NCD980602163_19971112_Warren County PCB Landfill_SERB C_Evaluation of Phase I - Joel Hirschhorn, Pat Barnes-OCR

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November 12, 1997 ................................................................................. by fax (2 pages)
To: Steve Detwiler
Mike Kelly
Pat Barnes
From: Joel Hirschhorn
-.. -/;/!},, r,·,,
Re: SUGGES1ED TOPICS FOR NOVEMBER 14 KICK-OFF J\.1EETING ON PHASE II
DETOXIFICATION PROJECT
General goal for meeting: to develop a specific work plan that details all the activities and the
specific outputs for the final Phase Il report.
At this meeting all major assumptions, tradeoffs, and particulars should be thoroughly discussed
and conseu~1.1s decisions reached on how to proceed. Any issues \.\-1th RFP should be thoroughly
addressed.
A detailed table of contents for the final report should be developed.
A detailed schedule for completion of the project should be developed, including iuterim
deliverables and review procedures, and a regular form of communicatio.n. A proceclme for
handling changes in the work plan should be agreed to .
.As to the Phase II repmt beinz prepared, the followin~ are important priorities
11:i.e repo1t should communicate in words, figures, and data a technically complete but easily
understood picture of what a full-scale detox project for the landfill would consist of and .look
like. All impacts on the local community should be dearly identified. An Executive Summary
should be conceived as serving as the basis for presentations to lawmakers and others 0.11 the
Phase IT proje<-'tlreport.
1l1e repo11 should have sufficient details to support a credible cost estimate for the entire detox
project, v,rith clear statements to describe the assumptions and unc.ertainties for the estimate. The
report should also present the detox project in terms of clearly defined and described discrete
phases or ~1ages, beginnmg with a final design phase, \.\-'ith a reliable cost estimate for ea.ch phase.
Supplemental site investigation work to be conducted during the final design phase should be
scoped out in order to resolve uncertainties about contamination outside the landfill that might
require detox.
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Several levels of potential cleanup performance objectives for PCBs and dioxins/fiuan.s should be
selected to assess different levels of detox and their associated costs. For example, one scenario
could use the stringent performance standards used in Phase I, while another might use the
numerical levels likely to be used in a standard state regulated cleanup. The impact of different
ped'ormance levels on volumes of material to be detoxified and costs must be specified.
A site perimeter air monitoring system should be designed and appropriate action levels defined.
Special attention should be given to landfill excavation and material handling processes and
procedures and how particulates will be effectively controlled. The need to address water ir.i the
landfill and mixing of wastes with varying contamination levels prior to treatment should also be
addressed. It may be appropriate to assume certain amounts of \\:ater removal by the state.
An early phase should be performance verification or demonstration for full-scale equipment at
the site during a trial production nm. The maxi.mum amount of excavated materials to be used
should be identified, as well as the general protocol, with special emphasis given to air pollution
control equipment and effective functioning of a perimeter air monitoring system.
An emergency response plan should be developed and any special costs identified, such as
necessary training for local hospital persounel. Special attention should be given to loc.al residents
,vjth.iu about five miles of the site.
A plan to use locally available labor should be developed, \\-ith special costs ideutified: such as
technical training for skilled and semi-skilled positions. Use oflocal finns for supplies should also
be examined. A reasonable estimate for the economic contribution to Wanen County from the
project should be given.
The use of a Citizen Advisory Board with its own independent technical consultants should be
included in project design and cost estimates. The CAB would provide oYersight throughout
project duration.
A plan to use the project to serve local educational institutions should be developed based on
cooperation with the CAB. For example, site tours, presentations by site managers, and possibly
ex'POlt of data from monitoring stations to schools or libraries sl1ould be considered.
2
~bd /f"~( HiRSCHHORN
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'/?--~ A Division of Hygienetics Environmental Services, Inc.
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Suite 411 . {J/lTPh9re: [phone]
2401 Blueridge Aven,ue /; Fa~ [phone]
Wheaton, MD 20902 _ · 1
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October 6, 1997
To: Mike Kelly, Division ofWaste Management
From: Joel Hirschhorn
.\
This is to formally submit to your office the report on the Phase I detoxification technology
testing that I and Pat Barnes, as Science Advisors for the State/County Warrent County PCB
Landfill Working Group, performed.
This report provides the basis for recommending the selection ofETG as the company best
qualified to perform the Phase Il activity originally scoped out in the state RFP.
Also enclosed is some supplemental materials regarding the analysis of the technology testing
work.
,I
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COMPARATIVE EVALUATION OF THE TWO PHASE I
REPORTS ON DETOXIFICATION TECHNOLOGY TESTING
OF MATERIALS FROM THEW ARREN COUNTY, NORTH
CAROLINA PCB LANDFILL
Prepared by:
Joel S. Hirschhorn, Ph.D., Hirschhorn & Associates
in association with
Patrick A Barnes, P.G., BFA Environmenta~ Inc.
October 1, 1997
1.0 Introduction
In response to a Request for Proposals to evaluate treatment technologies on soils
extracted from the PCB Landfill, Warren County, North Carolina, issued by the Division of Waste
Management ofDENR on January 31, 1997, two proposals were selected for funding. The RFP
had clearly identified two detoxification technologies as meeting the requirements established by
the Joint State/Warren County Working Group; these were Base Catalyzed Dechlorination (BCD)
and Gas Phase Chemical Reduction. The RFP notified potential proposers that the project was
divided into two phases and that multiple companies might be chosen for Phase I, but that only
one company would be awarded a contract for Phase II.
Section 2.1.4 of the RFP specified the following selection criteria for choosing one
company for the Phase II part of the RFP:
a. The ability to meet Phase I performance criteria as demonstrated through Phase I
test data. The performance criteria were presented in Section 2.5 of the RFP. For post-
treatment solids the Principal Preliminary Remediation Goals were 20 ppb for total PCBs
and 1 ppt for Dioxin TEQ. The Air Emission Performance Goals were 8xl 0-4 micrograms
per cubic meter (ug/cm) for PCBs and 5xl0-8 ug/cm for Dioxin TEQ.
b. The quality of the Phase I test report.
c. The ability of the vendor to provide full-scale equipment at the Warren County
PCB Landfill site.
1
d. The ability of the vendor to provide a safe, reliable and cost-effective full scale
application of the selected technology at the Warren County Landfill. Section 2.2 of the
RFP further clarified the goals and objectives of the testing, particularly in terms of
determining feasibility for full-scale detoxification and that, in addition to the meeting the
performance criteria, feasibility would also be determined by considering the safety of the
technology, the rate of detoxification, the cost per unit of detoxification, the reduction in
long term potential for environmental releases from residuals of the treatment process.
e. The quality and cost of the proposal for providing Phase II services.
This report by the two Science Advisors for the Working Group is the comparative
evaluation of the two Phase I reports submitted in this project and is provided to the Working
Group and the Division of Waste Management for the purpose of assisting with the selection of
the Phase II contractor. All reports and responses to questions submitted by the two companies,
ETG Environmental, Inc. (ETG) and ELI Eco Logic International Inc. (EL), have been
considered in preparing this report. The format is to present a discussion of the relative pros and
cons, or advantages and disadvantages, of each company's proposed technology for each of the
above selection criteria. Finally, a summary comparison and recommendation is presented in the
last section.
2.0 Meeting the performance criteria
2.1 Post-treatment solids -total PCBs
ETG conducted four test runs and in all four cases the total PCBs were reduced to levels
less than 20 ppb. The average of the four runs was 0.8 ppb. A consideration is the variation in
PCB levels in the input (raw feedstock) materials, which in this case averaged 508 ppm Because
nondetects (NDs) are often reported, detection limits are also a factor in evaluating results. In
comparing two the companies the issue that arises is ifNDs are reported but the detection limits
(DLs) are different, then the NDs are not exactly the same. With higher DLs the NDs are less
impressive, because the potential level of undetected PCBs is higher. Another way oflooking at
this issue is to realize that with lower DLs it is possible to have positive hits or :findings of PCB
isomers while if higher DLs were used, then those :findings would not be present.
EL conducted three test runs and reported NDs for all three results; however, the DLs
were significantly higher than in the ETG testing, primarily because smaller size samples were
used in the EL testing (i.e., 0.010 kg versus 0.030 kg for ETG). The only scientific way to better
compare the two sets oftest data, therefore, is to recalculate the total PCB levels by using the
worst possible case in which it is assumed that the NDs are actually equal to the DLs. This has
been done and the recalculated levels for both companies' data are given in the following table by
using the data given in the respective reports. It can be seen that by following this procedure, that
the recalculated average for ETG increases to 1.84 ppb and for EL the average changes from
2
what might be interpreted as zero to 3.63 ppb. Thus, while it is correct to say that both
companies were able to meet the performance criterion, it is also correct to conclude that ETG
performed better than EL, particularly because ETG conducted four runs while EL presented data
for three runs. Additionally, the average PCB level in the raw materials tested was 23 7 ppm for
EL but 385 ppm for ETG, which makes the ETG results even more significant, because a higher
fraction ofPCBs were removed.
Company/sample Original total PCBs (ppb) Recalculated total PCBs (ppb)
ETGWCl-3 .74 1.33
ETGWCl-4 2.55 3.06
ETGWC2-3 0(ND) 1.80
ETGWC2-4 0 (ND) 1.18
ETGaverage 0.8 1.84
EL 1 0(ND) 4.10
EL2 0(ND) 3.40
EL3 0(ND) 3.40
EL average 0(ND) 3.63
2.2 Post-treatment solids -dioxin TEQ
ETG reported data for four runs, with an average dioxin TEQ of0.91 ppt, however one of
the runs had a value of2.96 ppt, but this was for the sample with the highest level ofPCBs. In
fact, ETG had optimized its process based on a much lower level of chemical treatment (BCD)
additive, which would explain why in this one run both the PCB and dioxin TEQ levels were the
highest in the residual treated solids. In fact, the TEQs for the other three runs were exceptionally
low, with an average of about .23 ppt, which is insignificant. It should also be noted that even the
2.96 ppt level is very low and that EPA and most states have not approached this level for dioxin
cleanups. For example, for the Koppers Superfund site cleanup in Morrisville, North Carolina the
dioxin cleanup level was 7,000 ppt.
EL reported data for three runs. However, the dioxin analyses were redone for runs 1 and
3, but not run 2, because of overly high detection limits in the original testing. Also, some dioxins
were originally found in run 2 material, despite high detection levels, because of high dioxin levels
that resulted from run 2 representing a process failure due to too low a temperature in the TRM
desorption unit that did not allow removal of dioxins for chemical reduction in the second high
3
temperature stage. This is discussed in length later in this report. The original TEQ values for
runs 1 and 3, based on using detection limit values was reported by EL as 15 ppt and 32 ppt,
respectively. If the value for run 2 is included, then the average for all three runs in the original
data is very high at 142 ppt, and with the data from the retesting it is 127 ppt. The data are
summarized in the following table.
It is shown how comparable data can be used from both companies, in terms of either data
from all runs or only the best runs, and for EL for original and revised data. For example, the
average for the two best EL runs can be compared to the average of the three runs ofETG that
represented their best process performance. In other words, if all test data are considered for
both companies, then EL clearly fails to meet the performance criterion, and if only the best runs
are considered for both companies, then EL meets the criterion but ETG has superior
performance. From a community perspective, it is valid to judge the companies on the basis of all
their data, because they are responsible for suboptimal runs.
Average Dioxin TEQ Levels (ppt)
TEST RUNS ETG ECOLOGIC ECOLOGIC
original data revised data
All runs .91 142 127
Best runs .23 24 .50
It should be noted that the average dioxin TEQ level in the raw materials for EL runs 1
and 3 (the best runs) was 186 ppt, and 175 ppt for the three best runs ofETG. Proportionally,
ETG had slightly better performance (i.e., 99.89% versus 99. 73% removal).
2.3 Air releases -total PCBs
ETG reported data for three runs in terms of both stack discharges and modeling results
for a property line assumed to be 200 feet from the equipment, which is a proper procedure for
addressing an exposure concentration (and that had been deemed appropriate at the pre-bid
conference for the RFP). In fact, the performance criteria had been established on the basis of
exposure concentrations for a very low risk level. The average of the ETG data was .87x10·4
ug/cm, or about one-tenth the performance criterion of 8xl0·4 ug/cm
EL reported data for three runs in terms of stack gas concentrations only, for which the
average was l.26x10·4 ug/cm, which is below the performance criterion at the stack, and which
automatically makes it below the criterion at any distance to an exposure point.
The ETG data for the stack concentrations were significantly higher than for the EL data.
However, air sampling methods and equipment were not identical and, therefore, a direct
4
comparison of stack data alone is not necessarily complete. The main problem is that an air
sampling procedure that is more efficient and effective in removing material and obtaining low
detection levels will have a higher probability of detecting contaminants. For example, sampling a
larger volume of gas will increase the probability of detecting contaminants. For example, the
stack gas flow rate in the ETG tests were about three times larger than in the EL testing,
suggesting a higher sensitivity in the ETG air testing. It must be emphasized that the performance
level set for this testing was extremely low and stringent and that the data from both companies
indicates that no health hazard would be caused by PCB air emissions from the detoxification
process. Indeed, in all probability there may be greater concern about potential PCB air releases
from site excavation and material handling prior to treatment in equipment, but this issue should
be addressed in the Phase II work.
Based on available information it can be said that both companies are comparable on this
sub-criterion.
2.4 Air releases -dioxin TEQ
ETG reported stack and model data for three runs. The model data had an average of
.52xl0-8 ug/cm, about a tenth of the performance criterion.
EL reported that no dioxins/furans were found above detection limits, but that the highest
possible level was 1. 7x10-5 ug/cm, which is higher than the performance criterion. Therefore, EL
said that "Due to these sampling and analytical constraints, it is not possible to demonstrate the
ability of the ECO LOGIC Process to meet the dioxin TEQ performance goal..." The highest
possible EL level is some 1000 times greater than the performance goal. However, if EL would
have modeled its data to address levels at some reasonable exposure point, then it would have
been able to show compliance, because its stack level was similar to that found by ETG.
The Science Advisors conclude that ETG has the advantage on this sub-criterion.
3.0 Quality of the Phase I report
Making a professional judgment about the quality of a technical report can involve many
considerations. Certainly, the reports should present the information required in the RFP in a
user-friendly format. Additionally, however, the quality of the report can be considered to be
higher when there is considerable attention to particularly important issues and when additional
information is provided to assist the understanding and evaluation of the testing. It must also be
noted that EL submitted a draft report which was then modified in response to various questions
and comments to produce a final report, while ETG submitted only one initial final report.
Therefore, to some extent the one submission by ETG is comparable to the second submission by
EL that corrected deficiencies in the original draft report.
5
As an important example of a difference in presentation quality, consider the Tables 4-5
and 4-6 in the ETG report, which presented in easily understood tabular form the primary data on
treatment effectiveness for PCBs and dioxins/furans for all the test runs, and for all the individual
isomers or congeners in each category. A reader could immediately see how the post-treatment
levels compared to the original raw material levels, and when nondects were reported the
detection limits were also presented. In contrast, the EL report presented the analogous data in
two separate tables (Tables 8 and 9), and the contractor had to be instructed to provide detection
limits in the final report, and neither table presented the data for all the individual isomers or
congeners in the useful way employed by ETG.
Another factor was that ETG presented more information than was strictly required. For
example, ETG presented the results of testing to show that their process had actually destroyed
PCBs and also obtained data on particulate levels in emissions and water content in raw feed
materials.
It must also be noted that the quality of the report is merely a surrogate for the quality of
the bench-scale testing. In this sense, it is important to note that EL conducted three runs versus
four for ETG, and that one of the EL runs (run 2) was essentially a failure because of an operator
error that caused the initial TRM desorption part of the process to function poorly due to a low
temperature that did not separate dioxins/furans for chemical reduction in the second part of the
process. A major aspect of any type of technology testing is to see how well a company conducts
itself and operates its own equipment to demonstrate a very high level of competence that
provides confidence to potential clients that the very best performance will be obtained in full-
scale usage. The main question that merits attention for this aspect of the EL testing is why the
senior persons in charge of the test did not identizy the low temperature problem during the test
period and repeat the test run. This was especially important because only three runs were used.
Also, in discussing this event EL has referred to a minimum temperature in the TRM unit
of 550°C, but the unit is supposed to operate at 600°C according to the information in the EL
report. EL did not provide detailed data for run 2 on exactly what temperature was used or for
how long a suboptimal temperature existed during the run, except that the temperature dropped
to 500°C. However, it reported average mill temperatures of 595°C, 572°C, and 628°C for test
runs 1, 2, and 3 respectively. It is interesting that two of the runs did not have average
temperatures of 600°C. The fact that the average temperature in run 2 was above the 550°C
minimum that EL has mentioned also raises a question of uncertainty about what actually
occurred in run 2 to so thoroughly cause no treatment of the dioxin contamination. The
information suggests that out of the total of 15 minutes in the TRM unit even a small amount of
time at suboptimal temperature is sufficient to cause a complete failure to remove dioxin
contaminants from the feed materia~ which is a serious sensitivity to low temperature excursions.
EL also had a problem with an important part of its dioxin testing, which it blamed on the
testing laboratory. However, much of what has been said by EL simply does not hold up under
close scrutiny. Part of the competence of a company in the remediation technology business is
6
expertise for obtaining the best analytical services. If a company provides incomplete or
misleading information to a chemical analysis laboratory, then the laboratory may perform poorly.
In the EL testing, some of the most critical dioxin testing was inferior because of high detection
limits that resulted from unusually small sample sizes for the testing. EL claims that this resulted
from its telling the laboratory that there were high PCB levels, and that this caused the laboratory
to use lower than normal sample quantities. There are two problems, however. First, the overall
PCB levels in the raw materials (information given in the RFP) were not exceptionally high for
PCBs. Second, certainly there would be no rational reason why EL would want the laboratory to
believe that PCB levels were high in their treated materials. EL also said something that any
experienced professional who deals with dioxin testing of solids knows is incorrect, namely that a
target value of 1 ppt dioxin TEQ is impossible to obtain or verify for method 8290. This is plain
wrong, as any examination of test results for this method clearly shows, including the dioxin test
data obtained for the project's site investigation work, as well as the dioxin testing for ETG from
the same laboratory used by EL. In the opinion of one of the Science Advisors, who does
considerable work with dioxin contamination and cleanup and who discussed this issue with both
companies, EL did not exhibit a high degree of knowledge and experience in this area. ETG
verified that at no time did it change its instructions to the analytical laboratory that both
companies used, nor is their any logical basis for believing that actions taken for EL samples
would have affected ETG work in the very large laboratory. The one key fact that seems to
explain the cause of the dioxin testing problems faced by EL was the information it provided to
the laboratory which caused them to use irregular, low sample volumes for testing.
Another issue is that EL did not clearly represent what materials it tested relative to the
materials it had received. EL said that it received three 5-gallon buckets but that only two were
used. But no information was provided to indicate exactly what materials were tested in EL's
three runs. In contrast, ETG clearly indicated what materials had been received and tested in each
of their four runs.
The professional judgment of the Science Advisors is that the ETG report followed the
requested format of the RFP more closely than the EL report, and that the ETG report was in
general easier to follow and presented key information in a more concise manner than the EL
report. As the above discussion indicates, the conclusion is that the quality of the ETG report and
its testing was better than the EL report and its testing.
4.0 Ability to provide full-scale equipment
Both companies are in the position of most technology vendors, namely that either an
existing piece of equipment could be transported to the site and used, or new equipment would be
constructed for the particular job. Both companies have indicated that they would need up to six
months to provide necessary equipment, which is consistent with industry practice for large
cleanup projects. But there is more to consider for this evaluation criterion. The ability to
provide full-scale equipment is legitimately related to the stability and viability of the company,
7
because some significant investment is necessary for a large project, which this one would be
potentially. ETG is actually part of a business that is well established commercially and quite
substantial financially, and it has performed in similar remediation applications for U.S. clients
over some years.
Interestingly, in the BCD treatment technology arena, which is based on companies
obtaining licenses from EPA, ETG has outlasted other companies. In contrast, EL is more of a
start-up technology developer that has had few clients (and none in the U.S. for actual full scale
work) and is not the same level of a stable, financially successful company with a long commercial
track record as ETG. There may also be some significance to the fact that ETG is a U.S.
company located much closer to North Carolina, while EL is a more distant Canadian company.
It is also of some relevance that a very recent study for a major federal Superfund site at which
dioxin is a major contaminant (the Escambia Treating Company site in Pensacola, Florida)
examined potential treatment technologies, and the EPA contractor doing the Remedial
Investigation/Feasibility Study screened out EL and its technology at the earliest stage of
technology evaluation, but included BCD treatment and cited ETG as the source of the BCD
technology. While EL has performed treatability and demonstration tests in the U.S. it has not yet
secured any actual remediation project. In contrast, ETG is the vendor cleaning up the Southern
Maryland Wood Treatment Superfund site, where it will treat some 145,000 tons of material.
This job is closer to the Warren County project than any work that EL has performed.
The Science Advisors conclude that overall the ability to provide necessary full-scale
equipment for the Warren County project is better for ETG than for EL.
5.0 Safety, reliability, cost, and long term releases
5.1 Safety
There are two major ways to look at the safety issue. First, the intrinsic nature of the
technology can be assessed in terms of inherent hazards. For example, any process that utilizes
hazardous materials is fundamentally more hazardous than one that does not use any hazardous
materials, and one that operates at either higher pressure or temperature than another one poses
more potential for unsafe situations.
The second approach is to consider how vulnerable a process is to human error, because
most unsafe conditions and accidents relate to human error. Some technologies are inherently
safer because they are much simpler than other technologies, for example. As for treatability or
demonstration testing, it is presumed that a company will logically use its best trained and
qualified personnel. If human errors occur in testing, it does not portend well for full-scale
company operations.
ETG technology operates at a lower temperature than the EL process, roughly about
8
onehalf lower temperature. The ETG process also operates under vacuum conditions, while the
EL process operates at ambient pressure, and this reduces the potential for system leaks and
discharges of contaminants into the environment. The EL technology uses hydrogen gas, which is
intrinsically hazardous, while the ETG technology uses no hazardous materials, with the exception
of sodium hydroxide which is corrosive but not combustible or toxic. The EL process also
utilizes a bath of molten tin, which raises a safety concern.
Although EL has made a good argument that industrial processes have used hydrogen
very successfully, there is still an inherent hazard that cannot be entirely dismissed, especially
when one recognizes that safety issues generally are centered on unusuai unintended and
unforseen incidents or accidents. While process control instrumentation and monitoring
equipment may be used, the problem in the real-world are low probability events that consist of
several things going wrong to create an actual problem For example, for everyone of the nine
factors that EL has cited to assure the safety of using hydrogen it is possible to identify a
condition that nullifies the factor. For example, EL says that no open flames or smoking are
permitted onsite, but any experienced professional has probably seen just such human behavior on
actual industrial sties where the prohibitions exist. Similarly, leak proof process vessels in the
field can be rendered unsafe by, for example, a bullet piercing a piece of onsite equipment. The
use of nitrogen purging to avoid mixing with oxygen can fail when someone uses a wrong gas
tank or makes a wrong connection.
On the issue of human error, it is also relevant that in the bench-scale testing for this
project, there was a clear, admitted case of human error in the EL test, when a temperature was
not properly controlled in run 2 in the TRM unit. EL also acknowledged a second "operator
error" when the excess gas burner that was supposed to be operated at 800°C was actually
operated between 300 to 400°C, apparently for all the runs. The company also had problems with
equipment, including a micro-Ge instrument that was supposed to be used but was not
operationai and a broken mill shaft which happened twice and caused delays.
Another safety issue is the potential for the air pollution control system to function
effectively to prevent unacceptable discharges of hazardous substances. In this regard, the ETG
report paid considerable attention to this issue and provided extensive discussion of how the
company would employ the most sophisticated technology to collect and treat dust.
The Science Advisors conclude that, assuming that either company would employ the best
industrial safety practices in design and operation of their equipment, the ETG technology has an
advantage over the EL process.
5. 2 Reliability
Reliability can mean many different things, but one key engineering concept is whether a
process technology will offer the best performance under varying field and raw material
9
conditions. In other words, some technologies are more sensitive or vulnerable to variations in
key conditions or parameters and become less reliable because there are upsets created. Some
technologies are very complex with multiple steps or stages and the need for very complex
process control and monitoring equipment. All of these issues can reduce reliability. The use of
computers and sophisticated equipment has not eliminated major problems in industrial processes.
An issue of concern in the current project is the degree to which the detoxification technology
may become unreliable because of high water content in feed materials, for example. To some
degree it seems as if the EL process would be less sensitive to water content, but in fact a close
examination of discussions of this topic by the contractors reveals essentially the same problem
That is, both processes can handle higher moisture levels, but both would be negatively impacted
in terms of throughput, efficiency and processing time. Moreover, ETG actually measured water
content and concluded that no dewatering of materials will be required.
An important feature of the ETG process is that there is solid phase BCD treatment of
PCBs and dioxins in the thermal desorption part of the process and then more BCD liquid phase
treatment of oily condensate, if necessary. Their test results showed that the solid phase
detoxification was successful. In contrast, in the EL process there is no detoxification of PCBs
and dioxins in the first stage thermal desorption unit, and detoxification is dependent on first
separating the contaminants into a vapor phase that then undergoes high temperature reduction.
As the testing showed, the EL process was vulnerable to poor performance when the thermal
desorption stage was not operated at optimal conditions and, therefore, dioxins were not
detoxified.
It is the opinion of the Science Advisors that the ETG process is intrinsically simpler and
less prone to problems created during full-scale use that would reduce reliability.
5.3 Cost
EL has said that it foresees a cost of $300 to $350 per ton, based on processing 100 to
200 tons per day with a 70 to 80% availability, leading to a project duration of 90 to 123 weeks.
The availability range used by EL is not impressive and may indicate its experience in actual
projects where there has been significant down time. This cost does NOT include certain
activities, such as excavation, performance testing or disposal of processed solids, but it DOES
include system mobilization and commissioning, all waste preparation and processing, lab costs
for process outputs analysis and system demobilization.
ETG has said that its estimate of$390 per ton pertains to a processing rate of300 to 400
tons per day with 100% availability. ETG's cost is all inclusive and includes excavation and
backfilling of soil, which the EL estimate did not. ETG has also indicated that if less stringent
cleanup performance standards were used, then the cost could be decreased by some 35% if more
typical criteria were used for PCBs and dioxins. In fact, it is highly probable that the state would
use its normal cleanup criteria and that the ETG cost would likely be less than $300 per ton. It
should be noted that there is less intrinsic capability to reduce operating costs in the EL process,
as compared to the ETG process, and that EL did not offer a similar observation. Note that the
processing rate for ETG is about twice as high as the EL figure, meaning that total project
duration might well be reduced by 50% and require about one year rather than two years.
The Science Advisors conclude that for cost and cost-effectiveness the ETG process is
superior to that of EL.
5. 4 Long term releases from residuals
Any detoxification technology will create certain types of residuals, byproducts or waste
effluents that might pose longer term risks because of releases. Both companies have paid
sufficient attention to this issue and provided similar discussions about the safe and effective
handling of all process residuals and wastestreams, and neither has an advantage. The more
confidence there is in the company's ability to reduce residual levels of PCBs and dioxins to the
lowest possible levels, then there is minimal concern about long term releases from post-treatment
residuals replaced on the landfill site.
6.0 Quality and cost of Phase II proposal
The initial proposals that responded to the RFP included a proposal for the Phase II work.
For the most part, both companies submitte4 comparable proposals that addressed the
requirements of the RFP. Both companies teamed with large, experienced environmental
engineering firms for the Phase II work. However, the cost of the ETG Phase II work was
significantly less at $89,000, while EL proposed a cost of $115,000.
The Science Advisors conclude that ETG offers a significant cost advantage for the Phase
II work, especially in light of currently limited funding for all aspects of the current project. That
is, the saving of $25,000 offers the potential of being able to accomplish other functions and needs
prior to the state legislature authorizing funds for the full detoxification of the landfill.
7.0 Summary comparison and recommendation
The following table presents a simplified summary of the conclusions reached for the
individual evaluation criteria. Rather than using an artificial and subjective numerical rating
system, the Science Advisors have indicated a net advantage in terms of a + sign for the company
with the best capability. When both companies were comparable, both received a +.
11
SELECTION CRITERION ETG ECOLOGIC
Performance
solids -PCBs +
solids -dioxin TEQ +
air-PCBs + +
air -dioxin TEQ +
Quality of Phase I report +
Ability to provide full-scale equipment +
Safety, reliability, cost, long term effects ++++ +
Phase II proposai quality and cost +
As can be seen from the table, in most categories ETG was judged to have an advantage.
This is not to say or imply that Eco Logic and its technology was inferior, poor or completely
unacceptable, but only that, in this particular testing and for this specific application, ETG has a
number of advantages, as presented in the previous discussions. On the basis of visiting the test
sites, having discussions with company personnei and examining the reports, the Science
Advisors agreed that ETG seems a more engineering oriented company, while EL seems more
R&D or science oriented, with less of a practical, engineering construction focus.
Also, a close examination of all documents provided by EL indicated the following: ( 1) the
company probably has not met the stringent dioxin cleanup criteria used in this project in previous
projects; (2) the September 1994 EPA report on the thermal desoiption unit found that it "did not
perform to design specifications" and that the company "experienced material handling problems;"
and (3) the company does not seem to have been able to perform commercial projects at a profit
and may be experiencing uncertain financial conditions. On the latter point, the last two annual
reports from EL indicate that the company has continued to be unprofitable, despite rising
revenues, while the information supplied by ETG indicates a medium size environmental services
company that is profitable. For example, the highest revenue stream for EL in 1996 was less than
$5 million annually (for which the annual loss was nearly $12 million), while the company that
ETG is a division of grosses about $50 million and is profitable.
In conclusion, the Science Advisors agree that ETG is the best qualified company
for receiving the Phase II contract and advise the Working Group to accept this selection
and to formally communicate its recommendation to the Division of Waste Management.
12
October 6, 1997 ............................................................................. by FAX (6 pages)
To: Working Group and Pat Barnes
Through: Doris Fleetwood
From: Joel Hirschhorn
Re: Supplemental information Phase I evaluation, Phase II selection for detoxification technology
It is appropriate to transmit to the Working Group some new information, none of which affects
the recommendation in the previously submitted report by Pat Barnes and myseU: however.
First, on the basis of something that Mike Kelly said at the last meeting concerning his negative
view ofETG and their past effort in North Carolina, I asked for some clarifying information from
ETG. A copy of their letter to me is attached. My analysis of their past effort and their
demonstration for us has removed any technical concerns about their current technology and
technical approaches to assuring safe operation of their equipment.
Second, as discussed at the last meeting I have followed up in obtaining more information about
the unsolicited proposal from Triangle Environmental in which they wanted to test at their own
cost material from the landfill, using two technologies. Since that meeting I have had about three
phone conversations with persons from that company and now have received various materials
from them I have also had phone conversations about the Commodore technology, which is the
detoxification technology that they have indicated they would use, with two different persons
from Commodore and two EPA officials familiar with the company and its technology, including
one in the Office of Research & Development responsible for a SITE demonstration of the
Commodore technology and one in Region 2 in charge of a Superfund site demonstration that
included the technology. Triangle also indicated that it would first use the separation technology
from Environmental Technology to create a concentrated material that would be treated by the
Commodore technology.
Here are my conclusions, based on examining the materials submitted and the phone discussions:
--There is no evidence that the Commodore and Environmental Technology processes have been
used full scale in an actual commercial remedial project involving detoxification ofPCBs and
dioxins from soil type matrices. This was a screening criterion originally established for the
selection of Phase I participants and, therefore, both technologies do not meet a basic requirement
for participation in the Phase I testing.
--No data on technical performance, safety or cost are yet available from the two EPA
demonstrations of the Commodore technology. There is no indication at this time that
Commodore technology would actually get selected for any actual job based on the results of the
1
demonstrations.
--Data that has been submitted on both the separation and detoxification technologies presented
by Triangle Environmental do not demonstrate an ability to meet the performance standards
established for the Phase I bench scale testing.
--The situation with regard to Triangle Environmenta~ Commodore, and Environmental
Technology is not clear. Triangle has not indicated whether it has some type of license to use the
two technologies or whether it would subcontract out treatment to the two companies. It appears
that any bench-scale testing would be conducted by the two primary technology companies. The
RFP was aimed at companies with detoxification technologies, not environmental services firms,
which Triangle appears to be.
--Triangle has not been particularly responsive to all the questions posed to it. Importantly, there
is still no evidence that the company seriously examined the RFP for the Phase I and Phase II
efforts, nor that they understood exactly what type of testing would be required in Phase I.
Without seeming to fully understand the full extent of the required testing they could not
reasonably know the costs they faced. The extent of testing would be considerable, because two
different technologies would have to be fully evaluated. That is, first the separation technology
would have to be shown to reduce PCB and dioxin levels on landfill materials, and then the
detoxification technology would have to be shown effective on the concentrate from the first
treatment. Testing of any soil washing/separation technology poses some greater difficulties than
testing detoxification technologies, because such soil washing is sensitive to many parameters
associated with the physical and chemical characteristics of the feed materials.
--Triangle appears to give considerable importance to the fact that both Commodore and
Environmental Technology have received EPA PCB permits (in March 1996 and November 1996,
respectively), as if such permits are deemed as proof positive of performance, safety and cost-
effectiveness. However, such permits are granted on the basis of certain limited test data obtained
by companies and do not substitute for extensive demonstrations of technology for specific
applications. The companies did not have to demonstrate performance for dioxins and the
performance standard for PCBs was much higher than we have used.
--The situation with respect to the Commodore technology is very unclear. There appears to be
several business entities in several cities related to the original Commodore company. Even the
EPA ORD person expressed confusion over exactly what is going on, and my questioning of
several Commodore persons has not revealed the nature of the business organization. Attempts
to obtain technical information directly from Commodore have not yet proven successful.
--The technical information submitted thus far has not included the level of information that was
available when companies submitted their responses to the RFP. Aside from the lack of showing
actual full-scale commercial use, the information provided does not detail very much about the
treatment processes. Although the Commodore technology is not a high temperature process, it
2
does involve the use of hazardous materials and conditions, including elevated pressure, that raise
safety issues.
To sum up, I see no valid basis at this time to change the decisions made by the Working
Group. H there is some subsequent RFP, then Triangle Environmental and other
companies would be free to respond. But at this time it is appropriate and responsible for
the Working Group to accept the recommendation of the Science Advisors and recommend
to the state that it award the Phase II contract to ETG. I would also expect the Working
Group to send the letter to Triangle that the Working Group voted to send at the last
meeting.
3
,.
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lrlvlronmental, Inc.
Joel S. Hirschhorn, Ph.D.
Hirschhorn and Associates
2401 Blue Rid&c Avenue
Suite 411
Wheaton, MD 20902
Pmviding creative environmental solutions
October 1, 1997
Subject: Supcrfund Innovative Teclmoloay Evaluation (SITE) Demonstration
Koppers Supe.rfund Site -Morrisville, NC
Dear Joel:
As a result of several discussions on the subject project, ETO Environmental, Inc.
would like to provide additional information to you relative to the SITE demonstration
performed by ETG at the Koppers Superfund site . in Morrisville, NC in August, 1993.
ETO was contacted by the USEP A to demonstrate the USEP A patented, ETG
licemed Bue Catalyzed Decompo,ition (BCD) process at the Koppers Supetfund site in
Morrisville, NC. The Koppers site is a former wood treatment site near Ralei&h and
required remediation for soil contaminated with pemachlorophenol (PCP), creosote,
polychlorinated dibenzo-p-,dioxins (dioxin,), polychlorinated dibenzofarans (futans) and
isopropyl ether (IPE). Soil treatment standards of 7 puts-per-billion (ppb) for
dioxin/iuran toxicity equivalent concentration (TEQ) were establiahed in the Record of
Decision (ROD) for the site. The primary purpose of the demonstration wu to establish
the ability of the BCD prooeu to achieve these soil treatment standards, while also
evaluating the level of contaminants in the treatment residues (air, water and condensed
oil). No air standards for dioxins.lfurans were established for the demonstration, as the
low volumo of air flow would result in extremely low mus mniuions as compared to
hip air flow rate tecbnologie. (i.e. incineration).
Based on these requimnenta, £TO qtccd to participate in the SITE program.
The equipment utilized included a hollow~ftiaht screw type thermal deaorption sy•tem
(solid phase BCD reactor). The vapor recovery system consisted of multiple stageli of
16 Hag~rty Boulevard. West Chester. PA 19382-7594 • (610} 431 -9100 • Fax (610) 431 ·9140
~tNJ tsY: t I U t:NV U<ONMt:N I AL, 1 NC; 1 u-,-in a; Hl'M ; west cnester, l'A➔
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direct contact condensers/scrubbers (oil scrubber, water scrubber) and a condensina unit
followed by vapor phase carbon as tho final polishing step. The .demonstration results
indicated successful soil treatment, while air results indicated hiibar than desirable levels
of dioxim remained in 1he air stteam. The condenaers were ektive at reduoing dioxins
vaporized from the soil, however. vapor phise carbon WU only marginally effecti-ve in
reducin& dioxins/furans. In fact, as carbon became saturated, dioxins adsorbed or
deposited in the carbon unit during previous tests were actually released, resulting in
hipcr outlet concentrations than inlet for two of the seven test l'WlS, Since the
tempcranuc wu only in the 100°F ranae, no dioxins could have been generated -in the
vapor pbaae carbon.
As more data became available to the "'icntific community on dioxin/furan
toxicity, lower air emission standards IIDd lower soil treatment standards wore required by
Federal and State. enviromue11tal agencies. Clearly, improved tedmology developments
would be necessary to meet these lower standards. By applying the tedmology in full.
scale operations, ·ETG has continued to impiove the thermal · daorption/solid pbue BCD
systems and especially the vapor~ systems to meet thete lOMr standards. These
developments/improvcmcnts are summarized below:
TJampal Pwi:ptteafflelJd fhw BCD
ETG bu developed our Therm-O-DetodJ proprietary batch vacuum and
continuous thermal desorption sy1tems, both of which have been previously described to
· you in dotail in the Wamm County Phase I pil9t study report These systems have been
designed to improve the key process variables necessary for reduced residual contaminant
concentrations in the soil, by operatina under the following conditions: . .
1. Higher material temperature
2. lfiaher vacuum
3. Enh8X1Ced mixing of waste during processing to facilitate better heat
transfer
4. Loqer material residence time within the thermal deaorber vessel
5. Optimiml BCD additive utillution
These improvements ~ clearly illllsttatcd by the aoil n::sults of the Warren
Cowity pilot study, as compared to tho residual levels of dioxins. achieved at Koppers.
ETG
E11vtro11111t1ftl■I, 1110, ... ,............... .. .......... ....
'
SEN~ BY!ETG ENVIRONMENTAL, INC;10-1-97 3:14PM West Chester, PA◄
1ACI UJarbbern s,ptep,hs 10, 1997
ETG bas incorporate~ improvem.em in the air pollution control equipment { or
VRS) to achieve lower .emillions of contaminants. Initially, a cyclone removes larger
solid particulates ~ the air stmm. As ~viously designed and utilized at the SITE
demonstration, multiple stages of condensers reduce the vapor phase concentration of the
. contaminants. A wet electrostatic precipitator (WESP) is added to further remove
orpnic droplets (aerosols) and particulates. Finally. a flameless thenna1 oxidimr
replaces carbon as the final vapor polishina step.
These improvements result in extremely low concentrations of contaminants in
the discharged vapor stream. Raults at several ETG full-scale dioxin remediation
projects confirm the effmiveness of these improwments. The results of the Warren
County study also clearly dcmonstrab: the system perfonnance. As noted in the Warren
County report, the cyclone and WBSP me improvemenu that are planned to f\Jrther
reduce air emissions at the full•soalo Wmen County project. These improvemeim will
be utilized for the Southern Maryland Superfund Site in Holl~ ·Maryland.
We appreciate the opportunity to continue to work with you at Wmmi County.
Please call me at your convenience if you have any questions or require any idditional
information. ·
OII1t'lcld
PNJ4
Very truly youn.
G. Steven Detwiler
Vice President. Business Development
ETG
En.tronmenlal, Inc.
;1 4
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September 2, 1997 ............................................................................ by FAX
To: Mike Kelly
From: Joel Hirschhorn
Re: Phase l repo1ts
Using the scoring system suggested by Pat Barnes I score the submitted repo1ts as follows:
ETG E co Logic
35 20
13 8
18 10
20 10
Total 86 48
I see no n.eed or obligation to consider revised reports.
Therefore~ I recommend the selection ofETG for the Phase II contract. In my opinion, there is
considerably more than a "slight" advantage ofETG over Eco Logic. I view the difference as
substantial
Again, I repeat my hope that we can move quickly to advance to the Phase Il activity.
cc: Pat Barnes
Technical Committee
, . --.:~ ~ c~ r \
,.,'\" f '
rl\\~ 1~ ~: · Bc1rnes, Ferland and Associates, Inc.
/' · · 3655 Maguire Blvd. Suite 150
Date
Number of pages including cover sheet
To:
Phone
Fax Phone
CC:
J)ErlNR _;
.< · ~------· Orlando, Florida 32803
From:
Yo-l bar cos
Phone [phone]
Fax Phone [phone]
REMARKS:
D FYI ~;ee Attached O Urgent D For your review O Reply ASAP O Please comment
~--\ L--1 (l --c-/7 l _d~=
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BF A Environmental Consultants = == =-=-= = Barnes, Ferland and Associates, Inc.
MEMORANDUM
TO: Working Group
, FROM: Patrick A. Barnes, P.G.
DATE: August 29, 1997
SUBJECT: Review of the Warren County Bench Scale Test Report
Submitted by ETG Environmental, Inc. and
ELI Eco Logic Inc.
BFA #95-017
BF A reviewed the two referenced pilot scale reports using the following fonnat:
l . Form and Content: The documents were reviewed to determine if the prosecution format and
technical content was consistent with the requirements of the RFP and industry standards.
2. Consistency: The documents were reviewed for internal consistency.
3. RFP Criteria: They were reviewed in light of the criteria outlined in the State's RFP. A
memorandum summarizing the results of that review is attached.
4. Scoring: Finally, a point system was established for each of the major criteria as outlined in
Section 2.5 of the RFP as follows:
a) PCB and Dioxin Removal
b) Quality of Phase I Test Report
c) Ability to Provide Full Scale Equipment
d) Safety and Reliability
The scoring is detailed as follows:
TOTAL
ETG
30
10
15
20
75
Ecologic
30
5
15
10
60
40 Points
15 Points
20 Points
25 Points
Based on the above, we recommend proceeding to Phase II with the ETG team.
3655 Maguire Boulevard • Suite 150 • Orlando, Florida 32803
Office [phone] • Fax [phone]
MEMORANDUM
TO: Patrick Barnes, P.G.
FROM:· TedHortenstine,P.E. ~
DATE: August 28, 1997
SUBJECT: Review of the Warren County Pilot Scale Test Report
Submitted by ETG Environmental, Inc. and
ELI Eco Logic Inc.
BFA#95-017
The reports were reviewed based on the selection criteria presented in the Request for Proposal
(R.FP). A discussion of each of the five selection criteria as stated in paragraph 2.1.4 is provided
as follows:
a) The Ability to Meet Phase I Criteria (Section 2.5) as Demonstrated through Phase I Test
Data:
1) PCB and Dioxin Removal Performance -In general, both processes demonstrated the
ability to treat the contaminated soil to the levels requested (Total PCB less than 20 ppb)
for Total PCB's. Eco Logic expressed concern that the level of treatment could not be
demonstrated for Dioxin TEQ due to the detection limits achievable for soil samples
using method 8290. Reported values for Eco Logic were ND (non-detectable) for two
runs and 380 ppt for one of the runs. The 380 ppt wa,; attributed to low temperatures
during Run 2. ETG Environmental, Inc. did not express any concerns regarding detection
limjts. ETG Dioxin TEQ values ranged from ND to 2.96 ppt.
Eco Logic was able to demonstrate compliance with PCB emissions at the exhaust (gas)
stack. However, they were unable to demonstrate compliance with the Dioxin TEQ
emission perfom1ance requirement. Eco Logic attributed this problem to sample size and
analytical detection limits. ETG Environmental, Inc. did not meet the stated performance
at the exhaust stack. They did report compliance based on an EPA dispersion model
(Screen 3) which predicts air pollutant concentrations within a certain distance (200 ft.
was used).
2) General: Based on th.is review, ETG Environmental, Inc. appears to have a slight edge on
soil treatment perfonnance. Overall, it appears that each process can meet the treatment
performance requirements with slight modifications in the full-scale unit or v.1ith a slight
relaxation of performance requirements.
MEMORANDUM
August 28, l 997
Page 2
b) The Quality of the Phase I Test Report:
1) Format: Neither company adhered to the format required by paragraph 2.7.2 of the RFP .
The report submitted by ETG Environmental, Inc. seemed to follow the requested format
more closely than the Eco Logic report.
2) General: The report submitted by ETG Environmental, Inc. was easier to follow.
Information was presented in a more concise manner. Strictly based on the quality of
each report, the ETG Environmental, Inc . was a better report.
c) l11e Ability of the Vendor to Provide Full-Scale Equipment at the __ ~arren Com1ty PCB
Landfill Site:
Although ETG Environmental, Inc. discussed the capabilities of their full-scale units, no
statements were made concerning avrulability of these units. A phone conversation with Mr.
Steven Detwi.ler of ETG Environmental, Inc. confirmed that an existing treatment unit could
be relocated, or that a new treatment unit could be constructed depending on the timing of
the project. A maximum period of six months would be necessary prior to start-up.
Eco Logic discussed their situation in detail. They are in the same situation as ET(i
Environmental, Inc. Either an existing unit could be relocated or a new unit could be
constructed. They would also need up to six months prior to start-up.
d) The Ability of the Vendor to Provide a Safe, Reliable and Cost-Effective Full Scale
Application of the Selected Technology at the Warren Landfill:
1) Safety: Neither company addressed the issue of safety as it relates to the full-scal e
system. Based on the review of the reports, the system proposed by ETG Environmental ,
Inc. appears to be inherently safer than the system proposed by Eco Logic due to the
follov.ring reasons:
• The ETG Environmental, Inc. system operates at 600 -650° F, while the Eco Logic
system operates at 800-900 ° C (1,472-1,652° F).
• The ETG Environmental, Inc. system operates under vacuum conditions which
minimizes system leaks or discharges. The Eco Logic system operates at ambient
pressures.
• The ETG Environmental, Inc. system does not appear to introduce any potentially
explosive materials while the Eco Logic system utilizes hydrogen gas.
MEMORANDUM
August 28, 1997
Page 3
The above observations were based on infonnation contained in the report. Since no full-
scale safety data was presented by either firm, additional data should be requested to
substantiate or refute these observations.
2) Reliability: Neither company addressed the issue of full-scale system reliability. Due to
the complexity of each of the systems, no observations could be made to compare each of
the systems. Additional information should be requested from each company.
3) Cost Effectiveness: Minimal information was provided by each company concerning
cost effectiveness. An economic comparison of the two systems cannot be made W1less
more substantial cost data is provided.
e) The Qualitv and Cost of the Proposal for Providing Phase U Services:
Not Applicable: Proposals for providing Phase II services will be submitted after acceptance
of the Phase I reports.
TH/psg/8-28f'B
Augusr 21, 1997
F~:Ot1
&1<5
?~C/4-14-IIUG 21
. ,,. .
✓
To: :Mike Kelly, Pat Barnes, Technical Committee .................................... -...... by FAX (3 pages)
From: Joel Hirschhorn
Re: Evaluation ofETG Phase I report and recg!Dmendation of contractor for Phase II
After I had submitted my comments on the Draft Eco Logic Phase l repo1i I Ieceived the Phase I
report from ETG. I am v.'liting thls memo because I think it is possible to avoid a time consuming
comparative evaluation and discussion of the two repo1is. In my opinion the ETG work is
superior to the Eco Logic effo1t and I now fitlly support the selection ofETG for the Phase II
work. Considering all the time delays we have already faced, I hope that we may move forward
as speedily as possible at tl1is point.
I am particularly disrurbed by the submission of a Draft report by Eco Logic that lacked
considerable data. Their argument that the problem of inadequate dioxin test data was a result of
a bad decision by the laboratory is not satisfactory_ ETG used the same lab for its dioxin and PCB
testing and it obtained :fine dioxin test data, and at l°'v enough detection limits to demonstrate
compliance with the designated performance specjfication of lppt TEQ. The detection limits for
the PCB testing were also lower in the ETG work. The RFP did not specify submission of a Draft
Phase I report. ETG has submitted a final report and I see no reason why the state is obligated to
give Eco Logic still more time to respond to comments and submit a final Phase I report.
Most importantly, I have not found it necessary to raise the same level of issues for the ETG
report that I found necessa1y to raise for the Eco Logic report. To the contrary, I find the ETG
report considerably better, because they have given more complete and reasonable technical
information, analysis, and discussion. I am also impressed by the markedly greater experience
ETG has in working on actual cleanup sites, which I th.ink ex-plains their better Phase I
performance. The ETG comment on how cost would be reduced substantially if c1eanup
pe1fonnance goals were not as rigid as specified in the RFP was very important and appropriate,
and an indicator of the greater expe1ience with cleanup projects_
In particular, I make the following compa1isons between the two reports:
1. Unlike the Eco Logic report~ the ETG report is clear about what materials it tested in tem1s of
what was received an.d what was used for each run. Eco Logic used less than 60 pounds of site
soil for testing in three mlle, while ETG used about 200 pounds in four runs.
2. The ETG effort was considerably better with respect to analyzing all waste streams and aJso
about how they would be addressed :in full scale treatment.
3. The ETG report presented all the diox:in data that was expected.
l
1-19-1997 11 :30P~
4 . The ETG effort more convincingly demonstrated that their technology could meet the most
stringent cleanup goals. The problem of high detection limits confronted by Eco 1:,ogic can
probably best be understood on the basis of much smaller volullles of waste treated and, therefore,
less materia] available for analyses. ETG testing used 10 times as much soil for diox.-in testh1g and
three times as much for PCB testing.
5. Th.e ETG repo1t presented better information on full scale use of the technology.
6. The presentation of chemical analysis data was snperior in the ETG report (e.g., presenting
detection limits for non detects; presenting results for soil blank). The repo1ting of non-detects
for PCBs in treated soil in the Eco Logic report was somewhat misleading, because the detection
}fruits vvere relatively high; if one-half detection limits were used, then the levels would have been
comparable to the highest level reported for WC 1-4 in the ETG report (i.e., about 2 ppb).
7. I find it suspicious that the total PCB levels were so much lower for the Eco Logic feeds for all
th.rec runs as compared to the levels for the four ETG tests (i.e., an average of 234 ppm versus
508 ppm). Note that the RFP cited an average PCB level of 350 ppm. The difference is simply
too great to be explained by no1mal variations lvithin landfill materials. There may have been
some aspect of how Eco Logic processed the mate1ials that ex.'Plains such a major difference. In
any event, the higher levels for the ETG tests makes their results more impressive.
8. Unlike Eco Logic, ETG addressed pa1ticulate matter emissions.
9. Unlike Eco Logic, ETG presented data Oll VOCs in stack discharges and properly reponed
levels as less than the detection limits.
10. Unlike Eco Logic, ETG obtained some basic information on physical characteristics of the
\Vastes.
Issues for ETG Phase J report.:.
[If the state decides to wait for a final Eco Logic report, then I propose that we give ETG an
opportunity to submit .responses to technical issues that can be raised about their Phase I report_]
1. They might have e"--plicitly addressed the poorer results for the WC 1-4 nm. However, the
ex-planation is probably that the amount of BCD additives used were based on the overly low PCB
level obtained from less sophisticated chemical analysis that was used for the initial optimizatjou
test.
2. 11le acntal discharges measured at the stack for PCBs and diox.ins were greater than the
specjfi.ed performance standard; however, ETG correctly interpreted the levels as being at some
reasonable exposme points and their modeling was very conservative ( only 200 feet away from
2
,,,.
the treatment unit). The Eco Logic test results for stack levels were considerably lower for PCBs.
This appears a result of the basic differences in the narnre of the treatments (i.e., the efficiency of
PCB destruction). If it was solely a result of different gas flow rates ( about 50 dscfin for Eco
Logic versus about 160 dscfm for ETG) or mass throughputs of soil during the testing (i.e., less
than 7 lbs/hr for Eco Logic versus 5 lbs/hr for ETG), then higher levels wouJd be e;\_-pected for
Eco Logic (i.e., more PCBs in less gas). There were higher levels ofPCBs in the ETG feeds, but
not enough to account for the substantially higher PCB levels in the stack (i.e., an average of
about 8,000E-4 ug/dscm for ETG versus l.3E-4 ug/dscm for Eco Logic). All things considered,
it appears that the Eco Logic process is more effective at destroying PCBs. However, ETG
discussed using a more elaborate arr emissions control system in their full scale application.
Nevertheless, ETG couJd be asked to provide more detail on the air modeling used to sh.ow how
dispersion reduced PCB levels by a factor of about 7000 for a distance of only 200 feet.
3. Like Eco Logic, ETG used the lab data for total PCBs but not PCBs plus EMPCs; I believe
the latter should be used. However, in certain cases ETG did use EMPC levels, when only they
were reported for some isomers.
RECOMJ.\'IEI'lii"l>ATION
To summarize, I recommend that ETG be selected for the Phase II effort because:
■ ETG presented more complete Phase I test data.
■ ETG presented more data demonstrating feasibility of meeting very stringent cleanup
goals.
• ETG presented higher quality information and discussion of how the technology \vould be
implemented at fi.ill scale, including the potential for lowering costs by using less stringent
cleanup criteria.
■ ETG has more experience iu actual contaminated site cleanups and the conduct of the
Phase I work Jnvolved fewer human e1Tor and equipment problems than for Eco Logic.
■ In many respects, the ETG equipment is less complex than. the Eco Logic equipment and
poses fewer safety issues for the local commuu.ity.
3