United States 

Environmental Protection 

Agency 

Xpert Design and 

Diagnostics' (XDD) In Situ 

Chemical Oxidation Process 

Using Potassium 

Permanganate (KMnO4) 

Innovative Technology 

Evaluation Report 
EPA/540/R-07/005 

May 2007

 Xpert Design and


Diagnostics’ (XDD)


In Situ Chemical Oxidation


Process Using Potassium


Permanganate (KMnO )
 4

Innovative Technology Evaluation Report


National Risk Management Research Laboratory


Office of Research and Development


U.S. Environmental Protection Agency


Cincinnati, Ohio 45268

Notice 

The information in this document has been funded by the U.S. Environmental Protection Agency 

(USEPA) under Contract Number 68-C-00-179 to Science Applications International Corporation 

(SAIC). It has been subjected to the Agency’s peer and administrative reviews and has been 

approved for publication as an EPA document. Mention of trade names or commercial products does 

not constitute an endorsement or recommendation for use. 

ii 
Foreword 

The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation’s land, 

air, and water resources. Under a mandate of national environmental laws, the Agency strives to 

formulate and implement actions leading to a compatible balance between human activities and the 

ability of natural systems to support and nurture life. To meet this mandate, EPA’s research program 

is providing data and technical support for solving environmental problems today and building a 

science knowledge base necessary to manage our ecological resources wisely, understand how 

pollutants affect our health, and prevent or reduce environmental risks in the future. 

The National Risk Management Research Laboratory (NRMRL) is the Agency’s center for 

investigation of technological and management approaches for preventing and reducing risks from 

pollution that threatens human health and the environment. The focus of the Laboratory’s research 

program is on methods and their cost-effectiveness for prevention and control of pollution to air, land, 

water, and subsurface resources; protection of water quality in public water systems; remediation of 

contaminated sites, sediments and ground water; prevention and control of indoor air pollution; and 

restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster 

technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL’s 

research provides solutions to environmental problems by: developing and promoting technologies 

that protect and improve the environment; advancing scientific and engineering information to support 

regulatory and policy decisions; and providing the technical support and information transfer to ensure 

implementation of environmental regulations and strategies at the national, state, and community 

levels. 

This publication has been produced as part of the Laboratory’s strategic long-term research plan. 

It is published and made available by EPA’s Office of Research and Development to assist the user 

community and to link researchers with their clients. 

Sally C. Gutierrez, Director

National Risk Management Research Laboratory 

iii 
Abstract 

Xpert Design and Diagnostic's (XDD)potassium permanganate in situ chemical oxidation (ISCO) 

process was evaluated under the EPA Superfund Innovative Technology Evaluation (SITE) Program 

at the former MEC Building site located in Hudson, New Hampshire. At this site, both soil and 

groundwater are contaminated with chlorinated volatile organic compounds (VOCs). The VOCs are 

primarily perchloroethylene (PCE), trichloroethylene (TCE), and cis-1,2-dichloroethylene, (cDCE). 

Three saturated stratigraphic zones, occurring between 6 and 25 feet (1.8 to 7.6 m) below land 2 2 surface (bls) and within an approximate 1,200 ft (111.5 m ) area, were targeted for ISCO treatment.

Little [320 lb (145 kg)] potassium permanganate was able to be injected into the shallow, gravelly 

sandy zone, whereas 1,500 lbs (680 kg) and 1860 lbs (845 kg) were injected into the intermediate 

peat and deep, silty sand layers, respectively. The average soil concentrations of PCE decreased 

by 96 percent and 88.5 percent, in the peat and deep layers, respectively. The average soil TCE 

concentrations decreased by 92 and 98 percent, in the peat and deep layers, respectively. However, 

cDCE exhibited a no change (+1 percent) and strong increase (+2,570 percent) in the peat and deep 

layers. The average final ground water concentrations were 746, 612, and 3,090 :g/L PCE, TCE and 

cDCE, respectively, which were below the site specific remediation performance standards of 750, 

5,500, 17,500 :g/L. No chlorinated ethylenes were measurable in samples with visible potassium 

permanganate but potassium permanganate was not evenly injected into the target formation. 

iv 
Contents 

Notice ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . ii


Foreword ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . iii


Abstract ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. iv


Tables ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . viii


Figures ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ix


Abbreviations and Acronyms ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. x


Acknowledgments ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... xiii


Executive Summary ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . ES-1


1.0 Introduction ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 1


1.1 Background ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 1


1.2 Brief Description of the SITE Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4


1.3 The SITE Demonstration Program and Reports . . . . . . . . . . . . . . . . . . . . . . . . . 4


1.4 Purpose of the Innovative Technology Evaluation Report (ITER) . . . . . . . . . . . . 4


1.5 Technology Description ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 5


1.6 Key Contacts ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 5


2.0 Technology Applications Analysis ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 6


2.1 Key Features of the XDD ISCO Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6


2.1.1 Oxidant ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 6


2.1.2 Portable Oxidant Delivery System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7


2.1.3 Oxidant Injection Points ... ... ... ... ... ... ... ... ... ... ... ... .. 7


2.1.4 Monitoring Wells ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 9


2.2 Operability of the Technology ... ... ... ... ... ... ... ... ... ... ... ... ... 10


2.3 Applicable Wastes ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 11


2.4 Availability and Transportability of Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . 11


2.5 Materials Handling Requirements ... ... ... ... ... ... ... ... ... ... ... .. 11


2.6 Site Support Requirements ... ... ... ... ... ... ... ... ... ... ... ... ... . 11


2.7 Limitations of the Technology ... ... ... ... ... ... ... ... ... ... ... ... ... 12


2.8 ARARS for XDD’s ISCO Process ... ... ... ... ... ... ... ... ... ... ... ... 12


2.8.1 CERCLA ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 14


2.8.2 RCRA ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 14


2.8.3 CAA ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 15


2.8.4 CW A ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 15


2.8.5 SDWA ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 15


2.8.6 OSHA ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 15


2.8.7 State and Local Requirements ... ... ... ... ... ... ... ... ... ... . 16


v 
Contents (Cont’d) 

3.0 Economic Analysis ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 17


3.1 Introduction ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 17


3.2 Conclusions ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 20


3.3 Factors Affecting Estimated Cost ... ... ... ... ... ... ... ... ... ... ... ... 20


3.4 Issues and Assumptions ... ... ... ... ... ... ... ... ... ... ... ... ... ... 20


3.4.1 Site Characteristics ... ... ... ... ... ... ... ... ... ... ... ... ... . 20


3.4.2 Design and Performance Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21


3.4.3 Financial Assumptions ... ... ... ... ... ... ... ... ... ... ... ... . 21


3.5 Basis for Economic Analysis ... ... ... ... ... ... ... ... ... ... ... ... ... 21


3.5.1 Site Preparation ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 21


3.5.2 Permitting and Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . 22


3.5.3 Capital Equipment ... ... ... ... ... ... ... ... ... ... ... ... ... .. 22


3.5.4 Startup and Fixed Costs ... ... ... ... ... ... ... ... ... ... ... ... 23


3.5.5 Labor ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 24


3.5.6 Consumables and Supplies ... ... ... ... ... ... ... ... ... ... ... 26


3.5.7 Utilities ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 28


3.5.8 Effluent Treatment and Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28


3.5.9 Residuals Shipping and Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28


3.5.10 Analytical Services ... ... ... ... ... ... ... ... ... ... ... ... ... . 29


3.5.11 Maintenance and Modifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29


3.5.12 Site Restoration ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 29


4.0 Technology Effectiveness ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 30


4.1 Introduction ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 30


4.1.1 Project Background ... ... ... ... ... ... ... ... ... ... ... ... ... . 30


4.1.2 Project Objectives ... ... ... ... ... ... ... ... ... ... ... ... ... .. 30


4.2 Site Description ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 33


4.2.1 Site Location and History ... ... ... ... ... ... ... ... ... ... ... .. 33


4.2.2 Site Lithology and Hydrogeology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33


4.3 Pre-Demonstration Activities ... ... ... ... ... ... ... ... ... ... ... ... ... 35


4.3.1 Preliminary Sampling ... ... ... ... ... ... ... ... ... ... ... ... .. 35


4.3.2 MeOH Extraction Studies ... ... ... ... ... ... ... ... ... ... ... .. 35


4.3.3 Treatability Study ... ... ... ... ... ... ... ... ... ... ... ... ... ... 36


4.3.4 CPT/MIP Characterization ... ... ... ... ... ... ... ... ... ... ... .. 38


4.4 Demonstration Activities ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 43


4.4.1 Injection of Oxidant ... ... ... ... ... ... ... ... ... ... ... ... ... . 43


4.4.2 Soil and Groundwater Sample Collection . . . . . . . . . . . . . . . . . . . . . . . 45


4.4.3 Process Monitoring ... ... ... ... ... ... ... ... ... ... ... ... ... . 47


4.5 Performance and Data Evaluation ... ... ... ... ... ... ... ... ... ... ... . . 49


4.5.1 Soil Results ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 49


4.5.2 Groundwater Results ... ... ... ... ... ... ... ... ... ... ... ... ... 58


vi 
Contents (Cont’d) 

4.5.3 Quality Assurance/Quality Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65


4.5.4 Analytical QC Results ... ... ... ... ... ... ... ... ... ... ... ... .. 69


4.5.5 Audits ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 72


5.0 Other Technology Requirements ... ... ... ... ... ... ... ... ... ... ... ... ... ... 73


5.1 Environmental Regulation Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73


5.2 Personnel Issues ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 73


5.3 Community Acceptance ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 74


6.0 Technology Status ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 75


6.1 Previous Experience ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 75


6.2 Ability to Scale Up ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 75


7.0 References ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. 76


vii 
Tables 

Table Page 

ES-1 Summary of Results ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... .. ES-3


2-1 Properties of KMnO 4 ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 7


2-2 Federal and State ARARS for XDD’s ISCO Process . . . . . . . . . . . . . . . . . . . . . . . . . . . 13


2-3 Groundwater Cleanup Criteria Comparison . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16


3-1 Treatment Design for Hypothetical Site. ... ... ... ... ... ... ... ... ... ... ... ... . 17


3-2 Cost Estimate for a Full-Scale Application. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19


3-3 Estimated Labor Costs. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 24


3-4 Estimated Miscellaneous Supplies Costs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27


3-5 Estimated Residuals Shipping/Disposal Costs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28


3-6 Estimated Analytical Costs . ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 29


4-1 Demonstration Objectives ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 32


4-2 Remediation Performance Standards ... ... ... ... ... ... ... ... ... ... ... ... ... 33


4-3 Injection Summary ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 44


4-4 Summary of Laboratory Analyses ... ... ... ... ... ... ... ... ... ... ... ... ... ... 46


4-5 Shallow Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final . . . . . . . 50


4-6 Middle Peat Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final . . . . 51


4-7 Bottom Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final . . . . . . . . 52


4-8 Statistical Summary for Soil Sample Pair Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53


4-9 Averaged Soil Results (Excluding Non-Detects) for PCE, TCE, cDCE, and VC


 - Baseline Vs. Final. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 54


4-10 Averaged Soil Results (Including Non-Detects) for PCE, TCE, cDCE, and VC


 - Baseline Vs. Final. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 55


4-11 Humic Acid Results for Middle Peat Zone - Baseline Vs. Final (wt/wt %). . . . . . . . . . . . 57


4-12 Groundwater Results for Target Ethenes - Baseline Vs. Final . . . . . . . . . . . . . . . . . . . . 59


4-13 Shallow Zone Groundwater Results for Target Ethenes - Baseline Vs. Final . . . . . . . . . 60


4-14 Intermediate Zone Groundwater Results for Target Ethenes - Baseline Vs. Final . . . . 61


4-15 Deep Zone Groundwater Results for Target Ethenes - Baseline Vs. Final . . . . . . . . . . . 62


4-16 Groundwater Results for Non-Critical VOCs - Baseline Vs. Final . . . . . . . . . . . . . . . . . . 63


4-17 KMnO4 Vs. PCE, TCE, and cDCE Concentrations in Groundwater - All Events . . . . . . . 64


4-18 Metals Summary Results for Groundwater (mg/l). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66


4-19 Acetone, Bromide, and Bromoform Summary Results for Groundwater (:g/l) . ... ... . 67


4-20 Project Accuracy for Soil VOC Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68


4-21 Project Accuracy for Groundwater VOC Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69


4-22 Accuracy for Soil VOC - Spike Results - Baseline Event . . . . . . . . . . . . . . . . . . . . . . . . 69


4-23 Precision for Soil VOC - Spike Results - Baseline Event . . . . . . . . . . . . . . . . . . . . . . . . 70


viii 
Tables (Cont’d) 

4-24 Samples Analyzed Outside Holding Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70


4-25 Accuracy for Soil VOC - Spike Results - Post-treatment Event . . . . . . . . . . . . . . . . . . . 70


4-26 Precision for Soil VOC - Spike Results - Post-treatment Event . . . . . . . . . . . . . . . . . . . 71


4-27 Accuracy for Groundwater - Post-treatment VOCs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71


4-28 Precision for Groundwater - Post-treatment VOCs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71


Figures 

Figure Page 

1-1 Former MEC Building Source Area ... ... ... ... ... ... ... ... ... ... ... ... ... . . 2


1-2 Time Line of Demonstration Events ... ... ... ... ... ... ... ... ... ... ... ... ... . . 3


2-1 Injection W ell Cluster Schematics ... ... ... ... ... ... ... ... ... ... ... ... ... ... . 8


2-2 Multi-Chamber W ell Schematic ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 9


3-1 Hypothetical ISCO Site. ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 18


4-1 Map of Study Area Showing Demonstration Soil Boring and Well Locations . . . . . . . . . 31


4-2 Cross Section Showing Stratigraphic Zones of Study Area . . . . . . . . . . . . . . . . . . . . . . 34


4-3 Maximum MIP PID Response for Shallow Zone Soil (0-18 ft) - Baseline Vs. Final . . . . 39


4-4 Maximum MIP PID Response for Deep Zone Soil (18-36 ft) - Baseline Vs. Final . . . . . 40


4-5 Maximum MIP ECD Response for Shallow Zone Soil (0-18 ft) - Baseline Vs. Final . . . . 41


4-6 Maximum MIP ECD Response for Deep Zone Soil (18-36 ft) - Baseline Vs. Final . . . . . 42


4-7 Map of KMnO4 Injection Points ... ... ... ... ... ... ... ... ... ... ... ... ... ... . . 43


4-8 Estimated Dispersion of KMnO4 104 Days After First Injection . . . . . . . . . . . . . . . . . . . . 47


4-9 Estimated Dispersion of KMnO4 245 Days After First Injection and 125 Days


After Second Injection ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 48


4-10 Estimated Dispersion of KMnO4 280 Days After First Injection and 160 Days


After Second Injection ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... ... 48


ix 
Abbreviations and Acronyms 

AQCR Air Quality Control Regions 

AQMD Air Quality Management District 

ARARs Applicable or Relevant and Appropriate Requirements 

ASTM American Association of Testing and Materials 

ALSI Analytical Laboratory Services Inc. 

Aries Aries Engineering, Inc. 

As Arsenic 

bgs Below ground surface 

BFB Bromofluorobenzene (tune performance compound for SW 8260) 

CA Chloroethane 

CAA Clean Air Act 

Cl-ethenes Chlorinated ethenes 

CERI Center for Environmental Research Information 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFR Code of Federal Regulations 

CPT Cone penetrometer technology 

CW A Clean W ater Act 

Cr Chromium 

DCA 1,1-dichloroethane 

DCE 1,1-dichloroethylene N

C Degrees Celsius 

cDCE cis-1,2-dichloroethene 

DNAPL Dense non-aqueous phase liquid 

DPT Direct push technology 

ECD Electron capture detector 

EW Evaluation well 

EPA 

ft 2 

ft 3 

U.S. Environmental Protection Agency 

Square feet / square foot 

Cubic feet / cubic foot 

Gal Gallons 

GC/MS Gas chromatography/mass spectroscopy 

g/L Grams per liter 

G&A General and administrative 

GW -1 Groundwater criteria for NHDES 

GMP Groundwater Management Permit 

Hg Mercury 

H 2O2 Hydrogen peroxide 

HSW A Hazardous and Solid W aste Amendments 

ICAL Initial calibration standard 

In Inch 

ID Inner diameter 

IDW Investigation derived waste 

ISCO In situ chemical oxidation 

ITER Innovative Technology Evaluation Report 

x 
Abbreviations and Acronyms (Cont’d) 

IW Injection well 

KMnO4 Potassium permanganate 

Kg Kilogram 

KVA Kilovolt amperes 

LLC Limited liability corporation 

L Liter 

LL Lower limit (of a specified confidence interval) 

LCS Laboratory control sample 

LRL Laboratory reporting limit 

LDR Land disposal restriction 

LRPCD Land Remediation and Pollution Control Division 

MEC formerly Nashua Electric Motors 

MeOH Methanol 

MSDS Material Safety Data Sheet 

MS/MSD Matrix spike/matrix spike duplicate 

MCLs Maximum contaminant levels 

MCLGs Maximum contaminant level goals 

MIP Membrane interface probe 

m Meter 2 m Square meters 

MDL Method detection limit 

MnO2 Magnesium oxide 

MnO4 Permanganate 

NH New Hampshire 

mg/L Milligrams per liter 

ml Milliliters 

MV Millivolt 

MW Monitoring well 

NAAQS National ambient air quality standards 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NPDES National Pollutant Discharge Elimination System 

NPDW S National primary drinking water standards 

NRMRL-CI National Risk Management Research Laboratory (EPA-Cincinnati) 

NSCEP National Service Center for Environmental Publications 

NPDW S National primary drinking water standards 

NHDES New Hampshire Department of Environmental Services 

OSHA Occupational Safety and Health Administration 

ORD Office of Research and Development (EPA) 

OSW ER Office of Solid Waste and Emergency Response 

OSC On-scene coordinator 

O&M Operation and maintenance 

OD Outside diameter 

ORP Oxygen reduction potential 

PCE Perchloroethene or tetrachloroethene 

PID Photoionization detector 

PPE Personal protective equipment 

PQL Practical quantitation limit 

xi 
Abbreviations and Acronyms (Cont’d) 

PE Professional engineer 

PG Professional geologist 

PVC Polyvinyl chloride 

POD Portable oxidant delivery system 

POTW Publicly owned treatment works 

QAPP Quality assurance project plan 

QA Quality assurance 

QC Quality control 

Rfs Response factors 

RDL Reporting detection limit 

RPD Relative percent difference 

RSD Relative standard deviation 

RPM Remedial project manager 

RPS Remediation Performance Standard 

RCRA Resource Conservation and Recovery Act 

R&D Research and development 

SDW A Safe Drinking Water Act 

SAIC Science Applications International Corporation 

SARA Superfund Amendments and Reauthorization Act 

Se Selenium 

SOD Soil oxidant demand 

SOP Standard operating procedure 

SW -846 Test methods for evaluating solid waste, physical/chemical methods 

SW DA Solid Waste Disposal Act 

SITE Superfund Innovative Technology Evaluation 

1,1,1-TCA 1,1,1-Trichloroethane 

TCE Trichloroethene 

TER Technology Evaluation Report 

TSA Technical Systems Audit 

TSR Technical Systems Review 

TOC Top of casing 

TSCA Toxic Substances Control Act 

TSD Treatment, storage, and disposal 

UL Upper limit (of specified confidence interval) 

:g/Kg Micrograms per kilogram 

:g/L Micrograms per liter 

:V Microvolts 

USEPA United States Environmental Protection Agency 

VP Vertical profile 

VC Vinyl chloride 

VOCs Volatile organic compounds 

XDD 

yd 3 

Xpert Design and Diagnostics, LCC 

Cubic yards 

Zn Zinc 

xii 
Acknowledgments 

This report was prepared under the direction of Michelle Simon, the EPA Technical Project Monitor 

for this SITE demonstration at the National Risk Management Research Laboratory (NRMRL) in 

Cincinnati, Ohio. Both Dr. Simon and Paul de Percin (retired) served as EPA NRMRL Project 

Monitors for the demonstration. Joseph Evans and Joseph Tillman of Science Applications 

International Corporation (SAIC) served as the SITE work assignment managers for the 

implementation of demonstration field activities and completion of associated reports. 

Field sampling and data acquisition was conducted by Mr. Evans, Mr. Tillman, John King, Andrew 

Matuson, Mark Hasting, Jillian Loughlin, and Hakim Abdi (all of SAIC). Data validation was conducted 

by Mr. Evans and Rita Schmon-Stasik (SAIC); and a statistical evaluation of data was conducted by 

Dr. Maurice Owens, also of SAIC. 

The Demonstration required the combined services of Xpert Design and Diagnostics, LLC (XDD), and 

SAIC. Aaron Norton served as the primary developer contact throughout the Demonstration. Also, 

George Holt of Aries Engineering, provided valuable insight regarding site specific information 

throughout the project duration. The cooperation and efforts of these organizations and individuals 

are gratefully acknowledged. The cooperation and assistance of Bill Archibald, the contact for the 

former MEC Building site, was invaluable and greatly appreciated. 

Cover Photographs: Clockwise from top left are 1) Installation of Multi-Ch

granular KMnO (20 L); 3) KMnO in deep silt zone core sample (post-treatm

of pre-mixed KMnO4 oxidant solution (used for first injection) and water 4 4 

operation 5) dark purple KMnO in well purge water; 6); Adding granular K

7) Back end of XDD Portable Oxidant Delivery (POD) trailer-mounted unit, 

flow meters. 

4

amber Monitoring Well; 2) Jugs of 

ent sampling event) 4) Tanker (left) 

 tanker (right) used for batching 

MnO during batch operation, and 

showing distribution manifold and 4 

xiii 
Executive Summary 

Introduction 

This report summarizes the findings of an evaluation of the 

Xpert Design and Diagnostic's (XDD) in situ chemical 

oxidation (ISCO) process at the former MEC Building site 

located in Hudson, New Hampshire. At this site, both soil 

and groundwater are contaminated with chlorinated volatile 

organic compounds (VOCs) due to releases from a former 

underground concrete storage tank. The tank was 

removed in May 1997. 

Site contamination occurs as a dense non-aqueous phase 

liquid (DNAPL) at about 23-25 ft (7 to 7.6 m) below land 

surface (bls) and as dissolved phase VOCs in soil and 

groundwater, primarily from 6-25 ft (1.8 to 7.6 m) bls. The 

VOCs consist primarily of chlorinated ethenes, including 

perchloroethylene (PCE), trichloroethylene (TCE), cis-1, 

2-dichloroethylene, (cDCE), vinyl chloride (VC), and 

toluene. Ethane compounds, such as 1,1,1-trichloroethane 

(1,1,1-TCA) and 1,1-dichloroethane (1,1-DCA), are also 

present. The soil contamination is concentrated in three 

stratigraphic zones occurring between 6 and 25 feet (1.8 to 

7.6 m) below land surface (bls); including an upper gravelly 

silty-sand zone (6-13 ft bls), a thin peat zone (12-14 ft), and 

a fine sandy-silt zone (14-26 ft). The DNAPL occurs at the 

interface of the sand-silt zone and a basal till. The three 

stratigraphic zones were targeted for ISCO treatment. 

Project Objectives 

There were two primary objectives for the demonstration; 

one for soil and one for groundwater. The soil objective 

was to determine if the XDD’s process could reduce 

concentrations of the chlorinated ethenes PCE, TCE, 

cDCE, and VC by 90% over the course of the 

demonstration comparing pre-treatment to post-treatment. 

The 90% reduction objective was to be determined on a 

“paired sample evaluation” (i.e., pre-treatment versus posttreatment samples collected in close proximity to one 

another). The comparison was to be conducted for each 

soil zone and for all three zones combined. 

The primary objective for groundwater was to determine if 

the XDD’s process could reduce concentrations of specific 

VOCs to below their respective 0.5% solubility limit based 

on post-treatment results. VOCs having such a 

Remediation Performance Goal (RPG) included PCE (750 

:g/l), TCE (5,500 :g/l), and cDCE (17,500 :g/l). The 

groundwater objective also specified that 90% of the 

samples evaluated from post-treatment sampling were 

required to meet this goal (i.e., If 10 pre-treatments 

samples were above the limit to start, at least 9 posttreatment results would have to be below the limit). 

Treatment Design 

XDD’s treatment design included installation of three well 

clusters within an approximate 1,200 ft

2 area to serve as 

injection points for potassium permanganate (KMnO ), the 4

oxidant chosen by XDD for treating the site VOCs. The 

three well clusters were installed to form a triangle, each 

cluster being about 18 feet apart and each consisting of a 

well screened in each of the three stratigraphic zones 

targeted for treatment. Each well cluster injection had an 

estimated diameter of influence was 20 feet. Thus, 

injections were to overlap laterally. 

Oxidant Injection & Monitoring 

Injection of KMnO into all three well clusters began in early 4

June 2005. Just prior to this first injection the EPA SITE 

Program sampled soils and groundwater to establish 

baseline VOC concentrations. Soon after the start of 

oxidant injection, there was noted short-circuiting of KMnO4 

to the surface in two of the well clusters. This was 

evidenced by KMnO4 oozing from surface cracks shortly 

after injecting the oxidant into deep wells screened at 20­

25 ft (6.1-7.6 m) bls. Due to suspected failed well seals, 

ES-1 
the two well clusters in question were replaced and a 

second injection was conducted in October of 2005 into 

replacement wells. When combining the two injections, 

just over 15,000 gallons (5,640 L) and approximately 3,700 

lbs (1,680 kg) of KMnO4 was injected into the three well 

clusters combined, at concentrations ranging from 25 to 40 

g/l. Of the total mass of KMnO4 injected, approximately 

1,860 lbs (840 kg) was injected into the deep zone, 

approximately 1,500 lbs (680 kg) was injected into the 

middle peat zone, and approximately 320 lbs (145 kg) was 

injected into the shallow zone. 

Following the injection phase of the project, groundwater 

was monitored to gain insight into the ongoing 

effectiveness of the process. The monitoring included 

noting the visual presence of KMnO , tracking of a bromide 4

tracer used for the first injection, and analyzing samples for 

target VOCs and metals. For each event a total of 15 wells 

were sampled (five for each of the three zones). Following 

the initial baseline event and immediately preceding the 

second injection, a second groundwater baseline was 

needed to establish baseline VOC concentrations for the 

two replacement injection well clusters. Two additional 

intermediate events were conducted after both injections 

but well before the final post-treatment soil and 

groundwater sampling event. 

The final post-treatment sampling event for both soils and 

groundwater was conducted in March 2006 about nine 

months after the first injection and just over five months 

after the second injection. At this time KMnO4 was still 

visible in the deep zone groundwater and was observed in 

deep zone soil cores. However, KMnO4 was not observed 

in soil or groundwater collected from the shallow or middle 

peat zones. In fact KMnO4 was visually observed in just 

one peat zone well (IW -3i) following oxidant injection and 

was never visually observed in shallow zone groundwater 

samples collected after the injections. 

Results - Introduction 

The two primary objectives were evaluated using the VOC 

analytical results from the pre-treatment (baseline) and 

post-treatment (final) sampling events. Table ES-1 

provides a general overall summary of these results. For 

determining if the soil contaminant removal efficiency was 

90% or greater on a paired soil sample basis (i.e., the 

primary objective), eligible sample pairs were selected for 

statistical evaluation. (Note: due to high laboratory 

reporting limits resulting from field methanol extractions of 

soils, some sample pairs lacked quantified data results and 

so some of these pairs were not deemed eligible for 

evaluation). 

The primary objective for groundwater was to evaluate the 

effectiveness of XDD’s process in reducing concentrations 

of PCE, TCE, and cDCE in groundwater to below their 

corresponding RPS of 750 :g/l, 5,500 :g/l, and 17,500 

:g/l. The QAPP specified that to meet this objective more 

than 90% of eligible samples had to meet those regulatory 

criteria, as to reject the null hypothesis (i.e., have pretreatment concentrations reduced to below the RPS based 

on post-treatment sampling results). However, there were 

fewer than expected instances where criteria were 

exceeded prior to treatment. As a result, only those 

instances where such criteria were exceeded could be 

evaluated statistically to determine if the objective was met. 

Soil VOC Results 

The soil VOC data was highly variable. High sample 

concentration variability at DNAPL sites is commonly 

observed, particularly at sites with heterogeneous 

lithologies. Of the four critical VOCs evaluated (PCE, TCE, 

cDCE, and VC), TCE had the best overall percentage of 

sample pairs showing reductions > 90% (40.9% for all 

zones combined). However, VC fared the best for 

percentage of eligible pairs showing contaminant 

decreases of any magnitude. For all zones combined, 

82.1% of eligible sample pairs for VC showed contaminant 

reductions from baseline to final sampling; including 88.9% 

in the shallow zone and 70% in the peat zone. 

Soils were also statistically evaluated on an average pretreatment versus post-treatment basis, using the 

hypothesis test suggested in the Quality Assurance Project 

Plan (QAPP) that the process will remove 90% of 

contamination. For this evaluation, all pre-treatment and 

post-treatment soil data was used so that pre- and posttreatment sample population was equal. This meant 

including non-detect values, which were assigned a value 

of one half (1⁄2) the laboratory reporting limit. The null 

hypothesis tested is that the contamination removed does 

not exceed 90%. This null hypothesis was tested for 16 

sets of analyte-zone combinations (i.e., the four 

combinations for PCE would be PCE-shallow zone, PCEpeat zone, PCE-deep zone, and PCE-all three zones 

combined). Accepting the null hypothesis results in a 

finding that the process does not meet demonstration 

objectives; rejecting the null hypothesis results in a finding 

that the process meets the demonstration objective. In 

using a two-sided 95% confidence interval to test a onesided hypothesis, the null hypothesis could not be rejected 

for any of the 16 combinations. Thus, the objective was 

not met for any combination. 

ES-2 
Soil VOC Treatment 

Paired 

Analysis 

PCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

5 of 17 eligible pairs show a decrease; 4 of 17 eligible pairs show a decrease > 90%

7 of 9 eligible pairs show a decrease; 4 of 9 eligible pairs show a decrease > 90%

11 of 15 eligible pairs show a decrease; 6 of 15 eligible pairs show a decrease > 90%

23 of 41 eligible pairs show a decrease; 14 of 41 eligible pairs show a decrease > 90% 

TCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

6 of 14 eligible pairs show a decrease; 4 of 14 eligible pairs show a decrease > 90%

6 of 7 eligible pairs show a decrease; 4 of 7 eligible pairs show a decrease > 90%

1 of 1 eligible pair shows a decrease; and 1of 1 eligible pair shows a decrease > 90%

13 of 22 eligible pairs show a decrease; 9 of 22 eligible pairs show a decrease > 90% 

cDCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

14 of 26 eligible pairs show a decrease; 4 of 26 eligible pairs show a decrease > 90%

14 of 19 eligible pairs show a decrease; 6 of 19 eligible pairs show a decrease > 90%

1 of 2 eligible pairs show a decrease; 0 of 2 eligible pairs show a decrease > 90%

29 of 47 eligible pairs show a decrease; 10 of 47 eligible pairs show a decrease > 90% 

VC 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

16 of 18 eligible pairs show a decrease; 8 of 18 eligible pairs show a decrease > 90%

7 of 10 eligible pairs show a decrease; 2 of 10 eligible pairs show a decrease > 90%

There were no eligible pairs in the deep zone.

23 of 28 eligible pairs show a decrease; 10 of 28 eligible pairs show a decrease > 90% 

Number of 

Samples 

Average Pre-Treatment 

Concentration (:g/Kg) 

Average Post-Treatment 

Concentration (:g/Kg) 

% Change 

Averaged 

Results 

PCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

30 

27 

30 

87 

4,721

21,120

194,523

75,259 

54,395

1,105

12,586

23,440 

+ 1,050 - 94.8 

-93.5 

-68.9 

TCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

30 

27 

30 

87 

962 

2,825

306 

1,314 

7,099

291 

102 

2,573 

+ 638 

- 89.7 

-66.7 

+ 95.8 

cDCE 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

30 

27 

30 

87 

4,400

17,217

126 

6,904 

3,983

15,601

741 

6,471 

- 9.48 

- 9.39 

+ 488 

- 6.27 

VC 

Shallow Zone 

Middle (Peat) Zone

Deep Zone

All Zones Combined 

30 

27 

30 

87 

524 

4,700

109 

1,677 

118 

6,693

103 

2,154 

- 77.5 

+ 42.4 

- 5.5 

+ 28.4 

Table ES-1. Summary of Results. 

ES-3 
Groundwater VOC Treatment 

VOC exceeding criteria & 

Well which exceeded 

Pre-Treatment 

Concentration 

(:g/l) 

Post-Treatment 

Concentration 

(:g/l) 

Remediation 

Performance 

Standard (:g/l) 

Goal 

Attained 

Analysis of Individual 

Wells Having VOCs 

above Criteria 

PCE in IW-1s 

(Shallow Zone) 

5,200 1,090 / 1,360

Avg. = 1,225 

750 No 

PCE in EW-2s 

(Shallow Zone) 

6,830 4,190 / 5,560

Avg. = 4,875 

750 No 

PCE in EW-4d 

(Deep Zone) 

2,310 < 0.5 / < 0.5

Avg. = < 0.5 

750 Yes 

TCE in IW-1s 

(Shallow Zone) 

11,200 572 / 766

Avg. = 669 5,500 Yes 

TCE in EW-2s 

(Shallow Zone) 

7,090 4,810 / 7,430

Avg. = 6,120 5,500 No 

cDCE in IW-1s 

(Shallow Zone) 

31,000 3,630 / 3,620

Avg. = 3,625 17,500 Yes 

cDCE in IW-1i 

(Middle Peat Zone) 

50,100 20,100 / 16,700

Avg. = 18,400 17,500 No 

Analysis of Zone 

having concentrations 

of PCE above Criteria 

PCE in the five Shallow 

Zone Wells 

2,450 

(avg. of 5 values) 

1,390 

(avg. of 10 values) 

750 No 

Other Observations 

KMnO4 in 

Groundwater 

KMnO4 visually observed in deep zone samples for all deep wells after the first injection up 

through final event sampling; indicating good presence and persistence in deep zone. 

KMnO4 not observed in any shallow zone samples after either injections; but detection of 

bromide tracer in the same wells indicates possible exhausting of oxidant by high SOD. 

KMnO4 observed in just one intermediate (peat) zone sample on one occasion (i.e., about 4 

months after first injection event at the point of injection). But bromide tracer present. This 

also indicates possible exhausting of oxidant by high SOD. 

Metals in 

Groundwater 

There is no evidence indicating that metals were mobilized by XDD’s process. On an 

average basis, concentrations of most of the metals analyzed showed little change 

throughout the five groundwater sampling events. 

Estimated Cost 

(XDD ISCO Process) 

Using a hypothetical site having characteristics similar to the demonstration site, a size of 3 3 about 100,000 ft and 3,700 yd (i.e., 3.7 times the volume treated for the demonstration), 

the cost for implementing a 10-injection well ISCO treatment system and monitoring 

effectiveness over a 1-month period is estimated at $139,000 

Table ES-1. Summary of Results (Continued). 

ES-4 
However, it should be noted when using a two-sided 95% 

confidence interval to test a one-sided hypothesis, the 

hypothesis is actually being tested at the 97.5% level. 

Testing the hypothesis at the 90% hypothesis testing level 

results in rejecting the null hypothesis (i.e., meeting the 

objective) in one instance; namely PCE in the peat zone. 

PCE had a measured 94.8% decrease in the peat zone; 

from a 21,120 :g/kg baseline average to a 1,105 :g/kg 

post-treatment average. 

Soil was also qualitatively evaluated via cone penetrometer 

technology (CPT) and membrane interface probe (MIP) 

surveys. A total of 18 CPT /MIP survey points were 

completed prior to baseline sampling. During this survey, 

CPT/MIP logs were used to identify specific subsurface 

zones and the highest concentration areas to target for soil 

sampling. Although the final survey was scaled down, 

results were fairly consistent with the quantitative laboratory 

data. In the deep zone, there was a slight decrease of the 

PID signal in the vicinity of the two CPT/MIP points located 

within the more contaminated portion of the DNAPL plume. 

However, in the shallow zone there was a marked increase 

of the PID signal at those same locations. 

Groundwater - VOC Results 

On an individual well basis, there were only seven 

instances where any of the three critical VOCs exceeded 

their respective RPS prior to treatment. Of these seven 

instances VOCs were reduced to below the criteria in three 

cases and were reduced to very close to the criteria in two 

other instances. However, statistically, the null hypothesis 

was not rejected for any of the three compounds. 

On a per zone basis, there were apparent reductions from 

baseline to final in the shallow zone for PCE (43%), TCE 

(60%), and cDCE (61%), however the null hypothesis was 

accepted because out of five instances where the pretreatment value exceeded the criteria, reductions to below 

the criteria occurred in just three cases. The shallow zone, 

in fact, was the only zone of the three that had an average 

pre-treatment concentration for a particular contaminant 

above the criteria. When averaging results for all shallow 

zone wells, PCE averaged 2,450 :g/l in the shallow zone 

prior to treatment, which exceeded its RPS of 750 :g/l. 

PCE averaged 1,390 :g/l following treatment. 

Averaged results in the intermediate peat zone showed 

sharp increases in PCE and TCE, and a sharp decrease in 

cDCE. The majority of this variation, however, was 

attributable to one well which was closest to the source 

area. The only VOC measured pre-treatment above its 

criteria in an intermediate well was cDCE, which did show 

a significant reduction from pre- to post-treatment (from 

50,100 :g/l to an average of two sample results of 18,400 

:g/l). However, this final result was still above its criteria of 

17,500 :g/l). For the intermediate zone the null hypothesis 

was not rejected for each of the three contaminants. 

Averaged results of all deep zones wells showed no 

appreciable change in pre- vs. post-treatm ent 

concentration for the three VOCs. For the deep zone the 

null hypothesis was not rejected for each of the three 

contaminants. However PCE, the only VOC measured 

pre-treatment above its criteria in a deep well, did show a 

significant reduction to below the criteria (from 2,310 :g/l 

to < 0.5 :g/l). 

W hen all zones are combined as a single sample set (i.e., 

representing all site groundwater) PCE was the only VOC 

of the three that had a baseline average above its criteria 

of 750 :g/l. The average PCE baseline concentration was 

1,020 :g/l and the average final PCE concentration was 

746 :g/l. For the combined zone scenario, the null 

hypothesis was accepted for each of the three 

contaminants, including PCE. 

Groundwater - KMnO4 

Potassium permanganate, KMnO , is visually observable 4

in groundwater at relatively low concentrations (i.e., 1 

ppm). Therefore, following the initial injection of the 

oxidant, KMnO4 was visually monitored in the groundwater 

during sample collection. There were two observations of 

note regarding the presence of KMnO 4. 

1.	 KMnO4 was visually seen in all deep zone wells 

following the first injection, but was seen in only 

one well on one occasion in the intermediate zone 

(a well receiving injected KMnO4 about four 

months earlier). KMnO4 was not observed in any 

shallow zone well at any time. 

2.	 In most instances, target VOCs were reduced to 

below detectable levels when KMnO4 was visually 

present. 

Due to its higher capacity to receive fluids, more KMnO 4 

was injected into the deep zone relative to the peat zone 

and, especially, the shallow zone. Taking this into account, 

and knowing that the peat zone contained substantial 

humic material, the two observations above imply that the 

mass of KMnO4 injected into the shallow and peat zones 

may not have been sufficient to overcome high SOD 

suspected in these two zones. The detection of a bromide 

tracer ion at some measurable concentration in all shallow 

and peat zone wells following the first injection imply that 

the initial injected oxidant solution (containing KMnO ) was 4

indeed injected to those areas. 

ES-5 
On the other hand, the mass of KMnO4 injected into the 

deep zone appears to have been more than sufficient to 

treat deep zone groundwater, especially since the KMnO4 

persisted long after target VOCs were apparently oxidized. 

This observation is more fully supported by the soil oxidant 

demand (SOD) test for the soils at the MEC site, performed 

by XDD (2005). They found that the shallow, gravelly 

sands required 4.6 to 21.0 g KMnO4 per Kg sand; 104.7 to 

146.9 g KMnO4 per Kg peat; and 1.8 to 5.6 g KMnO4 per 

Kg deep silty sand. 

Groundwater - Metals Results 

There were no data suggesting that metals were mobilized 

due the XDD process. On an average basis, most of the 

metals analyzed did not change significantly in 

concentration throughout the five groundwater sampling 

events. Some metals (e.g., As, Be, Cr, Mg, and Zn) 

actually showed decreased concentrations in the shallow 

zone from baseline to final sampling events. Substantial 

increases in average manganese (Mn) concentrations in 

the peat and deep groundwater zones for the second 

baseline sampling event is attributed to the influx of Mn 

from the initial injection of KMnO4 into a nearby injection 

well cluster. Increases of Cr and Mg in the deep zone 

groundwater following both the first and second injections, 

and an increase in Se in the deep zone groundwater 

following the second injection were not sustained as the 

average concentrations of these three metals reverted 

back to an average value very close to baseline levels. 

Costs of applying the XDD ISCO process were estimated 

for a larger scale hypothetical site that was approximately 

3.7 times the treatment area of the demonstration site. The 

cost to install a 10-injection well ISCO treatment system, 

utilizing XDD's POD to deliver oxidant to approximately 

100,000 ft 3 (3,700 yd 3 ) of DNAPL-contaminated soil and 

groundwater, and monitor effectiveness over a 1-month 

period is estimated at $139,000. If further treatment were 

required (i.e., re-injection), thus extending the treatment 

period, the cost would increase by a considerable amount. 

The largest cost categories for the application of the XDD 

ISCO technology at a site having characteristics similar to 

those described for the hypothetical site are 1) 

consumables and supplies (41%) and 2) labor (21%), 

together accounting for 62% of the total cost. The other 

major costs, as estimated, include startup and fixed 

(18%),and analytical services (9.7%). 

ES-6 
Section 1.0


Introduction


This Section provides background information about this 

Superfund Innovative Technology Evaluation (SITE) 

demonstration, the SITE Program, discusses the purpose 

of this Innovative Technology Evaluation Report (ITER), 

and describes the Xpert Design and Diagnostic's (XDD) in 

situ chemical oxidation (ISCO) process using potassium 

permanganate (KMnO ) to treat chlorinated ethenes in soil 4

and groundwater. Key contacts are listed at section’s end 

for inquiries regarding additional information about the 

SITE Program, XDD’s technology, and the Demonstration. 

1.1 Background 

XDD’s ISCO process using KMnO4 was demonstrated 

under the SITE Program from May 2005 to May 2006 at 

the former MEC Building site in Hudson, New Hampshire. 

The specific area treated at the former MEC site was a 2 2 relatively small 1,200 ft (114 m ) area that was 

characterized as being contaminated with a dense nonaqueous phase liquid (DNAPL) and dissolved-phase 

volatile organic compounds (VOCs), primarily chlorinated 

ethenes. 

The source of the contamination was a concrete holding 

tank located adjacent to what is referred to as the “former 

MEC Building”. MEC (formerly Nashua Electric Motors) 

repaired and rebuilt electric motors at the property from the 

mid-1970s up until approximately 1990. The subsurface 

concrete holding tank, which had reportedly overflowed 

during their tenure, caused the contamination of underlying 

soil and groundwater. The tank was removed in May 1997. 

The general contaminant source area is defined in Figure 

1-1, which is from a Remedial Action Plan prepared in 

January 2001 (Aries Engineering, 2001). The approximate 

80 ft long x 50 ft wide x 26 ft deep plume (24 m x 15 m x 7 

m) depicted in Figure 1-1 was generated from 1) initially 

conducting vertical profiles (VPs) of soil and groundwater 

VOC headspace data via a Photovac Gas Chromatograph 

(GC); 2) comparing those data to a subset of samples that 

were analyzed in a laboratory; and 3) calculating a ratio 

between the laboratory-analyzed data and headspace data 

to generate estimated VOC concentrations. Aries 

conducted this characterization in May 1998. Soil and 

groundwater at the site are contaminated, primarily with 

perchloroethylene (PCE), trichloroethylene (TCE), cis-1,2­

dichloroethylene, (cDCE), and vinyl chloride (VC). 

The USEPA SITE program conducted a preliminary site 

assessment at the former MEC during 2003. Sampling 

and analysis of monitoring wells in the vicinity of the former 

MEC building revealed VOCs in excess of GW -1 

standards. The highest concentrations detected were near 

the former tank spillage. GW -1 standards are essentially 

equivalent to federal drinking water standard maximum 

contaminant levels (MCLs). Specifically the New 

Hampshire Department of Environmental Services 

(NHDES) regulates VOCs at the site that had exceeded 

their respective GW -1 numeric cleanup standards at least 

once in 2003. These include the following VOCs: 

< Perchloroethene (PCE) 

< Trichloroethene (TCE) 

< cis-1,2 Dichloroethane (cDCE) 

< Vinyl Chloride (VC) 

< Toluene 

< 1,1,1-Trichloroethane (1,1,1-TCA) 

< 1,2-Dichloroethane (1,1-DCA) 

The areal extent of the pilot-scale treatment system's 

injection and monitoring wells was approximately1,200 ft2 

(-35 ft x 35 ft) or 114 m 2. The locations of the oxidant 

injection wells and the monitoring wells are provided in 

Section 4.0 as Figure 4-1. 

1 
Figure 1-1. Former MEC Building Source Area (Source: Aries Engineering Inc., January 2001). 

2 
The demonstration of XDD's ISCO process was initiated in 

May of 2005 with pre-treatment cone penetrometer 

technology and membrane interface probe (CPT/MIP) 

characterization, followed by baseline soil sampling and the 

installation of three clusters of injection wells and three 

multi-chambered monitoring wells aligned parallel with the 

general northeasterly groundwater flow direction. The well 

installation was followed by baseline groundwater 

sampling. The demonstration concluded in March of 2006 

with final post-treatment soil and groundwater sampling. 

Figure 1-2 is a time line of major events that occurred 

during the demonstration. 

Both injection well clusters and multi-chamber well clusters 

were screened at three separate depth intervals; 4-9 ft 

(1.2-2.7 m) bls, 13-14 ft (4-4.3 m) bls, and 20-25 ft (6.1-7.6 

m) bls to target an upper gravelly sand zone, a thin zone of 

peat, and a lower sandy-silt zone, respectively. The 

injection wells also served as monitoring wells. Thus, there 

was a total of 15 monitoring points; five for each of the 

three soil horizons. 

The injection wells were spaced approximately 15-20 ft 

(4.6-6.1 m) apart from each another to provide adequate 

coverage of the demonstration area and provide overlap of 

a calculated 10-foot (3 m) radius of influence. 

There were two primary objectives of the demonstration: 

1) to determine if the XDD ISCO process could remove 

90% of target VOCs from paired soil samples in all three 

horizons, and 2) to determine if the process could reduce 

concentrations of critical VOCs in groundwater to below the 

following Remediation Performance Standards (RPS): 

< PCE 750 :g/l < TCE 5,500 :g/l < cDCE 17,500 :g/l < VC no Standard 

3 
1.2	 Brief Description of the SITE Program 

The U.S. Environmental Protection Agency's (EPA) SITE 

Program was established by EPA's Office of Solid W aste 

and Emergency Response and the Office of Research and 

Development (ORD) in response to the 1986 Superfund 

Amendments and Reauthorization Act, which recognized 

a need for an "Alternative or Innovative Treatment 

Technology Research and Demonstration Program." The 

SITE Program is administered by the ORD National Risk 

Management Research Laboratory (NRMRL) in the Land 

Remediation and Pollution Control Division (LRPCD), 

headquartered in Cincinnati, Ohio. The SITE 

Demonstration Program encourages the development and 

implementation of: 

1.	 Innovative treatment technologies for hazardous 

waste site remediation, and 

2.	 Monitoring and measurement. 

In the SITE Demonstration Program, the technology is 

field-tested on hazardous waste materials. Engineering 

and cost data are gathered on the innovative technology so 

that potential users can assess the technology's 

applicability to a particular site. Data collected during the 

field demonstration are used to assess the performance of 

the technology, the potential need for pre- and 

post-processing of the waste, applicable types of wastes 

and waste matrices, potential operating problems, and 

approximate capital and operating costs. 

1.3	 The SITE Demonstration Program and 

Reports 

In the past technologies have been selected for the SITE 

Demonstration Program through annual requests for 

proposal (RFP). EPA reviewed proposals to determine 

promising technologies for use at hazardous waste sites. 

Several technologies also entered the program from 

current Superfund projects, in which innovative techniques 

of broad interest were identified for evaluation under the 

program. More recently, EPA has selected sites that would 

require innovative technologies for clean-up. 

Once the EPA has accepted a proposal, cooperative 

arrangements are established among EPA, the developer, 

and the stakeholders. Site owners and Developers are 

responsible for implementing, operating and/or maintaining 

their innovative systems at a selected site, and are 

expected to pay the costs to transport equipment to the 

site, operate and/or maintain any equipment on-site during 

the demonstration, and remove the equipment from the 

site. EPA is responsible for project planning, sampling and 

analysis, quality assurance and quality control, preparing 

reports, and disseminating information. 

Results of Demonstration projects are usually published in 

three documents: the SITE Demonstration Bulletin, the 

Technology Capsule, and the ITER. The Bulletin describes 

the technology and provides preliminary results of the field 

demonstration. The Technology Capsule provides more 

detailed information about the technology, and emphasizes 

key results of the field demonstration. The ITER provides 

detailed information on the technology investigated, a 

categorical cost estimate, and all pertinent results of the 

field demonstration. A Technology Evaluation Report 

(TER) is sometimes prepared, but is available by request 

only. The TER serves as verification documentation 

contains a more comprehensive presentation of the 

analytical data (i.e., raw data packages, etc.) collected 

during the demonstration. For the demonstration of the 

XDD ISCO process, this ITER is intended for use by 

remedial managers for making a detailed evaluation of the 

technology for a specific site and waste. 

1.4	 Purpose of the Innovative Technology 

Evaluation Report (ITER) 

This ITER provides information on the XDD in situ 

chemical oxidation process for treating primarily chlorinated 

ethenes in soil and groundwater. The ITER includes a 

comprehensive description of this demonstration and its 

results and is intended for use by EPA remedial project 

managers, EPA on-scene coordinators, contractors, and 

other decision-makers carrying out specific remedial 

actions. The ITER is designed to aid decision-makers in 

evaluating specific technologies for further consideration as 

applicable options in a particular cleanup operation. 

To encourage the general use of demonstrated 

technologies, the EPA provides information regarding the 

technology applicability to specific sites and wastes. The 

ITER includes technology-specific information on cost, 

advantages, disadvantages, and limitations; and discusses 

desirable site-specific characteristics. Each demonstration 

evaluates the performance of a technology treating a 

specific waste matrix. Characteristics of other wastes and 

other sites may differ from the characteristics of the treated 

waste; therefore, a successful field demonstration of a 

technology at one site does not necessarily ensure 

applicability to other sites. Only limited conclusions can be 

drawn from a single field demonstration. 

4 
1.5	 Technology Description 

In situ chemical oxidation involves the introduction of a 

chemical oxidant into the subsurface for the purpose of 

transforming ground water or soil contaminants into less 

harmful chemical species. The process is non-selective; 

therefore, any oxidizable material reacts. Consequently, 

the natural humic content of the soil that contacts oxidant 

is an important measured parameter. 

XDD’s ISCO process utilizes several oxidants. Specific to 

this demonstration, KMnO4 was used to treat soil and 

groundwater contaminated with chlorinated VOCs. The 

KMnO4 is the less expensive of the two common MnO 4 

oxidants (the other being NaMnO ). KMnO is widely and 4 4 

commonly used in the wastewater treatment industry and 

therefore is readily available from several manufactures. 

Granular KMnO4 is packaged and shipped in 20 Liter 

plastic jugs, each weighing about 55 pounds. KMnO4 is 

mixed in large tanks at desired dosages with potable water, 

filtered to remove solids (e.g., silica) and metered for 

injection through a manifold and high-pressure hoses. 

There are several ways to inject oxidant to the desired 

contaminant location. The most common method, as was 

the case during the demonstration, is via traditional 

injection wells (2 inch ID is preferred). However XDD has 

utilized Geoprobe push points, infiltration galleries, and 

even trenches and pits for shallow zone treatments. For 

bedrock applications, they have utilized wells equipped with 

packers for targeting specific fractured bedrock zones. 

Other manufacturers have injected in situ oxidants by 

hydraulic or pneumatic fracturing. 

As shipped in granular form, KMnO4 is a strong oxidizer. It 

is a known irritant to the respiratory system, highly 

corrosive to the skin, and potentially fatal if swallowed. 

W hen handling the dark purple crystalline solid during 

batching operations, XDD personnel wear respirators and 

chemical-resistant clothing (e.g., coated tyvek) to avoid 

breathing dusts and dermal contact. Residuals potentially 

generated during a full-scale ISCO treatment are 

contaminated drill cuttings generated from well installation, 

purge water from well development and sampling of 

monitoring wells, and personal protective equipment. 

1.6	 Key Contacts 

Additional information regarding XDD’s technology and the 

SITE Program can be obtained from the following sources: 

Demonstration Technology Contact 

Ken Sperry, Branch Manager. 

Xpert Design and Diagnostics, LLC 

22 Marin Way, Unit # 3 

Stratham, NH 03885 

Phone: (603) 778-1100 

Fax: (603) 778-2121 

W eb Site: www.xdd-llc.com 

E-mail: sperry@xdd-llc.com 

The SITE Program 

Michelle Simon, Ph.D., P.E.


National Risk Management Research Laboratory


U.S. Environmental Protection Agency 

26 W est Martin Luther King Drive 

Cincinnati, OH 45268 

Phone: (513) 569-7469 

W eb Site: www.epa.gov/ord/SITE 

E-mail: simon.michelle@epa.gov 

Information on the SITE Program is available through the 

following on-line information clearinghouses: 

C The SITE Home page (www.epa.gov/ORD/SITE) 

provides general program information, current 

project status, technology documents, and access 

to other remediation home pages. 

C The OSW ER CLU-In electronic bulletin board 

(http://www.clu-in.org) provides information on 

innovative treatment and site characterization 

technologies while acting as a forum for all waste 

remediation stakeholders. 

5 
Section 2.0


Technology Applications Analysis


This section addresses the general applicability of the 

Xpert Design and Diagnostic’s (XDD) ISCO process to 

sites having soil and groundwater contaminated with 

chlorinated VOCs. The analysis is based on observations 

made during the SITE Program Demonstration, and from 

additional information received from XDD (the developer of 

a specialized ISCO treatment process). The results of this 

SITE Demonstration are presented in Section 4.0 of this 

report. XDD had the opportunity to discuss the 

applicability, other studies, and performance of the 

technology in Appendix A. 

2.1 Key Features of the XDD ISCO Process 

There are four key features comprising XDD’s ISCO 

process. These include the following: 

� Oxidant 

� Portable Oxidant Delivery (POD) System 

� Oxidant Injection Points 

� Monitoring W ells 

Each of these key features is discussed in the following 

paragraphs. 

2.1.1 Oxidant 

Depending on the contaminants to be treated XDD utilizes 

either persulfate (S O ) or permanganate (MnO ) as the 2 X 4

oxidizing agent. Potassium permanganate (KMnO ) was 4 

the chosen oxidant at the former MEC Building site due to 

its ability to economically treat chlorinated ethenes. MnO 4 

is a very stable oxidant and can persist for several months 

in the subsurface. This stability makes it a good choice for 

subsurface applications (i.e., fewer injection events, fewer 

wells to treat the target area, and the ability to more 

effectively penetrate into low permeability zones). XDD 

utilizes two forms of MnO4 to treat organic contaminants, 

1) sodium permanganate 4 (NaMnO ) and 2) potassium

permanganate (KMnO ). Each has its distinct advantages 4

and disadvantages as discussed below. 

NaMnO4 

Higher concentrations of MnO4 can be injected in the 

sodium form as compared to the potassium form. The 

most significant drawback to NaMnO4 is cost (NaMnO4 is 

five to seven times more expensive than KMnO ) 4

NaMnO is handled in a liquid form which is preferred over 4

the solid (i.e., granular) KMnO4 from a health and safety 

and materials handling perspective. The application of this 

liquid oxidant is simpler than injecting KMnO , which has to 4

be pre-mixed with potable water at the desired 

concentration prior to injection. But because of cost, a 

precise knowledge of where contaminant(s) are situated is 

needed to implement a surgical injection strategy. 

KMnO4 

KMnO4 is preferred over NaMnO4 when the subsurface 

lithology is complex or when soils with high humic content. 

This is because NaMnO is much more expensive and thus 4

must be precisely injected to accessible zones and not be 

exhausted by naturally occurring organic material. An 

assessment of SOD is needed to determine how much 

reagent may be wasted on oxidizing benign organic 

compounds. 

KMnO4 is a dark purple/bronze solid, produced in either a 

crystalline or free-flowing powder form. It is shipped in 20 

Liter plastic jugs and has a reported shelf life of one year. 

It is readily manufactured due to its common use in the 

wastewater treatment industry and usually contains silicon 

dioxide as an anti-caking agent. Consequently, the created 

oxidant solution is filtered prior to injection to remove such 

unwanted solids that may clog well screens. 

6 
Table 2-1 4 . Properties of KMnO . 

Appearance: Dark purple/bronze odorless solid in 

crystalline or free-flowing powder form. 

Molecular Wt. 158.04 

Spec. Gravity 2.7 @ 15 CN 

Bulk Density: 90-100 lbs/ft3 

Flash Point: Not combustible 

Storage: Strong Oxidizer: Store in cool, dry, nonfreezing area away from direct sunlight, 

intense heat, & combustible materials. 

Shelf Life: One year @ 13-32 CN 

Handling: Avoid dermal, gloves/goggles suggested 

Hazard 

Overview: 

Strong Oxidizer 

HMIS Ratings Health hazard - 3 (moderate)

Fire hazard - 0 (minimal)

Physical hazard - 0 (minimal) 

Water Soluble: 6.38 g/100 cc @ 20 CN 

Sources: CHEM ONE Product Specification, rev. 2/23/04; Material 

Safety Data Sheet, re. 7/31/03; XDD Personal Comm.,01/26/06. 

4

2.1.2	 Portable Oxidant Delivery System 

XDD’s Portable Oxidant Delivery (“POD”) System is an 

array of equipment mounted inside a utility trailer (13 by 7 

ft wide, not including a trailer hitch assembly). The POD 

can be towed with a heavy-duty pickup truck. The following 

primary equipment is contained within the POD.: 

•	 Two 300-gallon (1,140 L) chemical oxidant 

batching tanks which can be pumped in unison to 

transfer oxidant to injection wells. 

•	 Dual oxidant metering pumps (for injecting KMnO 4 

and NaMnO simultaneously) 4

•	 Process Equipment (i.e., high durable/chemicalresistant totalizer flow meters) for monitoring flow 

rates, temperature, and pressure. 

•	 Filtration system to remove particulate matter in 

the injection fluid stream. 

•	 Manifold designed to simultaneously deliver 

oxidant in up to 6 injection wells. 

During the demonstration, XDD performed batch 

operations within a bermed area in proximate vicinity to the 

POD. Batching was conducted in two larger chemical 

tanks, each having a capacity of 500 gal. (1,890 L). Jugs, 

each containing about 20 Liters of granular KMnO , were 

emptied into these tanks and mixed with potable water 

pumped from a water tanker trailer at the desired liquid 

KMnO concentration. The KMnO /water solution was then 4 4

mixed for 1⁄2-1 hour with a sump pump, routed through two 

cannister filters connected in series, and pumped onto the 

two 300-gallon chemical tanks within the POD unit. A 

piston pump within the POD pumps the oxidant through a 

PVC manifold assembly equipped with pressure valves and 

totaliser meters. The POD has the capability of routing 

oxidant to up to six injection wells simultaneously. 

2.1.3	 Oxidant Injection Points 

Injection points are required to properly deliver oxidant to 

the desired locations by means of the most effective and 

economical method possible. The most common type of 

injection points are injection wells that are screened within 

an aquifer at the targeted contaminated zone. At the 

former MEC Building site, XDD’s treatment system 

consisted of three injection well clusters. Each cluster 

consisted of three wells screened at three different depths; 

thus, there was a total of nine injection points. The 

injection wells targeting the top and bottom zones were 

fitted with 5-ft (1.5 m) long screens and the injection wells 

targeting the thin middle peat zone were fitted with 1-ft (0.3 

m) long screens. All wells were flush mounted since they 

were located in an area immediately adjacent to a docking 

bay that was frequented by heavy trucks and forklifts. The 

locations of all demonstration wells is shown in Figure 4-1. 

Injection wells require fittings for connecting a high 

pressure hose to the injection wellheads. XDD uses 

common materials and parts for these fittings, which are 

available at local hardware stores. As a result, existing 

monitoring wells can be adapted for injection as long as 

they are screened at the proper interval and are equipped 

with the appropriate slotted screens. For the 

demonstration XDD used 1⁄2 -inch ID high pressure hoses 

to injected into both 1-inch ID and 2-inch ID injection wells. 

7 
Figure 2-1 presents example schematics of injection wells 

comprising an injection well cluster that was used for the 

demonstration (IW -1 and IW -2, specifically). These wells 

are of traditional design and can be used for monitoring 

following injection of oxidant. 

The number and locations of injection wells are dependent 

on a site’s characterization. XDD has indicated that the 

preferred injection well construction would be comprised of 

a 2-inch inner diameter (ID) well having screen lengths 

preferably not in excess of 10 feet in length. 

It should be noted that there are direct-injection techniques 

that can be used to deliver oxidants which do not require 

an injection well. A geoprobe, equipped with drive rods of 

1.25-inch O.D./0.625-inch I.D. or 2.125-inch O.D./1.5-inch 

I.D., can be utilized to provide a temporary casing (i.e., 

drive point) to allow the oxidant to be pumped subsurface 

without installing a well. Also, oxidant can be injected into 

infiltration galleries, excavated trenches, hydraulic or 

pneumatic fractures and pits. 

8 
2.1.4 Monitoring Wells 

Monitoring wells are a necessary component for monitoring 

the effectiveness of an ISCO process. In many instances, 

existing monitoring wells can be utilized for the monitoring, 

dependent on their location. Also, in some instances (as 

was the case for the Demonstration), the injection wells 

can serve a dual purpose (i.e., as monitoring points). It 

should be noted that typically the injection wells are spaced 

or grouped in such a manner that they alone would not 

provide adequate coverage of a contaminant plume. 

For the SITE Demonstration, there were two types of wells 

installed for monitoring; traditional wells (as shown on 

Figure 2-1) and “multi-chamber wells” (Figure 2-2). The 

multi-chamber wells were essentially a 3- in-1 design; each 

1-inch OD casing containing three separate 7/16-inch ID 

wells set at different depths. All in all, there was a total of 

five monitoring wells for each of the three stratigraphic 

zones monitored (for a total of 15 wells). 

9 
The number of monitoring wells that would be needed for 

a remediation project using XDD’s process is highly sitespecific. At a minimum, monitoring wells are typically 

required upgradient, downgradient, and lateral to the area 

to be treated. The former MEC Building site has been 

monitored continuously for an extended period of time to 

track the slow dissolution of the DNAPL and dissolved 

organic contaminant plume. The Site Demonstration 

focused on monitoring treatment effectiveness within a 

small area side-gradient of the main DNAPL source zone. 

2.2	 Operability of the Technology 

The implementation of XDD’s technology is broken down 

into an eight-step process, listed and discussed below. 

1.	 Site Evaluation 

2.	 Treatability Testing 

3.	 System Design 

4.	 Injection Well Installation 

5.	 Pilot Testing (Water Injection Tests) 

6.	 System Setup 

7.	 Batching of Oxidant 

8.	 Oxidant Injection & Monitoring 

9.	 Equipment Decontamination 

10.	 Monitoring Treatment Effectiveness 

XDD will sometimes conduct site characterization activities 

themselves; but more commonly will evaluate existing 

characterization data for the site. But site evaluation is an 

important aspect, as XDD typically conducts treatability 

testing to determine various aspects of the contaminated 

soils that are to be treated. For example, prior to the 

demonstration XDD conducted a laboratory treatability 

study in order to evaluate the effectiveness of their ISCO 

process on contaminated soil from the site. The objectives 

of this treatability study were to: 

•	 Assess the overall feasibility of using ISCO to 

meet the site-specific cleanup goals; 

•	 Estimate the soil oxidant demand for the major soil 

units (i.e., gravelly sand, peat layer, and sandysilty) in the treatment area; 

•	 Develop site-specific data necessary to design an 

ISCO field pilot test and/or full-scale application. 

Injection well installation is performed by an outside 

contractor. The injection wells can typically serve a dual 

purpose (i.e., as monitoring wells once oxidant is injected). 

Also, existing monitoring wells may be able to be retrofitted 

for injection purposes. XDD sometimes conducts water 

injection testing on prospective injection wells, a practice 

they are utilizing more frequently. As an example, for the 

demonstration project at the former MEC Building site, 

XDD performed a small-scale water injection test at a 

target flow rate to monitor well seal and injection pressures 

of newly-installed injection wells that served as 

replacements for wells that had to be abandoned due to 

failed seals. 

The following tasks comprise the basic setup of XDD’s 

equipment (i.e., the system set-up step). 

•	 Oxidant delivery/storage of KMnO 4 

•	 Setup of spill guards for batch area 

•	 Potable water delivery (tanker) 

•	 Drop-off of rented generator 

•	 Hookup of batch operation to POD 

•	 Connect injection distribution system to wells 

The batching process is labor intensive. For example the 

granular KMnO4 used during the demonstration is 

containerized in 20 L jugs. The granular oxidant needs to 

be mixed with potable water to form an oxidant solution at 

the desired concentration. To do this, the jugs were 

manually transported to the top of a large mixing tank, 

where the jug contents were dumped into the tank 

equipped with a sump pump for mixing. Tyvek and 

respirators were worn during this process as a 

precautionary health and safety measure. 

To inject oxidant, the KMnO4 solution is pumped through 

one or more cannister filters (two filters, connected in 

series, were used during the demonstration). The filtration 

is needed to remove any unwanted material from the 

solution. Such material includes a small amount of silica 

(i.e., 1% or less of silica is mixed in with the granular 

KMnO4 as an anti-clogging agent). 

During XDD’s injection process, equipment 

decontamination consists of periodic flushing of cannister 

filters, which are used to remove unwanted material (e.g., 

silica solids) from the oxidant solution. Following an 

injection event, XDD conducts a thorough flushing of the 

oxidant from the POD and related equipment components. 

To accomplish this, a neutralizing solution is used, that 

consists of a 5:1:1 mixture of potable water, vinegar, and 

hydrogen peroxide (H O ), respectively. The neutralizer is 2 2

pumped through the POD components, through the high 

pressure hoses and down into the injection wells (the small 

amount of injected neutralizer has a negligible effect on the 

subsurface). 

Monitoring of treatment effectiveness is highly site-specific 

and very dependent on regulatory requirements as to the 

degree of monitoring required. This endeavor may or may 

10 
not be conducted by XDD, largely depending on whether 

they are serving as the site remediation contractor. 

Regardless, XDD would have some input into evaluating 

treatment results. In most cases monitoring of an ISCO 

process would involve at minimum a pre-treatment and 

post-treatment sampling event for all affected media (i.e., 

soils and groundwater). Typically groundwater would 

require continued post-treatment monitoring for an 

indefinite period, largely dependent on state and local 

regulatory requirements. 

2.3	 Applicable Wastes 

ISCO is primarily used to treat contaminated soil and 

groundwater. Permanganate (MnO ) has been widely used 4

and has been shown to completely mineralize several 

common chlorinated VOCs to yield innocuous end 

products. MnO4 is more effective for treating chlorinated 

ethenes; particularly tetrachloroethene (PCE) and 

trichloroethene (TCE) are most readily oxidized. However, 

significant degradation of chlorinated ethanes, such as 

1,1,1-trichloroethane (1,1,1-TCA), has also been observed. 

In addition to organics, MnO4 also reacts with natural soil 

organic matter and reduced metal oxides (e.g., iron and 

manganese oxides). 

W ith respect to applicable soil types, high clay soils would 

be expected to be less amenable to ISCO since plugging 

could cause the flow of groundwater to divert around areas 

of contamination. Deeper contamination would require 

more costly well installation. 

2.4	 Availability and Transportability of 

Equipment 

The XDD ISCO process can theoretically be implemented 

anywhere injection and monitoring wells can be installed, 

which would include any location that can be accessed by 

a drill rig, or geoprobe, or other direct push technology 

(DPT) equipment. Since all-terrain drill rigs and DPT 

equipment are available, most locations would be 

accessible. 

At the former MEC Building site, the injection system 

consisted of three injection well clusters, in which each 

cluster contained three separate wells screened in a 

shallow (4-9 ft), middle (13-14 ft), and deep (20-25 ft) 

stratigraphic zones that had been previously characterized. 

Nine additional small diameter wells were installed at three 

locations for monitoring purposes only. These wells were 

screened at the same depth intervals the injection wells 

were and were constructed with readily available 

construction materials typically used for well installation. 

The primary components for the KMnO4 injection 

equipment used during the demonstration were contained 

on a single trailer (the POD). The POD can be easily 

mobilized with a heavy duty pickup truck. Granular KMnO 4 

was shipped to the site in 20 Liter plastic jug-like 

containers, each weighing approximately 55 pounds. The 

jugs were unloaded from a truck on wooden pallets and 

stored in an adjacent warehouse. 

During the demonstration XDD's system required periodic 

monitoring of basic groundwater parameters. The 

equipment used for these activities (e.g., water level 

indicators, multi-parameter water quality meters, etc.) are 

portable and can be easily shipped or transported to a site. 

2.5	 Materials Handling Requirements 

Materials handling requirements for XDD’s ISCO process 

are largely dependent on the type of oxidant used. The 

considerably less expensive KMnO4 oxidant used during 

the demonstration requires a somewhat rigorous materials 

handling relative to the NaMnO 4 oxidant. Granular KMnO4

is shipped in 20 Liter plastic jugs, each jug weighing 

approximately 55 pounds. During the demonstration the 

jugs were manually carried from a loading dock to XDD’s 

batch set up area. To mix the oxidant with potable water 

the jugs had to be lifted via a ladder to the top of a mixing 

vessel and emptied into a tank. Due to the health and 

safety concerns (inhalation on KMnO4 dust), a respirator 

and coated tyvek were worn during this operation. 

NaMnO 4 is shipped in liquid form and thus can be delivered

in a large tanker, from which the oxidant can be pumped 

directly to the POD. 

Because drilling operations are involved to install the 

injection wells and possibly monitoring wells, there is the 

potential of handling hazardous residual materials. 

Examples would include drumming of soil cuttings, purge 

water, and decontamination water. 

2.6	 Site Support Requirements 

During the Demonstration, the equipment and supplies for 

the XDD ISCO process encompassed an approximate 80 2 2 ft x 30 ft area (i.e., 2,400 ft or 220 m ). The majority of 

space is needed for the batching process, which requires 

a large water supply for diluting granular KMnO4 (a 5,000 

gallon tanker was used for the demonstration), and a 

bermed area adjacent to the water supply that contains two 

500 gal. (1,890 L) polypropylene mixing tanks, three 

transfer pumps and two cartridge filters connected in 

series. The trailer-mounted POD and generator take up a 

11 
2 very small amount of space (i.e., approximately 200 ft or 2 18.5 m ).

For in situ oxidation to take place effectively in 

groundwater, it must be technically and economically 

feasible for the oxidant to contact the contaminated media 

(i.e., both soil and groundwater). This can be a tradeoff of 

cost of drilling multiple wells for injecting KMnO4 versus the 

cost of alternative treatments involving fewer wells (e.g., 

pump and treat systems). The sites where ISCO is to be 

used must be able to provide good access for a drill rig or 

DPT equipment. 

XDD typically rents a gasoline or diesel powered generator 

(e.g., 70 KVA) to supply electric power to the POD. The 

peristaltic pumps needed for low flow groundwater 

sampling of shallow wells can operate off a car battery. 

Both of these items are easily rented and are usually 

available locally. 

Electrical power may also be needed to supply lighting to 

an on-site trailer and a security light, and possibly for a 

phone and facsimile hookup. During the demonstration 

project, use of space within the former MEC Building was 

invaluable for preparing soil and groundwater samples 

during variable weather conditions encountered throughout 

the demonstration sampling events. W ithout the use of the 

building, a trailer would likely have been rented for that 

purpose. Other than electricity, a water source is needed 

for occasional decontamination activities (e.g., rinsing out 

the individual jugs of KMnO 4). Since XDD usually rents the

water tanker during an injection event, that could also 

serve as a source for water used for other purposes. 

2.7 Limitations of the Technology 

Because permanganate reacts with natural soil organic 

matter and reduced metal oxides, contaminant degradation 

rates can be adversely affected by the presence of these 

competing species. Humic and fulvic acids (collectively 

referred to as humates) are highly susceptible to 

permanganate oxidation. Humic-containing soils are 

categorized as having a high soil oxidant demand (SOD), 

a term used for measuring how much oxidant the natural 

material in a soil could potentially use up, thus depriving 

the oxidant’s intended use for treating organic 

contaminants. 

Chemical oxidation also has the potential to mobilize 

valence sensitive toxic metals, such as Arsenic (As), 

Chromium (Cr), Selenium (Se), Zinc (Zn), and Mercury 

(Hg), from soils into groundwater. As a result, sites that 

contain elevated levels of metals contaminants as well as 

organic contaminants should be monitored for such 

mobilization potential. 

The porosity of the soil and groundwater flow can affect the 

rate and overall effectiveness of oxidation. Low porous 

and low conductive soils would hamper injection and retard 

the mobility of the oxidant. Sites having heterogeneous 

stratigraphy will not have consistent hydraulic properties. 

Small-scale high permeability zones can act as localized 

conduits for dissolved-phase VOCs, thus making the 

contaminants a hard target for injected MnO . 4

Some organic compounds are not degraded as readily by 

permanganate as chlorinated ethenes are. For example, 

toluene is known to degrade in the presence of MnO 4, but 

at relatively slow rates. Compounds, such as toluene and 

harder to degrade ethanes, are commonly found at sites 

having ethene contamination. Such was the case for the 

former MEC Building site. 

2.8 ARARS for XDD’s ISCO Process 

This subsection discusses specific federal environmental 

regulations pertinent to the operation of the XDD ISCO 

process, referred to as Applicable or Relevant and 

Appropriate Requirements (ARARs). ARARs include the: 

(1 )C o m pre h e n s ive E nviron m e n ta l R e s ponse, 

Compensation, and Liability Act (CERCLA); (2) Resource 

Conservation and Recovery Act (RCRA); (3) Clean Air Act 

(CAA); (4) Clean W ater Act (CW A); (5) Safe Drinking 

W ater Act (SDW A), and the (6) Occupational Safety and 

Health Administration (OSHA) regulations. These six 

general ARARs and state requirements for the former MEC 

Building site are discussed in the following subsections. 

Specific ARARs that may be applicable to the XDD ISCO 

process are identified in Table 2-2. 

12 
Table 2-2. Federal and State ARARs for XDD’s ISCO Process. 

Process 

Activity 

ARAR Description Basis Response 

Waste 

Characterization 

RCRA: 40 CFR 

Part 261 ( or the 

state equivalent) 

Standards apply to 

the identification and 

characterization of 

wastes. Chemical 

an d p hy sical 

properties of waste 

determine suitability 

for ISCO treatment. 

Chemical and physical properties of waste 

determine its suitability for treatment by an 

ISCO process. 

Chemical and physical analyses 

must be performed to determine if 

waste is a hazardous waste. 

Waste 

RCRA: 40 CFR 

Part 264 (or the 

state equivalent) 

Standards apply to 

treatment of wastes 

in a treatment facility. 

Not likely to be applicable or appropriate for 

the XDD ISCO process. 

When hazardous wastes are 

treated, there are requirements for 

operations, record keeping, and 

contingency planning. 

Processing CAA: 40 CFR 

Part 50 (or the 

state equivalent) 

Regulations govern 

toxic pollutants, 

visible emissions and 

particulates. 

During well installation and oxidant 

batching/injection, any off-gas venting (i.e., 

from buildup of VOCs, etc.) must not 

exceed limits set for the air district of site. 

(Not likely to occur.) 

Off-gases may contain volatile 

organic compounds or other 

regulated substances, although 

levels are likely to be very low. 

Storage of 

auxiliary 

wastes 

RCRA: 40 CFR 

Part 264 

Subpart J (or the 

state equivalent) 

Regulation governs 

the standards for 

tanks at treatment 

facilities. 

Storage tanks for liquid wastes (e.g., 

decontamination waste) must be placarded 

appropriately, have secondary containment 

and be inspected daily. 

If storing non-RCRA wastes, RCRA 

requirements may still be relevant 

and appropriate. 

RCRA: 40 CFR 

Part 264 

Subpart I (or the 

state equivalent) 

Regulation covers 

the storage of waste 

materials generated. 

Potential hazardous wastes remaining after 

treatment (i.e., drill cuttings) must be 

labeled as hazardous waste and stored in 

containers in good condition. Containers 

should be stored in a designated storage 

area and storage should not exceed 90 

days unless a storage permit is obtained. 

Applicable for RCRA wastes; 

relevant and appropriate for nonRCRA wastes. 

Determination 

of cleanup 

standards 

SARA: Section 

121(d)(2)(ii); 

SDWA: 40 CFR 

Part 141 

Standards apply for 

treatment of surface 

water or groundwater 

that is to be used for 

dr i n ki n g wate r 

supplies. 

Remedial actions are required for 

groundwater to meet MCL goals (MCLGs) 

or MCLs established under the SDWA. 

Standards apply to surface & groundwater 

sources that may be used as drinking 

water. 

Remedial actions for surface and 

groundwater are required to meet 

federal MCL goals (MCLGs) or 

MCLs established under SDWA; or 

in the case of the former MEC site 

the NHDES site-specific criteria. 

RCRA: 40 CFR 

Part 262 

Standa rds that 

pertain to generators 

of hazardous waste. 

Potential hazardous waste generated by 

ISCO process is limited to drill cuttings, 

well purge water, PPE, and wastes 

generated from decontamination. 

Generators must dispose of wastes 

at facilities permitted to handle the 

waste. Generators must obtain an 

EPA ID number prior to disposal. 

Waste 

disposal 

CWA: 40 CFR 

Parts 403 and/or 

122 and 125 

S t an da rd s fo r 

dischar ge o f 

wastewater to a 

POTW or to a 

navigable waterway. 

Applicable and appropriate for well purge 

water and decontamination wastewater 

generated from drilling process. The ISCO 

process does not generate wastewater. 

Discharge of wastewater to a 

POTW must meet pre-treatment 

standards; discharges to a 

navigable waterway must be 

permitted under NPDES. 

RCRA: 40 CFR 

Part 268 

Standards regarding 

land disposal of 

hazardous wastes 

Applicable for off-site disposal of auxiliary 

waste (e.g., drill cuttings). 

Hazardous wastes must meet 

specific treatment standards prior 

to land disposal, or be treated using 

specific technologies. 

13 
2.8.1	 CERCLA 

The CERCLA of 1980 as amended by the Superfund 

Amendments and Reauthorization Act (SARA) of 1986 

provides for federal funding to respond to releases or 

potential releases of any hazardous substance into the 

environment. As part of the requirements of CERCLA, the 

EPA has prepared the National Oil and Hazardous 

Substances Pollution Contingency Plan (NCP) for 

hazardous substance response. The NCP is codified in 

Title 40 CFR Part 300, and delineates the methods and 

criteria used to determine the appropriate extent of removal 

and cleanup for hazardous waste contamination. SARA 

states a strong statutory preference for remedies that are 

highly reliable and provide long-term protection. It directs 

EPA to do the following: 

C Use remedial alternatives that permanently and 

significantly reduce the volume, toxicity, or the 

mobility of hazardous substances, pollutants, or 

contaminants; 

C Select remedial actions that protect human health 

and the environment, are cost-effective, and 

involve permanent solutions and alternative 

treatment or resource recovery technologies to the 

maximum extent possible; and 

C Avoid off-site transport and disposal of untreated 

hazardous substances or contaminated materials 

when practicable treatment technologies exist 

[Section 121(b)]. 

In general, two types of responses are possible under 

CERCLA: removal and remedial actions. Superfund 

removal actions are conducted in response to an 

immediate threat caused by a release of a hazardous 

substance. Many removals involve small quantities of 

waste of immediate threat requiring quick action to alleviate 

the hazard. Remedial actions are governed by the SARA 

amendments to CERCLA. As previously stated, these 

amendments promote remedies that permanently reduce 

the volume, toxicity, and mobility of hazardous substances 

or pollutants. 

The XDD ISCO process could possibly be part of a 

CERCLA remedial action since the toxicities of the 

contaminants of concern are intended to be reduced by 

chemical destruction or alteration. Remedial actions are 

governed by the SARA amendments to CERCLA. On-site 

remedial actions must comply with federal and more 

stringent state ARARs. ARARs are determined on a siteby-site basis and may be waived under six conditions: (1) 

the action is an interim measure, and the ARAR will be met 

at completion; (2) compliance with the ARAR would pose 

a greater risk to health and the environment than 

noncompliance; (3) it is technically impracticable to meet 

the ARAR; (4) the standard of performance of an ARAR 

can be met by an equivalent method; (5) a state ARAR has 

not been consistently applied elsewhere; and (6) ARAR 

compliance would not provide a balance between the 

protection achieved at a particular site and demands on the 

Superfund remedial project manager (RPM) for other sites. 

These waiver options apply only to Superfund actions 

taken on-site, and justification for the waiver must be 

clearly demonstrated. 

2.8.2	 RCRA 

RCRA, an amendment to the Solid Waste Disposal Act 

(SW DA), is the primary federal legislation governing 

hazardous waste activities. It was passed in 1976 to 

address the problem of how to safely dispose of the 

enormous volume of municipal and industrial solid waste 

generated annually. Subtitle C of RCRA contains 

requirements for generation, transport, treatment, storage, 

and disposal of hazardous waste, most of which are also 

applicable to CERCLA activities. The Hazardous and Solid 

Waste Amendments (HSW A) of 1984 greatly expanded the 

scope and requirements of RCRA. 

RCRA regulations define hazardous wastes and regulate 

their transport, treatment, storage, and disposal. These 

regulations are only applicable to the ISCO process if 

RCRA defined hazardous wastes are present. Hazardous 

wastes that may be present include contaminated soil 

cuttings and purge water generated during well installation 

and development, and the residual wastes generated from 

any groundwater sampling activities (e.g., PPE and purge 

water). If wastes are determined to be hazardous 

according to RCRA (either because of a characteristic or a 

listing carried by the waste), essentially all RCRA 

requirements regarding the management and disposal of 

this hazardous waste will need to be addressed by the 

remedial managers. 

W astes defined as hazardous under RCRA include 

characteristic and listed wastes. Criteria for identifying 

characteristic hazardous wastes are included in 40 CFR 

Part 261 Subpart C. Listed wastes from specific and 

nonspecific industrial sources, off-specification products, 

spill cleanups, and other industrial sources are itemized in 

40 CFR Part 261 Subpart D. RCRA regulations do not 

apply to sites where RCRA-defined wastes are not present. 

Unless	 they are specifically delisted through delisting 

14 
procedures, hazardous wastes listed in 40 CFR Part 261 

Subpart D currently remain listed wastes regardless of the 

treatment they may undergo and regardless of the final 

contamination levels in the resulting effluent streams and 

residues. This implies that even after remediation, treated 

wastes are still classified as hazardous wastes because 

the pre-treatment material was a listed waste. 

For generation of any hazardous waste, the site 

responsible party must obtain an EPA identification 

number. Other applicable RCRA requirements may 

include a Uniform Hazardous W aste Manifest (if the waste 

is transported off-site), restrictions on placing the waste in 

land disposal units, time limits on accumulating waste, and 

permits for storing the waste. 

Requirements for corrective action at RCRA-regulated 

facilities are provided in 40 CFR Part 264, Subpart F and 

Subpart S, which also generally apply to remediation at 

Superfund sites. Subparts F and S include requirements 

for initiating and conducting RCRA corrective action, 

remediating groundwater, and ensuring that corrective 

actions comply with other environmental regulations. 

Subpart S also details conditions under which particular 

RCRA requirements may be waived for temporary 

treatment units operating at corrective action sites and 

provides information regarding requirements for modifying 

permits to adequately describe the subject treatment unit. 

2.8.3 CAA 

The CAA establishes national primary and secondary air 

quality standards for sulfur oxides, particulate matter, 

carbon monoxide, ozone, nitrogen dioxide, and lead. It 

also limits the emission of 189 listed hazardous pollutants 

such as vinyl chloride, arsenic, asbestos and benzene. 

States are responsible for enforcing the CAA. To assist in 

this, Air Quality Control Regions (AQCR) were established. 

Allowable emission limits are determined by the AQCR, or 

its subunit, the Air Quality Management District (AQMD). 

These emission limits are based on whether or not the 

region is currently within attainment for National Ambient 

Air Quality Standards (NAAQS). 

The CAA requires that treatment, storage, and disposal 

facilities comply with primary and secondary ambient air 

quality standards. The most likely air emissions that would 

be anticipated with an activity associated with ISCO would 

be VOC emissions generated during drilling activities. The 

ISCO process also uses a generator during injections. 

However, these potential emissions would typically be very 

low concentrations and are easily monitored on-site. 

2.8.4 CWA 

The objective of the CW A is to restore and maintain the 

chemical, physical and biological integrity of the nation's 

waters by establishing federal, state, and local discharge 

standards. If treated water is discharged to surface water 

bodies or Publicly Owned Treatment Works (POTW ), CWA 

regulations will apply. A facility desiring to discharge water 

to a navigable waterway must apply for a permit under the 

National Pollutant Discharge Elimination System (NPDES). 

NPDES permits include waste discharge requirements. 

Discharges to POTW s also must comply with general 

pretreatment regulations outlined in 40 CFR Part 403, as 

well as other applicable state and local requirements. 

Since XDD’s chemical oxidation process is in situ and 

purge water generated during the demonstration was 

containerized and properly disposed of, CW A criteria did 

not apply for this demonstration. 

2.8.5 SDWA 

The SDW A of 1974, as most recently amended by the Safe 

Drinking Water Amendments of 1986, requires the EPA to 

establish regulations to protect human health from 

contaminants in drinking water. The legislation authorized 

national drinking water standards and a joint federal-state 

system for ensuring compliance with these standards. 

The National Primary Drinking W ater Standards (NPDW S) 

are found in 40 CFR Parts 141 through 149. Parts 144 and 

145 discuss requirements associated with the underground 

injection of contaminated water. If underground injection 

of wastewater is selected as a disposal means, approval 

from EPA or the delegated state for constructing and 

operating a new underground injection well is required. 

The contaminated groundwater at the former MEC Building 

site is not considered a source of drinking water. However, 

if the groundwater was to be used for drinking purposes 

while providing no additional treatment, the quality of the 

water would need to meet NPDW S. These are much more 

stringent than State of New Hampshire (NH) 0.5% aqueous 

solubility cleanup criteria specific to the former MEC 

Building site. Table 2-3 provides a comparison between 

these site specific criteria and federal drinking water 

standards. 

2.8.6 OSHA 

CERCLA remedial actions and RCRA corrective actions 

must be performed in accordance with the OSHA 

requirements detailed in 20 CFR Parts 1900 through 1926, 

especially Part 1910.120, which provides for the health and 

safety of workers at hazardous waste sites. On-site 

15 
Table 2-3. Groundwater Cleanup Criteria Comparison. 

Analyte 

0.5% aqueous solubility 

- State Regulatory Goal 

for the former MEC 

Building site (:g/L) 

National Primary 

Drinking Water 

Standards (:g/L) 

PCE 750 5 

TCE 5,500 5 

cDCE 17,500 70 

VC NA 2 

Toluene 2,750 1,000 

1,1,1-TCA 6,800 200 

1,1-DCA 27,500 ---

construction activities at Superfund or RCRA corrective 

action sites must be performed in accordance with Part 

1926 of OSHA, which describes safety and health 

regulations for construction sites. State OSHA 

requirements, which may be significantly stricter than 

federal standards, must also be met. 

If working at a hazardous waste site, all personnel involved 

with the installation of wells and implementation of the XDD 

treatment process are required to have completed an 

OSHA training course and must be familiar with all OSHA 

requirements relevant to hazardous waste sites. Workers 

on hazardous waste sites must also be enrolled in a 

medical monitoring program. The elements of any 

acceptable program must include: (1) a health history, (2) 

an initial exam before hazardous waste work starts to 

establish fitness for duty and as a medical baseline, (3) 

periodic examinations (usually annual) to determine 

whether changes due to exposure may have occurred and 

to ensure continued fitness for the job, (4) appropriate 

medical examinations after a suspected or known 

overexposure, and (5) an examination at termination. 

For most sites, minimum personal protective equipment 

(PPE) for workers will include gloves, hard hats, steel-toe 

boots, and tyvek coveralls. Depending on contaminant 

types and concentrations, additional PPE may be required, 

including the use of air purifying respirators or supplied air. 

For an ISCO process, XDD personnel utilized coated tyvek 

and respirators during the batching operation to minimize 

inhalation and dermal exposure to the strong oxidizer used. 

Noise levels would potentially be high only during drilling 

activities involving the operation of a drill rig or DPT probe. 

During these activities, noise levels should be monitored to 

ensure workers are not exposed to levels above a timeweighted average of 85 decibels over an eight-hour day. 

W orkers are required to wear hearing protection at noise 

levels above 85 decibels. The levels of noise anticipated 

are not expected to adversely effect the community, but 

this will depend on proximity to the treatment site. 

2.8.7 State and Local Requirements 

State and local regulatory agencies may require permits 

prior to implementing an ISCO technology and/or for 

specifically treating chlorinated ethenes. Specific to the 

State of New Hampshire, XDD was required to acquire an 

injection permit prior to implementing their treatment. 

Most federal permits will be issued by the authorized state 

agency. NH requires that a Groundwater Management 

Permit be issued to a site owner or legally responsible 

person to remedy contamination associated with the past 

discharge of regulated contaminants, and to manage the 

use of the contaminated groundwater. The state may also 

require a Treatment, Storage, and Disposal (TSD) Permit 

for on-site storage of hazardous waste for greater than 90 

days. An air permit issued by the state AQCR may be 

required if air emissions in excess of regulatory criteria, or 

of toxic concern, are anticipated (highly unlikely for this 

technology). Wastewater discharge permits may be 

required in the unlikely event that wastewater were to be 

discharged to a POTW . If remediation is conducted at a 

Superfund site, federal agencies, primarily the USEPA, will 

provide regulatory oversight. If off-site disposal of 

contaminated waste is required, the waste must be taken 

to the disposal facility by a licensed transporter. 

For the Demonstration, there were cleanup standards for 

both the soil and groundwater. The groundwater standards 

were based on the solubility of DNAPL and were 

presented in Table 2-2 as compared to U.S. EPA's MCLs 

for drinking water. The State of NH soil standards, referred 

to as S-1 Soil Standards, are as follows: 

< PCE 2 mg/Kg


< TCE 0.8 mg/Kg


< cDCE 2 mg/Kg


< VC 0.4 mg/Kg


< Toluene 100 mg/Kg


< 1,1 - TCA 42 mg/Kg


16 
Table 3-1. Treatment Design for Hypothetical Site. 

Injection Wells Oxidant Injection 

No. of wells 10 KMnO4 concentration 40 g/L 

Well spacing -18 ft Flow Rate/per well 2 gpm 

Well head ID 2 in. Volume injected 56,000 gal

(212,000 L) 

Screen length 10 ft Mass injected 14,000 lbs

(635 kg) 

Screened int. 30-40 ft Area treated 100,000 ft

2 

Radius of infl. 10 ft Volume treated 37,000 yd3 

Diam. Of infl. 20 ft Residence Time # 1 month 

For this cost estimate a larger hypothetical site is used to 

better represent full-scale remediation. Figure 3-1 

illustrates a hypothetical site, having an areal extent of 100 

ft x 32 ft (-32,000 ft 2

), or about 3⁄4 of an acre. Basic 

characteristics of this hypothetical site are as follows: 

Section 3.0


Economic Analysis


3.1	 Introduction 

The purpose of this economic analysis is to estimate costs 

for chlorinated ethene remediation of soil and groundwater 

utilizing a specialized application of in situ chemical 

oxidation (ISCO) developed by Xpert Design and 

Diagnostic’s (XDD) LLC of Stratham, New Hampshire. The 

estimated costs for this technology are based on 

information provided by XDD, and observations made by 

SITE Program personnel during the demonstration. 

The areal extent of the Demonstration treatment system’s 

injection wells, monitoring wells, and soil borings was 

roughly 1,200 ft2	 (114 m 2

). Based on groundwater levels of

about 3 ft bgs (as measured in June 2005, the vertical 

extent of contamination at the former MEC site was 

characterized to be roughly 22 ft (i.e., 3-25 ft bgs). 

Therefore the volume of groundwater and saturated soil 

targeted for treatment was approximately 27,000 ft3

 (1,000

yd 3

). This size can be considered pilot-scale. 

� Similar to the former MEC Building site, 

contamination consists of chlorinated compounds 

(e.g., PCE, TCE, cDCE, and VC). Contaminant 

concentrations and cleanup goals are the same; 

� Site characterization studies has identified a long, 

narrow DNAPL plume, approximately 100 ft long 

and 25 ft wide (30.5 x 7.6 m) is slowly dispersing 

from the source area and is following an easterly 

groundwater flow pattern; 

� The saturated soils occur from about 18-50 ft (5.5­

15.2 m) bgs and overlay a relatively impervious 

bedrock. Therefore, aquifer thickness at this 

specific location is approximately 32 ft (9.8 m). The 

volume of saturated aquifer material to be treated 

is roughly 100,000 ft3

 (100 ft x 32 ft x 32 ft).

� Site geology is similar to the demonstration site, 

but does not contain the thin peat layer that 

required an extraordinary effort to treat. Instead a 

loamy soil overlies the bedrock. There is a slight 

horizontal hydraulic gradient of - 0.04 ft/ft; 

� Relative to the plume, there are one upgradiant 

and two downgradiant monitoring wells. However, 

there are no wells set within the immediate plume 

area. Therefore, oxidant injection wells are 

available for monitoring. 

� The specific treatment design parameters for the 

hypothetical site are summarized in Table 3-1. 

17 
Figure 3-1 Hypothetical ISCO Site 

As shown in Figure 3-1, the plume is positioned at a slight 

angle and is situated between 35-45 ft bgs. Groundwater 

is at about 18 ft bgs, thus the estimated thickness of the 

saturated zone is approximately 32 ft (9.8 m). XDD in 

some instances could use well clusters to inject oxidant at 

various depths (this was done during the demonstration). 

However for this hypothetical site setting the screens at 30­

40 ft (9.1-12.2 m) bgs, should enable delivery of oxidant to 

the shallowest occurrences of the plume while downward 

flow of oxidant should enact contact with the deepest 

occurrences of the plume (i.e., entire plume thickness). 

Although the plume is depicted as narrow (i.e., about 25 ft 

or 7.6 m wide), dissolved phase organic compounds occur 

in the groundwater surrounding the plume. Overlapping 

radii of influences (depicted by the circles on Figure 3-1) 

are a conservative way of completely enveloping the entire 

plume and at the same time directing oxidant to 

contaminated groundwater surrounding the plume. 

The costs associated with implementing the XDD’s ISCO 

process at this hypothetical site have been broken down 

into 12 cost categories that reflect typical cleanup activities 

at Superfund sites. They include the following:

 (1) Site Preparation

 (2) Permitting and Regulatory Activities

 (3) Capital Equipment

 (4) Start-up and Fixed

 (5) Labor

 (6) Consumables and Supplies

 (7) Utilities

 (8) Effluent Treatment and Disposal

 (9) Residuals Shipping, & Disposal 

(10) Analytical Services 

(11) Maintenance and Modifications 

(12) Site Restoration/Demobilization 

Table 3-2 presents a categorical breakdown of the 

estimated costs for implementing XDD’s ISCO process at 

the hypothetical site, assuming a single injection event and 

monitoring consisting of a pre-injection sampling of soil 

and groundwater, one intermediate groundwater sampling, 

and a final post-treatment sampling of soil and 

groundwater. As with all cost estimates, there are 

associated factors, issues, and assumptions that caveat 

specific cost values. The major factors that can affect 

estimated costs are discussed in subsection 3.3. Specific 

issues and assum ptions m ade regarding site 

characteristics are incorporated into the cost estimate. 

They are discussed in subsection 3.4. 

18 
1 Table 3-2. Cost Estimate for Full-Scale Application.

2 Cost Category Quantity Units Unit Cost $ Total $/Category % of Total 2 

1. Site Preparation $1,000 0.7

 Site Clearing
 NA Each $0 $0

 Shipment of KMnO4
 1 Each $1,000 $1,000 

2. Permitting & Regulatory Activities $1,000 0.7

 GW Management Permit
 1 Each $1,000 $1,000

 Other Regulatory Requirements
 NA Each $0 $0 

3. Capital Equipment $5,100 3.7

 Storage Building (10 ft x 15 ft x 8 ft) 1 Each $1,000 $1,000

 Bladder Pumps/Tubing 5 Each $600 $3,000 

 Pump Flow Regulator 1 Each $1,100 $1,100 

4. Startup & Fixed $24,500 18

 Treatability Study (oxidant dosing) 3 Samples $1,500 $4,500 3 Injection Well Installation 10 Each $2,000 $20,000 

5. Labor $29,900 21

 Permit Preparation Costs 4 Hours $80 $320

 System Design 40 Hours $80 $3,200 

 W ell Installation Oversight 50 Hours $80 $4,000 

 KMnO4 Injection (XDD) 4 120 Hours $60 $7,200 

 GW Evaluation Sampling (3 events) 60 Hours $60 $3,600 

 Soil Evaluation Sampling (2 events) 120 Hours $60 $7,200 

 Site Restoration/Demobilization 20 Hours $60 $1,200 

 Report Preparation 40 Hours $80 $3,200 

6. Consumables and Supplies $56,300 41

 Granular KMnO4 14,000 lbs $2.30 $32,200 

 Potable Water (tankers) 56,000 Gallons $0.10 $5,600

 Rental - Geoprobe + mob./demob. 6 Day $1,400 $8,400

 Rental - Steam Cleaner 6 Day $150 $900

 Rental - XDD POD 1 W eek $4,500 $4,500

 Rental - Pick-Up Truck 1 W eek $225 $225

 Rental - Generator (70 KVA) 1 W eek $700 $700

 Rental - Pumps (1 sump; 2 centrifugal) 1 W eek $135 $135

 Rental - 500 gal. Poly Tanks w/mixer 2 W eek $105 $210

 Rental - H&S Equipment (PID & CGM) 3 W eek $350 $1,050 

 Rental - GW Sampling Equipment 6 Day $122 $730 5 Other Miscellaneous Supplies NA NA $1,700 $1,700 

7. Utilities NA NA NA $0 $0 0 

8. Effluent Treatment & Disposal NA NA NA $0 $0 0 

9. Residuals Shipping & Disposal $2,500 1.8

 Contaminated Solids 6
 4 Drums $90 $360 

 Contaminated Liquids 6
 15 NA $145 $2,175 

10. Analytical Services $13,500 9.7 

VOCs in Soil
 60 Each $130 $7,800 

VOCs in Groundwater
 30 Each $150 $4,500 

Sample Shipments
 23 Each $50 $1,150 

11. Maintenance & Modifications NA NA $0 $0 $0 

12. Site Restoration (Borehole grouting) 2,400 Feet $2 $4,800 $4,800 3.4 

Total Estimated Cost $139,000 100 1

 Based on the hypothetical site characteristics described in subsection 3.1, one injection application, and a treatment period of at least 1 month. 2

 Cost value totals are rounded to three significant digits; % of total values are rounded to two significant digits. 3 Includes installing 2 inch ID PVC wells to 40 ft bgs using a geoprobe with DPT. Well completion materials consist of road boxes. 4 Includes one day to set up and five days for KMnO 4 injection. 5

 Includes such items as PPE, well connect fittings, calibration gases, and shipping charges for rental equipment. 6

 Solids include drill cuttings, residual sample, sample liners, visqueen, and PPE. Liquids include well development water and sample purge water. 

19 
The basis for costing each of the individual 12 categories 

in Table 3-2 is discussed in detail in subsection 3.5. Much 

of the information presented in that subsection has been 

derived from observations made from the SITE 

demonstration that was conducted over an approximate 11 

month period at the former MEC Building site in Hudson. 

NH. Other cost information has been acquired through 

subsequent discussions with XDD representatives, 

information gathered from www.XDD-llc.com, and 

researching current estimates for specific cost items 

related to the technology. 

It should be emphasized that the cost figures provided in 

this economic analysis are “order-of-magnitude” estimates, 

generally + 50% / -30%. 

3.2	 Conclusions 

(1)	 The cost to install a 10-injection well ISCO 

treatment system, utilizing XDD’s POD to deliver 3 3 oxidant to approximately 100,000 ft (3,700 yd ) of 

DNAPL-contaminated soil and groundwater, and 

monitor effectiveness over a 1-month period is 

estimated at $139,000. If further treatment were 

required (i.e., re-injection), thus extending the 

treatment period, the cost would increase by a 

considerable amount. 

(2)	 The largest cost categories for the application of 

the XDD ISCO technology at a site having 

characteristics similar to those described for the 

hypothetical site are 1) consumables and supplies 

(41%) and 2) labor (21%), together accounting for 

62% of the total cost. The other major costs, as 

estimated, include startup and fixed (18%),and 

analytical services (9.7%). 

(3)	 The cost of implementing XDD’s process may be 

less or more expensive than the estimate given in 

this economic analysis, depending on several 

factors. Such factors may include the depth and 

areal extent of the contaminated media, site 

geology, contaminant concentration levels, the 

level of site preparation required, number of 

injection/monitoring wells needed to be installed, 

and the cleanup goals and process monitoring 

required by a regulatory agency. 

3.3	 Factors Affecting Estimated Cost 

There are a number of factors that could affect the cost of 

treating soils and groundwater contaminated with 

chlorinated VOCs using XDD’s ISCO technology. It is 

apparent that the number of injection wells required to 

deliver the oxidant to affected areas, the quantity of oxidant 

needed, and the number of wells required for monitoring 

the treatment have very significant impacts on up-front 

costs. The contaminant distribution pattern has the 

largest impact on the number of injection wells required to 

attain a sufficient area of oxidant coverage to contact and 

degrade the contaminants to acceptable levels. Soil 

humic content is a critical factor for determining the types 

and quantity of oxidants used, which would obviously 

directly affect treatment cost as well. 

Site hydrogeology is an important cost consideration, 

since it can dictate how well the oxidant will work, the 

ease of which oxidant can be injected and how many 

injection points may be needed; regardless of whether 

those points are injection wells, drive points, infiltration 

galleries, or simple pits. The amount and spacing needed 

for injection and the desired screened depth intervals 

determine if such injection methods were feasible. In 

general, increased drilling locations and deeper drilling 

directly lead to increased drill footage costs, increased 

decontamination costs, and increased costs for well 

construction materials. 

3.4	 Issues and Assumptions 

This section summarizes the major issues and 

assumptions used to estimate the cost of implementing 

the ISCO at full-scale. In general, the assumptions are 

based primarily on information provided by XDD and 

observations made by SAIC during the SITE 

demonstration. 

3.4.1	 Site Characteristics 

Site characteristics are an important consideration for 

deciding whether an ISCO process is an appropriate 

remedy for treating chlorinated ethenes at a particular site. 

In general in situ processes are more appropriate when 

contaminated soils and groundwater are at depth; which 

makes excavation and disposal too costly. Site geology 

must be well defined to determine areas of high humic 

content. Specific aspects of the groundwater flow regime 

(i.e., flow direction and rate), as well as plume delineation, 

need to be known prior to installing oxidant injection wells. 

The following specific assumptions have been made 

regarding the site characteristics of the hypothetical site. 

1.	 The target contaminated soil hotspots have been 

characterized with CPT/MIP technology, as was 

the case with the demonstration. 

2.	 Groundwater occurs at about 18 ft (5.5 m) bgs 

and has a well-defined flow pattern to the north. 

3.	 Groundwater at the site is contaminated primarily 

with chlorinated ethenes (PCE and TCE) as both 

DNAPL and a dissolved phase mobile plume. 

Also present as breakdown products are cDCE 

and VC. Concentrations of these compounds 

20 
well exceed their respective cleanup standards. 

Other contaminants (e.g., metals) either are not 

present at the site or have inconsequential 

concentrations. 

4.	 Site soils are assumed to have a low to moderate 

humic content, ensuring that the majority of the 

injected KMnO4 will react with contaminants and 

not with naturally occurring humic material. 

5.	 The site is easily accessible and secured; 

therefore there is no need to install special access 

roads, security fencing, etc. is not required. Also, 

there are no overhead, surface, or underground 

impediments that would interfere with borehole 

drilling and oxidant injection. 

3.4.2	 Design and Performance Factors 

The most important design aspects of ISCO processes is 

the selection of oxidant, oxidant dosage, and the injection 

well network (i.e., the number, depth, and areal pattern of 

injection wells) required for optimum treatment. Injection 

well spacing is usually dictated by the site geology. 

The following assumptions are made regarding the 

injection well network installed at the hypothetical site. 

(1)	 Ten injection wells, spaced - 18 ft (5.5 m)apart in 

two rows, will provide sufficient coverage of 

contaminated media above action levels. 

(2)	 All injection wells are constructed of 2 inch ID PVC 

casing and 10 ft-long, 40 slot well screens. The 

well screens are set at 30-40 ft bgs, above the top 

of bedrock at about 50 ft (15 m) bgs. W ells are 

flush mounted with road boxes. 

(3)	 As was the case with the demonstration site, pushpoints are not feasible. Therefore, a hollow stem 

auger (HSA) rig is required to drill 41⁄2 inch ID 

boreholes and set the wells. 

(4)	 Potassium permanganate (KMnO ) is used as the 4 

oxidizing agent of choice. A total of 15,000 gal. 

(56,800 L) of KMnO is to be injected once into the 4

contaminated area (1,600-1,700 gallons or 6,100­

6,400 L per well), at a concentration of 40 g/L. 

(5)	 Treatment duration is assumed to be at minimum 

of one month. Additional treatment (i.e., reinjection) is not considered for costing purposes, 

however monitoring is mandated for one year. 

3.4.3	 Financial Assumptions 

All costs are presented in Year 2006 U.S. dollars (unless 

otherwise noted) without accounting for interest rates, 

inflation, or the time value of money. Insurance and taxes 

are assumed to be fixed costs lumped into the specific 

costs under the “Startup and Fixed” category. Any 

licensing fees and site-specific royalties passed on by the 

developer, for use of any proprietary injection equipment 

or methods, would be considered profit. Those fees are 

not included in the cost estimate. 

3.5	 Basis for Economic Analysis 

In this section, each of the 12 cost categories that reflect 

typical clean-up activities encountered at Superfund sites, 

are defined and discussed. Combined, these 12 cost 

categories form the basis for the detailed estimated costs 

presented in Table 3-1. The labor costs are grouped into 

a single labor category (subsection 3.5.5). 

3.5.1	 Site Preparation 

Site preparation includes all activities necessary for 

preparing the site for installing injection wells and injecting 

of the KMnO4 oxidant. Included in this setup phase are 

non-labor cost for conducting any clearing and/or 

regrading of the site, hooking up utilities, providing for the 

storage of oxidant, and staging of equipment and 

supplies. Each of these site setup cost components is 

discussed in the following paragraphs. 

3.5.1.1 Site Clearing 

Although the XDD ISCO process does not require a large 

amount of setup space, such in situ processes typically 

involve subsurface drilling in some form. General 

requirements apply to all drilling operations. All 

impediments and surface, overhead and underground 

obstacles must be identified. These would include trees, 

utility lines and piping, sewers, drains, and landscape 

irrigation systems. 

No site clearing of above-ground obstructions or regrading 

was necessary at the demonstration site, however, a 

survey of potential underground utility lines was required 

to obtain a “dig safe” clearance before drilling activities 

could be initiated. For this economic analysis, an 

assumption is made that for the hypothetical site that 

there is no impediments in the area of the proposed ISCO 

injection and monitoring operations. Thus, there is no 

associated cost for site clearing. 

3.5.1.2 Site Setup 

Site setup typically includes making arrangements to 

secure a trailer, hooking up utilities, etc., and shipping 

supplies. If the treatment is being implemented at an 

active facility (such as the former MEC Building site), 

there may be no need for a site trailer. For the 

hypothetical site, this also will be the case. However, due 

to the large quantity of oxidant to be used a small building 

or shed will be needed to store the many jugs of KMnO4 

oxidant away from facility workers. 

21 
Because XDD is able to power the POD, pumps, and other 

equipment with a large portable generator, there is no need 

for hooking up electricity. As a result, the non-labor costs 

associated with site setup phase would most only include 

shipment of oxidant (as explained below). 

Shipment of Oxidant 

After the injection wells have been installed, the KMnO4 is 

shipped in bulk and properly stored at the site. (Note: 

granular KMnO4 has a reported shelf life of one year and 

should be stored in a dry place). The KMnO4 is packaged 

and shipped in 20 Liter (5.3 gal.) jugs. Each bucket 

contains approximately 55 pounds of KMnO . For the 4

hypothetical site, it is anticipated that a minimum of 250 

buckets will be required to ship approximately 14,000 lbs 

(635 kg) of KMnO . For large quantities such as this, the 4

buckets are stacked and secured on wooden pallets that 

can be transferred to the batching area with a forklift. 

XDD commonly uses a specific carrier for shipping oxidant 

and has estimated that shipping approximately 7,800 lbs of 

granular KMnO4 to the former MEC Building site cost 

approximately $900. For this cost estimate, a shipping cost 

of $1,000 will be used. 

3.5.2 Permitting and Regulatory Requirements 

3.5.2.1 Permitting Requirements 

Several types of permits may be required for implementing 

a full-scale ISCO remediation. Permits required may 

depend on the type and concentration of the contamination, 

the regulations covering the specific location, and the site’s 

proximity to residential neighborhoods. For example, the 

New Hampshire Department of Environmental Services 

(NHDES) requires a site owner or legally responsible 

person to remedy contamination associated with the past 

discharge of regulated contaminants, and to manage the 

use of contaminated groundwater. 

A Groundwater Management Permit (GMP) from the State 

is required for such endeavors. The application for the 

GMP must be prepared and stamped by a professional 

engineer (PE) or a professional geologist (PG) licensed in 

the State. There is an application fee of $1,000. 

Specific to ISCO processes there is in most cases, if not 

all, a requirement to obtain an injection permit. There may 

or may not be a fee for this. For the former MEC Building 

site, XDD was required to apply for and acquire an injection 

permit from the NHDES. However, there was no actual 

permit fee. Note that other states may require a fee. 

3.5.2.2 Other Regulatory Requirements 

The costs incurred for receiving approval from regulatory 

agencies to install a treatment system may include those 

associated with preparing site characterization reports and 

the feasibility study for treatment system design, and 

attending meetings with regulators for discussing 

comments and supplying related documentation for 

acquiring approval for implementing the treatment 

technology. 

Depending upon the classification of the site, certain 

RCRA requirements may have to be satisfied as well. For 

active Superfund sites it is possible that the technology 

could be implemented under the umbrella of existing 

permits and plans held by the site owner or other 

responsible party (e.g., the GMP). Certain regions or 

states have more rigorous environmental policies that 

may result in higher costs for permits and verification of 

cleanup. Added costs may result from investigating all 

regulations and policies relating to the location of the site; 

and for conducting a historical background check for fully 

understanding the scope of the contamination. Specific to 

ISCO technologies, states may require that injection wells 

be properly abandoned/decommissioned if they are no 

longer to be used. 

Due to the very site-specific nature of these costs, an 

assumption will be made that sufficient pre-existing site 

information exists for regulators to allow initiation of 

treatability and/or pilot-scale field studies. As a result, no 

further costs regarding regulatory requirements will be 

incurred. 

3.5.3 Capital Equipment 

In many instances ISCO processes consist of one-time 

applications at a particular contaminated area. As a 

result, the equipment for injection is required for a short 

period of time and is thus rented (see 3.5.6). Even if 

multiple injection applications are necessary, they would 

not occur immediately following an initial injection. 

Therefore, the equipment would be re-mobilized and 

rented again for additional injection events. 

For the particular hypothetical site example used for this 

economic analysis, it is assumed that the only capital 

equipment required is an outdoor shed to store oxidant, 

and dedicated bladder pumps used for groundwater 

monitoring before and after treatment. (Note: a peristaltic 

pump was used for collecting demonstration groundwater 

samples because water was pulled from less than 25 ft 

bgs. Since groundwater contamination at the hypothetical 

site is below the maximum sample depth of peristaltic 

pumps (i.e., > 25 ft bgs), other alternatives must be used. 

The storage shed must be large enough to contain 

approximately 250 jugs of KMnO . If the injection were to 4

take place in cold temperatures, the shed would need to 

22 
be heated to prevent freezing of the granular oxidant. 

However, for this scenario, this is not the case). The 

installation of the prefabricated shed for the hypothetical 

site is estimated to be $1,000. 

Although bladder pumps and tubing are relatively 

expensive, once installed these dedicated pumps 1) assure 

that there is no air/water contact during sampling; and 2) 

they eliminate the need to decontaminate sample collection 

equipment between wells and reduce the chance of crosscontamination or the introduction of decontamination 

chemicals into the groundwater. In essence, much of the 

capital expenditure related to the use of dedicated bladder 

pumps is recouped by reduced labor costs. 

Teflon bladder pumps with stainless steel housings can be 

purchased for about $500. Along with associated tubing, 

the cost of each pump is about $600. Five of the ten 

injection wells are to be sampled to monitor treatment 

effectiveness. Therefore, the total cost for five bladder 

pumps is estimated to be $3,000. A pump flow controller, 

estimated to cost $1,100, is required to regulate 

compressed air as a cycle of pulses that corresponds to a 

desired groundwater flow rate out of the well. The high 

rental cost of this equipment justifies its purchase if used 

for several sampling events. The total cost for capital 

equipment is estimated to be approximately $4,100. 

3.5.4 Startup and Fixed Costs 

Startup and fixed costs include those costs that must be 

incurred before treatment can commence. They are one 

time non-recurring costs in which labor is typically 

imbedded within a flat fee for a task. Based on information 

provided by XDD and SITE demonstration observations, 

these costs for full scale ISCO applications include 

primarily 1) initial treatability testing; 2) installation of 

injection wells and, if needed, 3) pilot-scale testing. 

Estimates for all three of these startup and fixed costs are 

discussed in the following subsections. 

3.5.4.1 Treatability Study 

Initial treatability testing is necessary for determinating 

whether the technology is feasible a particular site. XDD 

performed a two-part bench-scale treatability study prior to 

the demonstration; 1) A dosing study determined 

permanganate dosing level and exposure period for 

evaluating process effectiveness and assessment of 

feasibility of attaining site-specific cleanup goals; 2) A soil 

oxidant demand (SOD) study to estimate SOD for the three 

major soil units. The results of the treatability study helped 

XDD develop a site-specific strategy for applying ISCO 

treatment at the former MEC Building site. 

Per XDD, the SOD determination is always conducted. 

The cost for XDD treatability studies run approximately 

$1,500 per sample. Because there are no distinct soil 

zones at the hypothetical site, an assumption is made that 

three samples of the site soils are sufficient for 

determining SOD, even though the site is four times larger 

than the demonstration site. Therefore, treatability study 

costs are estimated at $4,500. 

3.5.4.2 Injection Well Installation 

The amount and location of oxidant injection points and 

the number of points required for monitoring 

effectiveness is highly site-specific. The number of 

injection wells required to produce an adequate ISCO is 

relatively high. Close injection well spacing is typically 

needed in heterogeneous soils to ensure adequate 

coverage. For the hypothetical site a total of 10 injection 

wells, each screened from 30-40 ft (9.1-12.2 m) is 

assumed sufficient to inject the volume of oxidant needed 

to treat 3,700 yd3

 of contaminated material. 

XDD prefers to inject into 2-inch ID wells installed within 

a 41⁄2 or 6-inch ID borehole. It should be noted that direct 

push technology (DPT) can be used to install wells and 

has the advantage of minimizing generation of 

contaminated soil cuttings. However, using traditional well 

installation methods involve auguring of larger boreholes 

that result in larger diameter annular spaces between the 

well casing and borehole sides. This makes for easier 

installation of a filter pack and bentonite seal. For the 

hypothetical site, each of the 10 injection wells is to be 

installed using HSA to drill 41⁄2-inch boreholes. 

An all inclusive well installation cost of $50 per foot will be 

assumed for this cost estimate (i.e., cost to include 

mobilization, demobilization, drilling, well materials and 

well development). The $50 rate would correlate to 

drilling costs of $2,000 per well (i.e., there are 10 wells 

total to be installed at a depth of 40 ft bgs. Therefore, the 

estimated total injection well drilling cost is $20,000. 

The total startup and fixed costs for this economic 

analysis is thus estimated to be approximately $24,500. 

3.5.4.3 Pilot-Scale Testing 

In addition to the bench-scale treatability study of 

formation material and sample groundwater, pilot-scale 

testing may be appropriate in certain instances. XDD 

sometimes conducts water injection testing on prospective 

injection wells, a practice they are utilizing more 

frequently. As an example, for the demonstration project 

at the former MEC Building site, XDD performed a smallscale water injection test at a target flow rate to monitor 

well seal and injection pressures of newly-installed 

injection wells. The costs of such field tests are almost 

exclusively labor (see 3.5.5). 

23 
Table 3-3. Estimated Labor Costs. 

Category Hours Cost 

Permit Preparation 4 $320 

System Design 40 $3,200 

Injection Well Installation 50 $4,000 

Oxidant Injection 120 $7,200 

Treatment Monitoring 180 $10,800 

Site Restoration/Demobilization 20 $1,200 

Report Preparation 40 $3,200 

Totals 454 $29,920 

3.5.5 Labor 

This subsection describes the core labor costs that are 

associated with the XDD ISCO technology. The hourly 

labor rates presented are loaded, which means they are 

intended to include base salary, benefits, overhead, and 

general and administrative (G&A) expenses. Travel, per 

diem, and standard vehicle rental have not been included 

in these figures. The labor tasks have been broken down 

into subcategories that represent distinct phases of 

technology implementation (Table 3-3). 

3.5.5.1 Permit Preparation 

As discussed in subsection 3.5.2 there is a fee for certain 

permits. However, researching permit requirements and 

preparing applications takes time and thus incurs a labor 

cost. If a groundwater management permit and injection 

permit are to be required for the hypothetical site the 

applications would have to be submitted by either a 

professional engineer (PE) or professional geologist (PG) 

licensed in the particular state that the site is located in. 

Assuming that both applications are prepared and 

submitted by a PE or PG in two hours at $80/hr, permit 

preparation costs can be estimated at $320. 

3.5.5.2 System Design 

In most all instances system design is conducted by the 

remediation contractor, in this case XDD. The information 

that XDD needs for system design are the 1) amount of 

contaminants present (i.e., mass and extent) and 2) Site 

hydrogeological information. For the SITE demonstration 

the system design was a joint effort among EPA, SAIC, 

XDD, the site owner and their remediation contractor. 

Although the demonstration project was smaller in scale 

than the remediation scenario used for this economic 

analysis, the experimental design for evaluating treatment 

effectiveness was relatively complex. 

Per XDD, it takes roughly 1-2 people any where from 2-5 

days to complete a proposed treatment strategy, 

depending on complexity. For this cost estimate, the 

primary labor task relating to system design would involve 

a senior level scientist or engineer reviewing existing site 

characterization data for the hypothetical site, reviewing 

results from SOD treatability testing of site samples, 

calculating oxidant mass and concentration, and 

determining location, depth, and number of injection wells 

needed to adequately treat the contaminated DNAPL 

plume. Assuming a 40-hr week sufficient to accomplish 

this task, and a labor rate of $80/hour, an estimated labor 

cost of $3,200 would be incurred for system design. 

3.5.5.3 Injection Well Installation Oversight 

Although drilling and well installation labor activities are 

performed by a drilling contractor, the remediation 

contractor (e.g., XDD) at a site would be responsible for 

logging boreholes, monitoring for VOCs and explosive 

conditions, and ensuring that well construction and 

installation is conducted in accordance with design 

specifications. It should be noted that since the 

hypothetical site is adequately characterized, geologic 

descriptions would not be required when drilling the 

boreholes for injection wells. 

During the demonstration, it took approximately four days 

for a subcontracted driller to mobilize to the site, install six 

injection wells to an average drilling depth of 16 ft using a 

hollow stem auger (HSA), conduct flush mount well 

completion with road boxes, develop the wells, and 

demobilize. Assuming that the drilling subcontractor is 

local and that there are only minor drilling impediments, 

the time required to mobilize, install 10 injection wells 40 

feet through unconsolidated sediments with similar well 

completion, and demobilize is estimated to take 

approximately one week. Assuming 10-hour days are 

required for subcontractor oversight, a geologist’s labor at 

an $80/hour rate would result in $4,000 in oversight labor. 

3.5.5.4 Oxidant Injection 

Assuming the site is within a 1⁄2 day or less driving 

distance (i.e., the demonstration site), mobilization and 

equipment setup can be done in one day by two people. 

The following tasks comprise the basic setup of 

equipment. 

• Oxidant delivery/storage of KMnO 4 

• Setup of spill guards for batch area 

• Potable water delivery (tanker) 

• Drop-off of rented generator 

• Hookup of batch operation to POD 

• Connect injection distribution system to wells 

24 
Injection of KMnO4 or other oxidant, as observed during the 

demonstration, involves three basic steps; 1) a batching 

operation in which granular KMnO4 is mixed with potable 

water to form an oxidant solution at the desired 

concentration; 2) pumping the KMnO4 solution from one or 

more mixing vessels through a series of cannister filters 

and onto the POD; and 3) pumping oxidant from the POD 

down the wells via high pressure hoses. 

During the demonstration, the injection rates for individual 

wells were varied on a regular basis to control seepage of 

oxidant. Flow rates during the second injection event 

ranged from 1.7 to 2.6 gpm for individual wells, the higher 

injection rates were typically for the deeper wells. The 

injection event took two people four days to inject a little 

over 1,900 lbs (862 kg) of KMnO4 into a total of 10 injection 

wells. At this same rate, it would take the same two 

individuals 28 days to batch, transfer, and inject over seven 

times that amount of KMnO4 (14,000 lbs or 635 kg). 

However, all of the wells at the hypothetical site are set in 

a formation similar to the demonstration site’s deep zone, 

which was able to take a large volume of oxidant (i.e., XDD 

was able to inject about 480 lbs (218 kg) of oxidant daily 

into the deep wells. Assuming XDD could inject via their 

POD the same amount into six wells at the hypothetical site 

simultaneously, they could inject a total of about 2,900 lbs 

(1,320 kg) of oxidant daily. 

At this rate, XDD could inject all 14,000 lbs of oxidant in 

five full days. If a day of mobilization and setup is included, 

the injection event could be completed in six days and 

would take two people and a total of 120 hours to 

complete. Thus, at a $60 per hour rate for the estimated 

120 labor hours, the labor cost for the KMnO4 injection 

phase would total $7,200. 

3.5.5.5 Treatment Monitoring 

As previously discussed, the contamination in the soil and 

groundwater at the hypothetical site has been assumed to 

be fully characterized prior to installation of the XDD ISCO 

injection wells. For monitoring the technology 

effectiveness on both the soil and groundwater, at least two 

soil and groundwater sampling events are required. A preinjection “baseline” event is typically desired to assess pretreatment concentration levels for both soil and 

groundwater. Intermediate events, conducted after 

treatment, but prior to the estimated treatment completion 

time, are used to determine the rate of treatment progress 

and to assess any trends. Final post-treatment monitoring 

is required to determine if treatment goals have been met. 

For the hypothetical site, a reasonable scenario for 

collecting treatment verification samples would be to collect 

groundwater samples from five of the 10 injection wells a 

week or two before the KMnO4 injection date to establish 

a true pretreatment groundwater baseline. At about the 

same time approximately 10 soil samples, randomlyselected within the 100 ft x 32 ft x 32 ft defined 

contaminated zone, would be collected to establish a 

baseline soil concentration. Following the first two weeks 

of treatment, an intermediate groundwater sampling of the 

same five wells would be conducted to evaluate 

groundwater contaminant trends. Finally, after at least 

one month has passed since the end of the injection date, 

a final post-treatment sampling of both soil and 

groundwater would be conducted to verify treatment 

effectiveness. These six sampling events are 

summarized as follows. 

1. Pre-Injection Soil (Baseline) 

2. Pre-Injection Groundwater (Baseline) 

3. Post-Injection Groundwater (Intermediate) 

4. Post-Treatment Soil (Final) 

5. Post-Treatment groundwater (Final) 

Groundwater Sampling 

For this cost analysis, it will be assumed that the twoperson sampling team can mobilize to the site, setup, 

purged and sample the five wells, ship the samples to an 

off-site laboratory, and demobilize in one 10-hour day. 

Therefore, each of the three groundwater sampling events 

would incur 20 hours of technician labor at $60/hr; or 

$1,200. Thus, from the time just prior to KMnO4 injection 

until one year following the KMnO4 injection, a labor cost 

of $3,600 would be incurred for groundwater sampling. 

Soil Sampling 

Collection of soil samples to determine the technology 

effectiveness was difficult and time consuming during the 

demonstration. Two events, a pre-treatment baseline and 

final post-treatment, are deemed sufficient so long as 

enough samples are collected to provide a statistically 

significant sample set. 

A geoprobe was used for collecting soil samples during 

the final sampling event at the demonstration site. A total 

of 30 samples was collected from each of three lithologic 

zones (for a total of 90 samples). However, Although the 

hypothetical site is larger there is only one contaminated 

zone. Therefore, an assumption is made that 30 soil 

samples from this zone prior to treatment and again one 

month after treatment will provide an adequate statistical 

sample set for evaluating treatment effectiveness. 

For the demonstration, sampling at 30 locations took 

approximately four days, however three discrete depth 

zones were sampled. Since there is essentially one 

affected zone at the hypothetical site, it is assumed that 

samples from the 30 locations can be collected in three 

10-hour days. Thus, combining baseline and posttreatment verification sampling (i.e., 60 samples), six 10­

25 
hour days are assumed sufficient to complete all soil 

sampling. Other than the geoprobe crew, two technicians 

at $60 per hour can collect, prepare, and ship the on-site 

methanol-extracted soil samples in this time period. This 

would equate to $1,200 of labor per day or a total of $7,200 

of total labor for soil sampling. 

Therefore, total treatment monitoring labor costs 

(groundwater plus soil) is estimated at $10,800. 

3.5.5.6 Site Restoration/Demobilization 

For the XDD ISCO process, the primary activity for 

demobilizing from the demonstration site involved a 

thorough flushing of the oxidant from the POD and related 

equipment components. To accomplish this, XDD uses a 

neutralizing solution that consists of a 5:1:1 mixture of 

potable water, vinegar, and hydrogen peroxide (H 2O 2), 

respectively. The neutralizer is pumped through the POD 

components and all of the high pressure hoses and 

injected down the injection wells (the small amount of 

neutralizer has a negligible effect on the subsurface). 

For the demonstration, the demobilization effort took 

approximately one day for two people to complete. 

Therefore, it is assumed that demobilization will take two 

people, working a ten-hour day (20 hours total) to 

demobilize. At a loaded rate of $60/hr per technician, the 

total demobilization labor cost is estimated at $1,200. 

3.5.5.7 Report Preparation 

Labor for report preparation can be quite variable, 

depending upon the complexity of the data and client 

expectations. For this economic analysis an assumption is 

made that XDD will prepare a brief final report containing 

the basic information and data needed for a third party to 

evaluate. The report would include the following 

information at a minimum. 

• Brief description of the site (including a site map); 

• Re-summarizing of the treatability study results; 

• Injection Summary (volume, mass, dosages, etc.) 

• Map of Injection points, wells, and borings 

• Groundwater sample results for all three events; 

• Soil sample results for both events; 

• Results of quality assurance samples; 

• Brief interpretation of results and conclusions. 

It is estimated that it would take a senior level engineer or 

scientist a week (i.e., 40 hours) to prepare such a report. 

At a loaded rate of $80/hr, report preparation is estimated 

at $3,200. 

3.5.6 Consumables & Supplies 

Consumables and supplies for implementing a full-scale 

ISCO process comprise a significant amount of total costs. 

They are estimated at $56,350 for this economic analysis. 

Consumable and supply costs can be segregated into 

three separate subcategories: 1) Consumables (i.e., 

materials consumed or used up); 2) Equipment Rentals; 

and 3) Miscellaneous Supplies. Each of these 

subcategories is discussed separately in the following 

subsections. 

3.5.6.1 Consumables 

The two major consumable items associated with XDD’s 

ISCO process are 1) the oxidant itself (KMnO 4) and 2) 

potable water that is needed to mix with the oxidant to 

form an injectable solution at a desired oxidant 

concentration. Note that water is considered a 

consumable in this instance (as opposed to a utility). 

KMnO4 

The injected KMnO 4 is considered a consumable because 

it is consumed after injection. During the demonstration, 

XDD injected approximately 15,000 gal. (57,000 L) of 

KMnO 3 

4 solution into about 1,000 yd of contaminated 

material. The 3,700 yd3

 of contaminated material at the 

hypothetical site is 3.7 times greater in volume. Therefore, 

there would need to be about 56,000 gal. (212,000 L) of 

oxidant/water solution injected at a similar dosage, or 

5,600 gal. of solution injected per the 10 injection wells. 

The bulk purchase price of treated granular KMnO4 is 

reported by XDD to be $2.30 a pound. Using a KMnO 4 

concentration of 30 g/L, approximately 14,000 lbs (7 tons) 

of granular KMnO4 would be required to produce 56,000 

gallons of oxidant solution. At the $2.30/lb price, the cost 

of granular KMnO4 is estimated to be $32,200. 

Potable Water 

The potable water that is used to make up the oxidant 

solution is also a consumable item. During the 

demonstration XDD utilized 5,000 gal. (18,900 L) tankers 

to supply potable water at the site at a cost of $0.10 per 

gallon. This cost included delivery and use of the tanker. 

The cost of 56,000 gallons of potable water is therefore 

estimated at $5,600. 

3.5.6.2 Equipment Rental Costs 

For this economic analysis equipment rentals include 

costs for non-capital equipment required to perform four 

basic functions. These include 1) Direct Push Technology 

(DPT) for conducting baseline and post-treatment soil 

sampling; 2) Equipment for injecting oxidant; 3) 

Equipment for health & safety monitoring during field 

activities; and 4) Equipment for conducting groundwater 

sampling. Each of these rental categories is discussed 

separately as follows: 

26 
Table 3-4. Estimated Miscellaneous Supplies Costs. 

Item Unit Cost No. Total 

Soil Sample Liners $10/Each 60 $600 

Decon. Containment $100/Each 1 $100 

Personal Protective Equip. $20/day 20 $400 

Calibration gases/solutions 50/Each 2 $100 

Well couplings $2/Each 10 $20 

Rental Shipping charges $80/Each 6 $480 

Total Estimate $1,700 

Soil Sampling 

Final event soil sampling at the demonstration site was 

accomplished with DPT employed by a geoprobe. 

Although this work is almost always subcontracted out, the 

use of the geoprobe is costed out on a daily basis (i.e., 

rented equipment). The cost of the geoprobe, including a 

daily mobilization charge for a local drilling company, is 

estimated at $1,400/day. During the demonstration, a 

geoprobe was able to collect 90 discrete soil samples from 

30 locations in about four days. If 30 locations are 

sampled at a depth of about 40 feet bls to collect both 

baseline and post-treatment soil samples at the 

hypothetical site, it will be assumed that soil sampling can 

be completed in six days. Therefore, the total geoprobe 

rental cost is estimated at $8,400. 

Directly associated with geoprobe soil sampling is steam 

cleaning of DPT samplers and push rods to prevent cross 

contamination between boreholes. Steam cleaner rental is 

estimated at $150 per day, or $900 for the six-day event. 

Oxidant Injection 

The primary rented item for injecting oxidant is XDD’s 

Portable Oxidant Delivery System (POD). XDD’s POD is 

a trailer-mounted unit specifically designed for injecting and 

monitoring delivery of oxidant at up to six injection points 

simultaneously. The unit’s primary components include 

batch tanks, mixers, a metering pump, a distribution 

manifold, and chemically-resistant digital flow meters that 

measure flow rates and total flow volumes. The POD can 

be rented on a daily basis for $1,500 or $4,500 weekly. 

During the demonstration, XDD was injected up to 1,000 

gal. (3,800 L) of oxidant solution into deep zone wells (i.e., 

25 ft bls) in a 10-hour day. Since the POD can deliver 

oxidant to six wells at a times, it is assumed that XDD 

could inject 6,000 gal. (22,700 L) of oxidant solution per 

day at the hypothetical site. Therefore, rental of the POD 

is estimated at $4,500. 

Directly associated with the POD is a rented pickup truck, 

used to transport the POD and supplies, and to mobilize 

personnel to and from the site on a daily basis. The truck 

is rented out at $225 per week. Other rented equipment 

needed by XDD for injection include a 70-KVA generator 

($700/week), transfer pumps (a combined $135/week), and 

two 500 gallon mixing tanks (a combined $210/week). 

Together, these items add up to an additional $1,270/week. 

Health and Safety Monitoring 

A photoionization detector (PID) and combustible gas 

indicator (CGI) are standard health and safety 

requirements for drilling operations (i.e., well installation 

and soil sampling). The PID can also be used to screen 

drill cuttings to aid in the determination of disposal options. 

Drilling operations should consist of just two events; 1) 

one week to install wells immediately followed by three 

days of soil sampling, and 2) three days of post-treatment 

soil sampling. A PID and CGI can be rented for $200 a 

week and $150 a week, respectively (i.e., a combined 

$350 per week. A conservative time frame estimate for 

use is three weeks for both events. Therefore, the cost 

of renting these field monitoring instruments is 

conservatively estimated at $1,050. 

Groundwater Sampling 

Groundwater sampling during the demonstration was 

conducted with a rented peristaltic pump. However, as 

previously discussed, purchased bladder pumps are to be 

used at the hypothetical site for sampling groundwater 

below 25 ft bgs (see 3.5.3). Sampling equipment is still 

required for low flow purging and sampling of wells. The 

largest rental cost is for use of a multi-parameter water 

quality meter. This instrument combines the 

measurement capabilities of several instruments and can 

be rented for $100 per day ( includes a flow-through cell). 

In addition to the multi-parameter meter, a water level 

indicator is required for recording water levels during the 

low-flow purging/sampling. A water level indicator can be 

rented for $22/day, thus the combined rental equipment 

needed is $122/day. For the six days required (i.e., 3 

events x 2 days), total rental costs are estimated at $730. 

3.5.6.3 Miscellaneous Supplies 

Miscellaneous supplies could include a whole array of 

items that by themselves are relatively insignificant in 

cost, but combined would add up to a sizable cost 

needing consideration. These items may include, but are 

not limited to, the following items shown in Table 3-4. 

As shown in Table 3-4, total miscellaneous supplies are 

estimated at $1,700, the largest component being soil 

sample liners used for the geoprobe sampling. 

27 
Table 3-5. Estimated Residuals Shipping/Disposal Costs. 

Item Unit Cost No. Total 

Waste Solids 

Residual Soil Sample $90/Drum 1 $90 

Miscellaneous Solids $90/Drum 3 $270 

Waste Liquids 

Well Development Water $145/Drum 7 $1,015 

Decontamination Water $145/Drum 7 $1,015 

Sample Purge Water $145/Drum 1 $145 

Total Estimate $2,535 

3.5.7 Utilities 

The predominant utility required for XDD’s oxidant injection 

is the electricity required to operate the POD and 

associated pumps. Electricity is also required for powering 

an air compressor during groundwater sampling. Certainly, 

the proximity of the demonstration site to a readily available 

facility would make this a minor issue. However, at a 

remote site, logistics can get complicated. It may even be 

necessary to use a gasoline or diesel powered generator 

if electrical hookup is not practicable. 

A small additional electrical cost may be needed to supply 

lighting to the trailer and a security light, and possibly for a 

phone and facsimile hookup. Other than electricity, a water 

source may be needed for occasional decontamination 

activities; however, those costs are considered negligible. 

During the demonstration, both electricity and water was 

available from the former MEC Building. For this economic 

analysis, the same is assumed for the hypothetical site. 

Thus, no costs for utilities are included. 

3.5.8 Effluent Treatment and Disposal 

For this technology there is no effluent. Therefore, it is 

assumed that there will be no effluent treatment and 

disposal expense. Disposal of small amounts of 

decontamination wastewater generated from cleaning 

sampling equipment is considered negligible and therefore 

no costs are included for this category. 

3.5.9 Residuals Shipping and Disposal 

The ISCO technology generates essentially no waste 

streams per se. However, investigation derived wastes 

(IDW ) are typically generated when installing injection and 

monitoring wells, and when collecting soil and groundwater 

samples for evaluating treatment effectiveness. 

The IDW generated for an ISCO remediation can be 

subdivided into two broad categories; 1) W aste Solids, and 

2) W aste Liquids. During the demonstration, waste solids 

consisted of soil cuttings from HSA drilling for well 

installation, residual soil sample material, and 

miscellaneous waste solids (i.e., visqueen and wood from 

the decontamination pad, PPE, used sample liners, etc.). 

W aste liquids consisted of well development water, 

sampling equipment decontamination water, and purge 

water generated during groundwater sampling. 

For the hypothetical site it is assumed that DPT will be 

used for both well installation and soil sampling (i.e., not 

HSA). Therefore, no soil cuttings will be generated. 

However, there will be residual soil sample material. Since 

only about 3⁄4 of one drum of residual sample material was 

generated for the 90 samples collected during the 

demonstration final event, it is assumed that just one drum 

of residual material will be generated from the 60 samples 

collected for the hypothetical site sampling scenario. As 

was the case with the demonstration, three additional 

drums of waste solids (e.g., sample liners, visqueen, PPE, 

etc.) will be assumed generated for the hypothetical site 

scenario. Disposal of waste solids cost $90 per drum. 

Therefore, the total cost of disposing the four waste solid 

drums is estimated at $360. 

Based on the demonstration IDW , generation of waste 

liquids is anticipated to substantially exceed waste solid 

generation in volume. During the demonstration about 2.6 

drums of well development water was generated for six 2­

inch ID wells representing about 90 feet of water column. 

The water column for each of the 2-inch ID hypothetical 

site wells is 22 feet, thus a total 220 feet of water column 

should generate about 370 gallons of development water, 

or about seven 55-gallon drums. 

Also, during the demonstration steam cleaning of DPT 

equipment used to bore about 1,200 feet of soil generated 

four 55-gallon drums of decontamination water. For the 

hypothetical site a total of 60 samples will be collected 

from an approximate 35-ft depth, which equates to 

roughly 2,100 ft. of boring footage. This would equate to 

1.75 times the demonstration volume of decontamination 

water generated and would require seven drums for 

containment. Purge water from both baseline and posttreatment events should add another drum. All in all there 

are an estimated 15 liquid drums requiring disposal. 

Disposal of waste liquids cost $145/drum. Therefore, 

disposal costs for the 15 drums of waste liquids are 

estimated at $2,175. Total disposal costs for the 

hypothetical site (solids + liquids) is estimated at 

approximately $2,530. It should be noted that there is a 

minor charge for pickup and manifesting, which will be 

considered negligible for this cost estimate. Table 3-5 

below summarizes the estimated disposal costs. 

28 
Table 3-6. Estimated Analytical Costs 1 

Item Unit Cost No. Total 

Soils 2 

Baseline Event $130/Sample 30 $3,900 

Post-treatment Event $130/Sample 30 $3,900 

Groundwater 

Baseline Event $150/Sample 10 $1,500 

Intermediate Event $150/Sample 10 $1,500 

Post-treatment Event $150/Sample 10 $1,500 

Sample Shipments 

Soil 3 $50/Shipment 20 $1,000 

Groundwater $50/Shipment 3 $150 

Total Estimate $13,450 

1

 Costs include QC sample analyses. 2

 Total solids analysis included for reporting dry weight soils 3 #MeOH 500 ml shipped in any container (3 borings max.) 

3.5.10 Analytical Services 

The level of testing required to substantiate successful 

ISCO treatment at full scale (i.e., at the hypothetical site) is 

assumed to be significantly scaled down from the SITE 

Demonstration sampling plan. For this cost analysis, a 

treatment period of one month is assumed and the twoevent soil and three-event groundwater sampling schedule 

discussed previously (see 3.5.5.4) is considered adequate 

to monitor and evaluate treatment effectiveness. 

Although the site owner or the site owner's contractor 

would likely collect these samples, the state or local 

regulatory agency may require independent analysis of the 

samples by an outside laboratory (especially for final 

post-treatment samples). 

It is also being assumed that for both soil and groundwater 

the only required analytical parameter is for volatile organic 

compounds (VOCs); for soil SW -846 Method 5035/8260B 

(including total solids analysis for soil samples to report 

results on a dry weight basis) and SW -846 8260B for 

water. VOC analyses are essential since specific VOCs 

are the target contaminants. Other analyses, such as 

metals, are considered optional (i.e., metals’ analyses may 

provide insight as to whether the ISCO process mobilizes 

metals or not, however metals are not considered a 

concern at the hypothetical site. 

Table 3-6 provides an estimate for the cost of analytical 

samples for the hypothetical site sampling scenario. 

As shown in Table 3-6, the total cost of analytical costs for 

the hypothetical site scenario is $13,450. Assumptions 

include that QA/QC samples (e.g., MS/MSDs, trip blanks, 

etc.) are included in the unit cost values shown. 

3.5.11 Maintenance and Modifications 

During the actual demonstration injections, maintenance 

activities and/or system modifications were performed on 

an as needed basis. For example, routine maintenance 

consisted of periodic flushing of cannister filters, which 

were used to remove unwanted material (e.g., silica 

solids) from the oxidant solution. On the infrequent 

occasion that a pump malfunctioned, it was either 

repaired or changed out. In instances where maintenance 

and/or modification were required, XDD was able to 

perform those activities without major disruption to the 

injection process. As a result, there were no additional 

labor costs or parts costs associated with those activities. 

For the hypothetical site, the same will be assumed (i.e., 

no additional cost for maintenance and modifications 

during injection). Also, with respect to post-oxidant 

injection monitoring events, no maintenance per se was 

conducted during the demonstration. Thus for this cost 

estimate it is assumed that no maintenance cost and/or 

modification costs will be incurred. 

It should be noted that for the demonstration, some 

injection wells had to be replaced due to short-circuiting 

problems. However, this did not relate to the XDD ISCO 

process. 

3.5.12 Site Restoration 

Site restoration is typically performed at the conclusion of 

the treatment project. It is assumed that the flushmounted injection wells that were installed for oxidant 

injection will remain on-site for future monitoring 

purposes; or in the unlikely case that re-injection of 

additional oxidant (i.e., either additional KMnO4 or a 

different oxidant) is needed at a later date. Therefore the 

abandonment of injection wells, a major site restoration 

cost if needed, will not apply in this case. 

As was the case with the demonstration site, site 

restoration related non-labor costs for the hypothetical site 

will consist almost exclusively of grouting of soil sample 

boreholes to seal off contaminant pathways to and from 

the subsurface. Grouting expenses can vary significantly. 

For this cost estimate, an average borehole depth of 40 

feet and a cost of $2 per foot is assumed. Since there is 

a total of 60 boreholes to grout (i.e., 30 baseline and 30 

post-treatment), total borehole grouting costs are 

estimated at $4,800. 

29 
Section 4.0


Technology Effectiveness


4.1 Introduction 

4.1.1 Project Background 

XDD’s ISCO process was evaluated under the EPA SITE 

Program at the former MEC Building site located in 

Hudson, NH. Soil and groundwater at this site are 

contaminated with DNAPL and dissolved-phase 

contaminants, such as TCE, cDCE, PCE, 1,1,1-TCA, 

1,1-DCA , toluene and VC. The contamination originated 

from releases from an underground concrete holding tank. 

The tank was removed in March 1997. Concentrations 

within the site soils were measured prior to the 

demonstration as high as the percent range. The overall 

goal of the study was to evaluate the ability of XDD’s ISCO 

process to reduce levels of specifically targeted organic 

compounds in contaminated soil by 90% and to reduce 

targeted groundwater contaminants to below remediation 

performance standards set specifically for the site. 

This pilot-scale study was initiated in August 2004 (predemonstration activities) and concluded in May 2006. The 

study focused on a small contaminated area located just 

downgradient of the former concrete tank excavation site. 

Figure 4-1 shows this demonstration study area, including 

locations of the demonstration injection wells (IW ), 

evaluation wells (EW ), and soil boring locations. The areal 

extent of this area was about 1,200 ft2 (370 m 2). The 

vertical extent of site contamination is roughly 22 ft or 6.7 

m (i.e., 3-25 ft bgs). Therefore the volume of groundwater 

and saturated soil targeted for treatment was 27,000 ft3 

(8,200 m3 or 1,000 yd 3).

A total of two soil and five groundwater sampling events 

were conducted during the demonstration. A pre-treatment 

baseline and post-treatment final soil sampling event were 

conducted in which approximately 90 soil samples were 

collected from three stratigraphic zones. For groundwater, 

emphasis was placed on the final post-treatment sampling 

in which 15 wells were samples twice to produce 30 

sample results. A day of well recovery was spaced 

between the two sampling rounds. Both the soil and 

groundwater samples were analyzed for VOCs and other 

parameters of interest. Results of VOC analyses were 

evaluated statistically to determine if primary project 

objectives were met. 

4.1.2 Project Objectives 

Specific objectives for this SITE demonstration were 

developed and defined prior to the initiation of field work. 

These objectives were subdivided into two categories; 

primary and secondary. Primary objectives are those goals 

that support the developer's specific claims for the 

technology demonstrated. These objectives are usually 

evaluated using both descriptive and inferential statistical 

analyses and require quantitative results to draw 

conclusions regarding technology perform ance. 

Secondary objectives are also in support of developer 

claims, however, the data analysis associated with these 

objectives are considered less rigorous. Secondary 

objectives pertain to information that is useful, and do not 

necessarily require the use of quantitative results to draw 

conclusions regarding technology performance. 

Critical data support primary objectives, and non-critical 

data support secondary objectives. Critical measurements 

were formally evaluated against the demonstration target 

level using statistical hypothesis tests that are summarized 

in subsection 4.5. 

Table 4-1 presents the two primary and four secondary 

objectives of the demonstration, and summarizes the 

method(s) by which each was evaluated. Objectives 1-4 

are addressed in this section. Objective 5 was not 

evaluated because adequate permeability data was not 

acquired from the CPT/MIP survey. The cost estimate 

(Objective 6), is discussed in Section 3. 

30 
31

Table 4-1. Demonstration Objectives. 

Objective Description	 Method of Evaluation 

Primary Objectives 

Objective 1	 Determine if there is a statistically significant 

reduction of VOCs in soil (specifically chlorinated 

ethenes) over the period of the demonstration; 

and specifically show that the XDD oxidation 

process can remove 90% of the VOCs from soil 

for all three contaminated soil horizons. 

Determine for each horizon and each individual compound 

(PCE, TCE, cDCE and VC) the removal efficiency by 

comparing the analysis of soil samples taken before and 

after the demonstration test period (baseline and final 

sampling events). Note: XDD’s claim was specific to 

chlorinated ethenes but the SITE Program also assessed the 

impact of the technology on chlorinated ethanes. 

Objective 2	 Determine whether the XDD oxidation process 

can reduce concentrations of contaminants in the 

groundwater to below the 0.5% solubility limit of 

750 :g/L, 5,500 :g/L, and 17,500 :g/L for PCE, 

TCE, and cDCE, respectively. These remediation 

performance standards are not for drinking water; 

they were provided by the state of New Hampshire 

to specifically address this site. 

Determined by analysis of groundwater samples collected 

during the final post-treatment sampling episode; in which 

each sample is considered spatially and temporally 

separated such that a statistically significant number of 

samples are collected for analysis. 

Secondary Objectives 

Objective 3 Assess the Impact of the Organic Matter in the 

Peat and its effect on Oxidant Depletion. 

Collect samples of peat material at each boring location 

during baseline and final sampling events and determine on 

average if there is a depletion of humic content in samples 

due to the ISCO process. 

Objective 4	 Evaluate the potential for mobilization of valence 

sensitive toxic metals (i.e., As, Cr, Se, Zn) into the 

groundwater system. 

Sample and analyze groundwater within and downgradient 

of the source area for metals at designated periods 

throughout the course of the demonstration. 

Objective 5	 Evaluate the effect of MnO4 on permeability 

reductions in the contaminated media due to the 

formation of MnO . 2	 Rapid buildup of MnO2 can 

occur when treating with MnO4 where high levels


of DNAPL saturation occur, leading to pore


plugging and an overall reduction in permeability.


Performing in situ permeability tests before and after 

treatment within the three stratigraphic zones, (i.e., fill 

material, peat, and sandy-silt).


Objective 6 Collect and compile information and data Acquire cost estimates from past SITE experience, and from 

pertaining to the cost of implementing the XDD the developer (XDD). Cost treatment for full-scale treatment 

ISCO process. of similar contaminated material. Break down estimates into 

12 cost categories that reflect typical cleanup activities at 

Superfund sites (See Section 3). 

32 
Table 4-2. Remediation Performance Standards. 

VOC Soil Standards 

(mg/Kg) 1 

Groundwater 

Standards (:g/l) 2 

PCE 2 750 

TCE 0.8 5,550 

cDCE 2 17,500 

VC 0.4 ---

Toluene 100 2,570 

1,1,1-TCA 42 6,800 

1,1-DCA 3 27,500 

1

2

 State of NH S-1 standards (Aries Engineering, Inc. July 2001). State of NH 0.5% aqueous solubility goal ( SAIC, May 2005). 

4.2 Site Description 

4.2.1 Site Location and History 

The approximate four-acre former MEC property contains 

a 36,000 square foot former MEC building and associated 

paved and unpaved parking and storage areas. MEC 

(formerly Nashua Electric Motors) repaired and rebuilt 

electric motors at the property from the mid 1970s up until 

approximately 1990. During this time frame, releases from 

an underground concrete holding tank has contaminated 

soil and groundwater in the vicinity of the southeast corner 

of the former MEC Building. 

Aries Engineering, Inc. (Aries) is the remediation contractor 

for the former MEC Building site. Per Aries, the concrete 

holding tank was excavated in May of 1997. A total of 

1,175 gallons (4,400 L) of liquids and five 55-gallon drums 

of sludge was removed from the tank (personal 

communication between Aries and SAIC, June 2006). 

Currently, Aries is conducting monitoring activities at the 

site in accordance with the site New Hampshire 

Department of Environmental Services (NHDES) 

Groundwater Management Permit (GMP), which was 

issued December 5, 1997 and renewed on January 17, 

2003. There are specific remediation goals for VOC 

contaminants at the former MEC Building site, both for 

soils and groundwater. These goals are referred to as 

Remediation Performance Standards (RPS) and are 

presented in Table 4-2. 

Attainment of the RPS via treatment, such as the XDD 

ISCO process, may allow for the utilization of natural 

attenuation as a follow-on treatment option (personal 

communication between Aries and SAIC, June 2006). 

4.2.2 Site Lithology and Hydrogeology 

4.2.2.1 Lithology 

Characterization of the demonstration study area lithology 

has resulted from several field investigation efforts; most 

notably the drilling of numerous soil borings and installation 

of several injection and monitoring wells. Site-specific 

lithology and geology were acquired via descriptions of 87 

soil samples collected from the 30 soil borings shown in 

Figure 4-1. An approximate equal number of samples 

were collected from each of the three stratigraphic zones 

targeted for the ISCO treatment. The shallowest sample 

collection intervals were 6-7 feet below land surface (bls). 

(The upper 0-6 ft bls consists of asphalt underlain with 

rubble and debris; this material was not sampled). 

Figure 4-2 is a generalized cross section showing distinct 

stratigraphic zones comprising the demonstration study 

area. These include an: 1)upper debris zone, 2) the three 

zones that were sampled for characterization and chemical 

analysis, 4) a basal till, and 5) underlying bedrock. Brief 

descriptions of these zones are as follows: 

Upper Fill/Debris Layer 0-6 ft bls (Not Sampled) 

The upper 6 feet of the demonstration site consists of fill 

material, including large chunks of concrete, rocks, 

plywood, shredded wood, etc. This zone was not sampled. 

Top Gravelly Sand Zone 6-13 ft bls (Sampled) 

Just below the upper fill material, there is a zone of loose 

gravelly-sand, with silt; which has an olive to grey color. 

This zone extended to about 6-13 feet bls. Samples from 

this zone were saturated since groundwater was typically 

just 31⁄2-4 feet bls. W ood fragments were frequently 

encountered in this zone and hydrocarbon odors were 

noted for several boring samples. A total of 30 baseline 

and 30 final soil samples were collected from this zone. 

Middle Peat Zone 12-14 ft bls (Sampled) 

At this approximate depth interval there exists a relatively 

thin peat zone, black in color, that varies in thickness from 

0.2 ft. to 3.2 ft (0.6-0.98 m). At several locations the peat 

was party composed of shredded wood fibers or wood 

chunks; and contained twigs, leaves, and bark. The peat 

occurred as shallow as 9 ft bls and as deep as 15.8 ft bls. 

Based on baseline and final borehole drilling, the peat was 

absent in boring location No. 30. Boring 30 is located on 

the south edge of the study area (Figure 4-1), not far from 

the former tank location. The peat may have been 

removed during excavation of the holding tank and 

surrounding soil material. A total of 27 baseline peat 

samples and 29 final peat samples were collected from 

this zone. 

33 
34

Lower Sandy-Silt Zone 14-26 ft bls (Sampled) 

A sandy-silt zone, olive-yellow to grey in color, extends 

from the bottom of the peat down to a basal till layer 

(anywhere from about 10-28 ft or 0.3-8.5 m bls). Typically 

this zone grades from a very course or gravelly-sand to a 

finer sandy-silt to pure silt. Product (i.e., DNAPL) was 

commonly observed in this zone. A total of 30 baseline 

and 30 final soil samples were collected from this zone. 

Basal Till Layer 26-30 ft (Not Sampled) 

This layer was not sampled but provided a reference point 

for collecting lower zone samples (i.e., the most 

contaminated portion of the overlying sandy silt was 

sampled). PID readings typically were the highest just 

above this till layer. 

Bedrock 30 ft (Not Sampled) 

Bedrock occurs roughly at 30 ft (9.1 m) bls and reportedly 

consists of a highly weathered quartz-biotite schist. 

Bedrock was encountered when drilling IW -3d at around 30 

ft (9.1 m) bls and at boring location No. 9 at about 31 ft bls. 

4.2.2.1 Hydrogeology 

Site overburden groundwater generally flows in a 

northeasterly direction across the entire former MEC 

Building area. Horizontal hydraulic gradient, based on 

Aries’s 2003 and earlier site groundwater data, is 

approximately 0.04 feet/foot (ft/ft) or 0.12 m/m between two 

monitoring wells located in the immediate vicinity of the 

study area. In addition, site vertical gradients have been 

measured by Aries (e.g., Aries observed vertically upward 

hydraulic gradients ranging between 0.04 ft/ft to 0.1 ft/ft in 

a monitoring well couplet upgradient of the study area). 

4.3 Pre-Demonstration Activities 

For this demonstration, a significant amount of time and 

effort was devoted to pre-demonstration activities (Phase 

1). These activities included preliminary sampling for site 

characterization (e.g., monitoring well installation; and soil 

and groundwater sampling), laboratory methanol (MeOH) 

extraction studies on soil samples, a treatability study 

conducted by the ISCO developer (XDD), and cone 

penetrometer technology and membrane interface probe 

(CPT/MIP) survey. Each of these pre-demonstration 

activities is discussed in the following subsections. 

4.3.1 Preliminary Sampling 

SAIC conducted pre-demonstration sampling during the 

latter part of August, 2004. The purpose of the preliminary 

sampling was twofold: 

1. Gain a better understanding of the distribution of 

the target VOCs within the context of the lithologic 

and hydraulic regimes of the site media and; 

2. Acquire samples for an XDD treatability study. 

Three contaminated soil zones (gravelly sand, peat, and 

silty sand) were sampled at each of three locations and 

three sets of nested monitoring wells (nine total) were 

installed at the same locations. Eight soil samples (3 

gravel/sand, 2 peat, and 3 silty sand) were collected from 

separate boreholes near an existing well located in the 

immediate vicinity of the demonstration site. Also, one 

groundwater sample was collected from that same well. 

Results of the pre-demonstration sampling indicated that 

contaminant levels at the site were sufficient for purposes 

of the demonstration. Samples collected from an existing 

monitoring well indicated that concentrations of cDCE were 

well above the RPS. However, TCE and PCE were below 

these standards. Although based on just sampling of one 

well, the data suggest that oxidation may have been 

in-process in the sampled groundwater, as the more 

chlorinated compounds were detected at lower 

concentrations (below the RPS) and one of the known 

breakdown products (e.g., cDCE) was at a much higher 

concentration. 

4.3.2 MeOH Extraction Studies 

Based upon previous experience with peat and several 

published laboratory studies, it had been anticipated that 

VOCs would be difficult to extract from the site peat 

material using the standard 1:1 MeOH to soil ratio. As a 

result, a series of MeOH extraction studies was conducted 

on peat and other material collected from the site, with 

native concentrations of contaminants. A detailed 

description of the extraction study procedures and results 

are presented in the QAPP (SAIC, May 2005). 

The difficulty with a 1:1 MeOH to soil extraction occurs 

because the contaminants reach an equilibrium with peat 

and MeOH. Thus, significant contamination remains on 

the peat even after two or three subsequent extractions. In 

order to find an optimum extraction procedure for the peat 

material, a set of experiments was performed by extracting 

the peat in MeOH following standard SW -846 protocol (i.e., 

soxhlet extractions). Additional studies varied the 

procedure by using sonication and heating. Resulting data 

suggested that much more contamination was present in 

the peat than that suggested by the initial test results. 

Further studies reinforced the notion that sonication and 

heating of the MeOH extract removed some additional 

VOC contamination from the peat, other then what was 

found in the original extraction using standard SW -846 

procedures. However, in every case it appeared that some 

contamination remained in the peat material. Even after 

35 
XDD Averaged SOD Results (g/Kg) 

Zone Sample 1 Sample 2 Sample 3 

Shallow Gr. Sand 21.0 4.6 8.8 

Middle Peat 104.7 --- 146.9 

Deep Silty Sand 5.6 1.8 2.3 

the final extraction, the procedure continued to recover and 

remove some portion of the contamination. Overall the 

results of the extraction study suggested that standard 

SW -846 procedures would not be robust enough to remove 

the VOCs present in the peat at the site. 

An additional extract sample, extracted in a 10 to 1 ratio of 

MeOH to peat instead of the usual 1 to 1 ratio, resulted in 

removal of almost all the contaminants of interest in the 

very first extraction. This suggested that the equilibrium 

between the MeOH and peat was affected by increasing 

the MeOH volume in contact with peat material. 

Subsequent studies were then undertaken to determine the 

ideal MeOH to peat ratios for the demonstration. 

Results of these subsequent studies suggested that a 

higher concentration of MeOH to peat was needed for the 

peat instead of the standard 1:1 ratio. The drawback of 

this increased ratio is increased detection limits. 

Results of these pre-demonstration analytical studies were 

implemented for the demonstration. For the demonstration 

a 5:1 milliliters (ml) of MeOH to grams of soil, was used for 

the middle peat and lower sandy-silt zones. A 1:1 ml of 

MeOH to grams of soil was used for the top gravelly-sand 

zone. 

4.3.3	 Treatability Study 

A laboratory treatability study was conducted by XDD prior 

to the demonstration in order to evaluate the effectiveness 

of their ISCO process on contaminated soil from the site. 

The objectives of this treatability study were to: 

•	 Assess the overall feasibility of using ISCO to 

meet the site-specific cleanup goals; 

•	 Estimate the soil oxidant demand (SOD) for the 

major soil units (i.e., gravelly sand, peat layer, and 

silty sand) in the treatment area; 

•	 Develop site-specific data necessary to design an 

ISCO field pilot test and/or full-scale application. 

The treatability study is detailed in a separate report 

prepared by XDD (XDD, January 2005). Permanganate 

(MnO 4	) was the chosen oxidant for the study. MnO4 is an 

oxidizer used extensively in wastewater treatment and 

drinking water purification processes. MnO4 is a very 

stable oxidant and can persist for several months in the 

subsurface. This stability makes it a good choice for 

subsurface applications (i.e., fewer injection events, fewer 

wells to treat the target area, and the ability to more 

effectively penetrate into low permeability soil zones). 

MnO4 also reacts with natural soil organic matter and 

reduced metal oxides (e.g., iron and manganese oxides, 

etc.). Contaminant degradation rates are influenced by the 

presence of these competing species. SOD is one 

measure of these additional demands that consume 

oxidant. Because the SOD exerts a competitive demand 

on the oxidant, it must typically be satisfied to ensure 

complete oxidation of the VOC compounds. 

The individual soil samples that were used in the SOD 

testing were combined into three composite soil samples 

representative of the three major soil units at the site: 1) 

gravelly sand, 2) peat, and 3) sandy silt. 

Laboratory testing consisted of two separate evaluations: 

1.	 SOD testing for evaluating utilization rates of 

variable MnO4 concentrations in a soil/groundwater 

system, and 

2.	 Testing the destruction efficiency of the VOCs. 

SOD Testing 

Eight representative soil samples were evaluated for the 

SOD procedure, which involved preparing eight separate 

40 mL VOA vials (batch reactors) with approximately 10 

grams (g) of each soil sample. This produced eight vials 

for each of the eight soil samples (64 total). 

The reactor vials were then dosed with KMnO4 oxidant 

solution at four different concentrations; approximately 2, 

5, 10, and 20 grams per liter (g/L) KMnO4 prepared using 

distilled water. Two reactor vials were prepared at each 

oxidant concentration for duplicating analyses on each soil 

sample. Controls, consisting of four MnO4 solution 

concentrations (plus four duplicate control samples with no 

soil added), were created at the start of the test and 

analyzed to evaluate if there were losses of MnO4 over the 

duration of the test. 

All the reactor vials and controls were allowed to equilibrate 

over a fourteen-day test period. On Days 3, 7, 10, and 14, 

aqueous samples from each vial were measured by a 

colorimeter for oxidant solution concentration change. A 

second dose of oxidant was applied to peat samples on 

Day 17 and samples from those peat reactors were 

analyzed for oxidant concentration changes on Days 24, 

28, and 34. XDD (January 2005) reported SOD test results 

as follows: 

36 
VOC Destruction Efficiency Testing 

VOC destruction efficiency testing involved placing a 

specific volume of groundwater/soil in a concentrated MnO4 

solution; and then placing the solution into a batch reactor 

(40-ml glass VOA vial) for a specified exposure period. 

Approximately 38 mL of 20 g/L oxidant (as KMnO 4) solution 

was prepared for site groundwater (from MW -10) and 10 

grams of each soil sample were added into each batch 

reactor. Six identical batch reactors for each soil

composite were prepared (18 reactor vials total) as follows: 

•	 Four reactor vials to be sacrificed at four different 

time intervals for the analysis of VOCs; 

•	 One duplicate reactor for VOCs analysis; and 

•	 One reactor vial used to monitor changes in 

oxidant concentration throughout the test duration. 

In addition to the above reactors, three “no oxidant” control 

reactors (one per soil composite) were prepared identically 

to the other reactors. The controls were used to assess 

losses in VOC concentrations due to mechanisms other 

than chemical oxidation (e.g., volatilization, biodegradation, 

etc.). To minimize volatilization losses, all batch reactors 

were completely filled with either oxidant solution or 

groundwater to zero headspace. 

In the peat composite, MnO4 appeared to be very effective 

in destroying high levels of cDCE and VC. Also, it appeared 

that most of the cDCE was destroyed after the first dose of 

oxidant. PCE and TCE were not evaluated due to very 

low/non-detect results in the control samples. Toluene 

exhibited reasonable reduction rates in the peat composite 

even though this compound typically reacts slowly with 

MnO 4. Interestingly, the chlorinated ethanes (1,1,1-TCA 

and 1,1-DCA) also appeared to exhibit significant

reductions. Available literature suggests that these 

compounds do not react directly with MnO 4. However, 

there may be other reactions occurring in the presence of 

the oxidant that may cause degradation (i.e., other reactive 

species may be forming, other abiotic processes, etc.). 

Nearly complete destruction of cDCE, VC, and toluene was 

observed in the shallow composite. TCE, present at 

relatively low concentrations in the aqueous control, was 

nonetheless reduced to non-detectable levels. PCE was 

not detected in control samples, thus it was not evaluated. 

Partial destruction of 1,1,1-TCA, and 1,1-DCA was also 

observed in the aqueous phase of the shallow composite. 

However, soil concentrations of 1,1-DCA were higher in all 

of the treated reactor vials as compared to the soil control 

sample (approximately 2 to 7 times higher). This trend for 

1,1-DCA was also observed in the deep composite soil 

samples (discussed in the next section). 

Nearly complete destruction of cDCE, VC, and toluene was 

observed in the soil and aqueous phases of the deep 

composite. Significant reduction of TCE was also 

observed in the Deep Composite tests. The Deep 

Composite control was the only sample in the study to 

exhibit significant aqueous TCE concentrations. The 

aqueous TCE concentration in the control sample was 

1,780 :g/L. This was significantly higher than the aqueous 

baseline TCE level (40.4 :g/L). Based on this, it appeared 

that the aqueous phase TCE in the control resulted from 

soil desorption. Although not certain, it seemed further 

supported by the fact that the deep composite soil control 

was the only control that exhibited detectable TCE on the 

soils, although relatively low (152 :g/Kg). 

Consistent with other tests, significant destruction of 

1,1,1-TCA, and 1,1-DCA was also observed in the aqueous 

phase samples. However, soil concentrations of 1,1-DCA 

in the Deep Composite test appeared to increase 

(approximately 3 to 8 times higher) as compared to the 

control sample (similar to the Shallow Composite test). 

Summary of Treatability Testing 

Soils were mixed together to create three separate soil 

composites representative of each of the three major 

stratum at the site (i.e., shallow gravelly sand composite, 

peat composite, and deep silty sand composite samples). 

The soil composites were dosed with approximately 20 g/L 

KMnO4 solution. The peat composite was dosed twice due 

to the high oxidant utilization rates. 

PCE was not present in any of the soil composite reactors, 

and as such could not be evaluated. The remaining VOCs 

(including TCE, cDCE, VC, 1,1,1-TCA, 1,1-DCA, and 

toluene) were present in one or more of the samples and 

were therefore evaluated for destruction efficiency. Only 

cDCE and toluene were detected in the studies at levels 

above the anticipated clean-up goals for the site. These 

two compounds were reduced to below the clean-up levels 

during the treatability study. 

Aqueous TCE, cDCE, and VC were effectively destroyed 

in all tests as anticipated. Even in the peat composite 

where SOD was very high, the cDCE and VC were 

destroyed rapidly and during the initial dose of oxidant. 

This is a positive result since there was some concern that 

VOCs would be difficult to treat in the presence of such a 

high oxidant demand. 

Chlorinated ethanes (1,1,1-TCA and 1,1-DCA) are typically 

not thought to be directly oxidizable by MnO 4. However, 

test results indicated that there was up to 75% reduction of 

1,1,1-TCA and 64% reduction of 1,1-DCA in the aqueous 

phase deep composite sample. As anticipated, reduction 

of these two ethanes in the peat composite samples were 

37 
slightly less efficient (49% reduction of 1,1,1-TCA and 41% 

reduction of 1,1-DCA in the aqueous phase). The actual 

mechanisms for destruction of these compounds in the 

presence of MnO4 are not fully known, but this behavior 

has been observed at other sites. 

Toluene also was significantly reduced (aqueous phase 

reduction of >99% in the Deep and Shallow Composites, 

and up to 62% in the Peat Composite). Toluene is known 

to degrade at relatively slow rates in the presence of MnO 4. 

Based on the results published by XDD’s chemical 

oxidation laboratory testing report (XDD, January 2005) 

and the summarized results noted above, ISCO was 

determined to be an effective treatment for the majority of 

the targeted VOCs at the site. Although the SOD is very 

high in the peat zone, significant reduction was observed 

for many of the target VOCs. 

4.3.4 CPT/MIP Characterization 

Cone Penetrometer Technology (CPT) and Membrane 

Interface Probe (MIP) was utilized for pre- and posttreatment characterization of the demonstration study area. 

CPT is basically a soil conductivity logging tool used to 

interpret lithology. The MIP is used to determine position 

and approximate concentration of VOCs (i.e., the MIP is 

not quantitative, but its detector response can be used at 

a particular site to estimate soil concentrations). These two 

logging tools, developed by Geoprobe Systems, can be 

combined into the same probe to collect subsurface 

information (Christy, no date). 

A total of 18 CPT/MIP survey points was completed prior to 

baseline sampling. During this survey, CPT/MIP logs were 

used to identify specific subsurface zones and the highest 

concentration areas to target for soil sampling. Following 

both XDD injections, a post-treatment CPT/MIP survey was 

conducted that was significantly scaled down from the 

baseline survey. A total of 5 CPT/MIP survey points were 

completed to adequate depths. The reduced number of 

post-treatment survey locations makes comparison to the 

baseline data difficult. Kriging contour lines are 

dramatically different due to the absence of data. 

Figure 4-3 shows the maximum response of the MIP’s 

photo-ionization detector (PID) in micro volts (:V) for a 

below-surface depth range of 0-18 ft (5.5 m), both for 

baseline and final post-treatment. Figure 4-4 shows the 

maximum response of the MIP’s PID in :V for a belowsurface depth range of 18-36 ft (5.5-11 m), both for 

baseline and final post-treatment. The baseline event plots 

are collectively based on 14 MIP baseline points and the 

final event plots are based on 5 final MIP points. Each MIP 

survey point identified as a blue cross on the plots. 

The more detailed baseline map shows that about 20% of 

the study area plume extends beneath the former MEC 

Building. This generally favors the use of an in situ 

treatment (especially for soil), since excavation near and 

beneath such a permanent structure is undesirable. The 

baseline map also reveals a concentrated circular-shaped 

plume, approximately 60 ft in diameter, whose center is in 

the immediate vicinity of the former concrete holding tank 

location. The highest :V response of 2.00E +06 :V 

comprises an approximate 30 ft-diameter area. The 

response rapidly dissipates beyond this area. Comparison 

of baseline to final PID shallow zone plots (Figure 4-3) 

show a potential increase of the maximum PID signal (vs. 

baseline) at locations 2-3 and 2-5. In the deep zone 

(Figure 4-4), there is a slight decrease of the maximum PID 

signal (vs. baseline) in the vicinity of locations 2-4 and 2-5. 

In addition to the PID detector, the MIP is also equipped 

with an electron capture detector (ECD), which is 

responsive to chlorinated compounds. Figures 4-5 and 4­

6 show the maximum response of the ECD in :V for belowsurface depth ranges of 0-18 ft (5.5 m) and 18-36 ft (5.5-11 

m), respectively. These baseline and final event plots are 

also collectively based on the 14 MIP points (baseline) and 

5 MIP points (final) identified as blue crosses. 

Evaluation of the shallow zone baseline ECD plot (Figure 

4-5) reveals a concentrated circular-shaped plume, similar 

in size and area shown by the PID shallow zone map. The 

only difference is increased intensity (i.e., an upper :V 

response of 1.00E +07 :V for the ECD versus a response 

of 2.00E +06 :V for the PID). It should be noted that the 

baseline plot in Figure 4-5 may be misleading in showing 

what appears to be a second plume, detached from the 

main plume that surrounds the former MEC building. The 

contours that comprise the shape of this apparent plume 

are interpolations from the single MIP point 4-2, which may 

only be an isolated contaminated spot. Comparison of the 

baseline and final plots show no appreciable difference in 

the maximum ECD response before and after injection 

The deep zone baseline ECD plot (Figure 4-6) also shows 

a concentrated plume emanating from the contaminant 

source area. However, the shape of the plume is more 

elliptical than circular and it is oriented in a southwest to 

northeast pattern. This is consistent with groundwater flow 

direction and is similar to the Aries plume characterization 

(refer back to Figure 1-1). Possibly, the deeper zone map 

is showing DNAPL that has settled along the top of the 

basal till layer and bedrock and is very slowly dispersing to 

the northeast. W hen comparing the baseline and final 

plots, there is no appreciable difference between the 

maximum ECD response before and after injection. 

38 
39
40


4.4 Demonstration Activities 

4.4.1 Injection of Oxidant 

XDD developed a 3-well cluster injection strategy for 

treating the chlorinated ethenes in all three soil zones at 

the demonstration site. Originally, a single injection event 

was planned. However, the originally-installed pre-packed 

one inch ID injection wells for two of the clusters had failed 

seals. They were replaced by traditional 2-inch ID wells. 

Thus, a second injection event was required. 

Figure 4-7 is an illustration showing the locations of the 

three injection well clusters (IW -1, IW -2, and IW -3), the 

estimated radii of influence (10 feet for each), and 

summarizes injected volumes of KMnO4 for each of the 

wells and for each injection. Table 4-3 provides a more 

detailed injection summary, including mass of KMnO 4 

injected per XDD’s injection logs. 

All injection wells were constructed of like materials and 

had similar well diameters (IW -3 cluster wells are 11⁄2-inch 

ID and IW -1 and IW -2 cluster wells are 2-inch ID). Well 

screen lengths for the shallow (s) and deep (d) zones were 

five feet and the screen length for the intermediate (I) a 

peat zone was one foot. W ell cluster spacing was roughly 

18 feet. 

43 
Table 4-3. Injection Summary 

First Injection Second Injection Both Injections 

June 6-10, 2005­ October 3-6, 2005 Combined 

second 

Zone Injection W ell Volume Mass Volume Mass Volume Mass 

(gallons) (Pounds) (gallons) (Pounds) (gallons) (Pounds) 

IW -1s 3 1 122 25 125 26 

IW -2s 27 8 386 78 413 86 Shallow 

IW -3s 647 208 --- --- 647 208 

Total 677 217 508 103 1,185 320 

IW -1i 33 10 2.186 451 2,219 461 

IW -2i 152 46 1.957 403 2,109 449 Intermediate 

(Peat) IW -3i 1,827 597 --- --- 1,827 597 

Total 2,012 653 4,143 854 6,155 1,507 

IW -1d 222 60 2,359 486 2,581 546 

IW -2d 251 76 2,355 486 2,606 562 Deep 

IW -3d 2,362 752 --- --- 2,362 752 

Total 2,835 888 4,714 972 7,549 1,860 

All Zones Combined Totals 5,524 1,758 9,365 1,929 14,889 3,687 

44

4.4.2 Soil and Groundwater Sample Collection 

Demonstration sampling and analysis began in May of 

2005 with baseline soil sampling and was followed by an 

initial baseline groundwater sampling event, a second 

baseline groundwater sampling event, two intermediate 

groundwater sampling events, and a final event for both 

soil and groundwater (events and dates are listed below). 

� Baseline Soil (May, 2005); 

� First Baseline for Groundwater (June, 2005); 

� Second Baseline for Groundwater (Sept. 2005); 

� Intermediate Groundwater (December, 2005); 

� Intermediate Groundwater (February, 2006); 

� Final Groundwater and Soil (March, 2006) 

4.4.2.1 Soil Sampling 

The two soil sampling events included a baseline event to 

establish pre-treatment soil concentrations for VOCs and 

soil humic content, and a final event to determine posttreatment soil concentrations for those same parameters. 

Each is discussed in detail below. 

Baseline Soil Sampling 

The baseline soil sampling event was initiated on May 12, 

2005 completed May 19, 2005, thus preceding the first 

injection event of early June 2005 by approximately three 

weeks. Soil collection was accomplished with a mini-sonic 

rig equipped with a direct push sampler. Boreholes were 

drilled at a total of 30 closely-spaced locations within the 

small area where a DNAPL plume had been identified (see 

Figure 4-1). Logs from a CPT/MIP survey were used to 

target hotspots at depth from which to collect soil samples. 

A total of 87 of the planned 90 soil samples were collected 

(i.e., 30 from each of three depth zones were planned; 

however, peat samples were not able to be collected at 

three borehole locations). 

During baseline sampling, samples collected from the 

shallow zone gravelly silty-sand material were field 

extracted in a 1:1 MeOH to soil ratio by volume. Samples 

collected from the intermediate peat layer were field 

extracted in a 5:1 MeOH to soil ratio by volume. However, 

there had still been uncertainty related to the deeper zone 

silt as to which extraction ratio would be the most suitable. 

As a result of this uncertainty, a field study (similar to the 

pre-demonstration MeOH extraction study described in 

4.3.2) was conducted during the baseline event to ensure 

that field extractions of the deep zone sandy silt material 

would be complete. 

Three samples from three boreholes were extracted in the 

normal fashion (1:1 MeOH to soil ratio) and three 

duplicates were extracted and analyzed as was done in the 

pre-demonstration extraction study (5:1 MeOH to soil ratio), 

following previously described protocols. Data was 

compared to determine if the extraction efficiency was 

significantly increased using a 5:1 ratio of MeOH to soil 

compared to a 1:1 ratio. In order to avoid losing data from 

either increased detection limits in the 5:1 extraction or not 

obtaining the actual concentration of organics as may be 

lost from a 1:1 extraction, all lower horizon samples 

collected during baseline sampling were extracted in the 

field using both protocols (5:1 and 1:1 ratio). This required 

all lower horizon samples to be collected in duplicate. 

Three selected samples had both extracts analyzed. 

Results of these analyses were used to determine if 

additional duplicate analyses were required and to 

determine the better extraction ratio for the final event. 

Final Soil Sampling 

The final soil sampling event was conducted in late March 

of 2006, approximately ten months following the first 

injection event and about eight months following the 

second injection event. A total of 90 soils samples were 

collected with a geoprobe equipped with a macrocore 

sampler. The final event boreholes were drilled as close as 

possible to the baseline borehole locations (i.e., from 0.3 to 

2 feet away) and soil samples were collected from the 

approximate same depth interval as were the baseline soil 

samples. A 1:1 MeOH to soil ratio was used for extracting 

the top zone samples and a 5:1 MeOH to soil ratio was 

used for extracting peat and bottom zone samples. 

4.4.2.2 Groundwater Sampling 

An initial baseline groundwater sampling event was 

conducted soon after the soil baseline event (i.e., the first 

week in June 2005). Due to failed seals in injection well 

clusters IW -1 and IW -2, all three wells for those clusters 

had to be replaced, and a second baseline groundwater 

event was conducted in September 2005. This event also 

served as an intermediate event to evaluate groundwater 

treated from the initial oxidant injection. Two more 

intermediate groundwater sample events were conducted 

following the second oxidant injection to evaluate target 

contaminant trends in groundwater. 

Groundwater was sampled at a low-flow rate using a 

peristaltic pump. Where possible the purged groundwater 

was routed through a flow-through cell so parameters could 

be monitored with a multi-parameter direct read probe and 

deemed stabilized prior to sampling. In some instances 

this procedure could not be conducted due to an 

insufficient volume of well water available for purging. This 

was the case with the small diameter multi-chamber wells, 

especially those set in the low recovery shallow and peat 

formations. In instances where the flow-through cell and 

probe could not be used, groundwater samples were 

collected directly into the sample container following a 

purge of anywhere between 250 mls to 550 mls of water. 

45 
4.4.2.4 Laboratory Analyses 

Table 4-4 summarizes the laboratory analyses conducted 

on soil and groundwater samples collected during each 

sampling event. Critical and non-critical measurements 

were conducted per the following discussion. 

Critical Measurements 

Critical measurements for the study included VOCs and 

moisture for soils, and VOCs for groundwater. Based on a 

pre-demonstration methanol extraction study (see 4.2.2), 

different MeOH to soil extraction ratios were used on 

different soil types that characterized each of the three 

zones. A 1:1 MeOH to soil extraction ratio was used for 

the shallow zone (dominated with gravelly silty-sand 

material). For the middle peat zone and the underlying 

deeper sandy-silt zone (where silt was prevalent), a 5:1 

MeOH to soil extraction ratio was used. 

To perform the field extraction procedure, the analytical 

laboratory had prepared pre-weighed sample containers 

containing the proper amount of MeOH for solvating 

approximately 5 grams of soil from each of the three soil 

horizons. The pre-weighed containers were shipped to the 

field site. W ide-mouth 4-ounce jars were used for 5:1 

MeOH to soil ratio extracts and 40-ml vials were used for 

1:1 MeOH to soil ratio extracts. This prevented extracting 

a particular soil type in the wrong volume of MeOH solvent. 

Because soil samples for VOC analyses were placed 

directly into jars containing MeOH, additional sample 

material from each core was also placed in a separate 

container for moisture analysis. This measurement was 

considered critical since the results were used to present 

the VOC data on a dry-weight basis. 

Groundwater samples were also analyzed for VOCs. Due 

to the target compounds being chlorinated VOCs, the 

samples were not preserved with acid. As a result, sample 

holding times were reduced from 28 to 7 days. 

Non-Critical Measurements 

Non-critical measurements for soils included humate 

analysis of the peat material that was located about 12-14 

bls. A total of 27 samples was analyzed for each the 

baseline and the final sampling events. In addition 

groundwater was also measured for total metals and 

specifically for bromide since that compound was a tracer 

within the KMnO4 oxidant solution used for the first 

injection. 

Table 4-4. Summary of Laboratory Analyses. 

Parameter 

Test 

Method 

Method 

Type 

NO. SAMPLES ANALYZED PER EVENT 1 

Baseline Second 

Baseline 

First 

Intermediate 

Second 

Intermediate 

Final 

Soil 

VOCs SW 5035/8260 Purge & Trap, GC/MS 87 --- --- --- 89 

% Moisture SW 3540 Dessication 87 --- --- --- 89 

Humates CA Humic Residue Separation/TOC analyzer 27 --- --- --- 27 

Groundwater 

VOCs SW 5035/8260 Purge & Trap, GC/MS 15 15 12 15 30 

Bromide EPA 300 Ion Chromatography 15 15 12 15 30 

Total Metals SW 3010/6010 Acid Digestion, ICP 15 15 12 15 30 

KMnO 4 NA Visual Observation --- 15 12 15 30 

1

 Does not include QC samples. 

46 
4.4.3 Process Monitoring 

XDD was ultimately responsible for monitoring its system 

parameters during the injection phase of the 

demonstration. XDD’s monitoring during injection 

consisted primarily of adjusting the flow rate of oxidant 

based on injection pressure readings. As a qualitative way 

of estimating oxidant dispersal throughout each of the three 

soil zones, the SITE Program visually monitored KMnO4 

during groundwater sampling rounds coupled with 

laboratory analysis of bromide. Bromide was used as a 

tracer for the first injection and was not detected in any 

baseline groundwater samples collected prior to oxidant 

injection (the bromide data for all events, including the 

baseline sampling, is presented in Subsection 4.5). 

Figure 4-8 is an illustration showing the estimated 

dispersion of the KMnO 4 (shown in purple) and the bromide 

concentration for each well (shown adjacent to the well 

screen), approximately 104 days following the initial 

injection into the IW -3 well cluster. As illustrated in Figure 

4-8, although KMnO4 was injected into all three zones, 

there was no visual evidence of the oxidant in any shallowzone wells 104 days following injection. Also, the only 

visual evidence of KMnO4 in the intermediate (peat) zone 

was at IW -3i (the point of injection). However, there are 

relatively high concentrations of bromide in IW -3 and EW ­

3 cluster wells in the absence of visual KMnO 4. This infers 

that the oxidant solution may have dispersed radially as 

expected (i.e., to and beyond the designed 10-foot radius 

of influence) but that consumption of KMnO4 by VOCs 

and/or naturally occurring humic material (especially in the 

peat zone) may have occurred during this time period. 

Figures 4-9 and 4-10 are similar illustrations showing the 

estimated dispersion of the KMnO4 and bromide 

concentrations at time intervals after the second injection. 

Both illustrations show that visual KMnO4 has, due to the 

second injection, dispersed throughout the entire area of 

the deep zone. However, visual KMnO4 is absent in both 

the shallow and intermediate (peat) zones. Although 

bromide diminishes in time from its injection during the first 

injection event, its persistence in all wells at some 

concentration indicates that the oxidant solution had 

dispersed throughout the desired treatment area. The 

visual absence of KMnO4 may indicate its consumption by 

the contaminant and/or natural humic material as 

previously discussed. 

It should be noted that it had been planned to inject KMnO4 

into all three injection well clusters during the initial June 

2005 injection event; however an apparent failure of well 

seals for the IW -1 and IW -2 well clusters resulted in shortcircuiting and necessitated the shutdown of injection into 

those wells. Only a very small volume of KMnO4 oxidant 

was actually injected into those wells during the first 

injection event (hence the low concentrations of bromide 

depicted in Figure 4-8 for the IW -1 wells). Consequently, 

those prepacked cluster wells were removed and replaced 

with traditional wells, and a second injection for the IW -1 

and IW -2 clusters was conducted in October of 2005. 

47 
48

4.5	 Performance and Data Evaluation 

This subsection presents the performance data obtained 

during the XDD ISCO SITE Demonstration conducted from 

August 2004 to May 2006. Subsection 4.5.1 summarizes 

the soil analyses results soil (target VOCs in all three soil 

zones and humic fraction for the peat zone). Subsection 

4.5.2 summarizes groundwater analyses results for target 

VOCs and metals. A detailed statistical evaluation of the 

soil and groundwater VOC data is also included. 

Subsection 4.5.3 summarizes data quality assurance. 

4.5.1 Soil Results 

Soils were evaluated as pre- and post-treatment sample 

pairs to determine if reductions of VOCs had occurred due 

to the ISCO treatment. Baseline (pre-treatment) and final 

(post-treatment) soil samples were collected on a “paired 

sample” basis; final samples were collected in the 

approximate same location as baseline samples (i.e., 

within 0.3 feet to 2 feet laterally and within about one foot 

vertically). Both baseline and final soil samples were 

analyzed for VOCs and humate content. The soil VOC 

data was highly variable. High sample concentration 

variability at DNAPL sites is commonly observed, 

particularly at sites with heterogeneous lithologies. 

4.5.1.1 VOC Results for Soil 

The primary objective for soil was to determine if XDD’s 

ISCO process could reduce concentrations of PCE, TCE, 

cDCE, and VC by 90% from baseline to final sampling 

events (Objective 1). Tables 4-5 through 4-7 present 

results of the baseline (pre-treatment) soil sampling versus 

the final (post-treatment) soil sampling for each of the four 

critical VOCs (PCE, TCE, cDCE, and VC) for the shallow, 

peat (middle or intermediate) and deep zones, respectively. 

Based on pre-demonstration extraction studies, shallowzone soils were field-extracted using a 1:1 MeOH to soil 

ratio by volume; the middle peat and bottom zone soils 

were extracted using a 5:1 MeOH to soil ratio by volume. 

It should be noted that due to the large number of nondetect results, due to high laboratory reporting limits 

resulting from the MeOH field extractions, the soil data was 

analyzed (i.e., evaluated) three separate ways by: 

1.	 Analysis of soil sample pairs; 

2.	 Analysis of averaged soil results using only 

detected values; and 

3.	 Analysis of averaged soil results using all values. 

Each analysis is discussed separately as follows. 

Analysis of Soil Sample Pairs 

Although there were 30 sample pairs planned for each of 

the three stratigraphic zones (i.e., a planned total of 90 

pairs), not all pairs could be evaluated for treatment 

performance at their sampling location. This was primarily 

due to many of the pairs consisting of two non-detect 

values (i.e., values below the laboratory reporting limit or 

LRL). In other instances a quantified value was paired with 

a non-detect result having a reporting limit exceeding the 

quantified value. In other instances (i.e., for the peat zone), 

there was no baseline peat sample to pair with the posttreatment peat sample. 

As a result of not being able to evaluate a significant 

number of soil sample pairs, a subset of "eligible pairs" was 

selected for descriptive evaluation and included the 

following: 

•	 Sample pairs that met the original criteria set forth 

in the QAPP (i.e., where the baseline value was at 

least ten times the LRL); 

•	 Sample pairs not meeting the QAPP criteria, but 

either consist of two quantified values or have one 

quantified value and one estimated J value; 

•	 Sample pairs that contain one non-detect value 

(i.e., < the LRL); and the other value is a quantified 

or estimated J value that is significantly higher or 

lower than that reporting limit value. 

Table 4-8 presents a statistical summary of the soil data 

based on the eligible sample pairs, as just described. For 

each of the four critical VOCs and for each of the three 

zones, table 4-8 summarizes the results of the eligible pair 

analysis from two perspectives: 

1.	 Eligible pairs that show decreases in critical VOC 

concentration of any magnitude, and; 

2.	 Eligible pairs that show decreases in critical VOC 

concentration > 90% (i.e., the primary soil 

objective). 

As inferred in Table 4-8, it is apparent that few of the 

eligible paired sample sets for any of the four critical VOCs 

showed concentration decreases > 90% from baseline to 

final sampling events. Aside from the single TCE deep 

zone sample pair (which did show a > 90% reduction), TCE 

in the middle peat zone was the only instance where a 90% 

reduction was measured for more than 1⁄2 (i.e., 50%) of the 

eligible sample pairs evaluated. Of the four VOCs, TCE 

had the best overall percentage of sample pairs showing 

reductions > 90% (i.e., 40.9% for all zones combined). 

W ith respect to the percentage of eligible pairs that showed 

contaminant decreases of any magnitude, VC fared the 

best. For all zones combined, 82.1% of eligible sample 

pairs for VC showed contaminant reductions from baseline 

to final sampling; including 88.9% in the shallow zone and 

70% in the peat zone. 

49 
Table 4-5. Shallow Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final 1


Parameter� PCE (:g/kg) TCE (:g/kg) cDCE (:g/kg) VC (:g/kg) 

Boring No. 

Baseline Final Baseline Final Baseline Final Baseline Final 

1
 < 52.4
 110
 < 26.2 < 30.3 3,080 891
 158
 < 30.3 

2
 7,710
 < 56.1 757
 < 28
 2,350 278
 261
 111

3
 < 61.5
 < 54.9 < 30.7 < 27.4 < 30.7 67.3 < 30.7 < 27.4 

4
 234
 275,000 < 53.5 19,600 16,500 9,630 35 J < 28.3 

5
 88
 11,100 < 26.8 1,500 10,400 38,300 1,410 638

6
 90.5
 103
 22.3 J 22.0 J 1,030 287
 138
 < 29.9 

7
 41,000
 20.3 J 1,860 < 29.3 6,850 5,860 280
 < 29.3 

8
 34.9 J
 183
 < 26.1 65
 1,740 179
 2,060 < 31.2 

9
 < 53.1
 < 57.5 < 26.5 < 28.8 < 26.5 17.4 J < 26.5 < 28.8 

10
 20,000
 1,160 4,110 243
 5,700 11,600 476
 208

11
 < 52.8
 < 54.3 < 26.4 < 27.2 < 26.4 < 27.2 < 26.4 < 27.2 

12
 < 114
 < 58.1 < 57.2 < 29.0 < 57.2 < 29.0 < 57.2 < 29.0 

13
 < 60.8
 < 57.7 < 30.4 < 28.9 7,530 < 28.9 331
 < 28.9 

14
 4,660
 29,100 158
 2,050 1,090 15,400 770
 137

15
 31.8 J
 201
 < 28
 21.6 J 1,710 18.6 J 166
 < 29.4 

16
 26,400
 393,000 3,160 58,700 1,950 4,610 504
 < 142 

17
 604
 25.3 J 165
 < 29.3 10,100 1,270 < 54.1 < 29.3 

18
 21.7 J
 < 54.8 < 59.1 < 27.4 19.0 J 75.4 37.5 < 27.4 

19
 < 59.4
 24.9 J < 59.4 < 30.6 26.0 J 1,190 254
 528

20
 287
 1,650 < 52.2 549
 67.2 1,240 76.8 427

21
 < 64.9
 116
 < 64.9 34.7 476
 1,090 417
 289

22
 24.2 J
 26.3 J < 65.8 < 29.6 8,900 335
 3,020 < 29.6 

23
 < 63.7
 < 60.5 < 63.7 < 30.3 19.4 J 30.6 < 31.9 < 30.3 

24
 < 65.3
 < 53.7 < 65.3 < 26.8 61.5 21.4 J 79
 < 26.8 

25
 41.3 J
 1,850 < 55.2 375
 367
 904
 1,900 654

26
 138
 799,000 25.1 J 112,000 4,290 4,320 19.3 J < 287 

27
 8,920
 684
 963
 137
 9,010 6,100 19.4 J < 29.9 

28
 < 59.9
 < 58.1 < 59.9 < 29.1 3,460 19.9 J 2,270 < 29.1 

29
 21,000
 107,000 1,700 10,900 12,800 13,100 98.5 < 131 

30
 9,940 11,200 15,500 6,570 22,400 2,620 833
 < 28.8

1
 Sam ples field extracted with a 1:1 MeOH to soil ratio by volum e. J = Estim ated value (i.e., value is above the detection limit but below the laboratory reporting limit). 

50

Parameter� PCE (:g/kg) TCE (:g/kg) cDCE (:g/kg) VC (:g/kg)


Boring No.


Baseline
 Final Baseline Final Baseline Final Baseline Final 

1 < 385 < 421 < 192 < 210 977 413 < 192 < 210 

2 < 298 < 396 < 149 < 198 97.8 J < 198 < 149 < 198 

3 < 332 < 404 < 166 < 202 < 166 < 202 < 166 < 202 

4 26,600 3,380 674 2,350 21,900 24,400 1,690 2,490 

5 157 J 644 J < 189 < 454 35,800 1,090 8,270 1,920 

6 936 < 549 < 175 < 549 453 2,410 < 175 < 549 

7 < 863 141 J < 431 < 234 41,300 19,700 55,100 21,300 

8 < 374 509 J < 187 < 348 < 187 < 348 < 187 < 348 

9 --- < 408 --- < 204 --- < 204 --- < 204 

10 < 560 338 J < 280 < 226 < 280 413 < 280 < 226 

11 < 378 < 581 < 189 < 290 < 189 < 290 < 189 < 290 

12 < 291 < 494 < 145 < 247 < 145 208 J < 145 < 247 

13 < 667 < 515 < 667 < 258 1,730 < 258 212 J < 258 

14 132,000 1,660 5,130 < 466 8,020 2,230 < 750 < 466 

15 < 865 < 606 < 865 < 303 280 J 662 < 432 < 303 

16 77,400 < 635 6,770 < 317 17,100 467 7,850 < 317 

17 243,000 < 788 40,900 < 394 51,600 7,650 < 5,980 7,310 

18 < 702 < 925 < 702 < 462 1,650 1,410 < 351 < 462 

19 < 693 < 728 < 693 < 364 1,710 207 J 328 J < 364 

20 < 419 < 558 < 419 < 279 < 210 272 J < 210 < 279 

21 307 J < 599 < 535 < 299 4,430 379 1,050 < 299 

22 < 888 < 821 < 888 < 410 10,800 461 3,160 < 410 

23 < 364 < 594 < 364 < 297 270 1,990 < 182 < 297 

24 < 307 < 542 < 307 < 271 < 153 < 271 < 153 140 J 

25 --- 521 --- 120 J --- 62,000 --- 60,900 

26 2,550 4,800 1,850 433 38,300 35,000 21,800 16,200 

27 34,900 999 13,600 254 181,000 159,000 10,400 36,000 

28 < 405 < 378 < 405 < 189 3,180 < 189 782 < 189 

29 48,000 12,100 3,380 1,190 43,600 162,000 11,500 92,400 

30* --- 47,400 --- 4,590 --- 28,300 --- < 171 

1

 Sam ples field extracted with a 5:1 MeOH to soil ratio by volum e. * At boring 30, peat m aterial absent, but a sand sam pled due to high PID reading.

 — no sam ple collected. J = Estim ated value (i.e., value is above the detection limit but below the laboratory reporting limit). 

Table 4-6. Middle Peat Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final 1 

51 
Parameter� PCE (:g/kg) TCE (:g/kg) cDCE (:g/kg) VC (:g/kg) 

Boring No. 

Baseline Final Baseline Final Baseline Final Baseline Final 

1 348 < 362 < 151 < 181 < 151 < 181 < 151 < 181 

2 < 150 111 J < 150 < 177 < 150 < 177 < 150 < 177 

3 < 200 < 369 < 200 < 184 < 200 < 184 < 200 < 184 

4 4,740,000 31,400 6,000 < 181 < 149 < 181 < 149 < 181 

5 330 J < 333 < 169 < 166 < 169 < 166 < 169 92.3 J 

6 553 166 J < 158 < 169 < 158 < 169 < 158 < 169 

7 < 174 < 357 < 174 < 178 < 174 < 178 < 174 < 178 

8 243 29,600 < 163 139 J 234 < 223 < 163 < 223 

9 188 J < 395 < 201 < 197 < 201 < 197 < 201 102 J 

10 2,950 < 310 < 122 < 155 < 122 < 155 < 122 < 155 

11 < 169 < 385 < 169 < 192 < 169 < 192 < 169 < 192 

12 < 128 < 326 < 128 < 163 < 128 < 163 < 128 < 163 

13 1,590 < 310 < 133 < 155 < 133 19,500 < 133 < 155 

14 249,000 < 364 < 178 < 182 < 178 < 182 < 178 < 182 

15 1,260 < 536 < 167 < 268 < 167 < 268 < 167 < 268 

16 < 162 < 382 < 162 < 191 < 162 < 191 < 162 < 191 

17 < 153 < 1,180 < 153 < 588 < 153 < 29.3 < 153 < 588 

18 301 5,240 < 131 < 193 < 131 < 193 < 131 < 193 

19 4,980 < 349 < 146 < 175 < 146 < 175 < 146 < 175 

20 < 185 2,930 < 185 < 163 < 185 < 163 < 185 < 163 

21 2,580 < 313 < 166 < 156 < 166 < 156 < 166 < 156 

22 < 167 < 409 < 167 < 204 < 167 < 204 < 167 < 204 

23 998 < 296 < 156 < 148 < 156 < 148 < 156 < 148 

24 < 148 < 330 < 148 < 165 < 148 < 165 < 148 < 165 

25 < 182 159 J < 182 < 185 < 182 < 185 < 182 < 185 

26 < 144 < 319 < 144 < 160 < 144 < 160 < 144 < 160 

27 1,910 205 J < 173 < 211 < 173 < 211 < 173 < 211 

28 384 J < 286 < 389 < 143 503 < 143 < 389 < 143 

29 13,100 15,800 < 229 < 170 < 229 < 170 < 229 < 170 

30 814,000 288,000 < 1,570 < 447 < 1,570 237 J < 1,570 < 447 

1

 Sam ples field extracted with a 5:1 MeOH to soil ratio by volum e. J = Estim ated value (i.e., value is above the detection limit but below the laboratory reporting limit). 

Table 4-7. Bottom Zone Soil Results for PCE, TCE, cDCE, and VC - Baseline Vs Final 1 

52 
Table 4-8. Statistical Summary for Soil Sample Pair Analysis. 

Analyte Zone 2 Eligible 

Pairs 

Decreases Decreases > 90% 

# Dec. % Dec. 95% LL 95% UL # Dec. % Dec. 95% LL 95% UL 

PCE 

Shallow 17 5 29.4 12.4 55.4 4 23.5 8.5 48.9 

Peat 9 7 77.8 44.2 95.9 4 44.4 16.9 74.9 

Deep 15 11 73.3 44.8 90.3 6 40 19.1 66.8 

All Combined 41 23 56.1 40.9 71.3 14 34.1 19.6 48.7 

TCE 

Shallow 14 6 42.9 20.6 68.8 4 28.6 10.4 61.1 

Peat 7 6 85.7 44.6 99.3 4 57.1 22.5 87.1 

Deep 1 1 100 5.0 100 1 100 5.0 100 

All Combined 22 13 59.1 38.5 79.6 9 40.9 20.4 61.5 

cDCE 

Shallow 26 14 53.8 32.5 71.8 4 15.4 5.4 32.5 

Peat 19 14 73.7 50 89 6 31.6 14.7 57.4 

Deep 2 1 50 2.5 97.5 0 0.0 0.0 77.6 

All Combined 47 29 61.7 47.8 75.6 10 21.3 9.6 33 

VC 

Shallow 18 16 88.9 67.5 98 8 44.4 23.6 67.5 

Peat 10 7 70 38.1 91.3 2 20 3.7 60.3 

Deep 0 0 --- --- --- 0 --- --- ---

All Combined 28 23 82.1 64.3 92.7 10 35.7 19.2 57.6 

LL = Lower limit of confidence interval. UL = Upper limit of confidence interval. Dashed line = no calculation possible. 

Analysis of Averaged Soil Results Using Detected Values 

In addition to analyzing soils on a paired sample basis, soil 

results were also evaluated on an average pre-treatment 

(baseline) versus post-treatment (final) basis. Table 4-9 

presents averaged results for the four critical VOC 

compounds (PCE, TCE, cDCE, and VC), using all 

quantified and estimated (“J”) values. Average values are 

shown for the three individual lithologic zones and for all 

zones combined. The number of values averaged are 

shown in parenthesis next to each average value. 

W hen excluding non-detected results, on an all zones 

combined basis, PCE is the only VOC of the four critical 

compounds for which there is shown a relevant decrease 

in average concentration (i.e., 63.5%). The averaged data 

suggests that there were reductions of PCE concentrations 

in the peat and deep zones, but an increase in PCE 

concentrations in the shallow zone. 

On a per zone basis and accounting for a decreased 

sample size, the best overall reductions appear to have 

been achieved in the middle peat zone. On average there 

are relatively large decreases shown for PCE (95.6%) and 

TCE (91.6%). A very small average reduction is shown for 

cDCE (1.03%) and VC is shown to increase on average by 

161%. For the shallow zone, two VOCs showed increased 

average concentrations (PCE and TCE) and two VOCs 

showed decreased average concentrations (cDCE and 

VC). For the bottom zone, PCE and TCE were also shown 

to have decreased average concentrations and cDCE was 

shown to have increased average concentrations. VC 

could not be evaluated due to the lack of baseline data 

above LRLs. 

Analysis of Averaged Soil Results Using All Values 

To statistically determine whether the null hypothesis is 

rejected or not (i.e., the primary objective), all soil results 

comprising baseline and final pairs were evaluated (Table 

4-10). By doing this, the sample population for baseline 

and final samples were the same for each of the three 

zones. For example, if non-detect results are included, 

there are 30 baseline and 30 final sample results for the 

shallow and deep zones; and there are 27 baseline and 27 

final sample results for the middle peat zone (Note: there 

were three borings at which peat was encountered at 27 of 

the 30 borings sampled during the baseline activity). 

53 
Table 4-9. Averaged Soil Results (Excluding Non-Detects) for PCE, TCE, cDCE, and VC - Baseline Vs. Final. 

Analyte Zone 

Average Concentration, :g/Kg (sample No.) Decrease / 

Increase % Change Baseline Final 

PCE 

Shallow 7,433 (19) 81,578 (20) Increase + 998 

Peat 56,585 (10) 2,509 (10) Decrease - 95.6 

Deep 324,151 (18) 37,361 (10) Decrease - 88.5 

All Combined 139,187 (47) 50,756 (40) Decrease - 63.5 

TCE 

Shallow 2,584 (11) 14,184 (15) Increase + 449 

Peat 10,329 (7) 869 (5) Decrease - 91.6 

Deep 6,000 (1) 139 (1) Decrease - 97.7 

All Combined 5,617 (19) 10,345 (21) Increase + 84.2 

cDCE 

Shallow 5,074 (26) 4,424 (27) Decrease - 12.8 

Peat 23,210 (20) 22,970 (21) Decrease - 1.03 

Deep 369 (2) 9,869 (2) Increase + 2,570 

All Combined 12,435 (48) 12,431 (50) No Change - 0.03 

VC 

Shallow 651 (24) 374 (8) Decrease - 42.5 

Peat 10,179 (12) 26,518 (9) Increase + 161 

Deep — (0) 97 (2) --- ---

All Combined 3,827 (36) 12,729 (19) Increase + 233 

W hen including non-detected results on an all zones 

combined basis, PCE is still the only VOC of the four 

critical compounds for which there is shown a decrease of 

any magnitude in average concentration (i.e., 68.9%). The 

other compound showing a decrease, although slight, is 

cDCE (6.27%). Averaged data suggests that there were 

considerable reductions of PCE concentrations in the peat 

material (94.8%) and deep zone (93.5%), but an increase 

in PCE concentrations in the shallow zone (1,050%). 

On a per zone basis and accounting for a decreased 

sample size, the best overall reductions appear to have 

been achieved in the middle peat material and in the deep 

zone. For the peat material, on average there are relatively 

large decreases shown for PCE (94.8%) and TCE (89.7%) 

and a small average reduction shown for cDCE (9.39%). 

VC is shown to increase on average by 42.4%. For the 

bottom zone, PCE and TCE were also shown to have 

considerable decreased average concentrations (93.5% 

and 66.7%, respectively). VC showed a slight decrease 

(5.5%). But cDCE, a known breakdown product, was 

shown to have increased by 488% on average. For the 

shallow zone, two VOCs showed increased average 

concentrations (PCE at 1,050% and TCE at 638%) and two 

VOCs showed decreased average concentrations (cDCE 

at 9.48% and VC at 77.5%). 

The hypothesis test suggested in the QAPP is that the 

technology will remove more than 90% of contamination. 

The null hypothesis tested here is that the contamination 

removed does not exceed 90%. That is, we test the null 

hypothesis: 

against the alternative hypothesis 

Accepting the null hypothesis would be a finding that the 

process does not meet demonstration objectives. If the 

null hypothesis is rejected for a given set of experimental 

circumstances, then the technology meets demonstration 

objectives for those experimental circumstances. 

54 
Table 4-10. Averaged Soil Results (Including Non-Detects) for PCE, TCE, cDCE, and VC - Baseline Vs. Final. 

Analyte Zone (Sample No) 

Average Concentration, :g/Kg Decrease / 

Increase 

% 

Change 

95% 1 

LL 

95%1 

UL 

Baseline Final 

PCE 

Shallow (30) 4,721 54,395 Increase + 1,050 - 166 + 2,270 

Peat (27) 21,120 1,105 Decrease - 94.8 - 99.9 - 89.6 

Deep (30) 194,523 12,586 Decrease - 93.5 - 103.5 - 83.5 

All Combined (87) 75,259 23,440 Decrease - 68.9 -117 - 21.2 

TCE 

Shallow (30) 962 7,099 Increase + 638 - 310 + 1,590 

Peat (27) 2,825 291 Decrease - 89.7 - 100 - 79.0 

Deep (30) 306 102 Decrease - 66.7 - 109 - 25.0 

All Combined (87) 1,314 2,573 Increase + 95.8 - 156 + 348 

cDCE 

Shallow (30) 4,400 3,983 Decrease - 9.48 - 73.1 + 54.2 

Peat (27) 17,217 15,601 Decrease - 9.39 - 68.2 + 49.5 

Deep (30) 126 741 Increase + 488 - 514 + 1,490 

All Combined (87) 6,904 6,471 Decrease - 6.27 - 51.1 + 38.6 

VC 

Shallow (30) 524 118 Decrease - 77.5 - 92.3 + 62.6 

Peat (27) 4,700 6,693 Increase + 42.4 - 91.8 + 177 

Deep (30) 109 103 Decrease - 5.5 - 38.8 + 28.4 

All Combined (87) 1,677 2,154 Increase + 28.4 - 83.3 + 140 

1

 Values rounded to three significant digits. 

Table 4-10 provides the basis for testing the null hypothesis 

for each of the four analytes for each of the three zones 

and for all zones combined. As previously discussed for 

each of these combinations, Table 4-10 provides an 

estimate in the percentage change or reduction in 

contamination in the third column from the right. In the last 

2 columns the table also provides the lower and upper 

limits of the 95% confidence interval for the actual or 

population percentage change. 

For example, consider TCE for the Peat zone. Table 4-10 

shows a percentage change of -89.7% with a 95% 

confidence interval of (-100%, -79%). 

Now for each of the 16 sets of analyte-zone combinations, 

the null hypothesis is accepted if the upper limit of the 95% 

confidence interval is greater than -90.0%. For instance, in 

the case of TCE in the Peat zone, the upper limit of the 

confidence interval is -79.0% which is greater than -90.0%. 

Thus, we fail to reject the null hypothesis for TCE in the 

Peat zone. Based on this hypothesis testing framework, 

we fail to reject the null hypothesis for each analyte in each 

zone and for each analyte in all zones combined. 

We hasten to add, however, that we are using a two-sided 

95% confidence interval to test a one-sided hypothesis, 

and therefore, the hypotheses are actually being tested at 

the 97.5% level. Testing these hypotheses at the 90% 

level, yields the same outcomes with one exception. At the 

90% hypothesis testing level, the null hypothesis would be 

rejected for PCE in the Peat zone. The null hypothesis 

would be accepted for all other cases. 

Statistical methods for confidence intervals provided in the 

tables for the soil results are provided as follows. 

Statistical Methods for Confidence Intervals 

In this section, confidence intervals are presented for three 

kinds of population quantities: 

< population proportion for a binomial distribution; 

< population mean values 

distribution theory; and 

based on normal 

< ratios of population means based 

distribution asymptotic theory. 

on normal 

55 
Equation (1) 

i where n = sample size, and X are the

 measurements for each sample for I = 1,..., n. Equation (2) 

Equation (3) 

Equation (4)

 where X denotes the sample mean of the pre-treatment measurements;

 where Y denotes the sample mean of the post-treatment measurements, and 

R = X / Y with n, post-treatment measurements, and n, pre-treatment measurements 

Equation (5) 

n number of successes 

p = 

n 

post-treatment constituent mass 

p R = -1

pre-treatment constituent mass 

Proportion 

For a binomial distribution population proportion, the 

sample proportion is given by: 

where n is the number trials or sample pairs. In case n > 

30, a 95% confidence interval for the population, proportion 

p is given by Equation 1 (Eq. 1) where t(0.975, n - 1) is the 

upper 97.5 percentile of the student-t distribution with (n ­

1)degrees of freedom. This confidence interval places 2.5 

percentage points for both the upper and lower endpoints 

of the confidence interval. 

One can multiply the confidence interval expression by 100 

to translate the proportional expression into percentage 

points. W hen n < 30, the two-sided confidence intervals 

were taken from tables of exact confidence intervals for a 

binomial distribution. (see Table A-22 of Natrella, 1963). 

Mean Value 

The sample mean value is given by Eq.2. The two-sided 

95% confidence interval for the population mean value is 

given by Eq. 3, where μ is the population mean value and 

S2

x in Eq. 4 is the sample estimate of the variance or the 

square of the sample standard deviation. 

Ratio of Mean Values 

Define the proportion of change of in place contamination 

from the baseline or pretreatment measurements to the 

final or post-treatment measurements as: 

where pR with the pretreatment and post-measurement 

sample mean values by Eq. 5. From Hansen, et al. 

(1993),the sample variance of 

is approximated by Eq. 6. The two-sided 95% confidence 

interval for pR is approximated by Eq. 7. Of course, one 

can multiply the confidence interval expression by 100 to 

translate the proportional expression into percentage 

points. 

56 
 where Equation (6) 

Equation (7) 

4.5.1.2 Humate Results for Soil 

To assess the impact of the organic matter in the peat with 

respect to its effect on oxidant depletion, samples were 

collected from the middle peat zone during both baseline 

and final sampling events (Objective 3). Table 4-11 

presents the results of the humic acid analyses, which 

reflects the amount of humate material in a soil. Instead of 

an expected potential depletion of humic material, there is 

shown a measured increase. The average of 27 baseline 

values was 2.6 % and the average of 26 final values was 

6.0 %, an increase of 230%. Also shown in the table is that 

for all borings in which there are paired values, the final 

value is always greater with the exception of Boring No. 1. 

There is no obvious explanation for the measured increase 

in humic acid content from baseline to final. 

Table 4-11. Humic Acid Results for Middle Peat Zone - Baseline Vs. Final (wt/wt %)1 

Boring No. Baseline Final Boring No. Baseline Final 

1 3.1 2.07 16 5.8 10.5 

2 1.1 2.65 17 4.4 8.21 

3 0.8 1.35 18 3.1 11.3 

4 0.6 --- 19 4.5 5.53 

5 1.4 8.33 20 2.4 4.57 

6 < 0.1 7.59 21 4.1 8.04 

7 2.1 9.58 22 6.4 7.32 

8 < 0.2 4.02 23 1.0 3.40 

9 --- 4.29 24 0.3 ---

10 3.7 4.27 25 --- 10.1 

11 1.1 --- 26 3.6 3.33 

12 < 0.1 6.08 27 0.5 7.29 

13 3.7 5.11 28 5.6 1.74 

14 3.6 7.02 29 < 0.1 4.77 

15 6.4 8.45 30 --- ---

1

 Values rounded to maxim um three significant digits. Dashed line = lack of peat m aterial to analyze.

Using 1⁄2 the reporting lim it for non-detect values (i.e., < values), the average of all baseline values = 2.6% & average of all final values = 6.0%. 

57
4.5.2 Groundwater Results 

4.5.2.1 Target Ethene VOCs 

The primary objective for groundwater was to evaluate the 

effectiveness of XDD’s ISCO process in reducing 

concentrations of the PCE, TCE, and cDCE in the 

groundwater to below their corresponding Remediation 

Performance Standards (RPS) of 750 :g/L, 5,500 :g/L, 

and 17,500 :g/L, respectively. The QAPP specified that to 

meet the primary groundwater objective (Objective 2) more 

than 90% of eligible groundwater samples had to meet 

those regulatory criteria, as to reject the null hypothesis 

(i.e., concentrations reduced to below the RPS). 

The hypothesis test proposed in the QAPP is based on the 

population proportion, call it p, of sample pairs that meet 

regulatory goals. The null hypothesis to be tested is: 

H : p < or = 0.90 0

against the alternative hypothesis 

 H : p > 0.90. A

Accepting the null hypothesis would be a finding that the 

process does not attain regulatory goals. For any 

experiment in which the sample proportion of pairs meeting 

regulatory goals do not exceed 0.90, the null hypothesis 

would be accepted. (Note that this does not imply that the 

proportion being, for example, 0.901 would be sufficient to 

reject the null hypothesis). 

It should be noted that, beginning with the initial baseline 

sampling event and continuing through intermediate 

sampling events, there was a total of up to 15 samples 

collected from 5 different wells at the three distinct 

horizons. However, the sample number for the final posttreatment event was increased to a total of 30. This 

change in strategy was due to a desire to increase the 

sample population and thus provide better statistics. 

To accomplish the increased sample number for the final 

event without having to install additional wells, samples 

were collected from the existing 15 wells on two different 

days (2 x 15 = 30). A day (i.e., 24 hours) separated these 

two sampling rounds so that, based on the horizontal 

gradient, samples were considered independent both 

spatially and with respect to temporal location. In other 

words, the second set of samples was considered separate 

and independent from the first set of samples. 

It also should be noted that since there were two injection 

events, there are two groundwater baseline events. W ells 

influenced by the first injection (IW -3, EW -3 and EW -4 well 

clusters) correlate to the April 2005 groundwater sampling 

event and wells influenced by the second injection (IW -1 

and EW -2 well clusters) correlate to the September 2005 

groundwater sampling event. 

Table 4-12 presents results of the baseline (pre-treatment) 

groundwater sampling and the two rounds comprising the 

final (post-treatment) groundwater sampling. Within Table 

4-12, the cells for baseline values that were measured 

above the RPS are blocked (e.g., for well cluster IW -1, 

shallow zone, the PCE value of 5,200 :g/L is blocked 

because it is above the RPS of 750 :g/L). 

The primary groundwater objective was evaluated three 

different ways; including: 

1.	 Baseline vs. final results for each individual 

well;(i.e., the baseline pre-treatment value vs. the 

average of the 2 final post-treatment values); 

2.	 On an overall sample set basis (i.e., the average 

of all 15 baseline pre-treatment values vs. the 

average of all 30 final post-treatment values); and 

3.	 On a per groundwater zone basis (i.e.,the average 

of 5 baseline pre-treatment values for each of the 

three zones vs. the average of 10 final posttreatment values for each of those three zones). 

Individual W ell Evaluation 

As shown in Table 4-12, on an individual well basis, there 

are only seven instances where any of the three ethene 

compounds exceeded their respective RPS prior to oxidant 

injection. Therefore, there are just seven eligible baseline 

samples to evaluate (Note: seven pairs do not give 

sufficient resolution to test the null hypothesis at the 95% 

confidence level). However, when averaging the two final 

result values to attain a final post-treatment concentration, 

such a reduction occurred in three of seven instances (i.e., 

PCE in EW -4, deep; TCE in IW -1 shallow; and cDCE in 

IW -1 shallow). In two other instances (cDCE in IW -1 

intermediate, and TCE in EW -2 shallow) reductions are 

measured close to the RPS. For the individual well 

evaluations, the null hypothesis is accepted for each of the 

three contaminants (i.e., the objective was not met). 

Total Sample Set Evaluation 

For the entire sample set, PCE was the only critical VOC 

that on average was above its respective RPS. On an 

overall contaminant average basis, PCE did show an 

approximate 27% reduction to very slightly below the RPS 

(from 1,020 :g/L to 746 :g/L). Apparent reductions are 

also shown for the two other critical compounds having 

RPSs, TCE and cDCE. TCE is shown to have an 

approximate 51% reduction (from an average baseline 

concentration of 1,260 :g/L to an average final 

concentration of 612 :g/L. For cDCE there is an 

approximate 58% reduction (from an average baseline 

concentration of about 7,400 :g/L to an average final 

concentration of approximately 3,090 :g/L). It should be 

noted that standard deviations are relatively high when 

observing the total groundwater sample set, especially for 

the baseline sample set. This is largely due to a high 

variability of contaminant concentrations among the three 

zone depths samples. 

58 
Table 4-12. Groundwater Results for Target Ethenes - Baseline Vs. Final. 

PARAMETER, Remediation Performance Standard (RPS) in :g/L 1 

Well 

PCE, 750 TCE, 5,500 cDCE, 17,500 Cluster 2 Zone

ID Baseline Final Baseline Final Baseline Final 

Shallow 5,200 1,090 11,200 572 31,000 3,630

1,360 766 3,620 

IW-1 Intermediate 16.4 J 1,120 62.1 892 50,100 20,100

1,310 1,950 16,700 

Deep 208 545 1.0 < 0.5 1.7 < 0.5 

5,370 < 0.5 0.34 J 

Shallow 81.7 718 63 677 4,590 2,810

637 620 1,890 

IW-3 Intermediate 3.6 J 9.1 < 5.0 6.3 18.4 392 

7.3 6.4 614 

Deep 369 < 0.5 0.75 < 0.5 < 0.5 < 0.5 

< 2.5 < 0.5 < 2.5 

Shallow 6,830 4,190 7,090 4,810 15,500 9,510

5,560 7,430 13,600 

EW-2 Intermediate 86.5 17.8 148 97.4 6,220 4,490

55.5 228 7,770 

Deep 10.6 3.0 < 1.0 < 0.5 < 1.0 < 0.5 

1.5 < 0.5 < 0.5 

Shallow 141 80.1 290 58.7 3,750 341 

284 194 894 

EW-3 Intermediate < 5.0 3.6 < 5.0 10.4 75.1 24.8 

8.2 38.3 105 

Deep 45.9 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 

< 0.5 < 0.5 < 0.5 

Shallow 2.6 0.75 2.5 3.3 345 978 

1.6 7.7 5,300 

EW-4 Intermediate 1.8 < 0.5 < 0.5 < 0.5 15.3 8.0 

< 0.5 0.37 J 6.9 

Deep 2,310 < 0.5 2.1 < 0.5 1.6 < 0.5 

< 0.5 < 0.5 < 0.5 

3 Average 1,020 746 1,260 612 7,440 3,090 

3 Standard Deviation 2,130 1,530 3,300 1,590 14,500 5,320 

3 Coefficient of Variance 2.09 2.05 2.62 2.6 1.95 1.72 

95% UL 3 2,200 1,320 3,080 1,210 15,500 5,080 

95% LL 3 - 160 174 - 568 17.7 - 604 1,110 

1 . Blocked values are those exceeding the RPS. Two sam pling rounds were conducted for the final sam pling event (March 14 & 16, 2006) 2

 Approxim ate depths for zones (i.e., screened intervals in feet bls) were as follows: Shallow (4-9), Interm ediate (13-14), and Deep (20-25) 3

 Values are rounded to a m axim um three significant digits. For Non-detect values (i.e., < values), 1⁄2 the reporting lim it was used for averaging.

 J = estim ated value. UL = Upper Lim it of 95% confidence interval. LL = Lower limit of 95% confidence interval. 

59

Table 4-13. Shallow Zone Groundwater Results for Target Ethenes - Baseline Vs. Final. 

PARAMETER, Remediation Performance Standard (RPS) in :g/L 1 

PCE, 750 TCE, 5,500 cDCE, 17,500 2 Well ID Zone 

Baseline Final Baseline Final Baseline Final 

IW-1s Shallow 5,200 1,090 11,200 572 31,000 3,630

1360 766 3,620 

IW-3s Shallow 81.7 718 63 677 4,590 2,810

637 620 1,890 

EW-2s Shallow 6,830 4,190 7,090 4,810 15,500 9,510

5560 7,430 13,600 

EW-3s Shallow 141 80.1 290 58.7 3,750 341 

284 194 894 

EW-4s Shallow 2.6 0.75 2.5 3.3 345 978 

1.6 7.7 5,300 

3 Average 2,450 1,390 3,730 1,510 11,000 4,260 

3 Standard Deviation 3,300 1,920 5,150 2,520 12,500 4,240 

3 Coefficient of Variance 1.35 1.38 1.38 1.67 1.13 1.00 

3 95% UL 6,550 2,770 10,100 3,320 26,600 7,290 

3 95% LL - 1,652 20 - 2,670 - 290 - 4,510 1,220 

1

 Blocked values are those exceeding the RPS. Two sam pling rounds were conducted for the final sam pling event (March 14 & 16, 2006).

2 Approxim ate depths for zones (i.e., screened intervals in feet bls) were as follows: Shallow (4-9), Interm ediate (13-14), and Deep (20-25). 

3

 Values are rounded to a m axim um three significant digits. For Non-detect values (i.e., < values), 1⁄2 the reporting lim it was used for averaging.

 J = estim ated value. UL = Upper Lim it of 95% confidence interval. LL = Lower limit of 95% confidence interval. 

Groundwater Zone Evaluation 

On a per groundwater zone basis the results are based on 

a small subset of the overall data set (i.e., there are just 5 

baseline pre-treatment values for each of the three zones 

versus the average of just 10 final post-treatment values 

for each of those same three zones). 

Shallow Zone: Standalone results for shallow zone 

groundwater are presented in Table 4-13. On average, 

there appears to be reductions in concentrations from 

baseline to final sampling for all three ethene compounds 

Intermediate (Peat) Zone: Standalone results for 

intermediate zone groundwater are presented in Table 4­

14. On average, there appears to be substantial increases 

for PCE and TCE; and a decrease in cDCE. The increases 

in PCE and TCE concentration averages are almost 

exclusively due to drastic increases in those compounds in 

well IW -1i (the IW -1 cluster is closest to the source area). 

In similar fashion, the decrease in average cDCE can be 

mostly attributed in a substantial decrease on that 

compound in well IW -1i. 

(i.e., PCE - 43%, TCE - 60%, and cDCE - 61%). Also 

shown in Table 4-13, there are five instances where the 

baseline value for any of the three ethene compounds 

exceeded their respective RPS prior to oxidant injection. 

Of these five instances, the average of the two final event 

values is below the RPS in two cases (i.e., TCE in wells 

IW -1s and cDCE in IW -1s). 

For the shallow zone evaluations, the null hypothesis is 

accepted for each of the three contaminants (i.e., the 

objective was not met). 

Also shown in Table 4-14, there is one instance where the 

baseline value for one of the ethene compounds exceeds 

its respective RPS prior to oxidant injection (i.e., cDCE in 

IW -1i). However the average of the two final event values 

is 18,400 :g/L, which is above the RPS of 17,500 :g/L. 

For the intermediate zone evaluations, the null hypothesis 

is accepted for each of the three contaminants (i.e., the 

objective was not met). 

60 
Table 4-14. Intermediate Zone Groundwater Results for Target Ethenes - Baseline Vs. Final. 

PARAMETER, Remediation Performance Standard (RPS) in :g/L 1 

PCE, 750 TCE, 5,500 cDCE, 17,500 2 Well ID Zone 

Baseline Final Baseline Final Baseline Final 

IW-1i Intermediate 16.4 J 1,120 62.1 892 50,100 20,100

1,310 1,950 16,700 

IW-3i Intermediate 3.6 J 9.1 < 5.0 6.3 18.4 392 

7.3 6.4 614 

EW-2i Intermediate 86.5 17.8 148 97.4 6,220 4,490

55.5 228 7,770 

EW-3i Intermediate < 5.0 3.6 < 5.0 10.4 75.1 24.8 

8.2 38.3 105 

EW-4i Intermediate 1.8 < 0.5 < 0.5 < 0.5 15.3 8.0 < 0.5 0.37 J 6.9 

3 Average 22.2 253 43.1 323 11,300 5,020 

3 Standard Deviation 36.5 509 64.2 634 21,900 7,540 

3 Coefficient of Variance 1.65 2.01 1.49 1.96 1.94 1.50 

3 95% UCL 67 617 123 777 38,400 10,400 

3 95% LCL - 23 - 111 - 37 - 131 - 15,900 - 374 

1

 Blocked value is that exceeding the RPS. Two sam pling rounds were conducted for the final sam pling event (March 14 & 16, 2006). 2

 Approxim ate depths for zones (i.e., screened intervals in feet bls) were as follows: Shallow (4-9), Interm ediate (13-14), and Deep (20-25). 3

 Values are rounded to a m axim um three significant digits. For Non-detect values (i.e., < values), 1⁄2 the reporting lim it was used for averaging.

 J = estim ated value. UL = Upper Lim it of 95% confidence interval. LL = Lower limit of 95% confidence interval. 

Deep Zone: Standalone results for deep zone 

groundwater are presented in Table 4-15. The average of 

all wells show no appreciable change in contaminant 

concentration from baseline to final sampling. However, 

that generalization is misleading for PCE, which shows an 

increase in well IW -1d but decreases in the other four 

wells. There are appreciable PCE concentration 

decreases in IW -3d and EW -4d where average baseline 

values of 369:g/L and 2,310 :g/L were reduced to below 

detection limits in final event samples. The 2,310 :g/L 

average value for EW -4d was the only instance where the 

baseline value for PCE exceeded the RPS prior to oxidant 

injection. 

For the deep zone evaluations, the null hypothesis is 

accepted for each of the three contaminants (i.e., the 

objective was not met). 

61 
Table 4-15. Deep Zone Groundwater Results for Target Ethenes - Baseline Vs. Final. 

PARAMETER, Remediation Performance Standard (RPS) in :g/L 1 

PCE, 750 TCE, 5,500 cDCE, 17,500 2 Well ID Zone 

Baseline Final Baseline Final Baseline Final 

IW-1d Deep 208 545 1.0 < 0.5 1.7 < 0.5 

5370 < 0.5 0.34 J 

IW-3d Deep 369 < 0.5 0.75 < 0.5 < 0.5 < 0.5 < 2.5 < 0.5 < 2.5 

EW-2d Deep 10.6 3.0 < 1.0 < 0.5 < 1.0 < 0.5 

1.5 < 0.5 < 0.5 

EW-3d Deep 45.9 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 

EW-4d Deep 2,310 < 0.5 2.1 < 0.5 1.6 < 0.5 < 0.5 < 0.5 < 0.5 

3 Average 589 592 0.8 0.4 0.86 0.36 

3 Standard Deviation 973 1,690 0.8 0.3 0.73 0.31 

3 Coefficient of Variance 1.65 2.85 0.89 0.90 0.85 0.88 

3 95% UL 1,800 1,800 1.79 0.58 1.77 0.58 

3 95% LL - 619 - 615 - 0.09 0.12 - 0.05 0.13 

1 . Blocked values are those exceeding the RPS. Two sam pling rounds were conducted for the final sam pling event (March 14 & 16, 2006) 2

 Approxim ate depths for zones (i.e., screened intervals in feet bls) were as follows: Shallow (4-9), Interm ediate (13-14), and Deep (20-25) 3

 Values are rounded to a m axim um three significant digits. For Non-detect values (i.e., < values), 1⁄2 the reporting lim it was used for averaging.

 J = estim ated value. UL = Upper Lim it of 95% confidence interval. LL = Lower limit of 95% confidence interval. 

4.5.2.2 Non-Critical VOCs 

In addition to the critical ethene compounds (PCE, TCE, 

and cDCE), there are three additional VOCs having an 

associated RPS for the former MEC building site. These 

included toluene and two ethane compounds 1,1,1 

Trichloroethane (1,1,1-TCA), and 1,1-Dichloroethane (1,1­

DCA). Table 4-16 presents results of the baseline 

(pre-treatment) groundwater sampling and the two rounds 

comprising the final (post-treatment) groundwater 

sampling. Toluene was the only compound measured at 

baseline above the RPS in any of the wells (i.e., EW -2). 

Final toluene concentrations for EW -2 were measured 

above the RPS of 2,570 :g/L. 

4.5.2.3 KMnO4 

KMnO4 is visually observable in groundwater at relatively 

low concentrations (i.e., 1 ppm). Therefore, following the 

initial injection of oxidant solution KMnO4 was visually 

monitored in all groundwater samples collected through the 

final post-treatment event. Table 4-17 presents the critical 

VOC results of all demonstration groundwater events with 

respect to the presence of KMnO4 (i.e., sample results 

shaded purple are those in which KMnO4 was observed in 

the groundwater during sample collection). There are two 

general observations that are apparent regarding the visual 

presence of KMnO4. 

1.	 KMnO 4 was seen in all deep zone wells following 

the first injection, but seen in only one well on one 

occasion in the intermediate zone (a well receiving 

injected KMnO4 about four months earlier). 

KMnO4 was never observed in upper zone wells. 

2.	 In most instances, target VOCs were reduced to 

below LRLs when KMnO4 was visually present. 

Knowing that there was more KMnO4 injected into the deep 

zone relative to the shallow and intermediate peat zones, 

and knowing that the peat zone contained substantial 

humic material, the two observations above infer that the 

mass of KMnO4 injected into the shallow and peat zones 

may not have been sufficient or was not delivered to all 

desired localities. However the mass of KMnO4 injected 

into the deep zone appears to have been more than 

sufficient to treat the deep zone groundwater, especially 

since the KMnO4 persisted long after the target VOCs were 

apparently oxidized. It is also possible that the deep zone 

benefitted from downward seeping oxidant that had been 

targeted for the peat zone. 

62 
Table 4-16. Groundwater Results for Non-Critical VOCs - Baseline Vs. Final. 

Well PARAMETER, Remediation Performance Standard (RPS) in :g/L 1 

Cluster Toluene, 2,570 1,1,1-TCA, 6,800 DCA, 27,500 ID Zone 

Baseline Final Baseline Final Baseline Final 

Shallow 43.1 7.7 69.7 62.9 < 10 12.6 

5.6 61.0 10.8 

IW-1 Intermediate 1,160 1,580 < 10 166 709 235 

1,250 163 192 

Deep 1.5 6.2 0.63 0.68 < 0.5 < 0.5 

12.2 1.20 < 0.5 

Shallow 37.5 221 61.5 159 29.3 123 

121 130 57.3 

IW-3 Intermediate 645 1,630 < 5 2.1 6.0 92.6 

1,780 11.2 93.4 

Deep < 0.5 0.39 J 0.54 2.9 < 0.5 < 0.5 

2.4 J 7.5 < 2.5 

Shallow 1,510 197 1,290 200 916 159 

296 346 251 

EW-2 Intermediate 5,770 5,660 125 4.7 J 234 79.5 

9,250 14.7 199 

Deep < 0.5 3.1 0.41 J < 0.5 < 0.5 < 0.5 

1.1 < 0.5 < 0.5 

Shallow 223 6.9 47.5 59.1 84.8 38.4 

3.1 58.5 48.2 

EW-3 

Intermediate 234 232 < 5 < 0.5 21.1 7.5 

467 1.0 18.5 

Deep < 0.5 0.24 J 0.39 J < 0.5 < 0.5 < 0.5 

< 0.5 < 0.5 < 0.5 

Shallow 154 270 < 0.5 < 0.5 14.8 34.9 

166 0.24 J 67.3 

EW-4 

Intermediate 90 5.6 < 0.5 < 0.5 2.9 0.49 J 

16.2 < 0.5 0.86 

Deep 9.4 4.2 < 0.5 3.5 < 0.5 < 0.5 

4.3 3.0 < 0.5 

3 Average 659 773 107 48.7 135 57.5

1 Blocked values are those exceeding the RPS. Two sam pling rounds were conducted for the final sam pling event (March 14 & 16, 2006). 2

 Approxim ate depths for zones (i.e., screened intervals in feet bls) were as follows: Shallow (4-9), Interm ediate (13-14), and Deep (20-25) 3

 Values are rounded to a m axim um three significant digits. For Non-detect values (i.e., < values), 1⁄2 the reporting lim it was used for averaging.

 J = estimated value. 

63

Tab 4 le 4-17. KMnO Vs. PCE, TCE, and cDCE Concentrations in Groundwater - All Events 

Well

ID 1 

Event

�

Zone 

PARAMETER (Units), Remediation Performance Standard (RPS) in :g/L 

PCE (:g/L), 750 TCE (:g/L), 5,500 cDCE (:g/L), 17,500 

IW -3 Injection IW -1 / IW -2 Injection

(June 6-10) (Oct. 3-6)

I I 

IW -3 Injection IW -1 / IW -2 Injection

(June 6-10) (Oct. 3-6)

I I 

IW -3 Injection IW -1 / IW -2 Injection

(June 6-10) (Oct. 3-6)

I I 

1 st

BL

6/05 

2 BL nd

9/05 

1 st

Int.

12/05 

2 nd

Int.

2/06 

Final

3/06 

1 BL st

6/05 

2 BL nd

9/05 

1 Int. st

12/05 

2 nd

Int.

2/06 

Final

3/06 

1 BL st

6/05 

2 BL nd

9/05 

1 Int. st

12/05 

2 nd

Int.

2/06 

Final

3/06 

R1 R2 R1 R2 R1 R2 

IW-1 

Shallow 220 5,200 126 343 1,090 1,360 854 11,200 638 748 572 766 6,500 31,000 3,840 1,620 3,630 3,620 

Inter. < 10 16.4J 13.4 102 1,120 1,310 < 10 62.1 12.3 932 892 1,950 2,180 50,100 27,800 23,800 20,100 16,700 

Deep 897 208 1.7 56.9 545 5,370 1.6 1.0 < 0.5 3.0 < 0.5 < 0.5 < 0.5 1.7 0.32 J 73.7 < 0.5 0.34 J 

IW-3 

Shallow 81.7 295 --- 175 718 637 63 467 --- 103 677 620 4,590 3,600 --- 390 2,810 1,890 

Inter. 3.6 J < 10 --- 7.6 9.1 7.3 < 5.0 < 10 --- 12.5 6.3 6.4 18.4 < 10 --- 623 392 614 

Deep 369 < 10 < 0.5 <0.5 < 0.5 < 2.5 0.75 < 10 < 0.5 < 0.5 < 0.5 < 2.5 < 0.5 7.5 J < 0.5 < 0.5 < 0.5 < 2.5 

EW-2 

Shallow 6,820 6,830 9,760 11,600 4,190 5,560 4,410 7,090 12,800 14,600 4,810 7,430 2,540 15,500 24,700 23,400 9,510 13,600 

Inter. 68.8 86.5 10.1 52.2 17.8 55.5 144 148 28.3 136 97.4 228 9,660 6,220 11,300 8050 4,490 7,770 

Deep 12.7 10.6 < 0.5 9.9 3.0 1.5 0.37 J < 1.0 < 0.5 31.4 < 0.5 < 0.5 0.35 J < 1.0 < 0.5 135 < 0.5 < 0.5 

EW-3 

Shallow 141 201 83 256 80.1 284 290 696 113 203 58.7 194 3,750 6,510 1,950 838 341 894 

Inter. < 5.0 < 10 5.9 15.9 3.6 8.2 < 5.0 9.4 J 18.1 62.7 10.4 38.3 75.1 137 129 203 24.8 105 

Deep 45.9 < 1.0 < 0.5 <0.5 < 0.5 < 0.5 < 0.5 < 1.0 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 < 1.0 < 0.5 < 0.5 < 0.5 < 0.5 

EW-4 

Shallow 2.6 0.59 2.2 3.2 0.75 1.6 2.5 2.0 6.0 9.5 3.3 7.7 345 176 740 983 978 5,300 

Inter. 1.8 < 1.0 1.6 2.2 < 0.5 < 0.5 < 0.5 0.62 J 2.2 3.7 < 0.5 0.37 J 15.3 8.8 40.9 21.3 8.0 6.9 

Deep 2,310 < 0.5 < 0.5 <0.5 < 0.5 < 0.5 2.1 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 1.6 < 0.5 < 0.5 < 0.5 < 0.5 < 0.5 

1 4 or 2 in ( ) denotes the injection that particular well is associated with based on its proximity to injected KM nO . Dashed line indicates no sam ple collected. J = estimated value. BL = Baseline Event. Int. 1 st nd 

= Interm ediate Event 4 ; R1 = Round 1 conducted 3/14/06; R2 = Round 2 conducted 3/16/06. Blocked cells indicate value above RPS. Purple indicates Km nO visually observed 
4.5.2.4 Metals 

Chemical oxidation has the potential to mobilize valence 

sensitive toxic metals, such as Arsenic (As), Chromium 

(Cr), Selenium (Se), Zinc (Zn), and Mercury (Hg), from 

soils into groundwater. As a result, sites that contain 

elevated levels of metals contaminants as well as organic 

contaminants should be monitored for such mobilization 

potential. In order to assess the mobilization potential of 

these compounds by KMnO , groundwater samples were 4

analyzed for metals for each event (Objective 3). 

Results for the toxic metals noted above are shown in 

Table 4-18. It should be noted that significant mercury 

concentrations were not detected during pre-demonstration 

studies therefore additional mercury monitoring was not 

continued for demonstration sampling. 

On an average basis, most of the metals analyzed did not 

change significantly in concentration throughout the five 

groundwater sampling events. Some metals (e.g., As, Be, 

Cr, Mg, and Zn) actually showed decreased concentrations 

in the shallow zone from baseline to final sampling events. 

There was however a fairly substantial increase in 

manganese (Mn) in the intermediate (peat) and deep 

groundwater zones for the second baseline sampling 

event. This average increase can be attributed to the influx 

of Mn from the initial injection of KMnO4 into the IW -3 

cluster. The resulting elevated levels of Mn in those IW -3 

cluster wells and nearby wells raised the overall average 

concentration of all wells samples for those zones. 

There was also an increase of Cr and Mg in the deep zone 

groundwater following both the first and second injections, 

and an increase in Se in the deep zone groundwater 

following the second injection. However, for the following 

sampling event, the average concentrations of these three 

metals reverted back to an average value that was very 

close to their respective original levels. 

4.5.2.5 Additional Observations 

There is one other noted observation which may be of 

some importance. Table 4-19 shows concentrations of 

acetone bromide, and bromoform. As previously 

discussed in subsection 4.4.3, bromide was used as a 

tracer ion in the KMnO solution used for the first injection. 4

It was noted during the intermediate groundwater sampling 

that bromoform formation was occurring in several of the 

wells. Because this was thought to be a possible concern 

and appeared to be a by-product of the use of the bromide 

tracer ion some investigation was performed as to why this 

was occurring. 

An interesting aspect of this investigation was that bromide 

showed up in several wells at significant levels (i.e., not just 

as residuum from the first preempted injection event). 

where there had been no indication of any visible KMnO . 4

Therefore it is possible that the KMnO4 had seeped into 

these upper wells (based on the presence of the bromide 

ion) but has been exhausted leaving no excess KMnO for 4

continued oxidation. 

A build-up of acetone was noted between the baseline 

sampling period and first injection suggesting oxidation of 

organic compounds was occurring. This was particularly 

noted in the deep wells where it appears, based upon 

reductions in chlorinated ethenes that the oxidation 

process was working the most effectively. What was also 

noted was the increased concentration of bromoform in 

upper, middle and lower wells between the baseline and 

first injection and the subsequent decrease between the 

first injection and second baseline sampling round. 

Bromoform is not a naturally occurring compound. In fact, 

the formation of bromoform is the result of a reaction 

between acetone and bromide (an artifact of the use of the 

bromide tracer ion in the KMnO4 solution). The reduction 

of bromoform over time suggests that this compound was 

not a concern at the end of the demonstration. The 

formation of bromoform suggests that oxidation was 

occurring in all three horizons, with the greatest oxidation 

reactions occurring in the deep wells. 

4.5.3 Quality Assurance/Quality Control 

Quality Assurance (QA)may be defined as a system of 

activities the purpose of which is to provide assurance that 

defined standards of quality are met with a stated level of 

confidence. A QA program is a means of integrating the 

quality planning, quality assessment, quality control (QC), 

and quality improvement efforts to meet user requirements. 

This includes all actions taken by project personnel, and 

the documentation of laboratory performance and, when 

appropriate, field performance. The objective of a quality 

assurance program is to reduce measurement errors to 

agreed upon limits and to produce results of acceptable 

and known quality. The laboratory data was generated 

under EPA-approved method guidelines to ensure that the 

measurement systems employed were in control. The 

following sections provide information on the use of data 

quality indicators, limitations on data use and a detailed 

summary of the laboratory QC analyses associated with 

select project measurements. 

65 
Table 4-18. Metals Summary Results for Groundwater (mg/l). 1 

Parameter Zone 

SAMPLE EVENT 

1 BL 6/05 2 BL 9/05 1 Int. 12/05 2 Int. 2/06 Final st nd st nd 

Arsenic 

Shallow 0.32 (5) 0.29 (5) 0.3 (4) 0.125 (10) 

Intermediate 0.07 (5) 0.11 (5) 0.18 (4) 0.133 (10) 

Deep 0.003 (5) 0.0 (5) 0.00 (4) 0.048 (10) 

---

---

---

Beryllium 

Shallow 0.003 (5) 0.001 (5) 0.002 (4) 0.00 (10) 

Intermediate 0.001 (5) 0.00 (5) 0.001 (4) 0.03 (10) 

Deep 0.001 (5) 0.00 (5) 0.00 (4) 0.00 (10) 

---

---

---

Cadmium 

Shallow 0.00 (5) 0.00 (5) 0.00 (4) 0.00 (10) 

Intermediate 0.00 (5) 0.004 (5) 0.00 (4) 0.00 (10) 

Deep 0.001 (5) 0.00 (5) 0.00 (4) 0.00 (10) 

---

---

---

Chromium 

Shallow 0.166 (5) 0.071 (5) 0.157 (4) 0.053 (10) 

Intermediate 0.05 (5) 0.18 (5) 0.08 (4) 0.164 (10) 

Deep 0.003 (5) 0.72 (5) 1.37 (4) 0.123 (10) 

---

---

---

Magnesium 

Shallow 27.6 (5) 13.4 (5) 31.8 (4) 16.7 (5) 17.3 (10) 

Intermediate 15.6 (5) 11.8 (5) 16.0 (4) 11.2 (5) 11.8 (10) 

Deep 8.6 (5) 12.3 (5) 29.9 (5) 9.6 (5) 14.5 (10) 

Manganese 

Shallow 4.5 (5) 9.5 (5) 16.8 (4) 16.5 (5) 15.5 (10) 

Intermediate 8.1 (5) 503 (5) 43.6 (4) 34.2 (5) 65.8 (10) 

Deep 0.8 (5) 825 (5) 159 (5) 102 (5) 39.4 (10) 

Selenium 

Shallow 0.004 (5) 0.003 (5) 0.001 (4) 0.003 (10) 

Intermediate 0.006 (5) 0.037 (5) 0.007 (4) 0.007 (10) 

Deep 0.001 (5) 0.00 (5) 68.4 (4) 0.002 (10) 

---

---

---

Zinc 

Shallow 0.133 (5) 0.041 (5) 1.13 (4) 0.037 (10) 

Intermediate 0.06 (5) 0.008 (5) 0.07 (4) 0.07 (10) 

Deep 0.013 (5) 0.032 (5) 0.00 (4) 0.04 (10)

 Values are averages of the # of wells sampled in ( ) and rounded to a maximum three significant digits. Averages include estimated (J) 1 

values and 0.0 is used for non-detected values except in cases where the LRL significantly exceeded quantified values. --- No metals sample 

collected. 

---

---

---

66 
Table 4-19. Acetone, Bromide, and Bromoform Summary Results for Groundwater (:g/l) 1 

Zone Parameter 

SAMPLE EVENT 

1 BL 6/05 2 BL 9/05 1 Int. 12/05 2 Int. 2/06 Final st nd st nd 

Shallow 

Acetone 15.5 (5) 13.6 (5) 12.4 (4) < 20 (4) 9.6 (5) 

Bromide 0.0 (5) 538 (5) 574 (4) 419 (5) 462 (10) 

Bromoform 0.00 (5) 5.9 (5) 3.5 (4) 11.6 (3) 5.8 (6) 

Intermediate 

Acetone 45 (5) 96.8 (5) 32 (4) 192 (3) 168 (8) 

Bromide 0.0 (5) 380 (5) 78.9 (4) 298 (5) 312 (10) 

Bromoform 0.00 (5) 941 (5) 1.1 (4) 1.0 (2) 0.0 (6) 

Deep 

Acetone 0.0 (5) 165 (5) 84.2 (5) 41.8 (5) 68 (10) 

Bromide 0.0 (5) 582 (5) 63 (5) 31.1 (5) 9.3 (10) 

Bromoform 0.0 (5) 1,450 (5) 213 (5) 20.6 (4) 34.3 (10)

 Values are averages of the # of wells sampled in ( ) and rounded to a maximum three significant digits. Averages include estimated (J) 1 

values and 0.0 is used for non-detected values except in cases where the LRL significantly exceeded quantified values. --- No sample 

collected. 

4.5.3.1 Data Quality Indicators 

To assess the quality of the data generated during this site 

investigation, two important data quality indicators are of 

primary concern: precision and accuracy. Precision can be 

defined as the degree of mutual agreement of independent 

measurements generated through repeated application of 

the process under specified conditions. Accuracy is the 

degree of agreement of a measured value with the true or 

expected value. 

Precision was assessed by laboratory spiked duplicates 

and sample duplicates. In the case of spiked duplicates, 

precision is evaluated by expressing, as a percentage, the 

difference between sample and sample duplicate results. 

The relative percent difference (RPD) is calculated as: 

(Maximum Value-Minimum Value) x 100 

RPD = 

(Maximum Value+Minimum Value) /2 

To determine and evaluate accuracy, known quantities of 

select target analytes were spiked into selected field 

Other data quality indicators influence whether a 

measurement is considered valid. A sample 

measurement must be reproducible and comparable. 

Comparability expresses the extent to which one data set 

can be compared to another. To generate comparable 

results, laboratory standard methods that are widely 

accepted were used. Data must also be representative of 

field conditions. Representativeness refers to the degree 

with which analytical results accurately and precisely reflect 

samples. Equipment used to provide data for this project 

was tested for accuracy through the analysis of calibration 

check standards and laboratory control samples (LCSs). 

To determine matrix spike recovery, the following equation 

was applied: 

C -C 

% Recovery = ss us x 100 

Csa

where 

Css = Analyte concentration in spiked sample 

Cus = Analyte concentration in unspiked sample 

Csa = Analyte concentration added to sample 

To determine the % recovery of LCS analyses or spiked 

blanks, the following equation was used: 

 Measured Concentration 

% Recovery = x 100

Theoretical Concentration 

actual conditions present at the locations chosen for 

sample collection. 

4.5.3.2 Conclusions and Data Quality Limitations 

A review of critical analytical sample data and associated 

QC analyses was performed for XDD samples. Duplicate 

spiked sample analyses and LCSs were used to assess 

precision and accuracy as discussed below. Details of the 

individual sample results with respect to surrogate spike 

67 
recoveries, internal standards, dilutions, etc. are presented 

in later subsections, along with information on calibrations, 

blanks, performance check standards, and other QC 

measurements. 

The critical parameter reviewed was VOCs, specifically 

cDCE, TCE, PCE, as well as VC, 1,1-DCA, 1,1,1-TCA and 

toluene in pre- and post-treatment soils and post-treatment 

groundwaters. The results of the measurements designed 

to assess the data quality for each method are summarized 

below, along with a discussion of any impact on data 

quality. 

Soil VOC Samples 

Accuracy: Matrix spike duplicates were analyzed with 

pre-and post-treatment soil sample MeOH extracts. Table 

4-20 presents average recoveries for both events. 

Table 4-20. Project Accuracy for Soil VOC Analyses. 

Compound Pre-treatment Avg. 

Recovery (%) 

Post-treatment 

Avg. Recovery (%) 

cDCE 97 111 

TCE 105 119 

PCE 74 112 

VC 127 88 

1,1-DCA 112 120 

1,1,1-TCA 107 121 

Toluene 106 117 

Average recoveries were within the QAPP specified criteria 

of 80-120% (VC 75-125%) with the exception of the 

baseline recovery of VC and PCE, and the post-treatment 

recovery of 1,1,1-TCA. The baseline recoveries were 

impacted by the spiking levels relative to the native sample 

concentrations; spike levels were adjusted during the 

post-treatment event to better accommodate the native 

contaminant concentrations. 

Precision: Duplicate spiked samples were used to assess 

method precision for VOCs in soils. W here spiked levels 

were appropriate, average RPD values for matrix 

spike/matrix spike duplicate (MS/MSD) results were 

generally less than 20%. 

Comparability: Comparability expresses the extent to 

which one data set can be compared to another. The 

methods used were clearly specified in the QAPP and 

reviewed before samples or data were collected. 

Representativeness: Representativeness refers to the 

degree with which a sample exhibits average properties of 

the site at the particular time being evaluated. The 

collection of representative samples was discussed 

previously in the QAPP. Representative samples were 

collected as per QAPP approved procedures. 

Detection limits: Detection limits for this project are defined 

as the reporting limit; the concentration determined by the 

lowest calibration standard as determined by the 

laboratory. Detection limits were adjusted as necessary 

based on matrix and the need for dilution. Due to the 

increased MeOH required for extracting peat, reporting 

limits were adjusted in order to meet project criteria. The 

typical reporting limit in soil for each of the critical 

compounds was 250 ug/kg, based on a 1g to 5ml methanol 

dilution as determined during the pre-demonstration 

analytical extraction study. Detection limit objectives were 

generally achieved for all samples; however, some 

samples did not meet these objectives due to high 

concentrations of one of the critical compounds thereby 

diluting the other compound concentrations or due to 

matrix interferences as occurred in several of the peat 

samples. 

Groundwater VOC Samples 

Accuracy: Matrix spike duplicates were analyzed to assess 

accuracy of the VOC analyses. Average recoveries for the 

groundwater MS/MSDs are summarized in Table 4-21 for 

VOC spikes from the post-treatment event. Two of the 30 

samples were selected for spiking and one had poor or no 

recovery of several critical compounds. The bottom 

sample of W ell IW -3 had no spike recovery of cDCE, TCE, 

and VC and very low recovery of PCE. The results were 

the same for the spike and spike duplicate. The sample 

was noted to be thick in consistency and purple in color 

and although the sample and MS/MSD were analyzed at a 

dilution, the recovery was still non-compliant. Results from 

this sample (GW -F-IW 3-B[2]) should be used cautiously; 

data for cDCE, TCE and VC should be rejected and data 

for PCE should be considered an estimated value 

potentially biased low. The other spiked sample was 

analyzed at two different spiking levels due to varying 

native sample concentrations. 

Precision: Duplicate spiked samples were used to assess 

method precision for groundwater VOCs. Maximum RPD 

values ranged from 2-34%; the outlier values (RPD values 

>20%) were associated with the spike having 

inappropriately low spike levels. 

Comparability: Comparability expresses the extent to 

which one data set can be compared to another. The 

methods used were clearly specified in the QAPP and 

reviewed before samples or data were collected. 

Representativeness: Representativeness refers to the 

68 
degree with which a sample exhibits average properties of 

the site at the particular time being evaluated. 

Representative samples were collected as per QAPP 

approved procedures.

Table 4-21. Project Accuracy for

Groundwater VOC Analysis. 

Compound Post-treatment Avg. Spike Recovery (%) 

cDCE 59 

TCE 50 

PCE 57 

VC 47 

1,1-DCA 110 

1,1,1-TCA 110 

Toluene 100 

4.5.4 Analytical QC Results 

4.5.4.1 Soil VOC Analyses 

A total of 87 pre- and 89 post-treatment soil samples were 

collected and analyzed for VOCs. The samples were 

collected from 30 locations, at three depths from each 

location, except in instances where sample material was 

not available. All solid samples were extracted into 

methanol and the extract analyzed in accordance with 

SW 846 Method 8260B. The discussions below provide 

details on the results of calibrations, surrogate recoveries, 

internal standard results, holding times and blank results 

for each event. 

Soils Baseline Event 

Accuracy and precision were assessed by the analysis of 

spiked duplicates. An LCS was also analyzed with each 

MS/MSD from a secondary source standard. All LCS 

(secondary source standard) samples were within the 

QAPP specified control limits of 80%-120% recovery. If the 

MS/MSD samples failed to meet these limits for any of the 

critical compounds then individual results were examined 

to determine cause for failure and appropriate recourse for 

corrective action. Because all LCS recoveries met 

appropriate QC limits it was determined that the cause of 

MS/MSD failures were matrix specific. 

As noted in Table 4-22 PCE and cDCE had low recovery 

values in one of the MS/MSD samples. This was due to 

the high native concentration of both these analytes 

compared to the spiking concentration used by the 

laboratory. W hen this situation occurs, natural variability of 

the analytical instrumentation will overwhelm the spike 

recovery detection and subsequently cause low and/or high 

calculated spike recoveries. Because the laboratory was 

unable to use higher spiking concentrations and because 

LCSs met accuracy specifications as noted in the QAPP, 

rerunning and or re-spiking of the MS/MSD samples was 

not performed. In addition, in these same samples all 

other critical compounds were within acceptable spiking 

limits. Therefore, no further action was taken in regards to 

MS/MSD recoveries for both analytes noted above. In 

addition, one MS/MSD recovery for VC was slightly above 

acceptable limits (control limits: 75-125%). But because 

this was not too far above acceptable recovery limits and 

because LCS recoveries were considered acceptable, no 

further action was taken. 

Table 4-22. Accuracy for Soil VOC - Spike Results ­

Baseline Event. 

Compound # of 

Spikes 

Spike Recovery, % # of 

Outside 

Avg. Range Limits 

cDCE 8 97 64-113 2 

TCE 8 105 96-115 0 

PCE 8 74 23-114 2 

VC 8 127 121-135 2 

1,1-DCA 8 112 106-123 1 

1,1,1-TCA 8 107 95-113 0 

Toluene 8 106 97-115 0 

Precision for volatile organics was assessed by the 

analysis of duplicate MS/MSDs performed on select project 

samples to determine the reproducibility of the 

measurements. The RPD between the spiked sample 

concentrations was compared to the objectives given in the 

QAPP. RPD values for all but two critical compounds were 

less than the QAPP specified objective of 20%. The two 

critical compounds not meeting specifications were PCE 

and cDCE. As noted above, these were the same 

compounds not meeting accuracy specifications. The 

likely reason for these out-of-bound specifications was 

because of the high native concentration for both these 

analytes compared to the spiking concentration used by 

the laboratory. When this situation occurs, natural 

variability of the analytical instrumentation will overwhelm 

the spike recovery detection and subsequently cause low 

and/or high calculated spike recoveries along with a 

greater RPD variability. For the same reasons noted 

69 
above in the accuracy discussion re-running of the spiked 

compounds was not considered necessary. Critical 

compound RPDs are reported in Table 4-23 which shows 

all other critical compounds met QAPP specifications. 

Table 4-23. Precision for Soil VOC - Spike Results ­

Baseline Event. 

Compound 

RPD 

Range, % 

# of Values # of Outside 

Limits 

cDCE 2-42 4 1 

TCE 4-8 4 0 

PCE 3-67 4 1 

VC 4-8 4 0 

1,1-DCA 1-8 4 0 

1,1,1-TCA 4-16 4 0 

Toluene 4-5 4 0 

Surrogate standards were added to all samples prior to 

analysis. Most sample surrogate recoveries met laboratory 

specified control limits. The few outliers noted were in 

samples that when re-analyzed at necessary dilutions, 

generally had compliant surrogates (BL-7-P[12], 

BL-30-SI[23], BL-27-P[13.5]). One sample (BL-28-SI[24.5]) 

had multiple non-compliant surrogate recoveries 

approximately 10-20% above control limits; this was not 

expected to have a significant impact on the sample data. 

Soils Final Post-Treatment Event 

Soil sample methanol extracts were analyzed by SW 846 

8260B. Several samples were analyzed past the 14 day 

hold time; these samples are listed in Table 4-24. Since 

most samples missed by only one day, and since the soils 

were preserved in methanol at the time of collection, the 

missed holding times are not considered to have an impact 

on data quality. 

Table 4-24. Samples Analyzed Outside Holding Times 

Sam ple ID /

Days Past 14 

Sam ple ID /

Days Past 14 

Sam ple ID /

Days Past 14 

F29-SA-(8) / 1 F25-P-(13) / 1 F02-SI-(25) / 1 

F04-SA-(8) / 4 F23-SI-(24) / 1 TB033006 / 1 

F04-P-(15) / 1 F23-SA-(8) / 1 TB2033006 / 1 

F04-SI-(27) / 1 F28-SI-(24) / 1 MTB033006 / 1 

F25-SI-(24.5) / 1 F23-P-(11) / 1 MTB2033006 / 1 

F25-SA-(8) / 4 F02-P-(13) / 1 MTB032906 / 1 

Calibration requirements for SW 8260B were generally met 

for all analyses with few minor exceptions not expected to 

impact data quality; for example the ICAL from April 12, 

2006 had an RSD for 1,1-DCA of 15.7% and for 1,1,1-TCA 

the RSD was 16%. VC reporting detection limits were 

raised when the compound was not detected in the 0.5 ppb 

standard of the ICAL. Two samples were analyzed beyond 

the 12-hour BFB clock. The initial analysis of sample 

F05-SI-[24.5] missed by four minutes and the dilution was 

analyzed 41 minutes after expiration of the BFB period. A 

diluted analysis of F11-P-[11.5] was started 3 minutes after 

the 12-hour clock expired. The tunes and continuing 

calibration subsequent to these analyses met criteria so 

the impact on data quality is considered minimal. 

Method, trip and MeOH trip blanks were analyzed with the 

samples. Several method blanks had low-level 

contamination of toluene and PCE at estimated 

concentrations below detection limits. A MeOH trip blank 

(MTB032906) also had an estimated concentration of 

toluene (10.6 J ug/kg) below the detection limit. 

Each sample was spiked with surrogate standards; all 

recoveries were within control limits except for F14-SA-[8], 

which had a slightly elevated surrogate recovery 

(toluene-d8 = 148%, upper control limit = 146%). But this 

did not affect data quality. All internal standards met 

criteria. 

LCSs and MS/MSDs were analyzed as required. Several 

LCS results had recoveries slightly above the 80-120% 

QAPP guideline (75-125% for VC). In particular, samples 

from each of the three intervals from F09, F23, F05, F18, 

F20 and F11 along with F02-SA were associated with LCS 

analyses having recoveries up to 20% above control limits 

for one or more VOCs. Nine spiked duplicate pairs were 

analyzed with post-treatment samples (Table 4-25). 

Table 4-25. Accuracy for Soil VOC - Spike Results ­

Post Treatment Event. 

Compound No. of 

Spikes* 

Spike Recovery, % No. Outside 

Avg. Range Limits 

cDCE 18 111 95-130 5 

TCE 18 119 105-148 4 

PCE 14 112 95-136 4 

VC 18 88 62-110 3 

1,1-DCA 18 120 108-152 4 

1,1,1-TCA 18 121 105-153 5 

Toluene 14 117 95-142 4 

* This colum n presents the # of spikes that were spiked at an appropriate 

level given the native sample concentration of the compound, relative to the 

# of spiked sam ples prepared; e.g., there were 18 spikes prepared but only 

14 had levels of PCE suitable given the PCE concentrations in the sample. 

70 
The average recovery for 1,1,1-TCA was above the upper 

control limit specified in the QAPP; results for this 

compound may be considered slightly biased high. Most 

of the spiked recovery outliers were associated with two 

spiked duplicate pairs (F11-P and F25-SI), which had 

elevated recoveries for all target compounds except VC. 

The MS/MSD pairs were also used to assess overall 

precision for the project. RPD results are summarized in 

Table 4-26. Only one spiked pair had an RPD value that 

exceeded the QAPP criteria of 20%. 

Table 4-26. Precision for Soil VOC - Spike Results ­

Post-treatment Event. 

Compound 

RPD 

Range, % 

No. of 

Values 

No. Outside 

Limits 

cDCE 1-7 9 0 

TCE 0-6 9 0 

PCE 0-22 7 1 

VC 0-13 9 0 

1,1-DCA 0-8 9 0 

1,1,1-TCA 0-8 9 0 

Toluene 1-10 7 0 

4.5.4.2 Groundwater VOCs - Post-treatment Results 

Fifteen wells were sampled at two different times for the 

final groundwater event. The 30 samples were analyzed in 

accordance with SW 846 Method 8260B. All samples were 

analyzed within holding times. Calibration requirements, 

including GC/MS tuning with BFB and initial and continuing 

calibrations, were met with one exception. One initial 

calibration for toluene exceeded the 15% RSD criteria 

slightly at 16%; this had no impact on data quality. 

Surrogate recovery and internal standards criteria were met 

for all samples. All method, trip and field blanks were free 

from contamination. 

Two samples were analyzed as spiked duplicate pairs. 

Sample GW -F-IW 1-M[1] was spiked at 500 ppb and then 

re-analyzed at a spiking level of 10,000 ppb due to elevated 

native concentrations of cDCE, TCE, PCE, VC and 

toluene. At the appropriate spiking levels, all recovery 

values were within control limits. Sample GW -F-IW 3-B[2] 

was noted to be thick and colored and was analyzed at a 

dilution. The MS/MSD was analyzed at the same dilution 

but had non-complaint recovery values (0%) for cDCE, 

TCE and VC and very low recovery (2%) for PCE. 

Table 4-27. Accuracy for Groundwater - Post 

Treatment VOCs. 

Compound 

No. of 

Spikes1 

Spike Recovery, % No. 

Outside 

Avg. Range Limits 

cDCE 4 59 0-119 1 

TCE 4 50 0-100 1 

PCE 4 57 2-113 1 

VC 4 47 0-95 1 

1,1-DCA 6 110 103-121 1 

1,1,1-TCA 6 110 104-119 0 

Toluene 4 100 93-109 0 

1 The number of spikes includes those with a spike level appropriate to the 

native contam inant concentration. 

Precision was assessed through these same spiked 

duplicates, as shown in Table 4-28. Of the 18 RPD values 

assessed, all but 2 were within lab limits. 

Table 4-28. Precision for Groundwater - Posttreatment VOCs. 

Compound Maximum 

RPD 

No. of 

Values 

No. Outside 

Limits 

cDCE 34 2 1 

TCE 6 2 0 

PCE 16 3 0 

VC 22 2 1 

1,1-DCA 2 3 0 

1,1,1-TCA 3 3 0 

Toluene 17 3 0 

71 
4.5.5	 Audits 

4.5.5.1 Field Audit 

A Technical Systems Audit (TSA) of the field activities at 

the Former MEC Building Site; Hudson, NH was conducted 

May 13, 2005. There were no Findings requiring corrective 

action. However, there were two observations noted. The 

first observation was that the required number of baseline 

peat zone samples (30) was not achieved during baseline 

sampling. During baseline sampling using a sonic rig, peat 

sample material was not collected at boring locations #s 9, 

25, and 30, and was thought absent at these three 

locations. In addition the peat material at boring # 2 was 

fragmented and a portion of that samples included nonpeat material. As a result, there was at most 27 peat 

samples instead of the desired 30. 

In response to this observation, results were tabulated and 

statistical parameters including mean, and 95% confidence 

intervals were calculated. Based upon actual results it was 

determined that the 27 samples collected during baseline 

would satisfy the project objective. Even prior to this 

calculation it was determined that a 90% completeness 

objective would likely meet project objectives. The goal for 

post-demonstration sampling was to collect at least as 

many samples as collected during baseline. This indeed 

was the case, however peat was found in borings drilled 

adjacent to baseline borings #s 9 and 25 using a geoprobe. 

The peat was again absent at boring # 30 (the closest 

boring to the excavated tank area). It is postulated that the 

peat had been excavated in the vicinity of boring 30. As for 

the partial peat sample at boring #2, the auditor advised the 

field manager to try to note the estimated composition of 

sample material if such an occurrence happened again. 

(This only happened once during baseline sampling). 

The second observation noted some minor inconsistencies 

in record keeping, including a missing calibration check of 

the field balance used to measure this mass of soil sample 

used for the field extraction procedure and an unsigned 

logbook for previous days records. In response to this 

concern the SAIC Project Manager met with some of the 

same site personnel while working on another project and 

explained and discussed what should be included in field 

notebooks. This issue is often a continuing concern that 

needs re-training on a regular basis. 

4.5.5.2 Lab Audit 

A Technical Systems Review (TSR) was performed at 

Analytical Laboratory Services, Inc. (ALSI) in Middletown, 

PA on May 25, 2005. In general ALSI met all QAPP and 

method specifications and was expected to generate data 

of known quality that meet project and data quality 

objectives. The few issues to be addressed were either 

resolved on-site or corrective action was expected to be 

initiated promptly. These corrective actions included: 

•	 Initiation of the tracking of surrogate standards by, 

at a minimum, lot # and date opened, either in the 

standards logbook or on the log sheets where 

medium level soil sample vials are prepared. ALSI 

was requested to provide copy of documentation 

to indicate that this corrective action had been 

complete. 

•	 Initiation of the tracking of VOC gas standard by, 

at a minimum, lot # and date opened, either in the 

standards logbook or in the analytical logbook. 

ALSI was requested to provide copy of 

documentation to indicate that this corrective 

action had been complete. 

72 
Section 5.0


Other Technology Requirements


5.1 	 E n vir o n m e n t a l Regulation 

Requirements 

State and local regulatory agencies may require permits 

prior to implementing an in situ chemical oxidation 

technology. Most federal permits will be issued by the 

authorized state agency. The specific permits required 

may depend on the type and concentration of the 

contamination, the regulations covering the specific 

location, and the site's proximity to residential 

neighborhoods. For example, the New Hampshire 

Department of Environmental Services (NHDES) requires 

a site owner or legally responsible person to acquire a 

Groundwater Management Permit (GMP) from the State to 

remedy contamination associated with the past discharge 

of regulated contaminants, and to manage the use of 

contaminated groundwater. The application for the GMP 

must be prepared and stamped by a PE or a PG licensed 

in the State. There is an application fee for this. 

Since oxidant is injected underground, an injection permit 

may also be required. For the former MEC Building site, 

XDD was required to apply for and acquire an injection 

permit from the NHDES. However, there was no actual 

permit fee. Note that other states may require a fee. In 

some cases permitting fees may be waived for 

government-conducted research type projects. 

An air permit issued by the state Air Quality Control Region 

may be required if it is anticipated that the air emissions 

from potential surface venting are in excess of regulatory 

criteria, or are of toxic concern. Wastewater discharge 

permits may be required if any wastewater generated from 

well purging and equipment decontamination activities 

were to be discharged to a POTW . If remediation is 

conducted at a Superfund site, federal agencies, primarily 

the U.S. EPA, will provide regulatory oversight. If off-site 

disposal of contaminated waste (contaminated drill 

cuttings) is required, the waste must be taken to the 

disposal facility by a licensed transporter. 

Section 2 of this report discusses the environmental 

regulations that may apply to XDD’s ISCO process. 

5.2	 Personnel Issues 

The number of personnel required to implement the XDD 

ISCO process is dependent on the size of the treatment 

system and the time desired for the installation. Initially, 

drilling and well installation labor activities are performed by 

a drilling contractor. These activities typically involve a 

minimum of two contractor personnel assigned to a drill rig 

or geoprobe (head driller and helper). There may be an 

additional contractor representative who conducts well 

completion and development following well installation 

(which can be conducted at the same time that additional 

wells are being installed). 

During well installation activities at a remediation site, the 

site remediation contractor would be responsible for 

logging boreholes, monitoring for VOCs and explosive 

conditions during drilling of boreholes, and ensuring that 

well construction and installation are conducted in 

accordance with design specifications. These activities 

would require the services of at least one individual 

(preferably a geologist). XDD may or may not be present 

for such activities. 

Based on the demonstration study requirements, XDD 

appears to need a minimum of two individuals to conduct 

the oxidant injection. The oxidant batching process is a 

labor intensive operation involving the shipment and 

handling of numerous 20 L jugs of granular oxidant. 

Estimated labor requirements for a full-scale treatment 

system are discussed in detail in Section 3 of this report. 

73 
Personnel are also required for sample collection and 

groundwater monitoring. During the demonstration 

sampling events, one to two SITE team members was 

required to conduct field measurements during low-flow 

well sampling via a multi-parameter instrument, collect 

groundwater samples with a peristaltic pump, and prepare 

the samples for shipment to an off-site laboratory. 

Personnel present during sample collection activities at a 

hazardous waste site must have current OSHA health and 

safety certification. Specific to the XDD ISCO process and 

chemical oxidation processes in general, the primary health 

and safety issue is personal protection from strong 

oxidizers. From a health and safety and materials handling 

perspective, NaMnO4 is handled in a liquid form and is 

preferred to solid (i.e., granular) KMnO 4. The application of 

this liquid oxidant is simpler than injecting KMnO 4, which 

has to be pre-mixed with potable water at the desired 

concentration prior to injection. 

Per the MSDS for KMnO 4, at a minimum, eye protection 

and protective gloves are strongly recommended to be 

worn during handling of oxidants. During the 

demonstration, the batching process involved emptying 

numerous 20 Liter jugs of granular KMnO4 into large batch 

tanks. Due to the potential inhalation of particulate, XDD 

also utilized full-face air-purifying respirators and 

chemically-resistant tyvek in addition to the standard Level 

D protection. Therefore the batch operation was 

conducted in Level C. (Generally speaking, for most sites, 

PPE for workers will include steel-toed shoes or boots, 

safety glasses, hard hats during drilling operations, and 

chemical resistant gloves). 

Noise levels would be a short-term concern during drilling 

operations and may be of concern during injection phases, 

particularly near the piston pump that is contained within 

the XDD POD. Noise levels should be monitored for such 

equipment to ensure that workers are not exposed to noise 

levels above the time weighted average of 85 decibels over 

an 8-hour day. If this level is exceeded and cannot be 

reduced, workers would be required to wear hearing 

protection and a hearing conservation program would need 

to be implemented. 

5.3 Community Acceptance 

The short-term risk to the community from implementing 

this technology is minimal since the oxidant is injected into 

the ground. In fact storage of the oxidant is of more 

concern since granular oxidant can be combustible if not 

stored properly. 

The level of environmental disturbance of a site would be 

dependent on the number of wells required and the 

locations of those wells. For example, if injection or 

monitoring wells were required to be installed in an area 

having vegetation, some clearing of the vegetation may be 

necessary to access the best injection or monitoring points. 

This may affect habitat areas to some extent. 

Other than the intermittent noise generated during drilling 

and, the relatively minor level of noise generated during 

oxidant injection is offset by the benefits of site 

remediation. 

74 
Section 6.0


Technology Status


6.1 Previous Experience 

Chemical oxidation’s use in the wastewater treatment 

industry dates back many years. In the past 10 years or 

so, the technology has been applied to remediation at 

hazardous waste sites. Specific to the use of KMnO4 for 

treatment of DNAPL and dissolved phase chlorinated 

organic contaminants at hazardous waste sites, case 

studies have been documented at least as far back as 

1996 (EPA, 1998). 

Xpert Design and Diagnostics, LLC (XDD) was founded in 

1997 as a provider of innovative soil and groundwater 

remediation technologies. Per its web site, XDD has 

experience with a wide range of ISCO applications at 

several sites. Their Portable Oxidant Delivery (POD) unit, 

which was used during the demonstration, has been 

operating since 2003. XDD staff is reported to have 

worked on several hundred sites throughout the United 

States, Canada, Europe and Asia for private industrial and 

federal sector clients. 

6.2 Ability to Scale Up 

Based on the nature of the technology, theoretically there 

is no limit to the areal extent of application of an ISCO 

process as long as the oxidant injection design (i.e., 

injection well spacing, screened interval, and oxidant 

dosage, etc.) is adequate. The areal extent of XDD’s ISCO 

treatment system implemented at the former MEC Building 

site was roughly 1,200 ft2

 (113 m 2). This is considered a 

pilot-scale application of the technology. 

The pilot-scale demonstration is also not considered to be 

a typical remediation, not only due to its small size but also 

because of the atypical soil profile (i.e., the thin peat layer). 

XDD has reported on their web site applications of their 

ISCO process that are much larger than that detailed in this 

report. One example includes a 16-injection point system, 

covering an area of approximately 1,400 ft 2

, (130 m 2) and

utilizing automated batching and dosing equipment capable 

of injecting up to 240 liters of oxidant per minute. A second 

example included treatment of an approximate 56,000 ft2 

(5,200 m 2) section of an approximate 3,300 ft (100 m) long

VOC plume. 

XDD reports considerable research for the development of 

an advanced oxidation process, referred to as X-Ox. This 

process is intended to use persulfate alone, or used in 

conjunction with a proprietary transition metal to treat 

petroleum hydrocarbons, MTBE, chlorinated solvents, coal 

tar residues, PCBs, and energetic compounds. 

75 
Section 7.0


References


Aries Engineering, Inc. 2006. 2006 Draft Preliminary 

Remediation Budget Estimate Update, Former MEC 

Building Site, Hudson, New Hampshire. June 2006. 

Aries Engineering, Inc. 2004. 2003 Annual Groundwater 

Monitoring Summary Report, Former MEC Building Site, 

Hudson, New Hampshire. January 2004. 

Aries Engineering, Inc. 2001. Remedial Action Plan ReEvaluation, Former MEC Building Site, Hudson, New 

Hampshire. July 2001. 

Aries Engineering, Inc. 2001. Revised Remedial Action 

Plan, Former MEC Building Site, Hudson, New Hampshire. 

January 2001. 

Chem One. 2004. Product Specification for KMnO 4 . 

Revised February 23, 2004. 

Christy, Thomas M. A Permeable Membrane Sensor for 

the Detection of Volatile Compounds in Soil. No Date. 

Hansen, Morris H., Hurwitz, W illiam N., Madow, W illiam G. 

1993. Sample Survey Methods and Theory: Volume II, 

Theory. John W iley & Sons, Inc., New York, 1993. 

Natrella, Mary Gibbons, Experimental Statistics, National 

Bureau of Standards Handbook 91. U.S. Government 

Printing Office, Washington, D.C. 1963. 

New Hampshire Department of Environmental Services. 

2001. Risk Characterization and Management Policy, rev. 

April 3, 2001,www.des.state.nh.us/orcb/doclist/pdf/rcmp.pdf 

SAIC. 2005. Quality Assurance Project Plan - XDD In-Situ 

Chemical Oxidation Process at the Former MEC Building 

Site, Hudson, NH; May 2005 Revision 1. 

U.S. Environmental Protection Agency. 2006. EPA 

Groundwater and Drinking Water - Current Drinking Water 

S t anda r d W eb Page 

www.epa.gov/safewater/mcl.html#mcls. June 2006. 

U.S. Environmental Protection Agency. 2002. Guidance on 

Data Quality Indicators. EPA G5i. Washington, D.C. July 

2002. 

U.S. Environmental Protection Agency. 1998. Field 

Applications of In Situ Remediation Technologies ­

Chemical Oxidation. EPA/542-R-980-008. September 

1998. 

U.S. Environmental Protection Agency. 1996. Test 

Methods for Evaluating Solid Waste, Physical/Chemical 

Methods, SW -846 CD ROM, which contains updates for 

1986, 1992, 1994, and 1996. W ashington, D.C. 

U.S. Environmental Protection Agency. 1991. Engineering 

Bulletin - Chemical Oxidation. EPA/540/2-91/025 October 

1991. 

Xpert Design and Diagnostics LLC. 2006 Equipment Fee 

Schedule. 

Xpert Design and Diagnostics LLC. 2005. Chemical 

Oxidation Laboratory Testing Report - Former MEC 

Building Site, Hudson, NH. January 2005. 

Xpert Design and Diagnostics LLC W eb site.

www.xdd-llc.com 

76