NCD980602163_19970319_Warren County PCB Landfill_SERB C_Gas Phase Chemical Reduction of PCBs in Soils Extracted from the Landfill During the EcoLogic Process-OCR

ECO LOGIC ------------tee:)
ELI Eco Logic Inc.
GAS PHASE CHEMICAL REDUCTION
OF PCBs in SOILS EXTRACTED FROM THE
WARREN COUNTY, NORTH CAROLINA LANDFILL
USING THE ECO LOGIC PROCESS
RFP No . PCB LF-4
PROPOSAL
Submitted to:
North Carolina Department of Environment,
Health & Natural Resources
Division of Waste Management
401 Oberlin Road , Suite 150
Raleigh, North Carolina 27605
Attention: Michael A. Kelly
Submitted by:
ELI Eco Logic International Inc .
143 Dennis Street
Rockwood , Ontario
NOB 2KO
March 19, 1 997
143 Denni s St., Rockwood, Onta ri o, Canada , NOB 2K0
Phone [phone]
Fax [phone]
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page i
TABLE OF CONTENTS
EXECUTIVE SUMMARY Page iv
1.
2.
3.
5.
INTRODUCTION ......................................... Page 1
BUSINESS STRUCTURE AND COMPLIANCE H1STORY .............. Page 1
2.1 Canadian Commercial Corporation . . . . . . . . . . . . . . . . . . . . . . . . . Page 1
2.2 ELI Eco Logic Inc ................................... Page 2
'),., __ .J Guild Incorporated ................................... Page 2
2.4 Camp Dresser & McKee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 2
PROCESS ENGINEERING ................................... Page 5
3.1 Introduction ........................................ Page 5
ECO LOGIC Process Components ......................... Page 5
3.3 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 6
3 .3. I Pre-Treatment Handling ........................... Page 6
3.3 .2 Waste Processing ............................... Page 6
3. 3. 3 Description and Handling of Process Outputs . . . . . . . . . . . . Page 10
3 .4 Process Chemistrv . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11
3. 5 Process Monitoring and Control . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12
3.6 Development and Testing .............................. Page 12
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
5.1
5.2
5.3
TECHNICAL PROPOSAL -Phase I . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15
Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page I 5
Project Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 15
Description of Treatability-Scale Process Unit .. • ............... Page 17
Phase I Testing Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18
Sampling And Monitoring Plan ........................... Page 20
4. 5. I Sampling Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23
4.5.2
4.6.1
4.6.2
4.6.3
4.6.4
4.5.1.1 Liquid Sample Collection ......................... Page 23
4.5.l.2 Solid Sampling ................................ Page 23
4 .. 5. I. 3 Gas Sampling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23
Sample Analysis Procedures . . . . . . . . . . . . . . . . . . . . . . . Page 23
Monitoring Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 24
Chemical Ionization Mass Specuometer (CIMS-500) . . . . . . . Page 24
Nova Multi-Gas Analyser . . . . . . . . . . . . . . . . . . . . . . . . . Page 25
Nova Oxygen Analyser .......................... Page 25
M200 Gas Chromatograph (M200 GC) . . . . . . . . . . . . . . . . Page 25
Quality Assurance/Quality Control . . . . . . . . . . . . . . . . . . . . . . . . Page 25
Waste Handling And Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 26
Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 27
Public Meeting to Present Phase I Results .................... Page 27
TECHNlCAL PROPOSAL -PHASE II . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29
Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29
Project Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29
5.2.1 ECOLOGIC ................................. Page29
-') ? ) ___ _ Camp Dresser & McKee ......................... Page 29
5.2.3 Guild Incorporated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 29
~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 30
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page ii
6.
7.
8.
9.
5.3 .1 Technical ................................... Page 30
5. 3. 2 Community Relations and Risk Communication . . . . . . . . . . . Page 31
5.3 .3 Key Personnel ................................ Page 33
5.3.3.1 ECOLOGIC ................................. Page33
5.3.3.2 Camp Dresser & McKee ......................... Page 33
5.3.3.3 Guild, Incorporated ............................. Page 34
5. 4 Schedule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 34
6.1
6.2
7.1
7.2
7.3
8.1
8.2
8.3
8 ,1 . -,
8.5
PERMITTING AND PUBLIC CONSULTATION .................. . Page 35
Page 35
Page 35
Page 35
Page 36
Page 36
Page 37
Page 37
6.1.1
6.1.2
6.1.3
6.1.4
6.1.5
6.1.6
ECO LOGIC's Past Performance ........................ .
General Motors of Canada Limited (Commercial-Scale) .... .
Kwinana, Western Australia (Commercial-Scale) ......... .
General Electric Canada Inc. (Commercial-Scale) ........ .
Bay City, Michigan (Pilot-Scale) ................... .
Hamilton Harbour, Ontario (Pilot-Scale) .............. .
TSCA R&D Permit ............................ .
Guild· s Past Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 3 7
RE LEV ANT EXPERIENCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 38
ECO LOGIC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 38
7 .1. 1
7.1.2
7 .1.3
7 .1.4
Laboratory-Scale Treatability Studies . . . . . . . . . . . . . . . . . Page 38
Demonstration-Scale Operations . . . . . . . . . . . . . . . . . . . . . Page 39
Current Commercial-Scale Applications ................ Page 40
Future Applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 43
Camp Dresser & McKee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44
Guild Incorporated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 44
HEAL TH & SAFETY/TRAINING ............................. Page 44
Hazardous Waste Operations Ceaification .................... Page 45
Worker Ri!;;ht-tn-Knnw . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 45
Demuctor Operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 45
Contin~encv Plans ................................... Page 46
Hazardous Materials Trainin~ -Site Specific . . . . . . . . . . . . . . . . . . Page 46
CORPORATE QUALITY ASSURANCE -
TOTAL QUALITY MANAGEMENT PLAN Page 47
10 . ASSUMPTIONS AND QUALIFICATIONS ....................... Page 47
11. PRICING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48
11 . 1 Cost Proposal for Phase I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 48
11.? Cost Proposal for Phase II . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 50
ECO LOCIC Proprietary Information Confidential
ECO LOGIC
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
TABLE I
T,\BLE 2
TABLE 3
TA.BLE 4
TABLE 5
T.-\.BLE 6
TABLE 7
TABLE 8
TABLE 9
TABLEl0
TABLE 11
TABLE 12
Treatment of Soil from Warren County, North Carolina Landfill
APPENDICES
Corporate Structures
Curriculum Vitae for Phase I and Phase II Key Personnel
Operating Permits for the Use of the ECO LOGIC Process
ECO LOGIC Detailed Project Summaries
Australia Stack Testing Reports
GMCL Source Testing Repon
Camp Dresser & McKee Project Experience and Relevant Project Data Sheets
Guild, Incorporated Project Summaries
ECO LOGIC Health and Safety Plan
ECO LOGIC Corporate QA Manual
LIST OF FIGURES
Page iii
PROJECT ORGANIZATION CHART ............................ Page 4
COMMERCIAL-SCALE PROCESS REACTOR ..................... Page 8
COMMERCIAL-SCALE PROCESS SCHEMATIC ................... Page 9
ECO LOGIC PROCESS REACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12
ORGANIZATION FOR TREATABILITY TESTING ................. Page 16
SCHEMATIC OF TREATABILITY-SCALE WASTE PROCESSING UNIT .. Page 19
LIST OF TABLES
DE VELOPMENT AND IMPLEMENTATION OF THE
ECO LOGIC PROCESS .................................... Page 14
TRE ATABILITY-SCALE STARTUP AND SHUTDOWN
PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 20
SUMMARY OF SAMPLING PROGRA.M FOR TREATABILITY TESTING .. Page 22
SAMPLING METHODS FOR TESTING PROGRM1 . . . . . . . . . . . . . . . . . Page 23
ANALYTICAL METHODS FOR TESTING PROGRA.i\1 ............... Page 24
ANALYTICAL QA /QC FOR TESTING PROGRAM ................. Page 26
RECENT THERMAL REDUCTION MILL TESTING RESULTS ......... Page 41
GREAT LAKES HARBOUR SEDIMENT TREAT ABILITY RES UL TS . . . . . Page 41
HA!vIILTON HARBOUR PERFORMANCE TEST RES UL TS ........... Page 42
USEPA SITE PROGRAM TEST RESULTS ....................... Page 42
STACK TEST DATA FOR COMMERCIAL-SCALE TREATMENT
OF DDT AND PCBs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 43
GMCL PERFORMANCE TESTING SUMMARY -DRE AND DE ........ Page 43
ECO LOGIC Proprietary In formation Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page iv
EXECUTIVE SU1HMARY
ELI Eco Log ic International Inc. (ECO LOGIC) is proposing to use ECO LOGIC's patented gas-phase
chemical reduction process (the ECO LOGIC Process) to treat contaminated soil fr om the Warren County,
North Carolina Landfill. This proposal is intended to comply with the requirements laid our in the State of
Nonh Carolina Department of Environment, Health and Natural Resources Division of Waste Management
Request for Proposal (RFP) Number PCB LF-4.
The Canadian Commercial Corporation (CCC) will act as Prime Contractor for all phases of the project with
100 percent of the work being subcontracted to ECO LOGIC . ECO LOGIC will, in turn, subcontract specific
requirements of the Scope of Work to Camp Dresser & McKee and Guild Incorporated in order to effectively
respond to the RFP .
The CCC is an Agency of the Government of Canada to assist in the development of trade between Canada
and other nations. The Corporation fulfills its mandate by assuming the role of prime contractor in expon
transactions to the United States involving Canadian companies. To this end , the CCC retains full
responsibility for the performance of a contract in the form of a Performance Guarantee .
ECO LOGIC proposes to conduct a pilot-scale treatability study at the US Army's Edgewood Research
Development, Engineering Center (ERDEC) toxic test chamber facility located at Aberdeen Proving Ground ,
Maryland to demonstrate system efficacy in treating soils contaminated with PCBs, dioxins and furans , and
other organ ic contaminants . Based on the Scope of Work presented in the RFP , ECO LOGIC believes that
th e State of North Carolina is expecting proposals from firms with technologies that are pre-qualified as
potential providers of the Phase II requirements. The ECO LOGIC Process is already fu!lv commercialized
with two full-scale units operating for commercial clients in Australia and Canada. This was accomplished
through successful field demonstrations in Canada and in the US under the auspices of the US EPA Superfund
Site Program on sediments, soils, and liquid wastes contaminated with PCBs, dioxins /furans, PAHs and other
organic contaminants.
The ECO LOGIC Process destroys organic contaminants in a hydrogen-rich reducing atmosphere and converts
these compounds inro recyclable and reusable products. The Process reactions are enhanced by the presence
of water, therefore , there is no requirement for waste dewatering prior to treatment. The ECO LOGIC
Process is an inherently safe process and is designed so that there are no uncontrolled releases to the
environmem. All system outputs are clean, reusable or disposable products, such as water, industrial grade
hydrochloric acid, treated solids, and product gas , and they can be stored and analysed, prior to reuse in the
system , or off-site recycling .
This document discusses the qualifications and relevam experience of ECO LOGIC and subcontractors; Camp
Dresser & McKee and Guild , Incorporated as well as the technical approach to completing the Phase I and
Phase II components of the Warren County Landfill remediation.
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 1
INTRODUCTION
The ECO LOGIC Process is a mobile, gas-phase chemical reduction process with demonsrrated experience
in the destruction of high and low srrength organic wastes such as polychlorinated biphenyls (PCBs).
polyaromatic hydrocarbons (PAHs), dioxins and furans (PCDDs and PCDFs), hexachloride wastes .
organophosphorous pesticides, chemical warfare agents, and other organic compounds. The Process involves
the gas-phase reduction of organic compounds at temperatures of approximately 850 °C and ambient pressure.
Chlorinated hydrocarbons such as PCBs and PCDD/Fs are chemically reduced to methane and hydrochloric
acid , while non-chlorinated compounds such as PAHs are substantially reduced to methane and minor amounts
of other light hydrocarbons. All outputs from the Process, including product gas, can be held and tested to
determine their compliance with regulatory criteria , prior to reuse in the system or disposal . The ECO LOGIC
Process has undergone regulatory testing at both pilot-and commercial-scale , with results of at least 99.9999 %
(6 nines) desuuction and removal efficiency (DRE) for all materials.
The ECO LOGIC Process is currently operating commercial-scale units at sites in Canada and Ausrralia ,
treating PCBs and DDT wastes in a variety of marrices including high-srrength oil, drummed watery waste ,
electrical equipment. concrete. soil. and miscellaneous other bulk solids. ECO LOGIC has also developed
a treatability-scale unit capable of performing treatability studies for clients either at ECO LOGIC's facility
in Rockwood. Ontario, Canada, or at the location where the hazardous waste is situated. This unit allows for
cost-effective demonsrration of the ECO LOGIC Process on the specific waste type, and optimization of
commercial-scale systems to meet the waste-specific requirements.
2. BUSINESS STRUCTURE AND COl\'fPLIANCE IDSTORY
The State of North Carolina Department of Environment, Health and Natural Resources Division of Waste
Management was advised by the Canadian Commercial Corporation in their letter dated March 19 , 1997, the
Canadian Commercial Corporation submits this proposal in response to RFP No. PCB LF-4 as Prime
Contracto r. Any resulting award of conrract will be in the name of the Canadian Commercial Corporation
(CCC ) which will. in turn, subcontract 100% of the work to ELI Eco Logic Inc.(ECO LOGIC). ECO LOGIC
will subsequently subcomracr ponions of the Phase I and Phase II Scope of Work to Guild, Incorporated for
activirie s re lated lO risk communication and to Camp Dresser & McKee for engineering and consulting
services. None of the firms associated with this proposal submission have any compliance history. Figure
I contains an organization chart for both Phase I and Phase II of the Warren County Landfill remediation
project. Ed Korhonen, Executive Vice President of ECO LOGIC will act as the project representative for
business purposes. Mr. Korhonen can be contacted at the following address :
2.1
ELI Eco Logic International. Inc .
143 Dennis Srreet
Rockwood, On NOB 2K0
[phone]
Canadian Commercial Corporation
The Canadian Commercial Corporation is an Agency of the Government of Canada, established in 1946 , co
assist in the development of trade between Canada and other nations. The Corporation fulfills its mandate (in
pan) by assuming the role of prime conrractor in selected expon transactions to the United States involving
Canadian companies and the US Department of Defence, national Aeronautics and Space Administration, US
civilian departments , and on request, State and Local Authorities as well as other private sector organizations.
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of So il from Warren County, N orth Carolina Landfill Page 2
As prime contractor, the Canadian Commercial Corporation is responsible for ensuring that the wo rk is
perfo rmed by itS subcontractor in accordance with the terms and conditions of the contract. This performance
guarante e includes the security fo r the faithful performance of the contract.
2.2 ELI Eco Logic Inc.
ECO LOGIC was formed in 1986 by Dr. Douglas J. Hallett. The head office is located in Rockwood, Ontario
with branch offices in Ann Arbor , .Michigan, and Perth, Western Australia. ECO LOGIC currently employs
over 110 professional and suppon staff. Since March, 1994, the company has been publicly owned and is
currently rraded on the Toronto Stock Exchange under the symbol ELI. Appendix A contains ECO LOGIC's
corporate structure and current Officers and Directors.
Currently, ECO LOGIC has two SE25 destructors operating at commercial scale . The first SE25 unit is
currentl y treating pesticide residuals and PCBs at a site in Kwinana , Western Australia. The second
commercial-scale unit is currently processing a variety of PCB wastes in St. Catharines at the General Motors
of Can ada Ltd . facility. ECO LOGIC has an additional commercial-scale contract with General Electric
Canada Inc. to treat above-ground PCB-impacted materials currently in storage at a site in Toronto, Ontario.
Treatment operations are expected to commence during the second quaner of 1997.
2.3 Guild, Incorporated
Guild, Inc. is the leading firm in the United States that combines risk communication techniques and
community relations services. Located in the Washington, D.C. area, the company specializes in risk
communication. organizational dynamics , training. strategic marketing , and visual communication products
and service s.
Guild was orig inally the in-house graphics and publications dep anment of McLaughlin Research Corporation.
It wa~ fo rm ally incorporated in 1974. Throughout its 22 year history, Guild has built a reputation for
prov iding high qu ality, professional communications services to government and commercial clients.
A network of associates --internationally recognized experts and leaders in their field --complementS the
corporate headquaners staff of 12. Guild's core capability services in risk communication and environmental
community relations are unmatched.
Appendix A contains Guild ·s corporate structure as well as their Officers and Directors.
2.4 Camp Dresser & McKee
Camp Dresser & McKee Inc. (CDM) provides environmental engineering, consulting, scientific , and
construction services to government and industry worldwide. Founded in 1947 as an engineering partnership
around Dr. Thomas R. Camp, Herman G. Dresser, and Jack E. McKee, CDM has grown steadily from one
office in downtown Boston, Massachusetts, to its current global status , employing more than 2300 people
worldwide. CDM continues to be an employee-owned firm.
ECO LOGIC Prop rieta ry In formation Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 3
Camp Dresser & McKee operates as a general parmership in North Carolina. Panners include the following:
Robert C. Marini Peter W. TunniclifJe
One Cambridge Center Ten Cambridge Center
Cambridge, Massachusetts 02142 Cambridge, Massachusens 02142
Thomas D. Furman, Jr. William S. Howard
One Cambridge Center Raritan Plaza I, Raritan Center
Cambridge, Massachusetts 02142 Edison, New Jersey 08818
William F. Callahan Michael A. Memoli
Ten Cambridge Center 100 Crossways Park West, Suite 415
Cambridge, Massachusetts 02142 Woodbury, New York 11797
ECO LOCIC Proprietar11 /n;ormation Confidential
ECO LOGIC
FIGlTRE I
Treatment of Soil from Warren County, North Carolina Landfi ll
PROJECT ORGANIZATION
State of N onh Carolina
Deparonent of Environment, Health and Natural Resources
Division of Waste Management
Page -I
ECO LOGIC
US Office
ECO LOGIC
Responsible Corporate Officer
Wayland Swain
Corporate Vice Presidellt
Canadian Commercial Corporation (CCC)
Lionel Edirisinghe
Ed Korhonen
Executive Vice Presidem
(Senior Contracts Officer, US Operations Group)
I
Guild Incorporated
Phase I
Bette Applewhite
Alwn Berger
I
ECO LOGIC
Phase I
Kelvin Campbell
Elizabeth Chisholm
Beth Rlryno
Rich Pinder
I
I
Guild Incorporated
Phase Il
M. Bergman
S. BroM1
ECO LOGIC Proprietar y In formation
I
ECO LOGIC
Phase Il
Peter Komelsen
Doug Gray
Beth Kummling
I
l
Camp Dresser & McKee
Phase Il
J. Wisemnn Jr.
D. Bennett
J. Mihm
C. Marlowe
M. Schultz
T. Grant
R.T. Clark
Confidential
ECO LOGIC
3.
3.1
Treatment of Soil from Warren County, N orth Carolina Landfill Page 5
PROCESS ENGINEERING
Introduction
Since 1986, ECO LOGIC has conducted extensive research, development, test evaluation and product
engineering with the aim of developing a technology for destroying organic wastes in a wide range of matrices
including harbor sediments, soil, leachates , lagoon sludges, and highly concentrated organic wastes. Much
of this work was supported by the Government of Canada and the USEPA. The goal was to develop a
commercially viable chemical process that could deal with aqueous wastes, contaminated soil, sediment, and
also destroy concentrated organic wastes (such as solvents , PCB oils, dioxins/furans, industrial wastes ,
pesticides , and chemical warfare agents).
3.2 ECO LOGIC Process Components
The ECO LOGIC Process is comprised of a cenrral reactor for the actual destruction of the liquid and gaseous
organic waste , with an attached multi-stage scrubbing system to remove inorganic contaminants and light
hydrocarbons from the reacted gas stream. In order to render the contaminants suitable for introduction to
th e reactor, the solid wastes must be preprocessed using one of two ancillary technologies. Waste
preprocessing systems associated with the ECO LOGIC Process are as follows:
Warery ivasres Watery waste is preheated with boiler steam in a pre-heater vessel before injection
into the reactor . The contaminated steam from the pre-heater vessel is metered into the reactor at a rate
determined by the process control system. Hot contaminated liquid exits the bottom of the vapourizer at a
controlled t1ow rate and enters the reactor through an atomizing nozzle.
High Srrengrh Liquids/Oils A liquid waste peristaltic pumping system is used to inject high strength oily
waste directly from drums through atomizing nozzles into the reactor. No waste preheating is required.
Soils and Serried Solids A Thermal Reduction ~Iii! (TR.!vf) is employed to separate contaminanL<; fr om
so il or decanted settled solids. The TRM is designed as a flow-through process which vapourizes all water
and organic contaminants in the waste soil/settled solids, while mechanically working the solids into as fine
a mix lure as possible. Prior to introduction to the TRM the soil is screened to 3/4 inch diameter with
oversized materials being crushed or treated as bulk solid. The heat transfer to soil is accomplished indirectly
using molten tin as well as directly by the hot recirculation sweep gas . The water vapour and organic
comaminanL'> which are volatilized from the soil are continuously swept into the reactor by the recirculation
gas. Treated soils exit the TRM as a fine, inert silica.
Bulk Solid Material A Sequencing Batch Vapourizer (SBV) is used to decontaminate large bulk solids not
suirable for TRM treatment, such as drums, electrical equipment, personal protective equipment (PPE), and
spent carbon from water and air treatment systems. The SBV consists of two autoclave-type chambers that
are sequent ially operated in batch mode. Residual PCBs, oil, and any solvents contained in the shredded
material are volatilized and the organic vapours are swept into the reactor by the hydrogen-rich hot
recirculation gas. The SBV is also suitable for processing high-strength wastes such as obsolete pesticides.
chemical warfare agents, and industrial by-products. which are volatile enough to evaporate or sublimate
directly from drums at SBV operation temperatures.
Typically, material processed in the SBV or TRM constitutes a relatively small contaminant load to the reactor .
and therefore can be processed by itself or simultaneously with high level liquid wastes injected directly to the
reactor .
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 6
3.3 Process Description
The ECO LOGIC Process is a mobile , gas-phase, chemical reduction technology suitable for the remediation
of virtually any high or low strength organic wastes . (It does not dispose of organic contaminants by
incineration or other thermo-chemical oxidation processes). Although the primary reduction process is a •'flow
through " system, there are no uncontrolled emissions to the environment. All system outputs from the process
are comained and held for testing prior to their release to the environment . Ancillary technologies which may
be employed include an atomizing nozzle system to inject contaminated liquids directly into the reactor, a
Thermal Reduction Mill (TRM) to desorb contaminants from soils, sludges, sediments and other granular
solids material, and a Sequencing Batch Vapourizer (SBV) to desorb contaminants from drums and other bulk
solids.
The ECO LOGIC Process involves the gas-phase reduction of organic compounds by hydrogen at temperatures
of 850°C or higher. Chlorinated hydrocarbons, such as polychlorinated biphenyls (PCBs) and polychlorinated
dibenzo-p-dioxins (dioxins), are chemically reduced to methane and hydrogen chloride (HCl), while non-
chlorinaced organic contaminants, such as polyaromatic hydrocarbons (PAHs), are reduced substantially to
methane and minor amounts of other light hydrocarbons. The HCl produced can be recovered as acid or
scrubbed out in a caustic scrubber downstream of the process reactor.
The ECO LOGIC Process takes place continuously in a flow-through reactor operated at atmospheric pressure
and elevated temperature. Various gaseous and liquid waste input streams are injected into the reactor through
several ports at the top of the reactor chamber. Special nozzles atomize liquid wastes to accelerate
vaporization. The gas/waste mixture is heated to approximately 850°C within the reactor. The gas flow rate
is such thac wasce residence time in the reactor is two to six seconds. The process reactions actually take less
than one second to complete at reaction temperature. The breakdown products from the reaction of typical
indu strial organic wastes (such as chlorinated solvents, PCBs, pesticides, etc .), are relatively innocuous
compound s, including carbon dioxide, carbon monoxide, wacer. and methane. Some of the scrubbed gas
produced by the reaction is recirculaced back inco the reactor, the remainder being compressed and tankered.
Complete destruction is verified by continuous monitoring of the reaction gas and by confirmation testing of
the compressed product gas.
The compressed and tankered product gas is regularly tested for the presence of contaminants to verify that
all comaminantS are completely destroyed. Once the gas has been proven to be free of contaminants, it is used
on site as fuel to po wer ancillary equipment, which may include a boiler for preheating of watery wastes , a
catalytic steam reformer for hydrogen production, and the TRi\1.
3.3.1 Pre-Treatment Handling
Depending upon the characterization of the waste , pre-screening of soil/sediment may be required prior to
processing using the TR..t\1. However, this is the only type of waste pre-treatment that may be required prior
to waste processing using the ECO LOGIC Process. Dewatering of input waste is unnecessary, as the
presence of water actually enhances the efficiency of the reduction reactions as discussed in Section 3 .4 .
3.3.2 Waste Processing
Figure 2 is a schematic of the SE25 reactor where the destruction of the toxic organic waste, through itS
breakdown into re-usable or disposable productS, occurs. The various input streams are injected through
several pons mounted tangentially near the top of the reactor . Special nozzles are used to atomize liquid
wastes, in order to accelerate liquid vapourization. The gas mixture swirls around a central stainless steel
rube. and is heated by 18 venical radiant tube heaters with internal electric heating elements. By the time it
reaches the bottom of the reactor, the gas mixture has reached a temperature of approximately 850°C. The
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process reactions take place from the bottom of the central rube onwards, and take less than one second to
complete.
Figure 3 is a process schematic of the entire system, including the SE25 reactor and ancillary technologies .
Most of the system components are mounted on highway trailers for ease of mobility . The reactor trailer
houses the reactor, the electric heating control system , the scrubber system, the recirculation gas blower, the
recirculation gas heater and the watery waste preheater vessel. A second trailer contains the main power
distribution room, the dual-fuel steam boiler and the catalytic steam reformer. Cooling water for the scrubbing
system is generated by skid-mounted evaporative coolers, and scrubber stripping operations are carried our
on a small skid situated near the boiler. The product gas compression and storage system is also skid-mounted
to allow flexibility in site layout. For processing soils and other solids, the TRM is housed on a separate
trailer, and the SBVs are skid-mourned units. The process control system, gas analyser systems , and command
centre are housed in a standard office trailer .
As shown in Figure 3, product gas leaving the reactor is scrubbed to remove HCI, water, heat, fine
particulates , aromatic compounds, carbon dioxide and some inorganic compounds . The first stage of the
scrubber can be operated to recover medium-strength hydrochloric acid, which avoids the cost of neutralization
with caustic . If the waste stream is heavily chlorinated, the acid can usually be sold to off-site industries, and
generation of large volumes of salty waste water is avoided. The second stage of scrubbing drops the
temperarure of the gas to remove water and completes the removal of HCl by caustic packed tower scrubbing.
Paniculate matter (which may have entered the reactor as dissolved or suspended solids in the watery waste)
is removed in both the first and second stages of the scrubber and is filtered out of the scrubber tanks
continuously. Heat is removed using plate heat exchangers on the first two stages and cooling water from the
evaporative cooling system .
The third stage of scrubbing removes low levels of benzene and naphthalene from the gas stream by neutral
oil washing . The oil is stripped and regenerated with the benzene and naphthalene going to the inlet of the
catalytic steam refo rmer. The fourth scrubbing stage is removal of carbon dioxide (CO1) and hydrogen sulfide
(H,S l using monoethanolamine (MEA) absorption. The MEA is stripped and regenerated with the carbon
dioxide going to the boiler stack.
The scrubber water from the stage-two scrubber leg rerurns to the covered section of the scrubber tank through
a dro p-tube that extends well below the water surface . This acts as a seal against air infiltration and as an
emergency pressure relief mechanism. There will be no gas release if a short-term pressure surge forces gas
out of the bottom of this rube since a check valve allows the gas to re-enter the system once the pressure
returns to normal. The system normally operates within 10 inches water gauge (0 .36 psig) of atmospheric
pressure.
As waste is processed through the system, acid and water are produced . Filtered acid is pumped to a storage
tank for further activated carbon or ion exchange treatment and chemical analysis. Excess water is also
filtered and carbon-treated to remove any trace of organic contamination, and is then stored for analysis .
Carbon from the filters can be regenerated on site in the SBV, and the minor amount of scrubber sludge
produced can also be processed through the SBV.
During previous use of the ECO LOGIC Process, both at pilot-and commercial-scale, the water has been
suirable for discharge to the municipal sewage system or sewage treatment plant. Alternately, the water can
be further treated to remove Total Dissolved Solids (TDS), and then used in the boiler and/or evaporative
coo lers. This would eliminate the need to dispose of process-related water , and in fact create a net
con:;umpti on of water by the system.
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FIGURE 2 COMMERCIAL-SCALE PROCESS REACTOR
I>~--rTHICK ·pvRO-BLOC' -v·
CERAMIC FIBRE INSULATION
TO GRIT BOX
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The cooled and scrubbed product gas is a clean dry mixture of hydrogen, methane, carbon monoxide , and
other light hydrocarbons . Some of the gas is reheated and recirculated back into the reactor to increase the
methane concentration in the reactor when processing low-strength wastes . Recirculation gas is also directed
to the TR,vl as sweep gas, to the SBV as sweep gas, to the catalytic steam reformer for hydrogen generation,
or to the compressor for storage .
Throughout waste processing operations , the product gas is sampled for analysis by the CIMS and other gas
analysers. The CIMS is capable of accurately monitoring up to IO organic compounds every few seconds at
concentrations ranging from percent levels down to ppb levels . It is used as part of the ECO LOGIC Process
to monitor the concentrations of cenain compounds indicative of the process desrruction efficiency. The
compounds selected for monitoring depend on the waste being processed. For example , during PCB
processing , monochlorobenzene is typically monitored as an indicator of destruction efficiency. Low levels
of this volatile compound indicate that desrruction of the PCBs is proceeding to completion. The CIMS
readings are monirored by the process control system, and the exceedance of alarm limits sends a message to
the operator (low-level alarm) or automatically curtails waste input (high-level alarm). The CIMS also
prov id es a continuous rec ord of the quality of the product gas being compressed and stored .
Storage of the product gas under pressure permits the analysis of the gas to be used as fuel and all ows the
operation of the system in a "stackless" mode. Should the product gas not meet the quality criteria established.
there will have been no em issions to the environment, and the gas can simply be reprocessed. Potential
appl ications fo r the srored product gas include heating the steam boiler , the SBV, the TRM, and the catalytic
steam reformer.
3.3.3 Description and Handling of Process Outputs
The ECO LOGIC Process is a closed-l oop system with no uncontrolled emissions. The system outputs include
product gas, liquids such as water and HCl , and treated solids. These outputs are discussed in more detail in
the fo ll owing sections . All outputs from the ECO LOGIC Process , including product gas, can be stored and
anal ysed prior to rransponation off site . Because of this, ECO LOGIC typically proposes extensive regularo ry
testing of outputs, followed by recycling or reuse of the material. This is a cost-effective approach, as material
such as scr ap metal and hydrochloric acid can be sold to interested parries, and there is no added cost for
landfill dis posal. As well as being cost-effective. the "batch and test" approach ensures that the material is
safe and free of contamination from organic compounds before it leaves the site .
Warer All water generated from site activities, including water collected from spill pad sumps (which
includes rain runoff from outdoor operations), undergoes activated carbon treatment along with the system
scrubber decant water and coolant water. The treated water is stored in one of four 15 ,000 gallon tanks on
site . Once a tank is full, it is chemically tested for waste-specific contaminants . Targeted contaminants
include original substances , intermediate products of the reduction process, and other substances as required
by the local regulatory agency .
After analytical confirmation that the water is free of contaminants , the contents of the tank can either be
sewered , pending regulatory approval, or reused in the system in the evaporative coolers or the boiler. If the
water is reused in the system, there is a net water consumption, thus eliminating the need to dispose of process-
related water . The second tank is utilized to store water while analytical results are pending for the first tank.
A small reservoir is placed before the treatment system to srore untreated water.
Treared Solids Tre ated solids are generated during operations . The solids output include treated soil residue,
reacror grit, and scrubber paniculate . The solids output streams are combined and held in a common storage
vessel during each day of operation. The treated soil is an inen silica-rich, organic-free material, similar to
silica sand. Following compliance testing . this material can be replaced on-site , or transported off-site for a
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variery of uses such as cement aggregate .
Treared Bulk Solids All material which has been treared in the SBV is subjected to chemical wipe resting
(as appropriate) to verify adequate removal of the PCBs from the material. Following confirmation (or
reprocessing in the system, if required), the material can be shipped off-sire for recycling .
Product Gas During waste processing operations, product gas is generated from the breakdown productS
of the reaction. Following scrubbing, the product gas is comprised primarily of hydrogen (65 %), methane
(30 % ) , and carbon monoxide (5 % ). The product gas is compressed , tankered, and chemically tested prior
to itS use on-sire as a fuel to heat a steam boiler and the SBV . All compressed product gas is consumed on-
sire , and the amount generated is dependent on the organic content of the input waste .
It should be noted that the internal reuse of the product gas does not constitute an additional treatment
component. The product gas is recycled within the system purely as a means of output disposition and in order
to recover the energy which has been produced. It was clearly proven in the USEPA SITE Demonstration
that:
;'Alrhough the resulr ,vas not listed as a primary or secondary objective for rhe demonstration ,
desrrucn·on and removal efficiencies (DREs) for PCBs in rhe scrubbed reformed gas ivere
essentially equal to the DREs achieved at the boiler stack. This shows that combustion of the
reformed gas in the boiler is not required to complete PCB desrruction . "1
Acid When chlorinated organic wastes are destroyed, hydrochloric acid (HCl) is produced. When the waste
is relatively IO\V in these contaminantS, the acid is neutralized with caustic soda in the system scrubber and
sodium chloride is formed. When high-strength chlorinated wastes are destroyed, significant amounts of
hydrochloric acid are formed, and an initial acid leg of the scrubber is implemented to remove the acid as a
liquid concentrate. All acid generated from high-strength waste processing is tested for contaminants prior
to final di sposition.
Reacror and Scrubber Particulate A small amount of particulate can be generated in the reactor and
ar the scrubber. The particulate is comprised of any matter that may have been entrained in the waste stream
as wdl as inorganic materials that are insoluble in water at neutral pH . During commercial-scale operations,
only a very minor amount of particulate is produced. This material is collected and subjected to SBV
treatment prior to resting for contaminants and off-sire disposal.
3.4 Process Chemistrv
Figure 4 shows some examples of the reduction reactions for the destruction of a variety of contaminantS using
the ECO LOGIC Process. Unlike oxidation reactions, the efficiency of these reduction reactions is enhanced
by the prese nce of water, which acts as a heat transfer and reducing agent, as well as a source of hydrogen.
Therefore , dewatering of input waste is unnecessary. The water shift reactions shown produce hydrogen,
carbon monoxide and carbon dioxide from methane and water . These reactions are used at higher efficiencies
in a catalytic steam reformer to generate hydrogen for reuse in the sysrem by subjecting scrubbed methane-rich
product gas to high temperatures in the presence of a catalyst.
Applications Analysis Report, Eco Logic l!ltemational Gas-Phase Chemical Reduction Process -The
Reactor Sysrem, USEPA, Office of Research Gild Developmenr, Seprember 1994. EPA/540/AR-931522.
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FIGURE 4 ECO LOGIC PROCESS REACTIONS
Cl Cl
0-0 + 5 H2 2 0 + 4 HCI
Cl Cl
c1~~0D c1 0 I ii I + 8 H2 2 + 4 HCl + 2
c ~O Cl
ob
0 + 9 H 2
WATER SHIFT REACTIONS
3.5
HO
2
co + ~o
Process Monitoring and Control
H2 0
PCB molecule & hydrogen
react to produce benzene
& hydrogen chloride
Dio>Cin molecule & hydrogen
react to produce benzene,
hydrogen chloride & water
PAH molecule & hydrogen
react to produce methane
Benzene & hydrogen react
to produce methane
Hydrocarbons & hydrogen
react to produce methane
Methane & water react lo
produce carbon mono>Cide
and hydrogen
Carbon mono>Cide & water
react to produce carbon
dio>Cide and hydrogen
The reducing hydrogen atmosphere is maintained at more than 50 percent hydrogen (dry basis) to prevent
formation of P AHs. This makes the scrubbed recirculation gas suitable for continuous monitoring using an
on-line Chemical Ionization Mass Spectrometer (CIMS) and other gas analyzers. The CIMS is capable of
accurately monitoring up to ten organic compounds every few seconds at concentrations ranging from percent
levels down to pans per billion levels. It is used as part of the ECO LOGIC Process to monitor the
concentrations of certain compounds indicative of the process destruction efficiency. Typically during pilot-
scale testing on PCB material , the CIMS is configured to monitor benzene, monochlorobenzene and toluene .
By measuring the concentrations of intermediate reduction products, the CIMS produces a continuous
indication of destruction efficiency.
ECO LOGIC also uses a micro gas chromatograph (micro-GC) to analyse for benzene, monochlorobenzene
and toluene, and Nova analyzers t0 measure for oxygen, hydrogen, methane, carbon monoxide and carbon
dioxide . The instruments are located after the scrubbers, where the majority of water is removed from the
gas stream. The instrument sample lines have small knockouts to further dry the gas before analysis.
3.6 Development and Testing
Table l presents a chronology of events in the development and implementation of the ECO LOGIC Process.
This section provides a summary of key field demonstration studies which provided early validation of the
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ECO LOGIC Process, and recent process improvements which have led to commercial-scale contracts for
PCB treatment in Canada and Ausrralia . More detailed information on these projects is contained in Section
7.
Field-Scale Testing, Hamilton Harbour, Ontario, Canada: In the summer of 1991 , the unit was tested at
Hamilton Harbour , Ontario, on coal-tar contaminated harbor sediments with polynuclear aromatic hydrocarbon
(PAH) concentrations averaging 30,000 mg /kg (dry weight). Three test runs were performed on the
contaminated sediment, with the third run being spiked with PCBs at a nominal concentration of 500 mg/kg.
The sediments were injected directly into the gas-phase chemical reduction reactor as a five to ten percent
slurry. PAH destruction and removal efficiencies (DREs) of 99.9999 percent were calculated. The
concentration of PCBs in the air emissions, liquid output and processed solids were all below detection limits ,
resulting in a PCB DRE of at least 99 .9999 percent.
Field-Scale Testing, Bay City, Michigan: In 1992 , the demonstration-scale unit was relocated to a site in Bay
City, Michigan. This field demonstration was performed under the auspices of the USEPA's Superfund
Innovative Technology Evaluation (SITE) program and was cosponsored by Environment Canada, the Ontario
Ministry of the Environment , and the City of Bay City . The wastes processed included oily PCB-contaminated
water , high strength PCB oil containing about 25 % PCBs, and PCB-contaminated soil containing about 1 , 000
mg/kg PCBs. As part of the demonsrration, ECO LOGIC constructed and commissioned a prototype thermal
desorption unit (TDU) for a "proof of concept" test. The TDU was utilized to desorb organic contaminants
fr om so il that were then swept to the gas-phase chemical reduction reactor for treatment. Water/oil and oily
wastes were injected directly into the reactor and DREs of 99 .9999 percent for PCBs on all six runs were
achieved. For the soil testS , a desorption efficiency of 94 percent was achieved for the first run, and, after
increasing soil residence time in the TDU, a desorption efficiency of 99 percent was achieved on the sec ond
and final run. The report prepared by the USEPA also confirmed that net destruction of dioxins and furans
in the waste fe ed had occurred.
Recent Process Improvements: The results of the two above-mentioned field tests verified the successful
reduction of complex organic contaminants into recyclable or reusable products. These tests also verified th e
conceptual use of a thermal desorption system to separate organic contaminants from soil for treatment in the
gas-phase chemical reduction reac tor. However, prior to full-scale implementation, certain limitations of the
prototype TD U needed to be addressed, including the inability of the prototype TDU to work the soil into a
form that could be uniformly exposed to sweep gases. The result was a completely new design, the Thermal
Reduction Mill (TR:\1).
The TRM contains a ball mill that pulverizes the soils and sediments during treatment , breaking up clumps
typical of soils with high clay content, thus expanding the range of soil and sediment types that can be treated
effectively . The TRM was also designed to operate in an oxygen-deficient environment, reducing the potential
for the format ion of unwanted dioxins and furans . When heated in a reducing hydrogen atmosphere , the
reduction of the desorbed organic contaminants begins in the TRM before introduction to the reactor, thus
improv ing the efficiency of the reactor and increasing throughput.
The newly-designed TRM has been incorporated into the existing pilor-scale system, which was used for waste-
specific treatability studies in developing specifications for full-scale remediation projects for commercial
clients including General Motors and General Electric. Results from several of these waste-specific treatability
studies are presented in Section 7. A commercial-scale TRM is currently in the final stages of commissioning
at General Motors in St. Catharines. Ontario , where PCB oil, concrete and electrical equipment have been
treated over the past year using the ECO LOGIC Process . When finished at General Motors , this same
commercial-scale unit , equipped with the commercial-scale TRM , will be transponed to a former General
Electric site in Toronto, Canada. to treat stored PCB-impacted soil and other material .
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Table 1 DEVELOPMENT AND IMPLEMENTATION OF THE ECO LOGIC PROCESS
I Date I Event I
1985 Development by Dr. Douglas Hallett of the concept of gas phase reduction of organic compounds
1986 ECO LOGIC formed 10 commercialize gas phase reduction of organic contaminants including PCBs
and chemical warfare agents
1987 Identification of basic process controls for gas phase reduction of organic compounds
1988 Completion of design and fabrication of laboratory-scale equipment to test process controls
1989 Successful completion of laboratory-scale, proof-of-concept testing on PCB-contaminated liquids
1990 Completion of design and fabrication of pilot-scale equipment to treat liquid wastes and sediments
1991 Completion of field demonstration at Hamilcon Harbour, Ontario, successfully treating aqueous
wastes and sediments contaminated with PAHs and PCBs
1992 Completion of field demonstration at the Bay City Landfill site in Bay City, Michigan, successfully
treating high strength PCB-contaminated oils and PCB-contaminated landfill leachate and soils
1993 Completion of design and fabrication of commercial-scale treaanent system
1994 Award of first commercial-scale remediation contract tO treat DDT residues in Western Australia
1995 Award of commercial-scale remediation contract from General Motors, St. Catharines , Ontario,
Canada, co treat PCB-contaminated process solids and equipment
199 5 Award of commercial-scale contract from General Electric Canada Inc. tO treat above-ground PCB-
impacted materials currently in scorage at a site in downtown Toronto , Ontario
1995 Award of commercial-scale remediation contract from Dofasco Steel to treat PCB-contaminated
equipment at a site in Ontario, Canada
1995 and Successful remediation of DDT residues and high-strengtl1 PCB oils and electrical equipment at a
ongomg commercial site in Kwinana, Western Australia
1995 and ECO LOGIC Process selected for evaluation in treating chemical warfare agents by US Army
1996 Chemical Demilitarization Program. Demonstration testing completed in 1996 with successful
treaunem of chemical warfare agents HD and VX , with 99. 999999 % destruction achieved
1996 Award of a contract from US Department of Energy tO treat hazardous wastes, radioactive mixed
low-level waste, and energetics
1996 Award of contract from the City of St. Catharines to treat PCB-contaminated electrical equipment at
the General Mocors Canada Limited facility in St. Catha.rines
1996 Approval for the General Electric Canada Inc. project granted following public hearing before the
Ontario Environmental Assessment Board
1996 ECO LOGIC Process selected by the US Navy to conduct laboracory-scale treatability testing on
PCB-contaminated soil from a site in ~orth Washingcon, D.C. and pesticide-contaminated soil from a
site in Patuxent, MD
1996 Award of pilot-scale treatability study contract to treat harbor sediment contaminated with PCBs and
dioxins and furans at a USEPA Superfund Site in New Bedford, Massachusetts
1996 Agreement with GTS Duratek Inc. tO supply and operate a model test unit tO demonstrate the efficacy
of t11e ECO LOGIC Process in treating radioactive ion-exchange resin
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4. TECHNICAL PROPOSAL -Phase I
4.1 Objectives
Based on the goals and objectives outlined in the RFP, ECO LOGIC's primary objective for the treatability-
scale testing (Phase I) is to demonstrate the ability of the ECO LOGIC Process to treat the Warren County
Land fill materials safely and effectively with the aim of achieving the State's preliminary target levels for
system outputs. This will be accomplished through characterization of contaminants of concern in system
inputs and outputs.
4.2 Project Organization
The org anizations involved in the test program for Phase I are shown in Figure 5. The testing will be carried
out within the US Army's Edgewood Research Development, Engineering Center (ERDEC) toxic test
chambers at Aberdeen Proving Ground , Maryland. Following completion of the Phase I treatability testing,
a public meeting will be held to inform the community of testing results . More information about this meeting
is provided in Section 4.9. Responsibilities for each organization are as follows:
ECOLOGIC
Permitting
Waste processing equipment operation/monitoring
Solid and liquid sampling
Project QA/QC
Solid and liquid sampling QA/QC
Preparation of Study Report
Srare of North Carolina
ERDEC
Delivery of soil to ERDEC testing facility
Site for test facility
Disposal of process outputs
Oper ation of Test Chambers
Sub conrracted Stack Sampling Firm
Stack sampling
Stack sampling QA/QC
Subcontracted Analytical Laboratory
Solid, liquid and stack sample analyses
Guild, Incorporated
Public Consultation
Community Relations
Laboratory analyses and stack sampling will be carried out by EPA-approved organizations, to be determined
prior to the start of the project.
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FIGURE 5 ORGANIZATION FOR TREATABILITY TESTING
i '
1 State of North ! __ ____,
! Carolina /
ECO LOGIC
I i
I
I
I I I
Subcontracted Subcontracted ! 1 B Analytical Stacie Sampling Guild, Inc. Laboratory Firm i
Curriculum Vitae fo r personnel involved in Phase I activities are provided in Appendix B. Personnel
responsibilities are as follows:
ECO LOGIC Personnel:
Wayland R. Swain, Ph.D. Vice President, US Markers
K. Elizabeth Kii.mmling, B.Sc. Manager, Pennirring and Approvals
Permitting
Eli::.aberh A. Chisholm, B .Sc. Manager, Engineering Development
Project Manager
Quality Assurance/Quality Control Manager
Person responsible for demonstration test
Kelvin R. Campbell, P.Eng. Vice President, Engineering
Reviewing Engineer
Person responsible for training
Berh Rhyno, B.Sc.Eng Project Engineer
Operations Supervisor
Quality Assurance Officer
Person responsible for training
Person responsible for demonstration test
Person responsible for operation of monitoring system
Rich Pinder, CET
System Operator
Maintenance Supervisor
Safety Officer
R&D Technologist
Person responsible for operation of monitoring system
Person responsible for recordkeeping and reporting
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In addition to the above ECO LOGIC personnel, one to two technicians will assist with testing operations.
Guild Incorporated Personnel:
Bettie Applewhite, Ph.D. Facilimror
Alton Berger, B.S. Community Relations Specialist
4.3 Description of Treatability-Scale Process Unit
As noted earlier, the treatability-scale unit for the Warren County Landfill soil will be set up at the ERDEC
toxic test chamber at Aberdeen Proving Ground in Maryland. This unit and its predecessors has been used
by ECO LOGIC over the past ten years to perform waste-specific treatability studies for many commercial
and government clients. These studies have led to full-scale remediation contracts in both Canada and
Australia. Figure 6 presents a generalized process schematic of the treatability-scale unit to be used for the
Warren County Landfill soil. The system includes the TR.1-1, a gas-phase chemical reduction reactor, a two-
stage gas scrubbing system, a product gas compression and storage system with continuous emission
moniroring equipment, and an excess gas burner. The treatability test unit utilizes the same conceptual
parameters as the commercial-scale system. Information garnered from treatability studies is used to generate
waste-specific performance data as well as more closely define the parameters of full-scale operation.
Sedirne m that has been pre-screened of material greater than 0.5 inch in diameter (SI on Figure 6) is fed via
a feed system to the TRM . The TRlvl consists of a heated ball mill that pulverizes the solid feed, enhancing
des orption of organic contaminants into the sweep gas, which is fed to the gas-phase chemical reduction
reactor . The TRM is heated by a bath of molten tin and is operated in a reducing hydrogen atmosphere at
abou t 600 °C. The TRM off-gas (sweep gas , steam and desorbed organic compounds from the TRM) is
further heated in the reactor to about 900°C. The process reactions (Figure 4) take place in less than one
sec.:ond. but a residence time of several seconds is used to ensure complete destruction.
In cnmmercial-,cale projects, material greater than 1 inch in diameter is treated in a Sequencing Batch
Yapourizer (SBV), which has been used over the past year at commercial-scale to treat rubbly soil, concrete,
elecuical equipment, and other bulk solids. The SBV is a large autoclave-type chamber which is heated in
the presence of hydrogen to desorb the organic contaminants, which are then swept into the reactor. It is not
expected that oversize material will be encountered in the treatability soil to be provided by the State at
quantities that would warrant SBV demonstration. Furthermore, extensive data is available on SBV treatment
at treatabiliry-and commercial-scale (see Section 7). Any oversize material encountered will be disposed of
using an approved waste hauling firm.
The reacted product gas leaving the reactor, consisting primarily of hydrogen, methane, carbon monoxide and
steam , is routed through a two-stage gas caustic scrubbing system t0 remove HCI, water, particulates, and
heat. The resulting dry, scrubbed product gas (S6) (approximately 25°C) is then compressed and sent to
temporary storage before being burned in the Excess Gas Burner (S7). The stored product gas is monitored
continuously by the Nova bulk gas analysers, CIMS and micro-GC.
At the end of each test run, the scrubber effluent is collected (S2) and pumped through a filter of activated
carbon. The treated eft1uem (S4) is analysed prior to off-site disposal. The paniculate filters that were in use
continuously during the run are removed for sampling and analysis (S3) and replaced for the next run.
The system is operated as a once-through system with hydrogen as the sweep gas. The product gas is
compressed. stored and analysed prior to being sent to the excess gas burner. If the on-line analysis of the
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product gas shows levels of monochlorobenzene greater than 100 ppm, the gas burning is discontinued, the
waste feed is halted, and the hydrogen input is shut off as the system recirculation valve is opened. This would
allow gas to recirculate until the monochlorobenzene concentration decreases to less than 100 ppm . It has
never been necessary to use this recirculation capability for any of the treatability tests carried out to date .
The excess gas burner is equipped with a propane fuel source . The temperature of the propane flame is
maintained at 800 to l000°C during operation. The hydrogen rich product gas is sent to the burner as it is
prod uced and burns as it enters the propane flame . The 8" gas burner stack is equipped with ports for gas
sampling .
4.4 Phase I Testing Program
A treatability study will be conducted on a representative sample from the Warren County Landfill. Three
test runs will be conducted on 3 separate days within a 5-day period. Each test run will process soil over a
2 to 4 hour period, at a rate of 5 to 10 pounds per hour.
The unit operation team for Warren County Landfill soil testing will be comprised of 3 to 4 ECO LOGIC staff
membe rs (Operations Supervisor, System Operator, Technician(s)). Daily activities will involve
approximately 2 hours of operations planning and equipment set-up, 4 hours operation (maximum), and 2
hours sampling and equipment shut-down. Routine system maintenance will be performed during start-up and
shut-down whenever possible, to maximize time spent treating sediment.
Operation of the unit will involve a standard set of start-up/normal operation/shut-down protocols (Table 2).
Before any test can begin, the process control computer and the CIMS must be operational and all sampling
apparatus must be ready. During the actual performance of the tests, certain operational parameters are
manually logged every ten to fifteen minutes by the operators. These include reactor pressure, reactor
temJ)l:rarure, scrubber temperature, scrubber pH , oxygen analysis, and dry gas flow rates of the hydrogen to
the TRM and the product gas to the burner. These data points complement the suite of compounds
continuously monitored by the CU-.1S and micro-Ge. All events that occur during a test (i.e., manual increase
in fl\)w rate, test stop, etc .), are recorded by the operators in the operating log book and the process data
log sheets .
ECO LOGTC will require a maximum of 120 pounds of landfill materials to complete the treatability
demonstration. Prior to the stan of the test program, the contaminated soil will be delivered to the ERDEC
toxic test chambers by the State of North Carolina. The sediment will then be screened to remove oversize
material (> 0.5 inches) and stored at the unit for testing . Following the unit start-up period, the contaminated
sediment will be manually placed in the TRM . The residence time in the mill will be approximately 15
minutes.
Treatmem of the soil at 5 to 10 pounds per hour will result in essentially complete removal of water from the
treated solids material as well as organic contaminants . The mass of the ueated material will be approximately
40 percent of the original mass. Therefore, from 2 t0 4 pounds of treated soil will be produced during every
hour of operation.
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n-, n 0 r---0 0 n IJ ..., 0 tl ~-~ ..., '< ::J o' 31 ~ 0 ::J ("") 0 :l ~ C. It) :l -c:;· II I~ 1., cfm H, N, Purge Soll Feed (5 -10 lbs/hr) S1 Treated Solids (2 -4 lbs/hr) S5 TRM TRM R s T F C PGS H, N, S1-7 Carbon Filter Purge Thermal Reduction Mill Reactor Scrubber Tank R Scrubber Particulate FIiier Compressor Product Gas Storage Hydrogen Nitrogen Sampling Stations ..... ,. s s Carbon Filter N, Purge C 10 US gallons per minute typical each scrubber) 20 US gallons per test S4 S7 Excess Gas Burner , •:Ge:m it i S6 Continuous Monitoring '"'1 -C") ~ 0\ VJ ("") ;:i:: M ~ ..., -("') 0 '"'1 >-l ~ > >-l ~ -r' -..., ';< VJ ("") ~ M ~ ► VJ >-l M "'Cl :,::, 0 Q VJ en -z () ~ >-l rn n 0 r-0 C) n :;-1 (l) fl.> 3 (l) ::J ,... 0 -, V) 0 ~ 0 :3 i ..., ..., (l) ::J n 0 C: ::J ? 2:. 0 rl :::r n ru ..., 2.. :3· ru r--ru ::J Q ~ '-o Cl Oq "' ..._ \Q
ECO LOGIC Treatment of So il from Warren County, North Carolina Landfill Page 20
TABLE 2 TREATABILITY-SCALE STARTUP AND SHUTDOWN PROCEDURES
START UP
Ensure data logging computer and all instrumentation operational
Begin N, purge . Stan compressor and excess gas burner.
After 5 volume exchanges with N2 and 02 analyser < 0 .4 % , begin reactor heating
Tum on cooling water pump and scrubber pumps
Take sample of pre-run scrubber water
Reactor temperature > 500°C, stan H2 purge , stop N2 purge, begin on TRM heating
Reactor temperature > 900°C and TRM > 550°C, connect exit gas stream to sampling apparatus, record test
stan in Jog book
Sran wasre feed . Begin gas sampling, if applicable.
SHlff DO\VN
Waste feed hopper emptied . Stop waste feed. Stop gas sampling.
Operare TRM 15 additional mintues then stop TRM mi..lling.
Shur off TRM heaters and reactor heaters.
Shut off H: purge, stan N2 purge
Reactor remperature < l00°C, shut off N2 purge , shut off cooling water pump , shut off scrubber pump
Remove processed soils from the T~\1 catch pot for sampling/disposal
Empry scrubber tanks, sample eftluenc, obtain filter sample
Carbon filter scrubber effluent. Sample treated water.
4.5 Sampling And Monitoring Plan
Sampling locations for the ireatability testing will be as follows:
SI - Soil Feed
S2 -Scrubber Eft1uent (pre-tertiary treatment)
S3 -Scrubber Eft1uent Particulate
S4 - Scrubber Eft1uem (post-tertiary treatment)
SS -Treated Solids
S6 -Scrubbed Product Gas
S7 -Stack Exhaust
These sampling locations are shown on Figure 6. The sampling program is summarized in Table 3 and
discussed below . The testing program will allow for verification of Desorption Efficiencies and Destruction
and Removal Efficiencies, and characterization of all output streams.
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ECO LOGIC Treatment of Soil from Warren County, N orth Carolina Landfill Page 21
Untreated Soil (51): Soil will be screened by ECO LOGIC, and the < 0.5 inch soil will be placed in three
clean five-gallon buckets. One bucket of screened sediment will be run per test, at a rate of 5 pounds per
hour. The oversize ( > 0.5 inch fraction) will be weighed and then disposed of off-site using a lisenced waste
hauler. The screened < 0.5 inch material will be well mixed prior to sampling to ensure it is representative
of the screened soil . A grab sample will be taken of screened material in each bucket to assess input waste
chemical and physical characteristics for each test. All sampling will be accomplished using a clean, stainless
steel trowel, and the samples will be analysed for PCB congeners, PCDDs and PCDFs, and VOCs, as
specified in the RFP . ECO LOGIC also proposes to the State that the untreated and treated soil be subjected
to a leach test, to assess post-treatment disposal options .
Scn,bber Effluent (Pre-Tertiary Treatment) (52): The liquid used for scrubbing the product gas is an aqueous
sodium hydroxide (NaOH) solution to collect hydrogen chloride emissions. Scrubber effluent samples will
be collected in suitably-sized containers (depending on the amount of material) at the end of each run. The
field personnel will also record the volumes of liquid collected .
Samples obtained for each run will be analysed for PCB congeners, PCDDs and PCDFs .
Scmbber Effluent Particulate (53): Particulate in the untreated scrubber effluent will be filtered using 1 µ.m
cartridge tilters. The particulate will be collected from the filters after each run, and, if the quantity is
adequate, subjected to analysis for PCB congeners, and PCDD/Fs .
Scrubber Effluent (post-tertiary treatment) (S4): After the scrubber effluent has been passed through the
activated carbon system, scrubber effluent samples (post-tertiary treatment) will be collected and analysed in
the same manner as S2.
Treated Soil (55): After treatment in the TRM, the dry treated soil is discharged into an accumulator where
it is cooled. and then collected in a suitable container , currently anticipated to be a five-gallon bucket. This
material will be weighed prior to sampling.
A grab sample will be obtained for each run, and analysed for PCBs, PCDDs, PCDFs, VOCs . and
leachability (if desired by the State).
Scmbbed Product Gas (S6): Samples will be collected dov:nstream of the reactor and the gas scrubbing system
through a single sampling pon throughout wasre processing. Gas sampling procedures will be provided by
the subcontracred stack sampling tinn. Samples will be analysed for PCBs. PCDDs and PCDFs. In addition
to this sampling, the product gas will be subjected to continuous analysis for monochJorobenzene, benzene and
toluene using the CIMS and the micro-GC, and bulk gas analyses for hydrogen, methane, CO and CO~.
Stack Exhaust (S7): Samples will be collected of the stack exhaust as it is discharged to the atmosphere. Two
sampling pons . 4 inches in diameter, located at right angles to each other, are available at this location , and
it can be sampled isokinetically in a conventional manner. This should facilitate obtaining representative
samples that can be used to determine overall process efficiency. Two-to four-hour continuous samples will
be collected for PCB, PCDD and PCDF analyses.
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I C:O LOGIC Treaunenr of Soil fro111 Warren Co11111y, Norri, C1mlin:i I ;111dfill /'age 22 TABLE 3 SUMMARY OF SAMPLING PROGRAM FOR TREATABILITY TESTING /'ammeter and Sa11111li11g/ Frequency of A11afylcs Sampling Metlwds A11alytical Methods /,11catio11 (see Mo11itori11;.: Sa111pli11g Fig11re 6) Method Untrealed Soil grah I grab sa111plc per lesl PCn cnngen<:rs Co111p./grab SW 846 EPA 8270 or 8080 (SI) sa111pling run PCDD/Fs Co111p./grab SW 846 EPA 8280 or 8290 voes Co111p./grah SW 846 EPA 5040/8260 Scrubber Eflluent -grab I grab sample per test PCB congeners Comp./grah SW 846 EPA 8270 or 8080 liquid (pre-tertiary sampling run l'CDD/Fs Co111p./grah SW 846 EPA 8280 or 8290 lrealment) (S2) Scruhher Ertluent -grab I grab sample from PCl3 congeners Comp./grah SW 1146 EPA 8270 or 8080 parliculale (SJ) sampling each liller after each PCDD/Fs Comp./grah SW 846 EPA 8280 or 8290 test run, composiled Leach lest Cu111p.lgrab SW 846 EPAIJI 1/7000/7196 10 one grab sample per test run Scrubber Ertluent grab I grab sample per test rcn congeners Comp.lgrab SW 846 EPA 8270 or 8080 (post-lertiary sampling run PCDD/Fs Comp./grab SW 846 EPA 8280 or 8290 treatmenl) (S4) Tre:1ted Solids grab I grab sample per lest PCB congeners Comp./grab SW 846 EPA 8270 or 8080 (S5) sampling run PCDD/Ps Comp./grah SW 846 EPA 8280 or 8290 voes Comp.lgrab SW 846 EPA 5040/8260 Leach Test (if Comp./grah SW 846 EPA 131 I /7000/7196 requested hy client) Scrubbed Product M23 I sample collecled for PCl3 congeners EPA Melhod 23 EPA 8270 or 8080 Gas (56) sampling each test run, over PCDD/Ps EPA Melhod 23 EPA 8280 or 8290 train length of test run Scrubbed Product Micro GC Continuous M onochlorobenzcne, Gas CIMS monitoring benzene, toluene Nova 112, Cl 14, CO, CO2 Stack Exhaust (S7) M23 I sample collected for PCB congeners EPA Metholl 23 EPA 8270 or 8080 sampling each test run, over PCDD/Ps EPA Method 23 EPA 8280 or 8290 Ira in length of test nm ECO LOGIC Proprie1arv l11forma1ion Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 23
4.5.1 Sampling Methods
Samp ling methods for the testing program are listed in Table 4.
TABLE 4 SAMPLING METHODS FOR TESTING PROGRAM
Parameter Matrix Sampling Reference
PCB Soil Composite grab/SW 846
Liquid Composite grab/SW 846
Gas EPA Method 23
Volatile Organic Compom1ds Soil Composite grab/SW 846
(VOCs)
PCDDIPCDF Soil Composite grab/SW 846
Liquid Composite grab/SW 846
Gas EPA Method 23
TCLP Volatiles (if required) Soil Composite grab/SW 846
TCLP Metals (if required) Soil Composite grab/SW 846
4.5. I. I Liquid Sample Collection
Liquid samples will be obtained by grab sampling . Samplers will wear solvent resistant latex gloves , and other
personal protective equipment (PPE) that is considered necessary for each particular sample . The liquid
samples will be treated and untreated scrubber water. Liquid grab samples will be poured directly into 500
ml amber glass bottles provided by the subcontracted analytical laboratory, and appropriately labelled.
Samples will then be logged in and stored in the refrigerator until transponed to the laboratory for analysis .
4.5. l .2 Solid Sampling
Soil and scrubbe r particulate will be sampled using the grab sampling technique. Samplers will be equipped
with stainless steel utensils and will wear solvent resistant latex gloves and other PPE that are considered
necessary for each panicular sample. All solid samples will be placed , using a clean steel utensil , into solvent
rinsed sample jars and appropriately labelled. Samples will then be logged in and stored in the refrigerator
until transported to the laboratory for analysis.
4.5.1.3 Gas Sampling
As specified in the RFP, air emissions must be monitored for PCBs and dioxins. Stack sampling will be
conducted by a subcontracted stack sampling firm using US EPA methodologies as indicated in Table 5.
4.5.2 Sample Analysis Procedures
All sample analyses will be performed by a subcontracted laboratory, using accepted US EPA methods . Table
5 presents the anticipated analytical methods for the testing program.
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 2-1
TABLE 5 ANALYTICAL METHODS FOR TESTING PROGRAM
Parameter Matrix Analytical Reference
PCB Soil EPA 8270 or 8080
Liquid EPA 8270 or 8080
Gas EPA 8270 or 8080
Volatile Organic Compounds Soil EPA 5040/EPA 8260
(VOCs)
PCDDIPCDF Soil EPA 8280 or 8290
Liquid EPA 8280 or 8290
Gas EPA 8280 or 8290
TCLP Volatiles (if required) Soil EPA 1311
TCLP Metals (if required) Soil EPA 1311/7000/7196
4.6 Monitoring Procedures
All critical information relating to the overall performance of the process is monitored continuously by the data
logging system. Key process parameters include:
• reactor temperarure ( > 850°C)
• TRM temperarure ( > 550°C)
• reactor pressure ( < 5 k.Pa)
• scrubber #2 temperarure ( < 25°C)
• CIMS and Micro-GC monochlorobenzene concentration ( < 100 ppm)
• gas burner temperature ( > 800 °C)
• hydrogen concentration ( > 70 % )
• oxygen concentration ( < 0.4 % )
Foll owing is a discussion of the monitoring devices.
4.6.1 Chemical Ionization Mass Spectrometer (CIMS-500)
The CIMS-500 (CIMS) is used to continuously monitor the product gas as it is produced. The CIMS is the
first indicator of destruction efficiency and allows the operator to immediately identify conditions causing
reduced destruction efficiency, should they occur. The CIMS readings are monitored by the data logging
system, and the exceedence of alarm limits sends a message to the operator (low-level alarm). The full-scale
unit is capable of automatically curtailing waste input (high-level alarm). The CIMS also provides a
continuous record of the quality of the product gas being compressed and stored.
The Cfiv1S measures monochlorobenzene, benzene and toluene in the product gas after it exits in the scrubber
system and is compressed. Dichlorobenzene and tr ichlorobenzene are monitored qualitatively. The CIMS
is capable of measuring PCBs, however it is very difficult to sample the gas for the higher chlorinated, less
volatile PCB s, which will condense out in the cooler temperarure . If there are PCBs remaining after the
reactor, they will be detected by conventional analysis of scrubber solutions and the product gas .
Monochlorobenzene is the key compound that is monitored while PCB materials are being processed. The
chemical reduction of PCBs generates monochlorobenzene as a final step before complete dechlorination ro
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 25
benzene. Therefore , during PCB processing, rnonochlorobenzene is monitored as an indicator of destruction
efficiency. The absence of monochlorobenzene in the product gas indicates that PCB destruction is proceeding
to completion. An increase in monochlorobenzene concentration in the product gas automatically triggers an
alarm. The system is placed in a waste shut-off mode at a monochlorobenzene concentration of 100 pans per
million by volume (ppmv) in the product gas to ensure complete destruction of PCBs at all times . Should the
product gas show excess levels of monochlorobenzene, it is diverted back to the reactor to be reprocessed.
The logic of using monochlorobenzene as an indicator of PCB destruction efficiency follows from the physical
characteristics of the compound. Monochlorobenzene is the last stage of reductive dechlorination of a cleaved
PCB molecule . It also has a substantial vapor pressure at room temperature , making it relatively easy to
sample without concern for losses in the sampling system. It is insoluble in water, so it is not removed in the
first stages of scrubbing when acid and water are removed , and it can be monitored at low parts per million
(ppm) levels with standard instrumentation. The reasoning behind selecting a I 00 ppm criteria for
monoc hlorobenzene in the product gas is based on the relative difference in vapor pressures for
monochlorobenzene and PCBs. The vapor pressure of rnonochlorobenzene at approximately 20°C is 10 mm
Hg. as compared to 0.0001 mm Hg for the most volatile PCB, monochlorobiphenyl, a difference of 100,000
times . The use of monochlorobenzene thus gives a method of sampling that is 100,000 times more sensitive
than the PCB analysis .
4.6.2 Nova Multi-Gas Analyser
The gas composition in the system must be carefully monitored to ensure that all components necessary for
the operation of the process are present . The levels of specific products of reduction are used to monit0r the
process and demonsrrate the appropriate reactions are taking place in the reactor . To this end , a Nova Multi-
Gas Analyser is used to monitor the concentrations of hydrogen, methane, carbon monoxide, and carbon
dioxide in the compressed product gas.
4.6.3 Norn Oxygen Analyser
Ac, part of a comprehensive plan for the safe handling of hydrogen in a closed, heated vessel , the concentration
ofoxygen is monitored on a continuous basis . A Nova Oxygen Analyser, equipped with an electrochemical
cel l, is use to sample the product gas to ensure that there is no oxygen in the system. Should oxygen be
detected at above 0.4 percent , an alarm will automatically alert the operator who will purge the system with
nitrogen. The O .4 percent limit is 10 times lower than the lower oxidant concentration (LOC) for oxygen in
hydrogen. as defmed by National Fire Protection Association (NFP A) 94 . A backup analyser is also kept on-
site.
4.6.4 l\U00 Gas Chromatograph (l\U00 GC)
In addition to the CIMS-500, an on-line M200 GC is used to monitor destruction efficiency in the process .
Monochlorobenzene, benzene and toluene concentrations are typically measured when PCBs are treated . This
on-line instrument is used to monitor the compressed product gas form the product gas storage tank. This
ensures that the gas sent to the excess gas burner does not contain precursors to the formation of dioxins and
furans . As with the CIMS-500, this data is used by ECO LOGIC to evaluate general process performance.
4.7 Oualitv Assurance/Oualitv Control
ECO LOGIC will ensure that data quality for the treatability study program is adequate by complying with
USEPA methodology requirements for quality assurance and quality control (QA/QC). This includes
appropriate QA/QC during sampling and analysis activities as outlined in Table 6.
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ECO LOGIC Treatment of Soil from Warren County, N orth Carolina Landfill Page 26
TABLE 6 ANALYTICAL QA/QC FOR TESTING PROGRAM
Sample Type Total Number of Samples Q;UQC Requirement Target Analytes
for Testing Program
Umreated Soil 1 MS/MSD PeBs, PeDD/Fs, v oes
1 Field Blank PeBs, PeDD/Fs, voes
Scru bber Effluent (pre-1 MS /MSD PeBs, PeDD/Fs
teniary treatment)
1 Field Blank PeBs, PCDD/Fs
Scrubber Effluent 1 MS/MSD PeBs, PeDD/Fs
Particulate
1 Field Blank PeBs, PeDD/Fs
Scrubber Effluent (post-1 MS/MSD PeBs, PeDD/Fs
tertiary treacmem)
1 Field Blank PeBs, PeDD/Fs
Treated Solids 1 MS/MSD PeBs, PeDD/Fs, voes
1 Field Blank PeBs, PeDD/Fs, voes
Scrubbed Product Gas 3 Field Blank (each test) PeBs, PeDD!Fs
Stack Exhaust 3 Field Blank (each test) PeBs, PeDD/Fs
MS/MSD = Matrix Spike/M atrix Spike Duplicate
4.8 Waste Handling And Disposal
Extensive experience with the ECO LOGIC Process at treatability-scale has shown that the byproducts and
output streams generated during the processing of PCB-contaminated soil are as follows:
Tr eated Soil Treated soil is generated at a rate as low as 70 percent of the input weight, due to losses of
water . organic contaminants, and carbon. For the Warren County Landfill soil, approximately 2 to 4 pounds
will be generated per hour of treatment . The total generated , assuming 3 runs at 4 hours per run, is a
maximum of 48 pounds . All treated soil will be analysed for PCBs, PCDDs , PCDFs and VOCs . All treated
soil will be disposed of off-site by a licenced waste hauler.
Liquid Effluent resulting from processing operations is in the form of scrubber water. All water
generated from daily operations is treated, stored and chemically tested prior to discharge . During treatment
of Warren County Landfill soil, approximately 20 gallons of water will be generated for each test. The total
amount generated from three test runs will therefore be approximately 60 gallons. Previous operational
experience has shown that following proof of compliance with criteria, the water is suitable for sewering. The
toxic test chamber requires that all water generated from Warren County Landfill soil processing be disposed
of off-site using a licenced hauler .
The hydrochloric acid will be neutralized using caustic soda at the scrubber to produce sodium chloride
(common salt) which will become pan of the liquid eft1uent stream. There may also be some particulate
sludge in this eft1uent, which will be caught by filters . This sludge will be analysed and disposed of in the
same manner as the treated soil .
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 27
Gas Product gas is generated by the treatability-scale unit at a rate of about 1.5 cubic feet per
minute , and stored temporarily. Continuous emission monitoring is used to monitor for reductive breakdown
products including monochlorobenzene , benzene and toluene in the gas on a continuous basis . Conventional
gas sampling will also be performed for PCBs, PCDDs and PCDFs. The stored gas will be used as fuel in
conj unction with propane gas in a combustion chamber designed to accommodate stack testing equipment .
This stack exhaust will be analysed for PCBs , PCDDs and PCDFs . All of the stack gases generated will be
filt ered, along with the room air, through the Toxic Test Chamber's carbon filter system.
Expended PPE Including TYVEK, respiratory cartridges , gloves, etc will be disposed of using a licenced
hauler.
All app ropriate safety and health guidelines and regulations will be followed by personnel on site when
handling contaminated materials. All site personnel will have received cenification for the 40-hour OSHA
training course in Hazardous Waste Operations and Emergency Response. As well, a health and safety officer
wi ll be on site at all times.
4.9 Schedule
As outlined in the RFP, the anticipated schedule for completion of Phase I is as follows :
I) Pre-bid conference -Monday, February 17 , 1997 (completed)
2) Submission of TSCA Permit Application (completed)
3) Pro posal Submission -Wednesday , ~larch I 9, 1997
4) Technology selection and Notice to Proceed with Phase I -April 18 , I 997
5) Completion of Treatability Study and final repo rt -June 17 , 1997
4.10 Public Meeting to Present Phase I Results
At the conclus io n of Phase I, ECO LOGIC and Guild, Incorporated will host an Open House within the
community in the area of the landfill to discuss the ECO LOGIC technology and the results of the treatability
demonstration. This Open House will be geared toward informing the community of how ECO LOGIC can
effectively remediare the Warren County landfill at fuU-scal e while considering health and safety and long-term
environmental impacts t0 the communi ty. Following are Proposed Community Relations Activities and
Srraregies as they relate t0 the Scope of Work for Phase I.
Community Relations And Risk Communication
Background
ECO LOGIC is fully cognizant of the history of the PCB Landfill in Warren County , and will team with one
of America ·s premier risk communication companies to conduct a fully coordinated and comprehensive
community relations program.
Guild Communications was selected for three reasons:
• Guild is a minoriry-owned firm ,vith exlensive expertise in Environmental Justice issues and
exp erience working in Nonh Carolina.
• Guild uses proactive and innovative approaches w communicare technical information lO
nonprofessional audiences.
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 28
• Guild has an impressive track record in helping cliems throughout the United States build trusr
and credibility ¼'ith stakeholders.
Guild's preliminary research indicates any discussion of the PCB Landfill in Warren County creates the
pmemial to raise emotional concerns at the local, regional , state , and even national levels. Initial reviews have
identified 34 environmental groups within a 100 mile radius of the site, and there are 13 Environmental Justice
organizations in North Carolina .
The high visibility of the landfill demands a partner with Guild's specialized capabilities and stature .
Pwpose
ECO LOGIC and Guild will develop community relations and risk communication strategies, products, and
services to achieve one main purpose:
Help the State of North Carolina, the Warren County PCB Landfill Worf....ing Group, and stakeholders
rea ch consensus on the issues involved in cleaning up the landfill.
Phase I Bench-scale Testing
Proposed Community Relations Activities:
Implementing proactive community relations actiiities in Phase I ,vill help minimize potenn·a1 obstacles
as the Norrh Carolina Division of Solid Waste Management strives to fulfill its commitment to
remediate the landfill.
l. Communi.ty Interviews: Guild will conduct independent, neutral interviews with citizens who represent
a cross-section of the community. The company will also interview with local and state civic leaders and
elected officials .
These interviews will identify questions, issues and concerns about detoxification technology. For example,
the public can be expected to be concerned about the safety of cleanup equipment used at the site, and affects
on the local community of a major construction type project over several years .
2. Fact Sheet: ECO LOGIC and Guild will jointly develop a fact sheet that outlines the goals and objectives
of the bench scale testing . This fact sheet will summarize the technical and scientific data of ECO LOGIC' s
test repon in a language and format that residents of the community can easily understand . Moreover, Guild
will ensure that all of the community's questions, concerns, and issues are fully addressed.
3. Open House: At the conclusion of Phase I, ECO LOGIC will host an open house at a conveniently
accessible site in the community. Exhibits , displays and a video will be used to present site specific technical
information in a format geared toward members of the community . This forum will graphically demonstrate
the considerations of health and safety , cost, and the long-term environmental impact of ECO LOGIC's full-
scale treatment technology. Guild will ensure that all information is presented in a form appropriate for the
local community.
Outside independent experts will be invited , along with environmental and other special interest groups and
opinion leaders . This open house will take place during a time period most convenient for the local
community.
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 29
5. TECHNICAL PROPOSAL -PHASE II
5.1 Objectives
The primary objective as outlined in the Scope of Work for Phase II is to produce a 60 percent preliminary
design of the full-scale detoxification system needed for the Warren County Landfill in the form of a Design
Repon. A 60 percent design will provide the level of detail necessary to prepare an accurate cost estimate fo r
full-scale remediation of the landfill.
5.2 Project Organization
The Phase II portion of the RFP for the treatment of the Warr en County Landfill materials will be conducted
by the team of ECO LOGIC, Camp Dresser & McKee, and Guild, Incorporated (Project Team). This
cooperative effort will draw on Guild's proven history in risk communication and environmental community
relations while utilizing the engineering, technical, and scientific expenise of ECO LOGIC and Camp Dresser
& rvkKee. As with all phases of the project, the Canadian Commercial Corporation will be the overall prime
contractor as discussed in Section 2.
Activities addressed in the Scope of Work for Phase II will be conducted by ECO LOGIC, CDM, and Guild.
These activities as well as the key members of the Project Team are listed below. Current curriculum vitae
for these individuals have been included in Appendix B.
5.2.1 ECO LOGIC
The strength of ECO LOGIC comes from the combined efforts of its scientific personnel, which have expertise
in analytical and environmental chemistry, toxicology, biology, hydrogeology, geophysics, chemical
engineering and atmospheric monitoring. Professionals are highly qualified in the field of toxic chemicals and
this wealth of expertise allows ECO LOGIC to provide fast, comprehensive environmental services of the
highest quality.
ECO LOGIC has been developing its innovative gas-phase chemical reduction technology since 1986. The
evolution of the ECO LOGIC Process has progressed through the bench-, laboratory-, pilot-scale to the current
full-scale systems in operation at sites in Canada and Australia. These units have been operating for more than
a year , treating PCBs, dioxins/furans , and DDT. Further detail is provided in Section 7.
Camp Dresser & McKee
Camp Dresser & McKee provides all of the environmental management services to plan, design, permit,
construct and operate environmental facilities and remediation projects for a variety of clients. CDM is a
world leader in environmental management with nearly 50 years of experience in this profession. Camp
Dresser & McKee ha ve comprised a team of professionals with experience in remedial action design,
environmental management, construction, hydrology, engineering, and environmental remediation health and
safety to execute various portions of the Scope of Work for Phase II of the Warren County Landfill
remediation.
5.2.3 Guild Incorporated
Guild has assembled an experienced, innovative team to support the North Carolina Department of
Environment, Health and Natural Resources and the Division of Waste Management for the proposed
remediation of the Warren County PCB Landfill. The team is composed of senior professionals who reflect
the diversity of the citizens of Afton and Warren County. Guild's key personnel have the right blend of
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 30
management, facilitation, risk communication, training , and intergovernmental coordination expertise. Guild's
people have been involved in complicated , politically sensitive, and emotionally-charged environmental
community relations projects throughout the United States . Guild has succeeded in providing its clients with
strategie s and products that elicit trust and credibility .
Guild is a small business , owned by an African-American who is a native of North Carolina.
5.3
5.3.1 Technical
ECO LOGIC will team with Camp Dresser & McKee in preparing a Preliminary Design Report (PDR) in
coo peration with the State , Working Group, and Science Advisors for implementation of the full-scale
detoxification system at the Warren County PCB Landfill.
The PD R will present a conceprual design of the recommended remedial action for the detoxification of the
PCB contaminants at the landfil l. CDM will complete the necessary conceprual design engineering work for
excavation and related site work , site preparation, site restoration, handling of waste and residual products in
conjunction with ECO LOGIC to produce the PDR. It is CDM 's understanding that the purpose of the PDR
ism complete the remedial design to the extent necessary so that an accurate cost estimate, including capital
cost, operating and maintenance cost, cost per unit of containment, and total cost of full-scale treaonem of the
landfill, can be developed. This cost will then be presented to the State of North Carolina General Assembly
for approval of funding .
The preliminary outline presented below represents the level of effort required to produce a 60 % preliminary
design. The ECO LOGIC/CDM project team feels that this minimal level of detail is necessary to prepare
a cost estimate that the NCDEHNR can present to the General Assembly. The PDR will not include
construction drawings or specifications. ECO LOGIC/CDM assumes that the State will provide site layo ut
dra\vings and AumCAD files with site fearures and topography. It is also assumed that the PDR will only be
required to address the contaminated soils within the landflll and will not include removal of potemially
contaminated soils located outside the boundaries of the landfill or pumping and/or treatment of groundwater .
A preliminary outline of the PDR is presented below.
Section 1 -Introduction
l . l Site Description
1.2 Purpose of Report
Section 2 -Site History and Environmental Setting
2.1 Site History
2. 2 Environmental Setting
2.3 Description of Site Contamination (narure and extent)
Section 3 -Description of the Recommended Remedial Action
3.1
...... ., . .,
3.4
Selection of the Proposed Remedy
Summary of the Bench-Scale Srudy
Basis of Design
Approach to Remediation and Process Description
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 31
3.5 Site Preparation (mobilization and site clearing, etc.)
3.6 Excavation and Related Sitework (including materials handling and backfill and
compaction of treated soils)
3. 7 On-site Demonstration Testing
3. 8 Treatment of PCB-Contaminated Soils
3. 9 Site Restoration and Demobilization
3 .10 Air Quality Monitoring
3.11 Soil Treatment Verification Sampling and Analysis (testing of treated soil)
3 .12 Soil Confirmational Sampling and Analysis (testing of excavation)
3.13 Handling of Waste Streams (liquid and solid residues generated during the remedial
action)
3. 14 Permitting and Regulatory Requirements
3. 15 Health and Safety Requirements
3. 16 Operation and Maintenance Requirements
3.17 Reponing Requirements (status reports, closure report, etc.)
3.18 Special Construction Requirements/Considerations (erosion and dust control, site
access and security, surrounding site considerations, temporary facilities, stormwater
management, etc.)
Section 4 -Estimated Construction Schedule
Section 5 -Drawings (assumed 11-inch by 17-inch size)
G-1 Legend, Site Location Map, and General Notes
C-1 Process Flow Diagram
C-2 Existing Site Plan
C-3 Work Staging and Control Plan
C-4 Excavation Plan
C-5 Civil Details and Cross Sections I
C-6 Civil Details and Cross Sections II
E-1 Electrical Plan
E-2 Electrical Schematic Diagram and Details
Appendices ( cost estimates, calculations, analytical reports, bench-scale study, etc.)
ECO LOGIC/CDM will meet with the State, Working Group, and Science Advisor staff at DEHNR's offices
in Raleigh at various stages of the project to plan, develop, and review the PDR. The level of effort for this
proposal assumes four meetings in Raleigh with two CDM staff members in anendance.
5.3.2 Community Relations and Risk Communication
Strategies
ECO LOGIC and Guild recommend proactive community relations and risk communication strategies for all
phases of the remediation of the landfill. These strategies will be fully coordinated and carried out under the
direction of the Nonh Carolina Department of Environment, Health and Natural Resources and the Warren
County PCB Landfill Working Group.
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ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill
Phase II -Full-Scale Preliminary Design
Proposed Community Relations Strategies
Page 32
I. Questions and Answers (Q&A) Development: It has been scientifically proven that more than 90 percent
of the questions asked in a public forum or by news media can be anticipated in advance . The site-specific
research and information on ECO LOGIC's treatment technology will provide the foundation for a series of
Questions and Answers. These Q&As will be incorporated into fact sheets, newsletters and summaries .
2. i'vlailing List: A mailing list will be established for stakeholders and other parties interested in the
remediation of the Warren County PCB Landfill.
3. Newsletters and Fact Sheets: Newsletters or fact sheets will be prepared as events warrant in the full scale
preliminary design phase. In consultation with the Working Group they will be mailed to people on the mailing
list and be made available at libraries, schools, churches, and businesses in the community.
4. Preliminary Design Workshop: A one-day risk communication consensus building workshop will be
conducted with state and federal regulators, state and county congressional representatives. state
environmentalists, the ECO LOGIC team of engineers and scientists, local citizens. and the Working Group .
A Guild faciliraror will guide participants through the process of developing key messages and supporting facts.
Participants will then build consensus on how to effectively communicate those messages in public forums and
with news media.
5. Economic Development Initiatives: ECO LOGIC recognizes that economic development of Afton and
Warren County can and should be an imponant pan of the environmental remediation process. ECO LOGIC
is committed to teaming and partnership arrangements that provide jobs and economic stimuli to the area.
ECO LOGIC and Guild will identify and recommend hands-on operations. maintenance , and health and safety
training courses for community residents seeking employment at the site during the actual cleanup phase.
ECO LOGIC and Guild will also identify local contractors for potential involvement in the full-scale
remediation. ECO LOGIC and Guild will purchase goods and services from local businesses wherever
possible .
6. Public Involvement Forum: Upon acceptance of the Final Report by the State, a full-scale Public
Involvement Forum using risk communication techniques developed by Guild is highly recommended.
All strategies outlined in phases I and II should continue to be updated and used during the actual
decontamination of the site .
Results:
ECO LOGIC and Guild are results-oriented. At the completion of Phase II, the State and The Working group
will have hands-on experience with community relations tools and techniques that will :
1. Identify key stakeholders and provide strategies on how to communicate with them.
2. Assist the State and the Working Group in developing key messages, setting one agenda, and
speaking ivith one voice.
3. Promote trust and credibility between the State, the Working Group, and stakeholders.
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Effective communication, especially in situations where there is a history of conuoversy, is an ongoing
process. The ECO LOGIC/Guild team can provide the communications foundation as the State and Working
Group continue on the path toward full decontamination of the Warren County PCB Landfill.
5.3.3 Key Personnel
5.3.3.1 ECO LOGIC
Peter Kornelsen, M.Sc. Vice President, Operations
Person responsible for reviewing overall Design Repon
Doug Gray, M .Sc . Project Manager
Project Manager
Person responsible for preparation of Design Report
K. Elizabeth Kurnmling, B.Sc. Manager, Permining and Approvals
Person responsible for determining permitting requirements as they relate to design
5.3.3.:2 Camp Dresser & McKee
Joseph Wiseman, Jr., P.E.
Timothy Grant, P.G.
R. Tom Clark, P.E .
Drew Bennett, B.S., M.S.
Joseph E. Mihm, P.E.
Michael Schultz, P.E.
Project Manager
Senior Geologist
Senior Design Engineer
Senior Environmental Scientist/Technical
Technical Review
Vice President/Technical Review
Christ0pher Marlowe, C.I.H., C .S.P Corporate Health and Safety Manager
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5.3.3 .3 Guild, Incorporated
NAME
*B. Applewhite
*A. Berger
*M. Bergman
*S. Brown
S. Chaloux
V. Covello
:V!. Higgs
P. Ruffins
.vi. Smith
5.4 Schedule
GUILD RESOURCES AV All.ABLE TO SUPPORT
THE WARREN COUNTY PCB LA.l''IDFILL
POSITION YEARS OF
EXPERIENCE
Facilitator 17
Commun.icy Relations 20
Specialist
Community Relations 30
Specialist
Trainer/Facilitator 22
Community Relations 12
Specialist
Risk. Communication 21
Advisor
Senior Graphic Designer 14
Environmental Justice 18
Advisor
Community Relations 18
Specialist
RISK COMMUNICATION
TRAINING
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
ECO LOGIC/CDM will prepare a draft PDR for review and comment followed by a final report. This report
will lay the foundation for the construction and implementation of the detoxification process. CDM estimates
8 to IO weeks to prepare the draft PDR after receiving the notice to proceed with Phase II work. A final PD R
can be submitted within 4 weeks of receiving comments on the draft report. This schedule adheres co the
anticipated schedule presented in the RFP. If the State wishes to modify the completion schedule, ECO
LOGIC /CDM will be willing discuss revisions to both the schedule and the anticipated scope of work. The
cost estimate will be revised accordingly.
Development of community relations and risk communication strategies as well as implementation of an Open
House fo llowing the treatabiliry testing will be conducted following a notice to proceed with Phase II activities.
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6. PER~IlTTING AND PUBLIC CONSULTATION
6.1 ECO LOGIC's Past Performance
The ECO LOGIC Process has been permitted for use at both a pilot-scale and commercial-scale throughout
North America and Australia. ECO LOGIC is currently operating at a commercial-scale in St. Catharines,
Ontario, Canada and Kwinana, Western Australia, treating PCB and pesticide wastes. In the summer of 1997,
ECO LOGIC is scheduled to begin another commercial-scale operation processing stored, above ground PCB-
impacted material at an urban site in Toronto, Ontario, Canada.
For all permining activities, ECO LOGIC initiates and maintains an extensive public consultation program,
which targers individuals from local community groups, environmental organizations . local media, and
government agencies, among others. ECO LOGIC's history of permitting and public consultation has been
highly successful, and permits have been awarded for the use of the Process in a variety of locations, from
remote northern areas to highly populated urban areas.
The following sections summarize the operating permits awarded for the use of the ECO LOGIC Process.
6.1.1 General Motors of Canada Limited (Commercial-Scale)
The ECO LOGIC Process has been fully permitted for use at the General Mot0rs of Canada Limited facility
in St. Catharines, Ontario , Canada, for the treatment of PCB-contaminated materials including soil, sediment.
electrical equipment. concrete, and other bulk solids. Copies of the operating permirs for the GM project are
included as Attachment A of Appendix C, and summarized below.
• Certificate of Approval, Waste Disposal Site (Processing), No. A181002, under Pan V of the
En vironmental Protection Act, R.S.O. 1990
1l1is permit addresses the use and operation of the unit at the site, and details sampling and
analysis requirements and output disposition
• Cenificate of Approval (Air), No. 8-3104-95-006, under Section 9 of the Environmental Protection
6.1.2
Act, R.S.O. 1990
This permit addresses the operation of various heating devices within the system,
including the boiler, the catalytic steam reformer, the recirculation gas heater, the
TRM heaters, and the SBV heaters.
Certificate of Approval, Industrial Sewage, No . 4-0007-95-006 , under Section 53 of the Ontario
Water Resources Act, R.S.O. 1990
This permit addresses the discharge of process \Vater to a surface water body.
Kwinana, Western Australia (Commercial-Scale)
A commercial-scale configuration of the ECO LOGIC Process is currently processing PCB and DDT wastes
in Kwinana, Western Australia. For this project, ECO LOGIC was issued the following approvals:
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• Works Approval Permit Number 1067 under the Western Australia Department of Environmental
Protection Environmental Protection Act 1986
This permit allows for the construction of the facility, and specifies conditions for air and
water pollution control.
• Licence No. 6297 under the Western Australia Department of Environmental Protection
6.1.3
Environmental Protecrion Act 1986
This pennit allows for the operation of a facility at the site, and specifies such things as
inventory requirements, processing conditions, and sampling and analytical requirements for
gaseous (stack), liquid and solid outputs.
General Electric Canada Inc. (Commercial-Scale)
In No\·ember 1996, the Ontario Environmental Assessment Board (EAB) approved the use of the ECO LOGIC
Process to desrroy PCB-impacted materials stored above ground at a site formerly owned by General Electric
Canada Inc (GECI) in Toronto, Ontario. This approval followed an extensive 6 month public hearing, which
involved 2 commnnity groups, a Greenpeace/Great Lakes United coalition, and the City of Toronto. The
outcome of the hearing was support from all hearing panicipants, and ratification of the follo\\ing Certificates
of Approval:
• Certificate of Approval for Waste Management System No. A84 l 53 l, under Regulation 352 of the
En vironmental Protecrion Act, R.S.O. 1990
This permit addresses requirements for the operation of the waste treatment system, including
process monitoring, air output monitoring, and system operating conditions
• Certificate of Appro\·al for \Vaste Dispos.n l Site No. A290030, under Part V of the Environmental
Protecrion Act. R.S.O. 1990
6.1.4
This permit addresses site-specific issues such as sampling and analysis requirements, solid
and liquid output disposition, noise monitoring, and community consultation.
Bay City, Michigan (Pilot-Scale)
ECO LOGIC demonsrrated the ECO LOGIC Process at pilot-scale in Bay City, Michigan, under the auspices
of the United States Environmental Protection Agency (USEPA) SITE program. A permit was awarded to
ECO LOGIC by the City of Bay City, Michigan entitled "Permit for Conduct of Superfund Innovative
Technology (Site) Program at Middleground Landfill" and is provided in Attachment D of Appendix C. The
permit grants the applicant (ECO LOGIC) access to the Middleground landfill for the purposes of site
preparation, mobilization, storage and/or delivery of hazardous/toxic wastes and substances, operation,
sampling and the elimination of hazardous/toxic wastes and substances. Also provided in Anachmem D of
Appendix C are the following State and Federal permilS:
• Michigan Department of Narural Resources (MDNR) air permit under the Michigan Clear Air Act,
to allow processing of PCB-contaminated feedstock
• Toxic Substances Control Act (TSCA) research and development demonstration permit (including
EPA/TSCA identification number to allow disposal of the test residues in accordance with Resource
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Conservation and Recovery Act (RCRA) requirements)
In addition to the above permits, ECO LOGIC was awarded a permit by the City of Bay City to discharge
process \\'aste water to the local publicly-om1ed treatment works.
6.1.5 Hamilton Harbour, Ontario (Pilot-Scale)
The first pilot-scale demonstration of the ECO LOGIC Process occurred at Hamilton Harbour, Ontario,
processing contaminated harbour sediments. The follov,i.ng permits and approvals were issued:
• Approval to proceed following the Federal Environmental Assessment Review Process
• Pro\·ince of Ontario Environmental Protection Act -Section 308 Certificate of Approval (Air) No.
8-2002-91-006.
• Notice of Permission to use Hamilton Harbour Commission property, Number 001682.
A complete package of permits issued to ECO LOGIC , entitled Operating Permits for the Use of the ECO
LOGIC Process are presented in Appendix C.
6.1.6 TSCA R&D Permit
An application for a TSCA Research and Development permit under the Toxic Substances Control Act (TSCA)
has been submined to the TSCA office in Washington (Mr. Winston Lue), as well as USEPA Region 3 (Ms .
Charlene Kreamer). This permit will alow for testing to occur at the ERDEC toxic test chambers at Aberdeen
Proving Ground . ECO LOGIC received a TSCA R&D permit for the larger unit that was used in Bay City
in 1992. Indications from the EPA are that this permit can be made available before the middle of April 1997.
6.2 Guild 's Past Performance
Guild specializes in working with stakeholders in environmental community relations programs. These
programs often present a common challenge : People have low trnst in the entity trying to implement an
activity, and high concern about health and safety issues in the community.
Guild typically encounters three problem areas:
• Inabiliry to identify the stakeholders and their concerns: Failure to understand who the stakeholders
are and their positions leads to a lack of understanding of the dynamics and communication climate
in the community .
Lack of focus : Without a strategic communication plan, multiple agencies often communicate to9
many messages, with too many voices. This diminishes credibility and creates a lack of trust.
• Techn ical barriers: Scientific and engineering concepts and terms are difficult to communicate to
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nonprofessional aucliences.
Guild provides the basic building blocks to solve these problems . Guild uses scientifically-proven
environmental risk communications principles to design and implement strategies and products that:
Are based on research and interviews unique to a site or situation,
Identify the stakeholders and bring them to the table,
• Focus on key messages,
• Inform and communicate these messages, and
Assist in achieving the goal of stakeholder "buy in"
Guild works closely with all stakeholders , including government agencies, minority and tribal communities,
special interest or environmental groups, citizens, and indusay . Guild has been highly successful in facilitating
discussions and developing communication products that enable stakeholders to achieve consensus on key issues
and messages, thus enabling controversial projects to move forward .
Guild has a proven track record of success with dozens of federal and state agencies and commercial firms
including the National Guard Bureau (100 task orders). US Army Corps of Engineers, US Army
Environmental Center, US Air Force Center for Environmental Excellence, US Environmental Protection
Agency. and the Washington Suburban Sanitary Commission.
7. RELEVANT EXPERIENCE
7.1 ECO LOGIC
Since 1986, ECO LOGIC has worked on identifying , evaluating, designing, fabricating, and implementing a
cost-effective and publicly acceptable alternative to incineration for the destruction of organic contaminants
in aqueous , liquid, and solid media. This section provides further detail on the development stages of the ECO
LOGIC technology, as well as the current and future applications . Detailed project descriptions for the
demonstration-, and commercial-scale projects are included in Appendix D.
7 .1.1 Laboratory-Scale Treatability Studies
Early in the development of the ECO LOGIC Process, a laboratory-scale treatability unit was constructed and
extensively tested. A more recent version of the unit is still being employed by ECO LOGIC to perform
treatability stuclies on client specific waste streams . The treacability test unit utilizes the same conceptual
parameters as the commercial-scale system including a suitably scaled TRM and SBV.
Table 7 summarizes the results of representative treatability testing on PCB-contaminated soils and sediments .
Table 8 lists treatability results specific to dioxin!furan-contaminated waste.
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In November , 1995, ECO LOGIC was selected for testing and evaluation under the US Army DOD
Alternative Technology Program. This program has been developed to identify alternative technologies
suitable fo r the destruction of chemical warfare agents and associated materiel currently in storage at various
sites in the US.
In May, 1996, ECO LOGIC completed treatability-scale testing of the ECO LOGIC Process the US Army's
Edgewood Research Design Engineering Center (ERDEC) toxic chamber facilities located at Aberdeen
Proving Ground , Maryland. The test program involved the treatment of distilled sulfur mustard (HD) and
nerve agent VX. ERDEC staff oversaw all treatment activities, and performed all sampling and analysis.
7.1.2 Demonstration-Scale Operations
Hamilton Harbour, Ontario, Canada
In the summer of 1991, the demonstration-scale unit was tested at Hamilton Harbour, Ontario, on coal tar-
contaminated harbour sediments with P AH concentrations averaging 30,000 mg/kg ( dry weight). Three test
runs were performed on the contaminated sediment, with the third run being spiked with PCBs at a nominal
concentration of 500 mg/kg . At the time sediments were injected directly into the gas-phase chemical
reduction reactor as a 5 to IO percent slurry. PAH destruction and removal efficiencies of 99.9999 percent
were calculated based on total organic input and the P AHs analysed in the boiler stack emissions (Table 9).
The concentration of PCBs in the air emissions, liquid output and processed solids were all below detection
limits, resulting in a PCB destruction and removal efficiency (DRE) of at least 99 .9999 % . Appendix D
contains the summary report entitled ECO LOGIC Pilar-Scale Demonstration in Hamilton Harbour .
Bay City, ,'vlichigan, USA
In 1992, ECO LOGIC relocated the demonstration-scale unit to a site in Bay City, Michigan. This field
demonstration was performed under the auspices of the SITE Program and was cosponsored by Environment
Canada, the Ontario Ministry of the Environment and the City of Bay City . The wastes processed included
a PCB-contaminated water stream , high strength PCB oil , and PCB-contaminated soil. PCB concentrations
in the test materials ranged from 25 .4 % to roughly 1,000 ppm. The minimum test criteria of 99. 9999 % DRE
,,. was achieved for all test runs (Table 10). A primary objective of the program, as stated in the USEPA's
Technology Evaluation Report, was to "ensure that no dioxins or furans were formed" (Technology Evaluation
Report, Page 2-5). In their discussion of the results of the demonstration, the US EPA stated the following :
To evaluate the forman·on potential of PCDD!PCDF, the input and output masses of these substances
were measured in key process streams. Formation was quantified by computing the [Destruction
Efficiency] DE for each test run. A DE greater than zero indicates no net formation of PCDDIPCDF
(Technology Evaluation Report, Page 5-19).
The DEs for dioxins and furans were much greater than zero for all tests , leading the USEPA to conclude:
··Net deStruction of PCDD /PCDF contained in the feed was demonstrated" (Technology Evaluation Report,
Page 1-3).
A Technology Demonstration Summary is included in Appendix D.
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7.1.3 Current Commercial-Scale Applications
Foll owing demonstr ation-scale validation of the ECO LOGIC Process , commercial-scale systems with
improved waste throughput were designed. These units were equipped with hydrogen regeneration capabilities
and improved front-end materials handling systems. The commercial-scale unit is still mobile , with individual
system components being mounted on highway trailers or skids .
Kwinana, Western Australia
The first SE25 ELI Destructor is currently operational in Kwinana , Western Australia, where contracts for
the destruction and recycling of pesticide residuals and PCB-contaminated electrical equipment have been
awarded. Results of both DDT and PCB testing have been included in Table 11.
This same unit is now being utilized to treat PCB-contaminated elecuical equipment from various regions in
Australia. Stack tests have recently been conducted while processing PCB oil. An independent stack sampling
company collected a stack gas sample from the catalytic steam reformer/boiler stack for PCB and semi-volatile
analyses. All analyses were conducted by a sub-contracted laboratory . All detected semi-volatile compounds
were at concentrations well below air emission guidelines . No PCBs were detected in the sample stack gas.
Based on a detection limit of 0. 72µ.g /m3 for PCBs, the destruction and removal efficiency (DRE) was
calculated to be 99 .999998% (seven nines). An additional compliance test performed recently has confirmed
the excellent DRE of the Process . Stack testing reports prepared following performance testing at the K winana
site are included in Appendix E.
St. Catharines, Ontario
The second SE25 ELI Destructor is currently processing PCB-contaminated materials at the General Motors
of Canada Lim ited (GMC L) facility in St. Catharines. Ontario . The contaminated matrices include soil ,
electr ical equipment, askarel, concrete , and various other solids including personal protective equipment and
tools . GMCL has indicated that their remaining stored PCB inventory currently located at various facilities
in Southern Ontario ,vill be transponed to St. Catharines for treatment.
Initial results of the treated material as well as ambient air have indicated that the system is conforming to the
guidelines set out by the Ontario MOEE. Table 12 presents a summary of the DREs and destruction
efficiencies (DEs) for PCBs and CBs from the performance testing program conducted at GMCL. Results
show that the ECO LOGIC treatment system consistently achieved a DRE of at least seven nines (99 .99999%)
for PCBs and at least six nines for CBs.
The stack gas was also analysed for dioxins and furans during the GMCL performance testing program.
Results indicated that concentrations of dioxins and furans were 10,000 times lower than regulatory criteria
at point of impingement.
A detailed repon on the GMCL performance testing program, entitled Source Testing Report, ECO LOGIC
PCB Treacmem Demonstration Project, General Mowrs of Canada Limited, Glendale A venue, St. Catharines,
Ontario, has been provided in Appendix F.
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TABLE 7 RECENT THERMAL REDUCTION MILL TESTING RESULTS
Waste PCB Processed Solids
Concentration PCB Concen-
Waste Type (ppm) tration (ppm)
Soil (moist, granular, PCB-spiked) 440 0.0039
Soil (moist, granular, PCB-spiked) 520 0.0016
Sediment (muddy, fine , PCB-spiked) 710 0.028
Sediment (muddy, fine, PCB-spiked) 790 0.0097
Sediment (muddy, fine, PCB-spiked) 750 0.065
Sediment (muddy, fine) 7.3 0.0029
Sediment (muddy, fine) 8.3 0.0066
Sediment (muddy, fine) 8.3 0.0013
Sediment (muddy. fine) 1200 ND (0.011)
Sediment (muddy, fine) 8.3 ND (0.005)
TABLE 8 GREAT LAKES HARBOUR SEDIMENT TREATABILITY RESULTS
Test Total PCDDs (ng/g) Total PCDFs (ng/g) Total EPA 8270 PAHs (µgig)
Pre-rest Was te 1 2,000 38 842
2 1,900 36 826
3 2,000 35 744
Processed 1 ND ND 5.4
Solids 2 ND ND ND
3 ND ND 12.4
Test Total PCDDs (pg/mL) Total PCDFs (pg/mL) Total EPA 8270 PAHs (ng/mL)
Pre-cest I ND ND 880
Scrubber (pg/mL) 2 ND ND 1.5
3 ND ND 161
Post-test I ND ND 324
Scrubber (pg/mL) 2 ND ND 3,281
3 ND ND 2,804
Test Total PCDDs (pg/L) Total PCDFs (pg/L)
EZ I Resin Tube 3 80 5.9
Resin Tube Back-up 3 93 5.5
Sysrem Blank 3 30.3 6.5
System Blank Back-up 3 ?",., _.:,_.:, 6.9
ND -not detected NA -not analysed
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TABLE 9 HAMIL TON HARBOUR PERFORI\UNCE TEST RESULTS
Cone.in Decant Grit Sludge Stack
Target Waste Water Cone. Cone. Cone. Gas Cone. DRE
Run Analytes (mg/kg) (~tg/kg) (mg/kg) (mg/kg) (µg/m3) (%)
Pl PAHs 21 ,000 483 1.67 32.8 0.27 99.9999
P2 PAHs 30,000 680 7.76 56.1 0.23 99.9999
P3 PAHs 30,000 423 0.37 4.3 0.14 99.9999
P3 PCBs 500 ND ND ND ND 99.9999
DRE= (Total Input -Stack Emissions) I (Total Input)
ND = Non-Detect
TABLE IO USEPA SITE PROGR.\M TEST RESULTS
Wa1er!Oil and High-Strength Oil Tests
Concentration Target
Run Waste Type Contaminant (mg/kg) DRE/DE Achieved
I Water/Oil PCBs 4,800 99.9999 Yes
Tracer Perchloroethene 4,670 99.99 Yes
2 Water/Oil PCB s 2.450 99.9999 Yes
Tracer Perchloroethene 2.360 99.99 Yes
_, \Vater/Oil PCBs 5.950 99.9999 Yes
Tracer Perchloroethene 6,100 99.99 Yes
4 Oil PCBs 254,000 99.9999 Yes
Tracer Perchloroethene 33,000 99.99 Yes
5 Oil PCBs 254,000 99.9999 Yes
Tracer Perchloroethene 26,000 99.99 Yes
6 Oil PCBs 254,000 99.9999 Yes
Tracer Perchloroethene 34,000 99.99 Yes
Soil Tests
Concentration Desorption E11iciency
Run Waste Typ e Contaminant (mg/kg) (%)
I Soil PCBs 53S 94
Tracer HCB 12,400 72
Tracer OCDD 0.744 40
2 Soil PCB;; 718 99
Tracer HCB 24,800 99.99
Tracer OCDD 1.49 99.8
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7.1.4
TABLE 11
Input
Duration of Run
Feed
Concentration
Mass Input
Output
Gas Flowrace
Concentration
Mass Output
STACK TEST DAT A FOR CO.lvllv1ERCIAL-SCALE
TREA Tlv1ENT OF DDT AND PCBs
DDT PCBs
Quamity Quantity
81 minutes 110 minutes
127.5 L 122 L
30.3 % 90 %
39.7915 kg 142.74kg
0.76 m3/sec 0.601 m3/sec
::: 1.7 µg/Nm3 <0.72 µg/m3
::: 0.00000628 kg ::: 0.00000187 kg
DRE s (39.7915 - 0.00000628)/39.7915 DRE ::: (142. 74 -0.00000187)/142. 74
~ 99.999984% ~ 99.999998%
TABLE 12 GMCL PERFORMANCE TESTING SUMMARY -DRE AND DE
I Parameter I Unils I Test 1 I Test 2 I Test 3
DRE for PCBs % 99.9999996 99.9999985 99.9999997
DRE for CBs % 99 .9999842 99.9999985 99 .9999977
DE for PCBs % 99.9999996 99.9999985 99 .9999808
DE for CBs % 99.9999836 99.9999972 99 .9999971
Future Applications
Page 43
I
General Electric Canada Inc . and ECO LOGIC have a contract to treat PCB-impacted materials stored above-
ground at a site in Toronto. Permitting and approvals for this project have been completed with operations
commencing in 1997.
ECO LOGIC has also obtained an award from the United States Department of Energy for various waste
streams including low level radioactive mixed wastes, PCB and dioxin contaminated soils and sedimenLs,
munitions , propellants , and a variety of specialized toxic organic waste streams. This award requires
treatability and commercial-scale remediation commencing in 1997 and is a multi-year, multi-phase project
a\.vard . Other strategic market sect0rs which are suitable for the technology include chemical manufacturing
residues and municipal/industrial sewage biosolids.
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7.2 Camp Dresser & McKee
CDM has completed solid waste projects for 23 counties and five cities in North Carolina. Of these local
governments, CDM is the ongoing solid waste consultant for Buncombe, Cabarrus, Cumberland, Davidson,
Mitchell, Rockingham, Wake, Onslow , and Yancey Counties. Most imponantly, CDM has completed or is
currently involved in various stages of 12 Subtitle D landfill projects in North Carolina . CDM has also
completed projects at more than 40 existing unlined and other proposed new Subtitle D land.fill sites in North
Carolina. This extensive North Carolina landfill work has allowed CDM's local staff to maintain a close
working relationship with staff from the North Carolina Division of Solid Waste Management (DSWM).
CDM • s Raleigh office is only four miles from the (DSWM) which allows for close contact with Division
personnel throughout all phases of solid waste projects. Furthermore, CDM's North Carolina experience is
supplemented by work on more than 75 lined landfills that are in operation across the country . Over the past
five years, CDM has completed more than 150 separate solid waste engineering projects for more than 25 local
governments in North Carolina. CDM is working on various phases of the siting, permitting, design, and
construction of new North Carolina Subtitle D land.fills as delineated in Table 1 of Append.ix G.
Detailed descriptions of CD M's Nonh Carolina Subtitle D land.fill projects are included in Appendix G as well
as other relevant projects . These projects demonstrate CDM's past performance with respect to working
relationships with clients and compliance with project cost, schedule, and management of change orders.
7.3 Guild, Incorporated
Guild has had contractual relationships with NASA and the U.S. Department of Transportation for more than
20 years. It has served the National Science Foundation for 18 years.
Guild was awarded a.first of its kind environmental community relations support contract for the National
Guard Bureau in 1 993 . In its first four years. Guild completed more than I 00 task orders. all within cost and
on schedule. The company is now entering a five year, follow-on contract with the National Guard .
Guild has received numerous awards recognizing the fum's exceptional ability to translate highly technical
jargon into products that can be easily understood by non-professional audiences. Guild's award winning
writers, editors, graphic artists, designers, risk communication expens and community outreach specialists
are trained in scientifically proven communication strategies. Together. they have supponed more than 50
programs throughout the United States.
Refer to Section 6 Permitting and Public Consultation and Appendix H for Guild's extensive experience
relevant to the Warren County Land.fill remediation project.
8. HEALTH & SAFETY/TRAINING
A Health and Safety Plan has been developed for ECO LOGIC's Research and Development operations. This
document addresses matters which have specific relevance to health and safety at the Rockwood site as well
as mobile operations. A complete copy of the Health and Safety Plan is included as Appendix I.
All ECO LOGIC personnel associated with the operation of ECO LOGIC's hazardous waste destructor are
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page :Jj
required to have a level of training and experience commensurate with their job responsibilities. Key aspectS
of ECO LOGIC's training program are highlighted below.
8.1 Hazardous Waste Operations Certification
Any employee working with the treatabilicy-scale equipment must be certified in the OSHA mandated 40-hour
hazardous waste (HAZWOPER) training course or equivalent training . Personnel are required to complete
a yearly 8-hour OSHA hazardous waste operations refresher course (or equivalent). All personnel are
required to achieve a 70 percent grade in the final examinations prior to certification.
Topics covered by this training program include the following :
Toxicology
Emergency response procedures
Chemical safety
Respiratory protection
Respirator fit test
Confined space entry
Protective clothing
Electrical safety
Eye safety
Field exercise--full dress
Fire protection
First aid and health factors
Decontamination and work zones
Site safety
Leak sealing
Hearing safety
General safety
Air monitoring instruments
and hazardous atmospheres
Hand safety
Recognizing site hazards
Examination
Materials handling
Material safety data sheets (MSDS)
and labelling requirements
In addition, supervisory personnel are required to have certification of the OSHA 8-hour supervisory training
course (or equivalent).
8.2 Worker Right-to-Know
Although worker right-to-know is part of the training course, it is supplemented and expanded to ensure that
all individuals entering the job site are knowledgable of this legislation. Topics covered include:
8.3
Legislative requirements
Employer responsibilities
Employee rights and responsibilities
Destructor Operations
To be full y knowledgeable of on-site operations and hazards, all personnel are required to be familiar with the
destructor and its operation and receive training in the following areas:
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill
Electrical distribution and isolation
Basic chemical processes
Design and operation
Potential operating hazards
Equipment inspections
Page 46
Personnel involved in the operation and maintenance of the destructor also receive training in the following
areas:
Distributive Control System (DCS)
Standard Operating Procedures (SOPs)
Control logic and instrumentation
In-depth design and operating parameters
Extensive on-the-job training
All destructor operators are required to panicipate in a 25 hour training course covering all parameters
necessary to properly operate the data logging computer and ancillary equipment. It is the responsibility of
the training coordinator to document all training and judge whether the employee has adequate job knowledge
and work experience . Personnel performing inadequately are not permined to operate the equipment.
8.4 Contjngencv Plans
All personnel are required to know all contingency plans for on-site emergencies that include the following :
Fire control
Medical emergencies
Adverse weather conditions
In addition, personnel involved with the operation and maintenance of the destructor receive training in the
following:
8.5
Spill control and cleanup
Emergency shutdown procedures
Process upset/equipment failure
Hazardous Materials Training -Site Specific
For each new job site, the health hazards associated with each hazardous chemical to be encountered are
reviewed with all personnel. Topics covered include :
important roure(s) of entry
critical target organs and associated health effects
review of appropriate PPE and other safety requirements
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of So il from Warren County, North Carolina Landfill Page 47
9. CORPORATE QUALITY ASSURANCE -TOTAL QUALITY MANAGE!\1ENT PLAN
ECO LOGIC has prepared a Quality Management System Manual based on ISO 9000 requirements as a
templ ate . This manual , presented in Appendix. J describes the Quality System adopted by ECO LOGIC and
identifies the key system documentation required to meet the strict requirements of the Quality Management
System.
IO. ASSUMPTIONS AND QUALIFICATIONS
• ECO LOGIC has assumed a start date of mid-April, 1997 for commencement of project activities.
Also, we have assumed that confirmation of an actual start date for the project will be determined at
the time of contract award.
• ECO LOGIC will no be responsible for any delay in delivery due to causes beyond its reasonable
control including, without limiting the generality of the foregoing , acts of God , acts of the civil ,
military or other regulatory authorities, fire, strikes, wars, inclement weather , wrecks, or delays in
transportation. Any delays may result in a need for an extension to the proposed contract period of
perfo rmance.
• ECO LOG I C's efforts will end on this project upon the submission of the Final Design Report for
Phase II assuming contract award .
ECO LOGIC will submit deliverables in accordance with the project schedule cited in Section 4 and
·section 5.
• The appropriate weight of contaminated soil will be delivered to the ERDEC toxic test chambers at
Aberdeen Proving Ground , Aberdeen , MD in sealed drums by the State .
All sampling and analysis activities are based on the requirements presented in the RFP . Any change
to these requirements may result in a need for an equitable adjustment for additional funding and/or
an extension to the proposed contract period of performance.
ECO LOGIC Proprietary In formation Confidential
ECO LOGIC Treatment of So il from Warren County, N orth Carolina Landfill Page ./.8
11. PRICING
11.1 Cost Proposal for Phase I
FORM OF PROPOSAL
The undersigned bidder proposes and agrees if this proposal is accepted to contract with the Department of
Environment , Health, and Natural Resources, Division of Waste Management to furnish the services required
herein, and to complete the scope of work as described in Part II hereof. Services should be accomplished
in full and complete accordance with the specifications and contract documents to the full and entire satisfaction
of the Division of Waste Management, with a definite understanding that no money will be allowed for extra
work except as may be set forth in v.Tinen addendum to the contract, duly executed by all parties therew.
The parties hereto agree that in consideration for performing all the requirements hereunder, DEHNR shall
pay the offerer as per the following cost proposal for the services as described herein, said sum to be full and
complete compensation for the offeror 's services required herein.
Pursuant to the provisions of G. S. I 43-54 , and under penalty of perjury, the signer of this proposal certifies
that this proposal has noc been arrived at collusively nor otherwise in violation of Federal nor North Carolina
antitrust lav,.;s_
ELI Eco Logic International Inc.
Federal I.D . Number: NA
s,~
Typed Name: Ed Korhonen
Titl e: Executive Vice President
Addr ess: ELI Eco Logic International Inc.
143 Dennis Street,
Rockwood, Ontario NOB 2K0
Witness,~
Please indicate if one of the following app lies: Women Owned/Controlled. ___ _
Minority Owned/Controlled. __ _ Handicapped Owned/Controlled __
Submitted this 19 day of March 1997.
RFP #PCB LF-4
ECO LOGIC Proprietary In formation Confidential
ECO LOGIC Treatmem of Soil from Warren County, North Carolina Landfill
PHASE I COST PROPOSAL
Treatabiliry Study Costs
Stack Testing
Analytical Services
Risk Communication Services
Total Price (US$)
51,456
16,050
57,780*
16,500
141,786
Page 49
*NOTE: Cost for Analytical Services are for strict compliance with RFP terms and are based on a
three run treatabiliry study . Analytical Costs could be decreased significantly by rationalizing
the testing program in consultation with North Carolina Department of Environment.
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 50
11.2 Cost Proposal for Phase TI
FOR:\1 OF PROPOSAL
The undersigned bidder proposes and agrees if this proposal is accepted to contract with the Department of
Environment, Health, and Natural Resources, Division of Waste Management to furnish the services required
herein, and to complete the scope of work as described in Pan II hereof. Services should be accomplished
in full and complete accordance with the specifications and contract documents to the full and entire satisfaction
of the Division of Waste Management, with a definite understanding that no money will be allowed for extra
work except as may be set forth in wrinen addendum to the contract, duly executed by all parties thereto.
The parties hereto agree that in consideration for performing all the requirements hereunder, DEHNR shall
pay the offerer as per the following cost proposal for the services as described herein, said sum to be full and
complete compensation for the offeror's services required herein.
Pursuant to the provisions of G .S. 143-54, and under penalty of perjury , the signer of this proposal certifies
that this proposal has nm been arrived at collusively nor otherwise in violation of Federal nor North Carolina
antitrust laws .
ELI Eco Logic International Inc.
Federal I. D. Number: NA
Typed Name : Ed Korhonen
Titk: Executive Vice President
Address: ELI Eco Logic International Inc.
143 Dennis Street,
Rockwood, Ontario NO • 2K0
Please indicate if one of the following applies: Women Owned/Controlled. ___ _
Minority Owned/Controlled __ _ Handicapped Owned/Controlled __
Submitted this 19 day of March 1997.
RFP #PCB LF-4
ECO LOGIC Proprietary Information Confidential
ECO LOGIC Treatment of Soil from Warren County, North Carolina Landfill Page 51
PHASE II COST PROPOSAL
All-inclusive price for 60 Percent Preliminary Design Drawings, Community Relations and Risk
Communication Strategies.
Total Price (US$) 115,700
ECO LOGIC Proprietary Information Confidential
SE\T BY:EPA 5-27-97 16:05 NAT'L CHEM PROG DIV-.
UNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 2 7 1997
·-' 2 ·11
OfFICEOf
PREVENTION, PESTICEES AND
Dr. WRyl.and Swain
Vice President
ELI Eco Logic International Inc.
2385 Huron Parkwa.y
Ann Arbor, MI 46104
Dear Dr. Swain:
TOXIC S4.ASST AHCES
Enclosed is the approval document for the R&D studies
entitled "Approval to Conduct. RP-search and Development Tests to
Dispose of Polychlorinated Biphenyls (PCBs), ELI Eco Logic
International Inc., (Eco Logic), Ann Arbor, Michigan, Removal of
PCBs from Soil." It grants approval to Eco Logic to conduct
research und development (R&D ) tes':s on their processes to remove
polychlorinated biphenyls (PCBs) from soils and other media
co~taining PCBs. The PCB disposal system to be demonstrated has
been described in the Eco Logic permit application (submitted in
March 5, 1997 ) a.ml subsequent submittals which were received at
EPA Headquarters.
The purposes of this ongoing R&D testing are: (1) to use the
Eco Logic process (process) to demonstrate the destruction of
PCBs from soils and other media; (2) to invcstig~te the
feasibility of t.hP. process at the commercial scale; and (3) to
identify any possible process defects prior to the scheduling of
a full-scale commercial demonstration.
All test reGulte and relateci information on this R&D project
shall be incorporated into a test report and submitted to the
Environmental Protection Agency (EPA) Headquarters' National
Program Chemicals Division (NPCD) for evaluation. The R&D test
report shuulJ include, at a minimum, the items listed in
Conditions of Approval numbers six ann seven in this enclosed
approval.
No wastes generated as a result of this ~tudy may be
transported off site except for disposal in accordance with the
reqllirements for the original concentration of PCBs in the feed .
SE\T BY :EPA 5-27-97 16 :05 ~AT'L CHE~ PROG DIV~
2
The effect i ve date for this approval is trom May 26, 1997 through
May 26, 1998 (~ee Condition 17).
Please direct matters concerning this subject to Winston Lue
of my staff on [phone].
Enclosure
cc:
Ed Cohen , PCB Coordinator
U.S. EPA, Region III
o W. Melone, Director
tional Program Chemicals Division
SE\T BY :EPA 5-27-97 16:06 :.\AT'L CHE.~ PROG DIV-
UNITED STATES ENVIRONMENTAL PROTECTTON AGENCY
Af PROV.P-_L TO CONDUCT RESEARCH AND DEVELOPMENT TESTS
TC DISPOSE OF POLYCHLORINATED BIPHENYLS (PCBS)
ELI ECO LOGIC INTERNATIONAL INCORPORATED
MTN ARBOR, MI 48104
REMOVAL OF PCBs FROM SOILS BY CHEMICAL REDUCTION
Authority
This approval to conduct research and development studies
R&D into PCB dispocal ic i~nucd pursuant to Section G(e) (1) of
the Toxic Substances Control Act (TSCA of 1976, Puhl :ir. T,aw No.
94-469, and the Federal PCB Regulations, 40 CFR, Section
761 .6 0(e), (48 Federal Register, 13181, March 30, 1983).
Bar kg round
ELI Eco Logic International Inc. (Eco Logic) submitted a
Research and uevelopment application and had tiled an RU) permit
appl ication with EPA headquarters on March 5, 1997 with
supplementary submission on April 14, 1997. The Eco Logic
process i nvolves gas phase reduction of organic compounds by
hydrogen at 85 0 C or higher. Polychlorinated biphenyls are
chemically reduced to methane and hydrogen chloride. The
hydroge11 chloride can be recovered as acid or neutr~lized in a
caustic scrubber downstream of the process reactor. In the
treatability scale unit, the components of the system include the
Thermal Reduction Mill, TRM, a gas-phase chemical reduction
react or, a two -stage gas scrubbing system, and a produc L gas
compression and storage system "-lith continuous emission
monitoring.
Proposed Tests
The purposes of this ongoing R&D testing arP.: (~) to use the
Eco Logic process (pr0cess) to destruction of PCBs from soils a nd
other media; {2) to investigate the feasibility of the process
at the commercial scale; and (3) Lo identify any possible process
defects prior to the scheduling of a full-scale commercial
demonstration.
The proposed tests will attempt to demonstrate the ability
of the ~co Logic process to reduce the PCB concentration: (1 ) in
soi l and sediment, liquids and other liquid to< 2 ppm .
The R&D project is classified into two phases of work fc~
chemical destruction as follows:
4 11
SE\T BY:EPA 5-27-97 16:06 l\AT'L OiEM PROG DIV-.
2
Phase 1 involves the determination of a range of process
variables on a larger scale to remove PCBs from soil, sediment,
and l.iqu.i<ls to less than 2 ppm.
Phase 2 involves the development of Eco Logic commP.rc.iaJ
process and the identification of any possible process defects
prior to the scheduling ot a tull-scale commercial demonstration
with EPA Headquarters.
EPA believes that when conducted in accordance with the
conditions of approval in this permit, these tests will not cause
an unreasonable risk to health or the environment by
inadvertently releasing PCBs into the environment.
Business Confidentiality
Pursuant to the 1:egulaLions at 40 CFR Part 2, Subpart B (4l
Federal Register, 36905, September 1, 1976, and 43 Fedcrul
ReqiAter, 39997, September 8, 19'78), Eco Logic is entitled to
assert a business confidentiality claim covering any information
Eco Logic submits under this R&.D approval. If such a
confidentiality claim is not asserted with any submission, EPA
may make this information available to the public without further
notice to Eco Logic. Information subject to a business
confidenciality claim may be made available to the public only to
the extent set forth in the above cited regulations. Any such
claim for confident.iallty mu:::;t conform to the requirements set
forth in 40 CFR §2.203(bl.
Liabilit;_y
The issuance of this R&D approval does not release Eco Logic
from any liability for damage to persons or property caused by or
resulting from the operation or maintenance of equipment covereo
by this approval. The conditions ot this approval are
enforceable under TOCA and its implementing regulations, 40 CFR
Part 761. k1y actions by Eco Logic which violate the terms and
conditions of this letter, TSCA, or the regulations may result in
administrative, civil, or criminal enforcement by EPA in
ctccorc.lance with Section 16 of TSCA, 15 U.S.C. §2615.
SE\T BY :EPA 5-27-97 16:06 \AT'L CHE~ PROG DIV~
3
Conditions of Approval
1. Advance Notificat.i.on: A 30-day advance written notice
of the proposed tests must be provided to the PCB Coordinator of
the appropriate EPA Region, and the State, and local officials
governing the site where the Eco Logic mobile test equipment is
located. These notices must include the dates and sites of
operation for Eco Logir.:'s process, along with an estima.L~ of the
length of testing. In additlon, r.hese notices must include
information pertaining to the type of process to be used, type of
material to be treated, amount ano concentration of material to
be treated, and information on how to contact responsible
parties. A sample form is enclosed. Copies of these letters
must be sent to the Chief, Fiber.sand Organic Branch of the
National Vrogram Chemicals Division, (7404) at EPA Headquarters
to be kept on file.
?. Agency Permits and Approvals: Prior to commencing the
tests, Eco Logic must obtain any necessary Federal, State or
local permits or approvals. During the course of the testing,
Bco Logic shall comply wi~h all conditions and requirements of
cuch permitG or u.pprovv.ls. Waste materials containing PCBs in
the concentration range o: approximately 200 ppm of PCBs or above
may also contain levels o: hexachlorobenzene at levels regulated
for dispos<1l under the Toxicity Characteristic Revisions (55
Federal Register, 11796, Mctrch 29, 1990 of the Resource
Conservation and Recovery Act (RCRA ) regulations.
3. Feedstock Quality and Rescrictions: The Eco Logic
process may be used to treat the tollowing:
Media m~an8 ~nn~aminated soils, sediments, paint coatings, PCB
oils, PCB soaked insulation and other bulk solid materials.
a. For chemical destruction:
Phase l -
1000 pounds of contaminated media with a maximum
concentration of 500,000 ppm.
Phase 2-
10 tons maximum of contaminutcd media with a maximum
concentration of 500,000 ppm.
A report. for the work on Phase 1 is required to be submitted
before the beginning oi Phase 2 to EPA.
4 . ProcPs~ WAS~P RPRtri c tions: All waste generated as a
result of this process must be disposed of as if it contained the
original concentration of PCBs as found in the feedstock. The
SE.\T BY :EPA 5-27-97 16:07 ~AT'L OiEM PROG DIV-
4
wastes produced by this process include, but are not limited to,
the processed wastes and solvents, any used filters and process
water employed in the sysLem.
5. Process Quality Control: All samples drawn must be in
accordance with Eco Logic's QAPP to the permit application dated
April 4, 1995. The final samples drawn at the end of the
decontamination process, to confirm that PCB concentraLlons is <2
ppm wi]l hR drAwn in duplicate.
6. Process Monitoring/Record.keeping: Provisions must be
made t.o assure that the following process elements are suitably
monitored and recorded for each run during these tests:
7.
a. amount and initial PCB concentration of
contaminated media;
b . final PCB concentration of the processed waste;
c. dale, time, and duration of each run;
d. the name of laboratory manager or project manager must
be written in each bound nn~~hnnk. Each project will
be contained in a single notebook;
e . final concentration of the dibenzofurans and
dibenzodioxins in the scrubber effluent (liquid .:md
particulate), scrubber product, treated solids, stack
exha~st and scrubbed product gas
R&D Test Report: All test results and related infonnalion
on this R&D project shall be incorporated into a test report
and submitted to National Program Chemical Division, NPCD
for evaluation. The R&D test report should include, at a
minimum, the following items:
a. Certification letter. This letter, signed by an
authorized official, must certify on behalf of the
applicant that the tests were carried out in accordanc~
wit.b the approved application and the results of all
determinations are submitted in the report. /\.ny
changes or deviations by the applicant from the
application must be documented and submitted in writing
t.o NPCD.
b. Detailed discussion of all process operations,
operational problems, if any, and corrective actions.
c. Chronology of significant events.
d. Quality assurance (QA ) report. This report should
address all the QA objectives, including whether or not
: :r: , 11
SE\T BY :EPA 5-27-97 16 :07 l'\AT'L CHE.~ PROG DIV_,
5
precision and accuracy objectives were met, as well as
results of quality control samples, performance audit
samples and systems audits.
e. Waste handling. Eco Loqic must provide documentation
(copies of manifest ar.d certificates of destruction} t o
show that all wastes gcnGrated during this R&D project
were properly disposed of according to the regulations
found in TSCA, the ResourcP. Conservation and Recovery
Act (RCRA), and the Clean Water Act (CWA). Eco Logic
should be aware that all waste generated during these
tests should be disposed of by incineration and not
landfilling, unless compliance with the landfill
restrictions can be demonstrated.
This intormation along with the information in Condition 6
and all other pertinent test data shall be incorporaLed into a
summary test report and submitted to EPA Headquarters before a
process demonstration test with Eco Logic starts. Phase 1 test
report shall be submitted to NPCD before Phase 2 is approved by
NPCD orally or in writing. Phase 2 test report shall be
E:llbmitted to NPCD before u process demonstration approval is
issued by NFCD.
8. PCB Releases: In the event Eco Logic believes, or has
reason to believe, thal a rc;lt;a.ise has or might have occur·red, the
facility operator must inform the Chief of Fibers and Organicc
Branch at 202-260-3933 and the uppropriate EPA Region PCB Region
coordinator immediately.
A written report describing the incident must be submitted
by the close of business on ~hp nPxt regular business day. No
PCB-contaminated waste may be processed in the facility until the
rel ease problem has been corrected to the satisfaction of EPA.
9 . Facility Incpection: EPA employees shall have access
to the Eco Logic process during the test runs for purposes of
inspection, observation, or sampling. This access is subject to
the normal safety requirements placed on Eco Logic personnel.
10. Safety and Health: Eco Logic must take all necessary
precautionary measures to ensure that the operation of the Eco
Logic process is in compliance with the applicable safety and
health standards, as required by Federal, State, and local
regulations and ordinances.
11. Facility Security: The Eco Logic process shall be
secured {e.g., tence, alarm system, etc.) at the test site to
restrict publ.i.c access to the area. Any personal injury
occurring as a result of the Eco Logic process must be reported
to the EPA PCB Coordinator by the next regular business day.
• .. 8 ' 11
SE\T BY:EPA 5-27-97 16:07 \AT'L OiE\1 PROG DIV~
6
12. PCB Soills: Any spills of PCBs or other fluids shall
be promptly controlled and cleaned up in accordance with the TSCA
PCB Spill Cleanup Policy and procedures (see 52 Federal Register,
10688, April 2, 1987). In addition, a written report describing
the spill, operations involved, and cleanup actions must be
submitted to EPA within five (5) business days.
PCB spills must be .r:eported in accordance with Lhe PCB spill
reporting requirements prescrihP.ci under Section 311 of the CWA
for discharges to navigable waters and under the Comprehensive
Environmental Response, Compensation, and Liability Act
(Superfund} for discharges to other media.
13. ~ersonnel Training: Eco Logic is responsible for
ensuring that personnel directly involved with handling PCB or
PCB-Contaminated material or using the Eco Logic process are
demonstrably familiar with the general requirements of this R&D
approval. At a minimum, this information includes:
a. the type of material which may be treated during
the testing of the Eco Logic process;
b. basic reporting and recordkeepjng requirements
under this R&D approval and Lhe location of records
at the test site;
c . notification requirementE; and
d. waste disposal requirements for process wastes
generated during the testing of the Eco Logic process.
Tn t.l1if1 regard, Eco Logic must maintain on-site, during the
testing of their destruction process, a copy of this R&D
approval, the spill prevention and cieanup plan, and the sampling
and analytical procedures used to determine J?CB concentrations in
the uced proceoG w~tcr.
14. PCB Transport Restrictions: All PCB material, and
other waste by-products may not be transported off-site except
for purposes of proper dls~o~al. PCB material transported off
the site for purposes of disposal must be in accordance with 40
CFR Section 761.40 and the DOT requirements of Title 49, CFR Part
172. Such requirements include placarding und labelling all
PCBs.
15. PCB Regulations Compliance: Eco Logic shall comply
with all applicable requiremento of the Federal PCB Regulations,
40 CFR, Section 761, in the operation of the Eco Logic
destruction process. Particular note should be given to:
a. 40 CFR, Section 761.60 -Disposal requirements;
• .. 9 • 11
S[\T BY:EPA 5-27-97 16:07 :_~AT 'L CHB1 PROG DJV-.
7
b. 40 CFR, Section 761.65 -Storage for disposal;
c. 4 0 CFR, Section 761.79 -Decontam.irn:1.tion; and
d. 40 CFR, Section 761 .180 -Records and monitoring.
e. 40 CFR, Section 761.202-218, Subpart K, PCB waste
dispos~l -Records and reports.
16. Process/Equipment Modifications: Any departure from
the conditions of this R&D approval or the terms expressed in the
ct.ppl.ic..:ct.tic.m 1:rnbmitted by Eco Logic must receive authorization
from EPA Headquarters. Verbal communications with EPA must be
followed within ten working days by a written notification from
Eco Logic describing a l l modificat ions. In this context,
"application and R&D plan" shal l be defined as all data and
materinls which have been received by this Agency from Ec.:u Lugi.c
regarding their decontamination and treatment process.
17. Permit Effective Dates: This R&D approval shall become
effective on May 26 , 1997, and shall expire on May 26, 1998.
Vnder the above conditions, and given the circumstanr.P-s .
under which the R&D tests will be conducted, EPA Headquarters'
Na t ional Program Chemical s Divi sio~ finds, pursuant to 40 CFR,
s~ction 761 .6 0(e ), that theBe test s wi ll not present an
unreasonable risk of injury to health or the environment.
This approval is val id when conducted within the Edgewood
Research Development, Engineeri ng Center (ERDEC) Toxic Test
Chamber Facilities, Aberdeen Proving Ground, Maryland. This
approval is a l s o valid when conducted at a laboratory facility
wh i ch o ffers the same standards of protection to human health a!1d
thE: e nvironment and anal ytical equipment as that of Eco Logi c.
Thi s approva l is va l id only when the process is operated by ~co
Logic personnel and/or ERDEC personne l .
Approval to conduct R&D testing into decontamination and
treat ment of PCB-contami nated waste is hereby granted to ELI Eco
Logic InternaLiunct.l Inc., of Ali.fl ArboL·, Michigan, subj~ct to Lh e
conditions expressed herein, and consistent with the materials
and data included in the Eco Logic application.
n W. Melone, Director
ational Program Chemicals Divi sion
SE\T BY:EPA 5-27-97 16:08 l'\AT'L OiEM PROG DIV~
8
Sample Form
THIRTY DAY NOTIFICATION OF INTENT TO DISPOSE OF PCBs
Company Name
Person and Phone Number for:
EPA Regional Contact
State Contact (including organization application)
Local (Town/City/County) Contact (include organization
application)
Nature of the Disposal Activity
Please indicate:
.Kind of Process:
(1) Incineration, (2) Other Thermal, (3) ChemicaJ.
Dechlorination, (4) Other (describe)
Kim.i:s of Material to be Treated:
Location
(1) Soils, (2) Aqueous and nonaqueous waste
streams, (3) Liquids from decontamination
operations (4) Other Fluids (describe sou.reel, (5)
Other Solid Materials {describe source)
Street Address or Other Identifier for All Sites:
Telephone Contact and Address for Site Manager:
Time of Processing
Date(s):
Time (s) :
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