an emergency occur, spilled material will be placed back
into the tank along with any extra material which becomes
contaminatad through a spill or rupture.
4.	Any spill will be reported to Of immediately. GM Is responsible
for reporting to the government, as necessary.

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VII.
SAFETY FLAM
Detox Industries, Xnc.'s safety plan insures that each eaployee has been
properly instructed in the use of a wide variety of safaty equipment
including, but not liaited to, the following}
•	Protective Clothing
•	raca Shields, Protective Gloves
•	Respirators
•	Kaergency Personnel Nash
•	First Aid

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VIII.
TRAINING FLJUf
Detox personnel previously trained in handling paraaeters of Detos process.
All training performed in Detox's Bouston facilities.

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XX.
QUALITY ASSURANCE PLAK
Dotox's biodogradation is a now altornato destruction technology Cor PCSs.
Quality assurance for analytical work is the responsibility of the third
party laboratory as such laboratory will be doing all saaple aonitoring and
analysis.
MgASllRPTOIT VtRiriCATIOW
PCB analysis. (Sao nest page for flowchart.)

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MEASUREMENT VERIFICATION (Coat.)
PROCESS
copy
o Preventative Maine•
o Corrective Action
Procedures
o Increased Productivity
of Process
DETOX
Proj. Mgr
GM
THIRD PARTY
LAI*
copy
o	Frequency - once per veek
o	Calibration Proccedures
o	Quality Control Checks
o	Data Reduction
o	Valuation Reporting
o	Distribution
o	Responsible for Accuracy,
Precision & Completeness
EPA
Onslte Coord.
o Audit procedure - Optional
* Using all EPA standard operating procedures and analytical
calculations.

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StoL
SOUTHWESTERN LABORATORIES
Materials, environmental and gtouchnical engineering, nondestructive, metallurgical and analytical services
222 Cavalcad* St. • RO. Box 8768. Houston. T«xss 77249 • 713/632-9131
File No.	2-1787-QO
Report No. 7.144-7355
Report Date —1/6/86—
Hent: DeTox Industries, Inc.
Gene liner
4 Sugar Grove, Suite 210
4800 Sugar Grove Boulevard
Stafford, Texas 77477
r**: Analysis of samples submitted 12/12/85 by Gene Liner.
_ {
RESULTS
Sample I.D.
SWL Lab No.
E
o.
G
•
t-
O
o
PCB, ppm
Baker 58055, Control
7344
3965


Baker 58196, Control
7345
117


Baker 58055, Treated
7346
2391


Baker 58196, Treated
7347
110


GM-Lagoon #1, Control
7348

338
as 1248
GH-D1fester, Control
7349

no
as 1248
GM-Actlvated Sludge, Control
7350

63
as 1248
GM-Lagoon #1, Treated
7351

107
as 1248
GM-D1gester, Treated
7352

63
as 1248
GM-Act1vated Sludge, Treated
7353

6.5
as 1248
GM*(IN0)*E-3» Treated 8/27
7354

8253
as 1242
GH-(IND), Treated 8/18
7355

4107
as 1242
simcian:
ja$: 3 - DeTox Industries, Inc.
pm
• lsrt»rs sra Itaont m* for tr.» «xciw«iv» «M of ctiant to whom ¦'*
rmtort* noelw nnlw to »*• trntrtnim	—— —			
aOt/TWWWBTftMN UUIOAATORlBa
i Barry
1st	0
tfirn
Chemist
Kiummi i'wo yM oi our nam* >nu«t raealw* our prior wntwi «ob'0»*» c,ur

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yyc? -/:>/" (K i " r^-^r
Division of General Motors Corporation
Massena Plant
Post Office Box 460
Massena. New York 13662
October 31, 1986
Cert i fi ed Ma iI -
Return Receipt
Requested
Chief, Site Investigation 6 Compliance Branch
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
26 Federal Plaza
New York, N.Y. 10278
Attn: G.M. Foundry Project Coordinator
Mr. Me Ivin Hauptman, P.E.
Dear Mel:
Enclosed you will find a copy of the letter and Laboratory
Report from Detox Industries, Inc. dated January 7, 1986.
As we discussed during last Wednesday's meeting, the test
run times were limited to 16 days duration. It should also
be noted that the report details samples taken from three
(3) areas of the Plant, the 350,000 gallon lagoon is listed
as CM Lagoon II, the remaining two samples were selected as
areas that might be benef ic ia I to the plant operation
should the process prove viable.
If there are any questions concerning this matter, please
contact me at	• -xfM' **•
Sincerely,
David P. Fayette
G.M. FacIIity Coordinator
cc: Joseph P. Chu, PhD, P.E.

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DETOX INDUSTRIES, INC.
*800 SUGAR GBOVE 8LVD
SUITS 210
STAFFORD. 'TEXAS 77*77
(713) 240-0892
January 7, 1986
Mr. David P. Fayette
Sr. Plant Engineer
Central Foundry Division
GENERAL MOTORS CORPORATION
P.O. Box 460
Masseaa, New York 13662
Dear Mr. Fayette:
This letter is to confirm our telephone conversation of last week
whereby we discussed our successful feasibility study conducted
on PCB samples sent to us by you from the Massena Plant.
Enclosed for your review is a laboratory report from Southwestern
Laboratories of Houston, Texas. This report is dated January 6,
1986 reporting analyses of three (3) samples provided by you.
Each of the three samples received from you was separated into a
control and a sample to be treated. The treated samples were
inoculated with our naturally occurlng microorganisms on November
27, 1985 and placed oa a water bath shaker to cause agitation.
Allquots of each control and treated sample were removed for
laboratory analysis of PCBs on December 11, 1985* The following
is a recapitulation of that analysiss
Control (untreated) Treated 1 Reduction
GH l(iiooa 11	. 33ft ppm (124ft)	107 ppa	6ft.3X
GM Digester	110 ppti	63 ppm	-42.7X
GN Activated Sludge	63 ppm	6.5 ppa	89.6X
The above analyses represent comparisons of the contaminated
samples seat to us before and after treatment with our p*or*s».
They demonstrate a slgalfleant reduction la PCB coacamiaation
after only sixteen (16) days of treatment by our biological
process* Consequently, we are confident that our process may be
successfully applied to the sites from which each sample was

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; Mr. D a v1
January
Page Two
P. Fayette
, 1986
provided to reduce the contamination level to a very low concen-
tration. As discussed, application of our process to the conta-
minated sludge may be expected to ultimately result in water and
sediment relatively uncontaninated for all practical purposes.
We hope you are as excited about the above results as we are. We
look forward to the possibility of using our technology to solve
your disposal dilemma and hope to hear from you soon.
Thank you for giving us the opportunity to demonstrate the effec-
tiveness of our preferred disposal alternative.
Sincerely yours,
Thomas A. Dardas
cc: Dr. J. Chu
Mr. J. Medved
TAD/mec
Enclo sure

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