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HomeMy WebLinkAboutWI0800038_Other Correspondence_20031028North Carolina Department of Health and Human Services Division of Public Health • Epidemiology Section 1912 Mail Service Center • Raleigh, North Carolina 27699-1912 Tel 919-733-3410 • Fax 919-733-9555 Michael F. Easley, Governor October 28, 2003 MEMORANDUM TO: Evan Kane Groundwater Section FROM: Luanne K. Williams, Pharm.D., Toxicologist (A. Carmen Hooker Odot,Secreta , W G GI m ..- •i crn W o O -10 "co rno � �rn iV rr*t:i J o Medical Evaluation and Risk Assessment Unit Occupational and Environmental Epidemiology Branch North Carolina Department of Health and Human Services SUBJECT: Use of Hydrogen and Helium for Bioremediatioin of Chlorinated Solvent Contaminated Groundwater at the Maintenance Complex for Amphibious Vehicles at Camp Lejeune Marine Corps Base in Camp Lejeune, North Carolina. I am writing in response to a request for a health risk evaluation regarding the use of hydrogen and helium for bioremediatioin of chlorinated solvent contaminated groundwater at the maintenance complex for amphibious vehicles at Camp Lejeune Marine Corps Base in Camp Lejeune, North Carolina. Based upon my review of the information submitted, I offer the following health risk evaluation: WORKER PRECAUTIONS DURING APPLICATION 1. Some effects reported to be associated with the chemicals present in the product following short-term exposure are as follows: • Skin contact with helium or hydrogen can cause severe burns and frostbite to the skin (Hazardous Substance Fact Sheet by Micromedex TOMEs Plus System CD-ROM Database, Volume 58, 2003). • Significant inhalation exposure to helium or hydrogen can cause suffocation from lack of oxygen. Symptoms include dizziness, weakness, nausea, vomiting, loss of coordination and judgment, increased breathing rate, and loss of consciousnes and death (Hazardous Substance Fact Sheet by Micromedex TOMEs Plus System CD-ROM Database, Volume 58, 2003). 2. Hydrogen is a highly flammable liquid or gas and a dangerous fire and explosion hazard. Hydrogen must be stored to avoid contact with heat, flames, sparks, 1 of 3 () Location: 2728 Capital Boulevard • Parker Lincoln Building • Raleigh, N.C. 27604 An Equal Opportunity Employer oxidizing agents (e.g., perchlorates, peroxides, permanganates, chlorates, nitrates, and bromine), explosives, liquid nitrogen, ozone, palladium, catalysts, lithium, strontium, barium, and calcium since violent explosions may occur (Hazardous Substances Data Bank by Micromedex TOMEs Plus System CD-ROM Database, Volume 58, 2003). 3. In order to reduce the risk of injury, certain precautions should be followed when applying the product: (a) If the product is released into the environment in a way that should result in a suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous shaking or mixing, or opening of a container where the internal pressure may be different from ambient pressure), then proper respiratory protection should be worn. The application process should be reviewed by an industrial hygienist to ensure that the most appropriate respiratory equipment is worn if needed. (b) Persons working with this product should wear goggles or a face shield, gloves, and protective clothing. In order to prevent contamination of the worker's home and other work areas, the gloves and protective clothing should only be worn in the application area and should never be taken home. (c) Eating, drinking, smoking, handling contact lenses, and applying cosmetics should not be permitted in the application area during or immediately following application. (d) Workers should wash their hands after applying the product. 4. Safety controls should be in place to ensure that the check valve and the pressure delivery systems are working properly. 5. The Material Safety Data Sheets should be followed to prevent adverse reactions and injuries. OTHER PRECAUTIONS 1. Access to the area of application should be limited to the workers applying the product. In order to minimize exposure to unprotected individuals, measures should be taken to prevent access to the area of application. 2. Because of the toxicity associated with the chemicals listed in this product, measures should be taken to prevent contamination to groundwater or surface water beyond the injection or remediation area. 2 of 3 3. In order to minimize risk to the residents that may live near the application area, measures should be taken to limit access to the area of application to workers applying the product. In addition, measures should be taken to prevent the product from being dispersed in the air or released on the ground outside the application area. Please do not hesitate to call me if you have any questions at (919)715-6429. LW:pw cc: Randy McElveen, NC Groundwater Section Mr. Rick Raines, IR Program Director Camp Lejeune, Commanding General PCS-EMD Building 58, PSC Box 20004, Marine Corps Base Camp Lejeune, NC 28542-004 Mr. Richard E. Bonelli Michael Baker Jr., Inc., Airside Business Park, 100 Airside Drive Moon Township, PA 15108 3 of 3 INFORMATION NEEDED TO DO RISK ASSESSMENTS FOR PRODUCTS APPLIED TO GROUNDWATER OR SOIL CONTAINING NO MICROORGANISMS SEND TWO COPIES TO: UIC PROGRAM GROUNDWATER SECTION NORTH CAROLINA DENR-DWQ 1636 MAIL SERVICE CENTER RALEIGH, NC 27699-1636 TELEPHONE (919) 715-6165 Note: Please provide direct responses to each of the following items, rather than "see attachment", etc. Required General Information 1. Department of Environment and Natural Resources Groundwater Section contact person and phone number. Response: Mr. Randy McElveen 919-733-2801 2. Current or future use of site with site contact person, address, and phone number. Response: Current/future site use: Maintenance complex for amphibious vehicles, Camp Lejeune Contact Person: Mr. Rick Raines, IR Program Director, Camp Lejeune, Commanding General PCS-EMD, Building 58, PSC Box 20004, Marine Corps Base, Camp Lejeune, NC 28542-0004, (910) 451-5068 3. Contractor applying product, contact person, address, and phone number. Response: Contractor: Michael Baker Jr., Inc. Contact Person: Mr. Richard E. Bonelli, Airside Business Park, 100 Airside Drive, Moon Township, PA 15108, (412) 269-2033 4. Distance and likelihood of impact to public or private wells used for drinking, industrial processes, cooling, agriculture, etc. Is area served by public water supply? Verification must be provided by the appropriate Regional Offices of the Groundwater Section and Public Water Supply Section. G W/UIC-3 Response: Distance to nearest Base water supply well: 2 active wells are roughly 1 mile from the site Likelihood of impact: None, given the distance to the wells. 5. General description of the contaminants if present in the soil and/or groundwater at the site. Response: Groundwater is impacted by various chlorinated compounds, including TCE, 1,2-cis-DCE, 1,2-trans-DCE, and vinyl chloride. 6. Name, approximate distance, and likelihood of impact to the nearest body of surface water to the site. Response: Name: Courthouse Bay (part of the New River) Distance: 500 feet Likelihood of impact: None, due to the low groundwater velocity in the area to the bay. 7. Approximate distance to nearest residence(s) and workplace. Distance: Site is within an active industrial compound on a military installation. Required Product/Process-Specific Information 1. Product manufacturer name, address, phone number, and contact person. Response: Product names: Hydrogen (to be sparged as a substrate); helium (to be injected as a tracer) Manufactures/supplier: National Welders Supply Company, Jacksonville, NC 910-353- 9291 2. Identity of specific ingredients (including CAS#) and concentrations of ingredients contained in the product and purpose of each. Response: Ingredients: Hydrogen: CAS #1333-74-0, 80% per volume, sparge gas Helium: CAS # 7440-59-7, 20% per volume, tracer gas GW/UIC-3 3. Approximate concentration of each ingredient following release into groundwater or soil. Response: Hydrogen: 0.5 mg/L (estimated) Helium: 1 mg/L (estimated) INFORMATION NEEDED TO DO RISK ASSESSMENTS FOR PRODUCTS APPLIED TO GROUNDWATER OR SOIL CONTAINING NO MICROORGANISMS Page 2 Approximate distance and direction of travel for product in groundwater, the groundwater concentration of each ingredient at this distance, and distance from this point to the nearest drinking water source (that is currently used for drinking purposes). These should be reasonably accurate estimates based on the best available information and calculations (modeling, if necessary) regarding aquifer characteristics and flowpaths at the site; where uncertainty exists in critical aquifer parameters (e.g. effective porosity), conservative assumptions should be made in estimating these values so that worst -case predictions of travel distances are made. Response: Based on the design prepared, the zone of influence will triangular, and extend up from the injection well (depth of 70 feet below ground surface) a distance of approximately 40 feet and extend outward 40 feet in each direction perpendicular to the injection. This equates to a zone of influence of approximately 1,600 square feet. 5. Approximate groundwater concentration of each ingredient after pumping or recovery (if applicable). Response: Not applicable 6. If the product is expected to discharge to a nearby surface water, approximate concentrations of product in the water. Response: Not applicable. The product is not expected to discharge to any nearby waterways. GW/UIC-3 7. Documentation from authoritative technical references of specific degradation products expected. Response: No degradation products are anticipated with the products. 8. Documentation from authoritative technical references of expected migratory potential of specific ingredients and degradation products in soil and groundwater. Response: The products are not anticipated to migrate or generate any degradation products that would impact soil or groundwater. 9. Complete description of the use of the product at the site. Response: (taken from the design specifications) Hydrogen is now widely recognized as a key electron donor required for the biologically -mediated dechlorination of chlorinated compounds. Hydrogen acts as an electron donor, and halogenated compounds such as chlorinated solvents act as electron acceptors that are reduced in the reductive dechlorination process. To enhance beneficial anaerobic processes for the purpose of bioremediation, numerous research groups have focused on methods to increase the supply of electron donor to the dechlorinating bacteria. Most researchers and technology developers have focused on adding an indirect electron donor (such as lactate, molasses, mulch, edible oil, or other carbon source) that is fermented by one type of bacteria to produce hydrogen for the dechlorinators. Direct hydrogen addition simply eliminates the rate -limiting step (i.e., fermentation), by providing naturally -occurring dechlorinating bacteria with substantive quantities of hydrogen, the key growth substrate (Hughes et al., 1997; Newell et al. 1998; Newell et al., 2000, Newell et al., 2001). Direct delivery methods that have been proposed include circulation of groundwater containing dissolved hydrogen, placement of chemical agents that release dissolved hydrogen, electrolysis of water with subsurface electrodes, use of colloidal gas aphrons (foams), and low -volume pulsed biosparging (Hughes et al., 1997). Because of its simplicity and low-cost, AFCEE funded an 18- month long field trial of low -volume pulsed biosparging of hydrogen gas in the subsurface. With this approach, small volumes of hydrogen gas from cylinders were sparged directly into the contaminated zone in short intervals. In this case the sparge interval was approximately one 20 minute pulse once a week for most of the test. Small volumes are used to ensure that breakthrough to the surface will not present safety problems. The hydrogen is pulsed to allow effective dissolution of the trapped gas, thereby transferring the residual hydrogen gas to the aqueous phase. Results from an eighteen -month low -volume pulsed hydrogen biosparging pilot test at Cape Canaveral Air Station Florida showed extensive biological dechlorination in a 30 x 30 ft (9.1 m x 9.1 m) zone located 15 to 20 ft (4.6 to 6 m) below the water table in a sandy aquifer. The test zone was in or very near a DNAPL source zone, as chlorinated ethene concentrations were very high (-300 mg/L). Hydrogen gas was pulsed into three sparge points at regular intervals (weekly for most of GW/UIC-3 the test) to form residual hydrogen gas bubbles, which then dissolved to deliver electron donor directly to the test zone. Significant concentration reductions were observed, both on a percentage basis and on an absolute basis. Removals in wells close to the sparge point were more than 90%, and in downgradient wells there was an approximately 50% reduction in contaminant concentration. More mass reduction was also observed in the test zone than the two controls, although interpretation is difficult as some of this removal may have been due to: 1) unintended hydrogen transport into the groundwater near the control wells; and 2) natural changes in the plume. DESIGN PARAMETERS Based on previous hydrogen biosparging projects, the conceptual design of a hydrogen biosparging system includes the determination of the following five key parameters: i) sparge volume, ii) injection pressure, iii) gas flow rate, iv) sparge time, and v) sparge frequency. Additionally, a method of measuring gas distribution and consumption (i.e. tracer gas injection) in the subsurface should be selected and monitoring frequency determined. Sparge Volume Sparge volume refers to the volume of gas injected through the well and into the subsurface during each sparging event. A conceptual model of the sparge volume resulting from hydrogen injection into a horizontal well is illustrated in Figure 1. Figure 1. Sparge Volume Conceptual Model The sparge volume (V) is calculated via the following equation: V(ft)=ZIxLxnxSg where, ZI = zone of gas influence (ft) L = length of screen (ft) n = porosity (unitless) Sg = gas saturation (unitless) For the Camp Lejeune site, the length of screen, L, is 400 ft. and the porosity, n, is estimated as 0.3. The other parameters, ZI and Sg, must be estimated based on experience and literature reports. In previous vertical well injection systems, a zone of influence of approximately 10-15 ft in the horizontal direction has typically been achieved (Newell et al. 2001). In a system similar to that GW/UIC-3 proposed at Camp Lejeune, a horizontal well achieved methane delivery up to 100 ft. from the well (USDOE 1995). As a conservative estimate, it is assumed that the zone of influence at Camp Lejeune will be triangular (as depicted above in Figure 1), and extend up from the injection well a distance of approximately 40 feet and extend outward 40 feet in each direction perpendicular to the injection well. This equates to a zone of influence of approximately 1600 ft2. The gas saturation is defined as the ratio of gas remaining in the system to total gas added. Gas saturations achieved in the field are site -specific and variable depending on factors such as subsurface heterogeneities, distance from sparge point, and formation of preferential flowpaths. Previous studies have shown that hydrogen gas saturations are typically <0.5-2% up to 24 hours following the sparge (GSI 2003). It is conservatively assumed that a gas saturation range of 0.5% to 1 % will be achieved at Camp Lejeune. Since all parameters are known or have been estimated, the sparge volume for the Camp Lejeune pilot test can be calculated. The result is a sparge volume in the range of approximately 1000 standard cubic feet (scf) to 2000 scf. For this application, the volume of the well is significant and therefore should also be considered in calculating the sparge volume. The proposed well has an open length of 900 feet and a 4-inch diameter. This equates to a well volume of approximately 78.5 cubic feet. Adjusting the sparge volume for the volume of the well, the new hydrogen volume required is about 1100 scf to 2100 scf. Finally, the sparge volume must be corrected for the effect of hydrostatic pressure. Assuming a water column of approximately 70 feet above the well, the hydrostatic pressure is about 2.1 atm. The gas volume under this pressure is calculated using the following form of the Ideal Gas law: PIVI = P2V2 where, PI = hydrostatic pressure (2.1 atm) VI = volume of hydrogen required at 2.1 atm (1100 to 2100 scf) P2 = atmospheric pressure (1 atm) V2 = volume of hydrogen at 1 atm to achieve required volume at 2.1 atm This relationship implies a given volume of gas at atmospheric pressure will be 2.1 times its volume under hydrostatic pressure of 2.1 atm. Therefore, the resulting sparge volume required to achieve delivery of 1100 scf to 2100 scf under the given hydrostatic pressure is calculated to range from approximately 2300 scf to 4400 scf. Readily available cylinder packs contain approximately 2600 scf of hydrogen gas; therefore, the recommended sparge volume for the Camp Lejeune site is 2600 scf. Injection Pressure The pressure at which hydrogen is injected into the subsurface must be maintained above that needed to induce gas flow into the subsurface (Pmin), and below the pressure resulting in fracturing of the formation (l max)• These values are a function of the well depth and permeability of the formation (Leeson et al. 2002). Pmin is calculated as the sum of the hydrostatic pressure, the gas entry pressure for the well annulus packing material, and the gas entry pressure for the formation. The gas entry pressure for the packing material and the formation are typically less than 0.4 psig (for sands and silts), and are GW/UIC-3 negligible compared to the hydrostatic pressure (Leeson et al. 2002). Therefore, the Pmin calculation reduces to the following formula: Pmin (psig) = 0.43 H where, H = depth below water table of screen (ft), and the factor, 0.43, represents the hydrostatic pressure in psig of 1 foot of water. From this equation, the minimum pressure required to induce hydrogen flow, given the proposed well depth of 75 feet and groundwater occurrence of 5 feet (H = 70 feet), is calculated as 30.1 psig. Injection pressure should remain below the overburden pressure, or Pmax, to avoid fracturing the formation around the well. Overburden pressure is defined as the sum of the pressure of the soil column and the pressure of the water column (USACE 1997). The pressure of the water column was calculated above as Pmin. The pressure of the soil column, Psni,, is calculated via the following equation (Sowers and Sowers 1970): Psai1= Pb D where, pb is the soil bulk density and D is the depth below ground surface of the screen. If a soil bulk density of 105 lb/ft3 is assumed (NFESC 2001), then Pmax in units of psig can be calculated by dividing the soil bulk density by 144 in2/ft2 to obtain a factor (0.73) for psig per foot of soil column. Therefore, the formula for Pmax reduces as follows (USACE 1997; Battelle 1998): Pmax = Psoil + Pwater where, Pwater = Pmin, and substitute equation above for Psoil, Pmax = Pb D + Pmin then, substitute conversion factors discussed above to calculate Pmax in psig, Pmax (psig) = 0.73 D + 0.43 H The horizontal well is to be installed to a depth of approximately 75 ft below ground surface resulting in a Pawl of 55 psig and a Pmax of approximately 85 psig (55 psig + 30.1 psig). The USACE In -Situ Air Sparging Engineering and Design manual (1997) recommends the actual Pmax should be between 60 and 80 percent of the calculated Pmax (i.e. safety factor of 20 to 40 percent). For the Camp Lejeune sparging system, a safety factor of 30 percent is recommended, resulting in an actual Pmax of 60 psig. Given the current knowledge of the Camp Lejeune site and the preliminary well design (HWEC 2003), the estimated injection pressure for the hydrogen sparge system should be in the approximate range of 31 psig to 60 psig. Gas Flow Rate Proper gas flow rate is important to ensure that gas distribution is maximized without generating pressures that may lead to fracturing of the formation. There are few references of flow rates specific to horizontal wells; however, typical ranges for flow rates used in vertical wells typically range from <5 scfm to 40 scfm with typical screen intervals of 2 to 10 feet in length (USACE 1997, NFESC 2001). GW/UIC-3 In a successful demonstration of air sparging through a horizontal well, USDOE (1995) reported a gas flow rate of 200 scfm air through a horizontal well installed at a total depth of 175 feet below ground surface and 55 feet below the water table. The screen length for this well was 310 feet, corresponding to 0.65 scfm per foot of horizontal well. This well achieved gas delivery up to 100 feet from the well based on electrical resistance tomography measurements. The flow rate used in the USDOE study is consistent with a typical flow rate of 1 scfm per foot of horizontal well reported by a horizontal well driller with air sparging experience (Wilson 2003). The Camp Lejeune well has a proposed screen length of 400 feet. Using the normalized flow rate referenced above (0.65 scfm per ft horizontal well), a gas flow rate of approximately 260 scfm air is proposed for the Camp Lejeune hydrogen sparge system. Since hydrogen is less dense than air, the equivalent hydrogen flow rate for 260 scfm of air must be calculated. The relationship between gas flow rates and densities for two different gases is expressed by the following equation (Felder and Rousseau 1986; Enardo 2003): QH2 Q air v pair _ y MWair V PH2 V MWH, where, Q = volumetric flow rate for respective gas p = density of respective gas (air = 1.29 g/L; H2 = 0.09) MW = molecular weight of respective gas (air = 29 g/mol; H2 = 2 g/mol) From this relationship, the volumetric flow rate of hydrogen is 3.8 times greater than the equivalent air flow rate. Therefore, a gas flow rate of 260 scfm air is equivalent to 1000 scfm hydrogen. Sparge Time The time required to deliver the desired volume of hydrogen with the flow rate proposed above is simply calculated as the volume divided by the flow rate. Using the values proposed above (2600 scf volume H2 / 1000 scfm flow rate), this corresponds to a sparge interval of approximately 2.6 minutes. Sparge Frequency Previous experience has shown that a sparge frequency of once per week is adequate initially (GSI 2003). However, as biomass throughout the system increases, hydrogen consumption also increases and the frequency of sparging may need to be increased to compensate. A determination of whether sparge frequency should be increased to twice per week will be made based on data from a tracer gas study. The tracer gas study will be performed 6 months into the pilot -test, and daily hydrogen and helium measurements following tracer gas injection will be used to evaluate hydrogen consumption and lifetime. TRACER GAS GW/UIC-3 Helium is used as a tracer gas to determine the distribution and consumption of hydrogen gas. Helium will be introduced into the hydrogen stream twice during the project at a final concentration of 0.1%. The initial tracer gas study will be conducted after two weeks of operation and the second study will be conducted after 6 months of operation. For the tracer gas injection, one cylinder (of twelve) will contain a custom H2/He mixture at a He concentration of 1.2% (remainder hydrogen). The remaining eleven cylinders will contain the standard high purity hydrogen (99.995%). The gases will enter a manifold, where they will mix, and the gas will enter the well at a H2/He concentration of 99.9%/0.1%. A sample port in the delivery piping will allow the exact H2/He concentrations to be measured via a Summa® canister. Immediately following tracer gas injection, the groundwater in all nearby wells is to be sampled for hydrogen and helium via the bubble strip sampling method to determine hydrogen distribution. The bubble strip sampler, manufactured by Microseeps, has a glass cell with an air bubble through which groundwater flows until equilibrium is attained and hydrogen and He have partitioned to the air bubble. A sample from the air bubble is then withdrawn and placed in an air -tight serum vial, containing an internal standard, for analysis via a gas chromatograph equipped with an electron capture detector by Consolidated Sciences (Houston, TX). Typical detection limits for hydrogen and He are 1 ppm and 10-20 ppb, respectively. Groundwater samples from approximately three wells in the vicinity of the injection well are collected daily (for 4 to 5 days) following the tracer gas injection for hydrogen and He analysis to determine hydrogen consumption rates. Key Conceptual Design Parameters Sparge Volume = 2300 to 4400 scf (estimate 2600) Injection Pressure = 31 to 60 psig Gas Flow Rate = 1000 scfm H2 Sparge Time = 2.6 minutes Sparge Frequency = 1 per week Tracer Gas = He (0.1%) injection at 2 weeks and 6 months REFERENCES Battelle, 1998. "Air Sparging for Site Remediation" Presentation, p. 58 of 97, http://enviro.nfesc.navy.mil/erb/erb_a/restoration/technologies/remed/phys_chem/pres_air- sparge.pdf Enardo, 2003. Company website, "Vapor Flow to Equivalent Air Flow Conversion Equations", http://www.enardo.com/Conversions.asp Felder, R.M. and Rousseau, R.W., 1986. Elementary Principles of Chemical Processes, 2nd Edition, John Wiley & Sons, Inc., New York. GSI, 2003. "Low Volume Pulse Hydrogen Biosparging 2002 Annual Report", Groundwater Services, Inc., Houston, TX. Hughes, J., C. J. Newell, and R.T. Fisher, 1997. "Process for In -Situ Biodegradation of Chlorinated Aliphatic Hydrocarbons By Subsurface Hydrogen Injection," U.S. Patent No. 5602296, 2/14/97. GW/UIC-3 HWEC, 2003. "Horizontal Air Sparging Well Perforation Design" (Draft), Horizontal Well and Environmental Consultants, LLC, Arvada, CO. Leeson, A., Johnson, P.C., Johnson R.L., Vogel, C.M., Hinchee, R.E., Marley, M., Peargin, T., Bruce, C.L., Amerson, I.L., Coonfare, C.T., Gillespie, R.D., and McWhorter, D.B., 2002. Air Sparging Design Paradigm, Battelle, Columbus, OH. Newell, C.J., J.S. Hughes, R.T. Fisher, and P.E. Haas, 1998. "Subsurface Hydrogen Addition for the In -Situ Bioremediation of Chlorinated Solvents," in Designing and Applying Treatment Technologies, First International Conference on Remediation of Chlorinated and Recalcitrant Compounds Conference, G. B. Wickramanayake and R. Hinchee, eds., May 21-28,1998, Battelle Press, Columbus, Ohio, pp. 47-52. Newell, C.J., P.E. Haas, J. B. Hughes, and T.A. Khan, 2000. "Results From Two Direct Hydrogen Delivery Field Tests For Enhanced Dechlorination," in Bioremediation and Phytoremediation of Chlorinated and Recalcitrant Compounds, G. B. Wickramanayake, A. R. Gavaskar, B.C. Alleman, and V.S. Magar, eds., The Second International Conference on Remediation of Chlorinated and Recalcitrant Compounds Conference, Monterey, California, May 22-25, 2000, Battelle Press, Columbus, Ohio, pg. 21-38. Newell, C.J., C.E. Aziz, P.E. Haas, J. B. Hughes, and T.A. Khan, 2001. Two Novel Methods for Enhancing Source Zone Bioremediation: Direct Hydrogen Addition and Electron Acceptor Diversion, Anaerobic Degradation of Chlorinated Solvents, pg. 19-26, In: Anaerobic Degradation of Chlorinated Solvents, V. Magar, D. Fennell, J. Morse, B. Alleman, and A. Leason, eds., In Situ and On -Site Bioremediation: The Sixth International Symposium, Battelle Press, Columbus, Ohio. Sowers, G.B., and Sowers, G.F., 1970. Introductory Soil Mechanics and Foundations, 3rd Edition, Macmillan Publishing Co., Inc., New York. NFESC, 2001. Air Sparging Guidance Document, Technical Report TR-2193-ENV, Naval Facilities Engineering Service Center, Port Hueneme, CA. USACE, 1997. In -Situ Air Sparging Engineering and Design Manual, EM1110-1-4005, US Army Corps of Engineers, Hyattsville, MD. USDOE, 1995. In Situ Bioremediation Using Horizontal Wells, Innovative Technology Summary Report, US Department of Energy Office of Environmental Management Office of Technology Development. Wilson, David, 2003. Personal communication, July, 11, 2003. The risk assessment will be forwarded to the designated contact person for the site, consultant applying the product, and Groundwater Section contact person. GW/UIC-3