United States

Environmental Protection

Agency

Electrochemical Design Associates

(formerly Geokinetics International, Inc.)

Lead Recovery Technology Evaluation

Building 394 Battery Shop 

Pearl Harbor Naval Shipyard and 

Intermediate Maintenance Facility 

Honolulu, Hawaii

Innovative Technology 

Evaluation Report
EPA/540/R-04/506 

September 2003 

FINAL 

INNOVATIVE TECHNOLOGY EVALUATION REPORT 

ELECTROCHEMICAL DESIGN ASSOCIATES 

(FORMERLY GEOKINETICS INTERNATIONAL, INC.) 

LEAD RECOVERY TECHNOLOGY EVALUATION 

at the 

BUILDING 394 BATTERY SHOP
 

PEARL HARBOR NAVAL SHIPYARD AND INTERMEDIATE
 

MAINTENANCE FACILITY
 

HONOLULU, HAWAII
 

Prepared for: 

U.S. Environmental Protection Agency
 

Office of Research and Development
 

National Risk Management Research Laboratory
 

Cincinnati, Ohio
 

Prepared by:
 

Tetra Tech EM Inc.
 

1230 Columbia Street, Suite 1000
 

San Diego, California 92101
 

EPA Contract No. 68-C-00-181
 

September 2003
 
CONTENTS
 

Section Page
 

NOTICE ....................... ....................... ....................... ....... i
 

FOREWORD ....................... ....................... ....................... .. ii
 

ABSTRACT ....................... ....................... ....................... . . iii
 

ACKNOWLEDGMENTS ....................... ....................... ............... iv
 

ACRONYMS AND ABBREVIATIONS ....................... ....................... ... v
 

EXECUTIVE SUMMARY ....................... ....................... ........... ES-1
 

1.0 INTRODUCTION ....................... ....................... ............. 1-1
 

1.1 PROJECT BACKGROUND ....................... ...................... 1-1
 

1.2 TECHNOLOGY DESCRIPTION ....................... .................. 1-2
 

1.3 KEY CONTACTS ....................... ....................... ....... 1-5
 

2.0 TECHNOLOGY APPLICATIONS ANALYSIS ....................... ............ 2-1
 

2.1 FEASIBILITY STUDY EVALUATION CRITERIA ....................... . . 2-1
 

2.1.1 Overall Protection of Human Health and the Environment ............... 2-1
 

2.1.2 Compliance with Applicable or Relevant and Appropriate Requirements ... 2-1
 

2.1.3 Long-Term Effectiveness and Permanence ....................... .... 2-8
 

2.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment .......... 2-8
 

2.1.5 Short-Term Effectiveness ....................... .................. 2-8
 

2.1.6 Ability to Implement ....................... ..................... 2-9
 

2.1.7 Cost ....................... ....................... ............ 2-9
 

2.1.8 State Acceptance ....................... ....................... . . 2-9
 

2.1.9 Community Acceptance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... 2-9
 

2.2 TECHNOLOGY APPLICABILITY ....................... ............... 2-10
 

2.3 KEY FEATURES OF THE TREATMENT TECHNOLOGY .................. 2-10
 

2.4 MATERIALS HANDLING REQUIREMENTS ....................... ..... 2-10
 

2.5 SITE SUPPORT REQUIREMENTS ....................... .............. 2-11
 

2.6 LIMITATIONS OF THE TECHNOLOGY ....................... ......... 2-12
 
3.0 ECONOMIC ANALYSIS ....................... ....................... ....... 3-1
 

3.1 INTRODUCTION ....................... ....................... ....... 3-1
 

3.2 CONCLUSIONS ....................... ....................... ........ 3-1
 

3.3 ISSUES AND ASSUMPTIONS ....................... ................... 3-2
 

3.4 BASIS FOR ECONOMIC ANALYSIS ....................... ............ 3-10
 

3.4.1 Site and Facility Preparation Cost ....................... .......... 3-10
 

3.4.2 Permitting and Regulatory Costs ....................... ........... 3-11
 

3.4.3 Equipment Costs ....................... ....................... . 3-11
 

3.4.4 Start-up and Fixed Costs ....................... ................. 3-12
 

3.4.5 Labor Costs ....................... ....................... ..... 3-12
 

3.4.6 Supplies and Consumable Costs ....................... ........... 3-13
 

3.4.7 Utilities Costs ....................... ....................... ... 3-13
 

3.4.8 Effluent Treatment and Disposal Costs ....................... ...... 3-13
 

3.4.9 Residuals and Waste Shipping, Handling, and Transport Costs .......... 3-13
 

3.4.10 Analytical Costs ....................... ....................... . 3-14
 

3.4.11 Facility Modification, Repair, and Replacement Costs ................. 3-14
 

3.4.12 Site Restoration Costs ....................... .................... 3-14
 

4.0 TREATMENT EFFECTIVENESS ....................... ....................... 4-1
 

4.1 BACKGROUND ....................... ....................... ........ 4-1
 

4.1.1 Site Description ....................... ....................... . . 4-1
 

4.1.2 Evaluation Objectives and Approach ....................... ......... 4-2
 

4.2 EVALUATION PROCEDURES ....................... .................. 4-2
 

4.2.1 Evaluation Preparation ....................... .................... 4-2
 

4.2.2 Evaluation Design ....................... ....................... 4-3
 

4.2.3 Sampling Methods ....................... ....................... 4-5
 

4.2.4 Quality Assurance and Quality Control Program ...................... 4-7
 

4.3 EVALUATION RESULTS AND CONCLUSIONS ....................... ... 4-8
 

4.3.1 Primary Objectives ....................... ...................... 4-12
 

4.3.2 Secondary Objectives ....................... .................... 4-14
 

4.3.3 Data Quality ....................... ....................... .... 4-18
 

4.3.4 Conclusions ....................... ....................... .... 4-19
 

5.0 TECHNOLOGY STATUS ....................... ....................... ....... 5-1
 

6.0 REFERENCES ....................... ....................... ................ 6-1
 
FIGURES
 

Figure Page
 

1-1 SYSTEM SCHEMATIC ....................... ....................... ... 1-4
 

3-1 ESTIMATED TREATMENT COSTS FOR 5 TONS OF SOIL USING EDA
 

LEAD REMOVAL TECHNOLOGY ....................... ............... 3-8
 

3-2 ESTIMATED TREATMENT COSTS FOR 500 TONS OF SOIL USING EDA
 

LEAD REMOVAL TECHNOLOGY ....................... ............... 3-9
 

TABLES 

Table Page 

ES-1 EVALUATION CRITERIA FOR THE EDA LEAD RECOVERY 

TECHNOLOGY ....................... ....................... ....... ES-4
 

2-1 SUMMARY OF APPLICABLE REGULATIONS ....................... .... 2-2
 

2-2 POTENTIAL FEDERAL ARARs FOR THE EDA LEAD RECOVERY 
 

TECHNOLOGY ....................... ....................... ......... 2-5
 

3-1 ESTIMATED COSTS FOR TREATMENT USING THE EDA LEAD
 

RECOVERY TECHNOLOGY ....................... ..................... 3-3
 

3-2 ESTIMATED COST PERCENTAGES FOR TREATMENT USING THE EDA 
 

LEAD RECOVERY TECHNOLOGY ....................... ............... 3-7
 

4-1 TREATMENT BIN 1 ....................... ....................... ..... 4-9
 

4-2 TREATMENT BIN 2 ....................... ....................... .... 4-10
 

4-3 TREATMENT BIN 4 ....................... ....................... .... 4-11
 

4-4 RESULTS FOR LEAD USING EPA METHOD 6010B ....................... 4-12
 

4-5 AVERAGE REMOVAL EFFICIENCIES ....................... ........... 4-13
 

4-6 RESULTS FOR LEAD USING TCLP ....................... .............. 4-14
 

4-7 MASS OF SOLID LEAD RECOVERED BY THE ESMS ..................... 4-14
 

4-8 RECOVERY EFFICIENCY OF THE ESMS ....................... ........ 4-15
 
NOTICE
 

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

(EPA) under Contract No. 68-C-00-181 to Tetra Tech EM Inc. 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 of recommendation for use. 

i 
FOREWORD
 

The U.S. Environmental Protection Agency (EPA) 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 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 is the Agency’s center for investigation of 

technological and management approaches for reducing risks from threats to human health and the 

environment. The focus of the Laboratory’s research program is on methods for the prevention and 

control of pollution to air, land, water and subsurface resources; protection of water quality in public 

water systems; remediation of contaminated sites and groundwater; and prevention and control of indoor 

air pollution. The goal of this research effort is to catalyze development and implementation of 

innovative, cost-effective environmental technologies; develop scientific and engineering information 

needed by EPA to support regulatory and policy decisions; and provide technical support and information 

transfer to ensure effective implementation of environmental regulations and strategies. 

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. 

E. Timothy Oppelt, Director 

National Risk Management Research Laboratory 

ii 
ABSTRACT
 

This report presents performance and economic data from U.S. Environmental Protection Agency (EPA) 

Superfund Innovative Technology Evaluation (SITE) Program evaluation of Electrochemical Design 

Associates (EDA), formerly known as Geokinetics International Inc., Lead Recovery Technology 

Evaluation. The demonstration evaluated the technology's ability to remove lead contamination from 

soil. 

The EDA technology was operated by injecting electrolyte solution into the treatment tank, allowing the 

electrolyte solution to migrate vertically and horizontally through the soil. The ethylene diamine 

tetraacetic acid in the electrolyte solution acted as a chelating agent, forming a soluble Pb-EDTA2­

complex. The Pb-EDTA2- complex within the electrolyte was removed from the bottom of the treatment 

tank through extraction pipes. From here, the electrolyte solution flowed into the header tank and fed 

directly into the proprietary electrolyte solution management system (ESMS). The ESMS consisted of 

proprietary electrochemical lead recovery cells. Once it had passed through the ESMS, the electrolyte 

solution was delivered to a holding tank where it was stored and the pH was adjusted. From here, the 

electrolyte solution was re-delivered to the treatment tank and the process was repeated. The entire 

system is a batch closed-loop process, which is initiated and controlled by a single automated process 

control system (GII 1998b). 

This demonstration tested the ability of the EDA technology to remove lead from in two phases. Phase I 

was conducted at Building 394 Battery Shop from August 8 to September 28, 2001 and Phase II was 

conducted from April 1 to July 22, 2002. 

Primary demonstration objectives evaluated whether the EDA technology reduced lead concentrations in 

soil to below the clean-up goal of 2,000 milligrams per kilogram (mg/kg). The EDA technology reduced 

lead concentrations in soil; however, not below the 2,000 mg/kg clean-up goal for all batches. 

Potential sites for applying this technology include Superfund and other hazardous waste sites where 

soils are contaminated with lead. Economic data indicate that remediation costs of using this technology 

are affected by site-specific factors, such as the availability to electrical and water lines. The operating 

cost for implementing the EDA technology is estimated to be $11,980 per ton for a 5-ton pilot study, and 

$546 per ton for a 500-ton full-scale study. Capital costs are not available at this time. 

iii 
ACKNOWLEDGMENTS
 

This report was prepared for the U.S. Environmental Protection Agency (EPA) Superfund Innovative 

Technology Evaluation (SITE) program by Tetra Tech EM Inc. (Tetra Tech) under the direction and 

coordination of Mr. Thomas Holdsworth at the National Risk Management Research Laboratory 

(NRMRL) in Cincinnati, Ohio. 

The lead recovery technology evaluation was a cooperative effort that involved the following personnel 

from EPA NRMRL SITE Program in cooperation with the Pacific Division Naval Facilities Engineering 

Command (PACNAVFACENGCOM), and Electrochemical Design Associates (EDA), formerly known 

as Geokinetics International Inc.: 

Annette Gatchett EPA NRMRL Assistant Director of Technology 

Thomas Holdsworth EPA NRMRL Work Assignment Manager 

Ann Vega EPA NRMRL Quality Assurance Coordinator 

Clint Zenigami PACNAVFACENGCOM Remedial Project Manager 

Randal Kido Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility 

Richard Sturm AMEC Project Manager 

Lewis Mitani EPA Region IX Project Manager 

Mike Miyasaka State of Hawaii Department of Health Project Manager 

Stephen Clarke Electrochemical Design Associates Project Manager 

Carl Rhodes Tetra Tech EM Inc. SITE Program Manager 

Greg Swanson Tetra Tech EM Inc. SITE QA Manager 

Linda Hunter Tetra Tech EM Inc. Project Quality Control Coordinator 

Roger Argus Tetra Tech EM Inc. Project Manager 

Barry Hicks Tetra Tech EM Inc. Project Field Manager 

Donna Rydberg Severn Trent Laboratory Project Manager 

iv 
ARAR Applicable or relevant and appropriate requirement 

CAA Clean Air Act 

CAMU 

CERCLA 

Corrective action management unit 

Comprehensive Environmental Response, Compensation, and 

Liability Act 

EDA 

EDTA 

EE/CA 

EPA 

ESMS 

ETU 

Electrochemical Design Associates 

Ethylene diamine tetraacetic acid 

Engineering evaluation/cost analysis 

U.S. Environmental Protection Agency 


Electrolyte solution management system 


Electrochemical treatment unit 


ITER Innovative technology evaluation report 

kg Kilogram 

mg/kg 

mg/L 

MS/MSD 

Milligram per kilogram 


Milligram per liter 


Matrix spike/matrix spike duplicate 


NRMRL National Risk Management Research Laboratory 

OSWER 

ORD 

Office of Solid Waste and Emergency Response 


Office of Research and Development 


PACNAVFACENGCOM 

PPE 

Pacific Division Naval Facilities Engineering Command 


Personal protective equipment 


QA 

QA/QC 

QC 

Quality assurance 


Quality assurance/quality control 


Quality control 


RCRA 

RI 

RSE 

Resource Conservation and Recovery Act 


Remedial investigation 


Removal site evaluation 


SARA 

SI 

SITE 

Superfund Amendments and Preauthorization Act of 1986 


Site inspection 


Superfund Innovative Technology Evaluation 


ACRONYMS AND ABBREVIATIONS 

v 
TCLP Toxic Characteristics Leaching Procedures 

Tetra Tech Tetra Tech EM Inc. 

vi
 
EXECUTIVE SUMMARY 
 

The Electrochemical Design Associates (EDA), formerly known as Geokinetics International Inc., lead 

recovery technology was evaluated as a remediation technology to remove lead from the soil. The 

evaluation was accomplished through a partnership between the U.S. Environmental Protection Agency 

(EPA) Superfund Innovative Technology Evaluation (SITE), and Pacific Division Naval Facilities 

Engineering Command (PACNAVFACENGCOM). The demonstration was conducted at Building 394 

Battery Shop, Pearl Harbor Naval Shipyard and Intermediate Maintenance Facility, Honolulu, Hawaii. 

The purpose of this Innovative Technology Evaluation Report (ITER) is to present information that will 

assist SITE decision-makers in evaluating the lead recovery technology as a potential remediation 

alternative for application at sites with lead contamination in soil. 

The executive summary briefly describes the lead recovery technology, provides an overview of the SITE 

evaluation of the technology, summarizes the SITE evaluation results, and discusses the Superfund 

feasibility evaluation criteria for the lead recovery technology. 

The Lead Recovery Technology 

The basic process for electrokinetic treatment of soil ex-situ is similar to in-situ treatment, except that the 

ex-situ soil contact with the process fluids is within a water-tight soil containment vessel , eliminating 

problems with loss of fluids and potential mobilization of lead to beyond the treatment area. 

Drainage at the bottom of the soil containment vessel is provided through a gravel pack, which contains a 

manifold of slotted well screen to improve flow to the collection pump. One or two layers of filter fabric 

(drainfield cloth or equivalent) and a screen separate the soil and gravel pack to reduce the movement of 

soil particles into the electrochemical treatment unit (ETU). 

An ethylene diamine tetraacetic acid (EDTA) solution is infiltrated through the soil. Lead within the soil 

bonds with the EDTA during infiltration, forming a Pb-EDTA2- complex. The solution is recovered at 

the bottom of the tank, and transferred to the ETU where lead is removed from the EDTA solution by 

electroplating. The EDTA solution is then reconditioned in the electrolyte solution management system 

ES-1
 
(ESMS) as necessary (pH adjustment, EDTA concentration adjustment) and recirculated through the soil. 

Plated lead is scraped from the electrodes and containerized. Treated soil is stored under cover and 

tested for disposal purposes. 

Overview of the Lead Recovery Technology SITE Demonstration 

The EDA lead recovery technology demonstration was conducted in two phases using lead-contaminated 

soil from the former battery acid pit adjacent to Building 394. The first phase was conducted from 

August 8, 2001 to September 28, 2001, and the second phase was conducted from April 1, 2002 to July 

22, 2002. 

The SITE evaluation for the lead recovery technology was designed with three primary and three 

secondary objectives to provide potential users of the technology with the information necessary to 

assess the applicability of the lead recovery technology for other contaminated sites. 

The primary objectives (P) of the technology demonstration were as follows: 

P1	 Determine if the EDA Technology is able to reduce soil lead concentrations in the 

treatment tank to less than the regulatory threshold limit of 2,000 mg/kg. 

P2	 Determine the removal efficiency of the EDA technology for lead within the treatment 

tank. 

P3	 Determine whether the post-treatment soil meets the Resource Conservation and 

Recovery Act (RCRA) landban standards for Toxic Characteristics Leaching Procedure 

(TCLP) for lead concentration. 

The secondary objectives (S) of the technology demonstration were as follows: 

S1	 Evaluate the mass of lead recovered by the electrolyte solution management system 

(ESMS) and estimate the recovery efficiency of the ESMS. 

ES-2
 
S2	 Document specific EDA system operation and maintenance parameters. 

S3	 Estimate capital and operating costs for constructing a full-scale EDA system. 

Key findings of the EDA technology are listed below: 

•	 Approximately six percent of the total post-treatment soil samples met the regulatory 

threshold lead concentration of 2,000 milligrams per kilogram or less (1 of 18 post 

treatment samples). 

•	 The average lead removal efficiency was 59 percent for all three bins. Due to variations 

in the treatment process for Bin 4, which included changing the concentration of the 

EDTA solution and extensively flushing the soil with water, the removal efficiency was 

81 percent. 

•	 TCLP lead concentrations did not meet the RCRA landban standard of the 5.0 milligrams 

per liter for samples collected from Bin 1 and Bin 2 due to adsorption of the Pb-EDTA2­

complex to soil particles during infiltration. Extensive flushing of water in Bin 4 

effectively removed sorbed solution, which resulted in a reduction in TCLP lead 

concentrations and attainment of the RCRA landban standard. 

Technology Evaluation Summary 

Table ES-1 briefly discusses the Superfund feasibility evaluation criteria for the lead recovery technology 

to assist Superfund decision-makers considering the technology for remediation of lead-contaminated 

soils at hazardous waste sites. 

ES-3
 
Table ES-1

Evaluation Criteria for EDA Lead Recovery Technology

Overall Protection of Human Health and the Environment 

Compliance with Federal ARARs 

Long-Term Effectiveness and Performance 

Short-Term Effectiveness 

Reduction of or Volume Th

Provides both short- and long-term protection by removing lead in soil. 

Requires compliance with Toxic Substances Control Act (TSCA) regulations for treatment, management, and disposal of lead-contaminated waste. Prior to cleaning a site, the contaminated material must be sampled to determine waste management requirements. May require compliance with hazardous waste storage requirements, depending on the contaminant extracted. 

Effectively removes lead with high level of treatment efficiency. Does not destroy or degrade the physical properties of the affected media. (Note: This lead recovery Technology FEATS evaluation did not directly evaluate the “long-term” effectiveness of this technology; however destruction of contaminants is considered to be a “long-term” treatment.) 

Presents minimal shortterm risks to workers and nearby community, including noise and exposure to airborne contaminants. Pretreatment of material (i.e. grinding) can enhance treatment success. 

Reduces toxicity acontaminated soil the soil. Minimal waste is contaminant destr

ES-4
Table ES-1 (Continued)

Evaluation Criteria for EDA Lead Recovery Technology

Implementability Cost Community Acceptance State AccTechnology is a mobile system that can be transported anywhere. Can be applied to any amount of material. There is no maximum or minimum volume. System is not labor intensive and requires minimal physical effort. The equipment cannot be left to run unattended. 

Based on information from GII, and observations made during the SITE evaluation, the estimated cost is $45,063 per ton for treating 5 tons of soil; and $28,252 per ton for treating 25 tons of soil. These costs include personnel, equipment and supplies, chemicals, and technical support. Actual cost is site-specific and depends on the media to be treated, severity of contamination, contaminant, and amount of material to be treated. 

Minimal short-term risks and long-term permanence make this technology favorable to the public. Implementation of the technology creates low levels of noise and creates no traffic problems. 

If remediatioof a ResourcRecovery Aaction, state may require before impleThese may ioperate the tHowever, thtechnology mstate accepta(Note: For thwhere the FEsoil was collrequired a le2,000 mg/kg

ES-5
1.0 INTRODUCTION 

This section describes the U.S. Environmental Protection Agency (EPA) Superfund Innovative 

Technology Evaluation (SITE) Program and reports the purpose and organization of the innovative 

technology evaluation report (ITER), the demonstration background, and the ability of the 

Electrochemical Design Associates (EDA), formerly known as Geokinetics International Inc., lead 

recovery technology to remove lead contamination from soil. For additional information about the SITE 

Program, the EDA lead recovery technology, and the evaluation site, refer to key contacts listed at the 

end of this section. 

1.1 PROJECT BACKGROUND 

The primary purpose of the SITE Program is to advance the development and demonstration, and thereby 

establish the commercial availability, of innovative treatment technologies applicable to Superfund and 

other hazardous waste sites. The SITE Program was established by the EPA Office of Solid Waste and 

Emergency Response (OSWER) and Office of Research and Development (ORD) in response to the 

Superfund Amendments and Preauthorization Act of 1986 (SARA), which recognizes the need for an 

alternative or innovative treatment technology research and demonstration program. The SITE Program 

is administered by ORD's National Risk Management Research Laboratory (NRMRL) in Cincinnati, 

Ohio. The overall goal of the SITE Program is to carry out a program of research, evaluation, testing, 

development, and demonstration of alternative or innovative treatment technologies that can be used in 

response actions to achieve more permanent protection of human health and welfare and the 

environment. 

The SITE Program consists of four component programs: (1) the Demonstration Program, (2) the 

Emerging Technology Program, (3) the Monitoring and Measurement Technologies Program, and (4) the 

Technology Transfer Program. This ITER was prepared under the SITE Demonstration Program. The 

objective of the Demonstration Program is to provide reliable performance and cost data on innovative 

technologies so that potential users can assess a given technology's suitability for specific site cleanups. 

To produce useful and reliable data, demonstrations are conducted at hazardous waste sites or under 

conditions that closely simulate actual waste site conditions. Innovative technologies chosen for a SITE 

1-1
 
demonstration must be pilot- or full-scale applications and must offer some advantage over existing 

technologies. 

Implementation of the SITE Program is a significant, ongoing effort involving ORD, OSWER, various 

EPA regions, and private business concerns, including technology developers and parties responsible for 

site remediation. Cooperative agreements between EPA and the innovative technology developer 

establish responsibilities for conducting the demonstrations and evaluating the technology. The 

developer is typically responsible for demonstrating the technology at the selected site and is expected to 

pay any costs for the transport, operation, and removal of related equipment. EPA is typically 

responsible for evaluating the performance of the technology during the demonstration. This 

responsibility includes project planning, site preparation, technical assistance support, sampling and 

analysis, quality assurance and quality control (QA/QC), report preparation, information dissemination, 

and transport and disposal of treated waste materials. 

In 1990, an expanded Site Inspection (SI) at the site was conducted. Based on the results of the SI, a 

remedial investigation was conducted including: a geophysical survey; collection of soil and groundwater 

samples; analysis of samples for chemical and geotechnical parameters; assessment of hydraulic aquifer 

characteristics; and performance of a land survey. Following the remedial investigation, and based on 

the analytical findings, a removal site evaluation (RSE) was conducted for the site. In July 1997, Tetra 

Tech conducted soil sampling at the site in support of the proposed lead remediation technology 

evaluation (Tetra Tech 1997a). In April 1999, Tetra Tech conducted pre-treatment sampling at Building 

394 site in accordance with the previously planned lead remediation technology evaluation (Tetra Tech 

1999a). 

1.2 TECHNOLOGY DESCRIPTION 

The Electrochemical Design Associates Lead Recovery Technology is a soil remediation process that 

mobilizes lead in soil by introducing ethylene diamine tetraacetic acid (EDTA), a lead chelating agent, 

into the soil mass. EDA conducted Phase I and Phase II treatability studies on site soil to determine an 

appropriate chelating agent. EDTA, a weak acid, was identified by EDA as a successful chelating agent 

due to its ability to absorb lead from the highly buffered soil present at the site. EDTA is a nonhazardous and environmentally safe organic acid which naturally biodegrades (GII 1998b). 

1-2
 
EDA found that by saturating the soil column in the laboratory with an electrolyte solution containing 

EDTA (0.3 molar concentration) at a pH of 5 to 6, lead was mobilized in ionic form (in solution) by the 

formation of a Pb-EDTA2- complex. To mobilize and remove lead from the site soil by the EDA ex-situ 

process, EDA used a 4-cubic-yard batch treatment process (Dimensions: 4 feet by 4 feet by 6 feet) . 

Treatment involved flushing the soil with the EDTA electrolyte solution. The electrolyte solution was 

introduced into the treatment tank containing the volume of soil to be treated through a manifold of 

microjets distributed across the top of the tank. The solution, then, migrated through the soil column 

while the EDTA extracted lead from the soil; thus forming the Pb-EDTA2- complex. The electrolyte 

solution (containing Pb-EDTA2- complex) was then allowed to drain the bottom of the tank. Once the 

electrolyte solution was removed from the tank, it was then delivered to a holding tank prior to being 

cycled through a proprietary electrochemical processing unit. Here lead was electroplated out of 

solution and recovered as metallic lead. Afterward, the electrolyte solution was delivered to a holding 

tank where it was regenerated (pH adjusted) before being reintroduced to the soil undergoing treatment. 

Lead removed from the electrolyte solution was accumulated and transported off site for recycling. The 

entire system is a batch, closed-loop process. During operation, frequent sampling and analysis was used 

to monitor the concentration of lead in the electrolyte solution extracted from the soil. 

Site-Specific Configuration 

The system designed by EDA for this evaluation consisted of the following: 

C Two 1,500-gallon primary electrolyte solution holding tanks 

C An electrolyte solution management system 

C One 1,500-gallon header tank 

C A process control system 

Figure 1-1 shows the general configuration of the proposed ex-situ treatment process. 

1-3
 
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
 

 

 

 

 

   
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1.3 KEY CONTACTS 

Additional information regarding the SITE Program and the evaluation can be obtained from the EPA 

SITE Task Order: 

Mr. Thomas Holdsworth 

U.S. Environmental Protection Agency 

Office of Research and Development 

26 W. Martin Luther King Drive 

Cincinnati, Ohio 45268 

Telephone: (513)-569-7675 and (513) 569-7635 

FAX: (513)-569-7676 and (513) 569-7585 

E-mail: holdsworth.thomas@epa.gov 

Additional information on the EDA Lead Recovery technology or the evaluation can be obtained from 

the technology developer: 

Stephen Clarke 

Electrochemical Design Associates 

829 Heinz Street 

Berkeley, CA 94710 

Telephone: (510) 704-2940 

FAX: (510) 848-1581 

E-mail: steve.clarke@e-d-a.com 

Additional information on the demonstration area or the evaluation can be obtained from Pacific Division 

Naval Facilities Engineering Command (PACNAVFACENGCOM): 

Clint Zenigami 

Pacific Division 

Naval Facilities Engineering Command 

Environmental Restoration Branch 

1-5
 
258 Makalapa Drive, Suite 100
 

Code ENV1821
 

Pearl Harbor, Hawaii 96860-7300
 

Telephone: (808) 472 - 1433
 

FAX: (808) 421 - 3800
 

Email: zenigamict@efdpac.navfac.navy.mil
 

Information on the SITE Program is also available through the following on-line information
 

clearinghouse: The Vendor Information System for Innovative Treatment Technologies (Hotline: (800)
 

245-4505) database contains information on 154 technologies offered by 97 developers. Technical
 

reports may be obtained by contacting U.S. EPA/NCEPI, P.O. Box 42419, Cincinnati, Ohio 45242-2419,
 

or by calling (800) 490-9198.
 

1-6
 
2.0 TECHNOLOGY APPLICATIONS ANALYSIS
 

This section of the report describes the general applicability of EDA’s lead recovery technology to 

contaminated sites. The analysis is based primarily on this SITE demonstration, which evaluated the 

treatment of lead contaminated soil. Conclusions are based exclusively on these data since only limited 

information is available on other applications of the technology. Vendor claims regarding the 

applicability of the lead recovery system are included in the appendix. 

2.1 FEASIBILITY STUDY EVALUATION CRITERIA 

2.1.1 Overall Protection of Human Health and the Environment 

The system was setup and maintained by EDA. Soil treated was characterized by AMEC based on the RI 

and engineering evaluation and cost analysis (EE/CA) for the subject site (Ogden 1995, 1996); and Tetra 

Tech during pre-treatment sampling for the proposed in-situ technology evaluation. 

Personal protective equipment (PPE) was worn to protect field personnel from known or suspected 

physical hazards and from potential airborne contamination. The levels of personal protection used 

during excavation and sampling were selected based on known or anticipated physical hazards, 

concentration of contaminants that may be encountered on site, and their chemical properties, toxicity, 

exposure routes, and contaminant matrices. 

Field personnel wore Level D clothing when initially entering the site. Chemical-resistant clothing was 

worn when Level C protection was warranted. Chemical-resistant clothing protected the skin from 

contact with skin-destructive and absorbable chemicals, and helped to prevent contaminants from leaving 

the site when removed before leaving the treatment area. Lead concentrations in dust were monitored to 

establish when respirator protection was necessary. 

2.1.2 Compliance with Applicable or Relevant and Appropriate Requirements 

This section describes the performance of the EDA lead recovery technology in removing lead during the 

evaluation and compliance with applicable or relevant and appropriate requirements (ARARs) identified 

2-1
 
Act or 

Authority 

CERCLA 

RCRA 

CAA 

OSHA 

Requirements 

Table 2-1 Summary of Applicable Regulations 

Applicability	 Application to EDA Lead Recovery Citation 

System 

Superfund sites 

Superfund and 

RCRA sites 

Air emissions from 

stationary and 

mobile sources 

All remedial actions 

This program authorizes and regulates the 

cleanup of environmental contamination. It 

applies to all CERCLA site cleanups and 

requires that other environmental laws be 

considered as appropriate to protect human 

health and the environme nt. 

RCRA defines and regulates the trea tment, 

storage, and disposal o f hazardo us wastes. 

RCRA also regulates corrective action at 

generator and treatment, storage and disposal 

facilities. 

If VOC emissions oc cur or haza rdous air 

pollutants are of concern, these standards 

may be applicable to ensure that air pollution 

is not associate d with the use o f this 

technolog y. State air prog ram requ irements 

should also be considered. 

OSHA regulates on-site construction 

activities and the health and safety of workers 

at hazardous waste sites installation and 

operation of the system at Superfund or 

RCRA sites must m eet OSHA requirements. 

40 CFR, Part 300 

40 CFR, Parts 260 

through 270 

40 CFR, Parts 50 

and 70 

29 CFR, Parts 1900 

through 1926 

for the technology demonstration. Potential federal ARARs for the technology are presented in Table 

2-1. These regulations include the Comprehensive Environmental Response, Compensation and Liability 

act (CERCLA); Resource Conservation and Recovery Act (RCRA); the Clean Air Act (CAA); and 

Occupational Safety and Health Administration (OSHA) requirements. 

This discusses federal environmental regulations that could be pertinent to operation of the EDA 

technology, including transport, treatment, storage, and disposal of wastes and treatment residuals during 

a response action pursuant to the CERCLA of 1980 as amended by the SARA. CERCLA provides for 

federal funding to respond to releases or potential releases of any hazardous substance into the 

environment, as well as to releases of pollutants or contaminants that may present an imminent or 

significant danger to public health and welfare or to the environment. 

2-2
 
EPA has prepared the National Oil and Hazardous Substances Pollution Contingency Plan (NOHSPCP) 

for hazardous substance response. The NOHSPCP is codified at Title 40 CFR Part 300, and delineates 

the methods and criteria used to determine the appropriate extent of removal and cleanup for hazardous 

substances, pollutants or contaminants as defined by CERCLA. 

SARA includes a strong statutory preference for innovative technologies that provide long-term 

protection and directs EPA to: 

•	 Use remedial alternatives that permanently and significantly reduce the volume, 

toxicity, or mobility of hazardous substances, pollutants, or contaminants 

•	 Select remedial actions that protect human health and the environment, are costeffective, and involve permanent solutions and alternative treatment or resource 

recovery technologies to the maximum extent possible 

•	 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 response actions are possible under CERCLA: removal activities, and remedial 

actions. The EDA lead recovery technology is likely to be part of a CERCLA remedial action. Remedial 

actions are governed by the SARA amendments to CERCLA. As stated above, these amendments 

promote remedies that permanently reduce the volume, toxicity, and mobility of hazardous substances, 

pollutants, or contaminants. The lead recovery technology is a toxicity reduction technology, as it 

reduces lead in solid media. 

On-site CERCLA remedial actions must comply with federal and more stringent state ARARs. CERCLA 

provides no ARARs itself; instead, CERCLA requires that remedial actions comply with the substantive 

requirements of other environmental statutes. ARARs are determined on a site-by-site basis considering 

the types of chemicals present (chemical-specific), actions taken and waste streams generated (actionspecific), and location of the site in relation to sensitive environments (location-specific). Locationspecific ARARs depend on site-specific conditions and are not addressed in this report. This discussion 

addresses potential chemical- and action-specific ARARs. The waste streams generated relate to the 

material to be treated, the material after treatment, and PPE. The lead recovery technology is an ex-situ 

treatment technology and the generation and disposal of lead remediation waste is regulated by the Toxic 

2-3
 
Substances Control Act and its implementing regulations at 40 CFR Part 761. If other contaminants are 

also present at a site, the site wastes should be characterized to determine whether they meet the 

definition of hazardous wastes under RCRA. If so, RCRA requirements for the management of 

hazardous wastes will also be ARARs for this technology. Specific ARARs that may be applicable to the 

lead recovery technology are identified in Table 2-2. 

Resource Conservation and Recovery Act 

RCRA, an amendment to the Solid Waste Disposal Act, is the primary federal legislation governing 

hazardous waste activities. RCRA was enacted in 1976 to address safe disposal 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 

relevant and appropriate to CERCLA activities where hazardous wastes are managed. The Hazardous 

and Solid Waste Amendments 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 applicable to the lead recovery technology only if RCRA-defined hazardous wastes 

are generated during the CERCLA action. The regulations that are likely to be listed as ARARs include 

the requirement to characterize waste for a hazardous waste generator (40 CFR P262.11); the 

requirement to determine if the hazardous waste is restricted from land disposal (40 CFR 268.7(a)); and 

either 40 CFR 262.34(a) for storage of waste on site up to 90 days prior to off-site shipment, or 40 CFR 

264.553 for storage of waste in a temporary unit for up to 1 year prior to disposal. However, the 

requirements for treatment and disposal units are not ARARs unless these activities (such as land 

disposal or storage of waste) will be conducted on site. Potential hazardous wastes generated by using 

lead recovery technology include the extracted contaminants in the soil to be treated, the residual process 

chemicals, and used PPE. If these wastes are determined to be hazardous according to RCRA (either 

because of a characteristic or a listing carried by the waste), all substantive RCRA requirements 

regarding management and disposal of hazardous waste must be addressed by the remedial managers. 

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. The technology could be used 

on sites where lead, cadmium, chromium or other metals are present and could, depending on 

2-4
 
Table 2-2

Potential Federal ARARs for the Lead Recovery Technology

Process Activity ARAR Description Basis Response Waste treatment 40 CFR Part 

761.3 and 761.61 or state equivalent 

Standards that apply to treatment and disposal of Pb remediation wastes 

Generally applies to materials contaminated from Pb releases more than 48 hours old 

Three options proviwaste disposal; incluperformance 

On-site/off-site disposal 

40 CFR Part 761.61(b) or state equivalent 

Technology-specific performance standards for disposal of Pb remediation waste 

Pb remediation wastes may be disposed by meeting technology-specific performance standards for chemical landfills, incinerators, etc. 

Permitted landfills, intechnologies may be uremediation waste 

On-site/off-site disposal (continued) 

SARA Section 121(d)(3) 

Requirements for the off-site disposal of wastes from a Superfund site. This statutory requirement is not an ARAR and cannot be waived. 

If the waste is being generated from a response action authorized under CERCLA, there may be additional disposal requirements. 

Wastes must be dispocompliant waste dispo

Transportation for offsite disposal 4 CFR Part 172 or state 

equivalent 

DOT requirements for packaging and labeling hazardous materials prior to transport 

The treated waste must be managed as a hazardous material under DOT regulations 

Packaging and labelinhazardous materials anot be waived. 

Notes: 

ARAR Applicable or Relevant and Appropriate Requirements CERCLA Comprehensive Environmental Response, Comensation, and Liability Act CFR Code of Federal Regulations DOT Department of Transportation Pb Lead SARA Superfund Amendments and Reauthorization Act 

2-5
concentrations, be characteristic hazardous wastes. Contaminated PPE is subject to land disposal 

restriction only if it contains more than 5 percent contamination per square inch. 

Listed hazardous wastes (40 CFR Part 261 Subpart D) 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 regulation implies that, even after remediation, treated wastes are still classified as 

hazardous if the pre-treatment material was a listed waste. Under the contained-in policy, listed wastes 

contained in other materials that are managed as waste require that those materials be managed as listed 

wastes. 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 Waste 

Manifest (if the waste is transported), restrictions on placing the waste in land disposal units, time limits 

on accumulating waste, and permits for storing the waste. 

RCRA corrective action regulations regarding corrective action management units (CAMU) and 

temporary units may be ARARs for CERCLA action involving RCRA hazardous waste. The CAMU rule 

allows for disposal of remediation wastes without triggering landfill disposal requirements and minimum 

technology requirements. The temporary units rule allows treatment or tanks without triggering RCRA 

tank regulations. 

Other Non-ARAR Requirements 

Several requirements must be addressed by remedial managers although they are not ARARs. These 

requirements cannot be waived. CERCLA remedial actions and RCRA corrective actions must be 

performed in accordance with the OSHA requirements detailed in 29 CFR Parts 1900 through 1926, 

especially 29 CFR Part 1910.120, which provides for the health and safety of workers at hazardous waste 

sites. On-site construction activities at Superfund or RCRA corrective action sites must be conducted in 

accordance with 29 CFR Part 1926, which describes safety and health regulations for construction sites. 

State OSHA requirements, which may be significantly stricter than federal standards, must also be met. 

All technicians operating the lead recovery system are required to have completed an OSHA training 

course and must be familiar with all OSHA requirements relevant to hazardous waste sites. Noise levels 

are not expected to be high. The levels of noise anticipated are not expected to adversely affect the 

community. 

2-6
 
Department of Transportation Regulations 

Off-site shipment of hazardous materials is subject to Department of Transportation (DOT) requirements 

for packaging and placarding. The treated soil from the lead recovery technology would likely be a 

hazardous material subject to DOT regulations regulations in 49 CFR Parts 172 and 173. These 

requirements cannot be waived, and as such, are not ARARs. 

CERCLA Off-Site Rule 

The CERCLA Off-Site Rule requires that wastes taken from a CERCLA site for off-site disposal must be 

transported to permitted waste disposal facilities. These facilities must be properly permitted and must 

not have any violations that adversely affect human health or the environment. Each EPA region has a 

coordinator for assistance in identifying disposal facilities in the region that are in compliance with their 

appropriate permits and that are approved to receive waste from CERCLA sites. 

Clean Air Act 

The CAA as amended in 1990 regulates stationary and mobile sources of air emissions. CAA regulations 

are generally implemented through combined federal, state, and local programs. The CAA requires that 

treatment, storage, and disposal facilities comply with primary and secondary ambient air quality 

standards. Air emissions from the EDA lead recovery system may result from dust during the excavation 

process. State air quality standards may require additional measures to prevent fugitive emissions. 

Occupational Safety and Health Administration Requirements 

OSHA regulations in 29 CFR, Parts 1900 through 1926, are designed to protect worker health and safety. 

Both Superfund and RCRA corrective actions must meet OSHA requirements, particularly Part 

1910.129, “Hazardous Waste Operations and Emergency Response.” Part 1926, “Safety and Health 

Regulations for Construction,” applies to any on-site construction activities. For example, electric utility 

hookups for the EDA lead recovery system must comply with Part 1926, Subpart K, “Electrical.” 

Product chemicals used with the EDA lead recovery system must be managed in accordance with OSHA 

2-7
 
requirements (for example, Part 1926, Subpart D, “Occupational Health and Environmental Controls, “ 

and Subpart H, “Materials Handling, Storage, and Disposal”). More stringent state or local requirements 

must also be met, if applicable. In addition, health and safety plans for site remediation should address 

chemicals of concern and include monitoring practices to ensure that worker health and safety are 

maintained. 

2.1.3 Long-Term Effectiveness and Permanence 

This criterion refers to the ability of a remedy to maintain reliable protection of human health and the 

environment over time. Electrokinetics is a treatment technology for metals in the soil. Electrokinetics 

transforms the physical state of contaminated soil to clean soil with a solid-metal product. 

2.1.4 Reduction of Toxicity, Mobility, or Volume Through Treatment 

This criterion refers to the anticipated performance of the treatment technology potentially employed in a 

Superfund remediation. With electrokinetics, the contamination of the soil is reduced by permanently 

removing the metals from the soil. If high-density soil treatment blocks are desired, the runs of 

electrolyte solution would increase. When the EDA system is run the way that was originally planned for 

the SITE demonstration (that is, in situ), there would be no waste product planned for disposal as it 

would be completely remediated. 

Results of lead tests indicated that the EDA process reduced the lead in the soil. However, this did not 

reach below the regulatory limit defined for a characteristic waste as defined by RCRA. 

2.1.5 Short-Term Effectiveness 

This criterion addresses the period of time needed to achieve lasting protection of human health and the 

environment as well as any adverse impacts that may be posed during the construction and 

implementation period before cleanup goals are achieved. 

2-8
 
2.1.6 Ability to Implement 

This criterion considers the technical and administrative feasibility of a remedy, including the availability 

of materials and services needed to implement a particular option. EDA operates other pilot programs, 

but does not operate on the open market yet. Therefore, only the primary and secondary objectives need 

to be evaluated for this criterion. 

2.1.7 Cost 

This criterion addresses estimated capital, operation and maintenance costs as well as net present worth 

costs. Costs for treatment by the EDA technology will depend on site-specific factors such as the volume 

of material to be treated, physical properties of the material, contaminant types and concentrations, and 

site location. Section 3 of this report provides a detailed discussion of costs for the application of this 

technology. 

2.1.8 State Acceptance 

Because few applications of the EDA Electrokinetic system have been attempted beyond the bench- or 

pilot scale, limited information is available to assess state acceptance of the system. Although some 

contaminants may be released during electrode and ancillary equipment installation, the potential for 

emissions during drilling is substantially lower than during excavation. State acceptance of the 

technology may involve consideration of performance data from applications such as the SITE 

demonstration and results from on-site, pilot-scale studies using the actual wastes to be treated during 

later, full-scale remediation. 

2.1.9 Community Acceptance 

Because few applications of the EDA system have been attempted beyond the bench- or pilot scale, 

limited information is available to assess state acceptance of the system. Although some contaminants 

may be released during electrode and ancillary equipment installation, the potential for emissions during 

drilling is substantially lower than during excavation. 

2-9
 
EDA claims one distinguishing feature of the lead recovery process is that no portion of the original 

molecule is discharged to the atmosphere or to water. Further, EDA claims that the process is reductive 

in nature and therefore not capable of forming dioxins or furans, which can be found in oxidizing 

technologies. This result is especially beneficial because communities are becoming increasingly aware 

of waste facilities and concerned over contaminant releases to the atmosphere and surrounding water. 

Due the operational parameters of the lead recovery system, there are almost no potential hazards to the 

community from implementation of the EDA technology. No loud or heavy equipment is associated with 

the technology, and no substantial quantities of waste are generated apart from the treated soil. When 

proper operational and safety procedures are followed, hazards to personnel are minimized and the 

potential for a chemical spill to the environment that might endanger the community is minimal. 

2.2 TECHNOLOGY APPLICABILITY 

The EDA process was tested for the remediation of lead in the soil at the SITE demonstration. However, 

EDTA removes metals in a specific order within the plating process providing the potential capability to 

remove other metals. 

2.3 KEY FEATURES OF THE TREATMENT TECHNOLOGY 

The most common remediation method for soil contaminated with metals is excavation and permanent 

landfill disposal. The byproducts of the EDA lead recovery technology can be recyclable amounts of 

lead and other metals such as iron and copper that may present in treated soil. A major advantage of this 

technology is that contaminants can be reused rather than transferred to a landfill. 

2.4 MATERIALS HANDLING REQUIREMENTS 

It was imperative that sample logging and tracking procedures are in place and followed. Defined 

procedures ensured that all core samples were properly labeled following retrieval from the sampler, 

tracked through the homogenization area and homogenized correctly, and that appropriate sample 

volumes of homogenized samples were collected and properly labeled before shipping to the analytical 

laboratory. 

2-10
 
Prior to collecting the core samples from each grid-cell, the sampling personnel recorded the grid-cell 

number being sampled, the sampler’s name, and the date and time. This information was logged on a 

field sampling form. A field sampling form was completed for each grid-cell sample. As each 2-foot 

core sample was retrieved, the sampling personnel recorded the time and the core samples were labeled 

with their grid-cell number, depth interval, samplers initial, and date and time. This information was 

written on the acetate sleeve with a permanent marker. 

In addition, a site plan is required to provide for personnel protection and special handling measures. 

Wastes need to be appropriately stored until sampling results indicate their acceptability for disposal or 

release to a treatment facility. 

2.5 SITE SUPPORT REQUIREMENTS 

Site-specific factors can impact the application of the lead recovery system. These factors should 

therefore be considered before the system is selected for remediation of a specific site. Site-specific 

factors addressed in this section include site access, area, and preparation requirements; climate 

requirements; utility and supply requirements; support system requirements; and personnel requirements. 

Site Access, Area, and Preparation Requirements: The site must be prepared for the mobilization, 

O&M, and demobilization of the equipment. Access roads are necessary for equipment transport. The 

site must be accessible to equipment necessary to install electrodes and ancillary equipment, such as 

Geoprobe® and drill rigs. The air space in the equipment installation area must be clear of obstacles 

(such as overhead wires). 

In addition to the treatment area and corresponding exclusion zone, enough space should be available to 

accommodate the control trailer, hazardous waste storage area, water tanks, and supply storage. This 

additional area is estimated to require 8,800 square feet. 

Climate Requirements: Climate does not determine the effectiveness or the applicability in this 

demonstration. The only time the climate may effect the demonstration is when the soil needs to be dried 

after the treatment. 

2-11
 
Utility and Supply Requirements: The electrochemical treatment unit (ETU) system demonstrated at 

Pearl Harbor Naval Shipyard was powered by a 20 kV DC power supply unit providing 200 amps at 

100V DC. 

Maintenance Requirements: Maintenance of a full-scale lead recovery system is estimated to require 

15 hours weekly, 3 hours / 5 days per week. This estimate is based on the assumption that the design of 

parts of the system that caused frequent shutdowns during the SITE demonstration, such as bladders and 

float switches, would be modified to eliminate the problems. 

2.6 LIMITATIONS OF THE TECHNOLOGY 

Prior to implementing electrokinetic remediation at a specific site, field and laboratory screening tests 

should be conducted to determine if the site is amenable to this technology. Field conductivity surveys 

are necessary to determine the soil’s electrical conductivity. Also, buried metallic objects and utility 

lines could short circuit the current path, thereby influencing the voltage gradient and affecting the 

contaminant extraction rate. Electromagnetic surveys should be conducted to determine the presence of 

buried metallic objects. 

In addition, if volatile organic carbons (VOC) are present in soil undergoing electrokinetic treatment, the 

VOCs may be stripped from the soil to significantly increase the soil vapor VOC concentrations that 

would result in significant VOC migration from the treatment area, if soil temperature exceeds 500

C. 

Special measure therefore need to be taken to contain and control VOC emissions. 

2-12
 
3.0 ECONOMIC ANALYSIS
 

This economic analysis presents the costs for using the lead recovery technology to remove lead from the 

soil collected at Building 394 Battery Shop, Pearl Harbor Naval Shipyard and Intermediate Maintenance 

Facility in Honolulu, Hawaii. Costs are organized under 12 categories applicable to typical cleanup 

activities at Superfund and RCRA sites (Evans 1990). 

3.1 INTRODUCTION 

The primary purpose of this economic analysis is to provide a cost estimate for using EDA’s Lead 

Recovery Technology to commercially remediate lead-contaminated soil. This analysis is based on the 

assumptions and costs provided by EDA, and on the results and experiences gained from the SITE 

evaluation that was conducted at Building 394 Battery Shop, Pearl harbor Naval Shipyard and 

Intermediate Maintenance Facility, Honolulu, Hawaii. The SITE demonstration included the treatment of 

three 500-gallon bins of lead-contaminated soil. The average pre-treatment lead soil concentration 

ranged from 13,800 milligrams per kilogram (mg/kg) to 153,000 mg/kg. Results of the SITE 

demonstration are presented in Section 4.0 of this report. 

Economic calculations were compiled for: (1) 5 tons of soil with lead contamination similar to the SITE 

evaluation using the EDA lead recovery technology, and (2) 500 tons of soil with lead contamination 

similar to the SITE evaluation using the EDA lead recovery technology. Many factors affect the cost of 

treatment. These include, but are not limited to; treatment mass, initial soil contaminate concentration, 

final required target soil contaminate concentration, treatment soil type and characteristics, system design 

and operating parameters, and type of contaminants. 

3.2 CONCLUSIONS 

This analysis presents cost estimates for treating contaminated soil with the EDA lead recovery 

technology. Table 3-1 lists a detailed breakdown of each cost category for each of the cases. Costs that 

are assumed to be the technology-independent obligation of the responsible party or site owner have been 

3-1
 
omitted from this cost estimate and are indicated by a line (---) in Tables 3-1 and 3-2. Categories with no 

costs associated with this technology are indicated by a zero (0) in Tables 3-1 and 3-2. Figures 3-1, and 

Figure 3-2 show graphic presentations of the costs for pilot-study and the full-scale project respectively. 

The estimated treatment costs are $11,980 per ton, and $546 per ton for the 5-ton case and the 500-ton 

case, respectively. The cost of labor required is directly proportional to the treatment time per ton of soil. 

Therefore, the estimated treatment cost would be lower if the percent lead reduction per EDA run is 

increased, and the treatment time per batch is decreased. Also, the treatment time decreases for lower 

initial lead concentrations and therefore treatment costs could decrease. For the 5-ton case and the 25­

ton case, the treatment time per cycle is based on 7, 24-hour days. 

3.3 ISSUES AND ASSUMPTIONS 

This section lists the major assumptions, site-specific factors, equipment and operating parameters, and 

financial calculations used in this economic analysis of the EDA lead recovery technology. 

The cost estimates presented in this analysis are representative of charges typically assessed to the client 

by the vendor, but do not include profit. In general, assumptions are based on information provided by the 

vendor and observations made during this and other SITE evaluation projects. 

Many actual or potential costs that exist were not included as part of this estimate. They were omitted 

because site-specific engineering designs that are beyond the scope of this SITE project would be 

required. Also, certain functions were assumed to be the obligation of the responsible party or site owner 

and were not included in the estimates. These costs are site-specific; thus, calculations are left to the 

decision-maker so that relevant information may be obtained for specific cases. Whenever possible, 

applicable information is provided on these topics so that a decision-maker can independently perform the 

calculations required to acquire relevant economic data. 

3-2
 
Table 3-1 Estimated Costs for Treatment Using the EDA Lead Recovery Technology 

Treatment Unit Pilot Study Full-Scale Study 

Treatment Volume per Batch (tons) 5 25 

Number of Batches 1 20 

Site and Facility Preparation Costs 

Site selection and preparation --- ---

Soil collection, transportation, and stockpiling --- ---

Legal Searches --- ---

Access rights and roads --- ---

Preparations for support facilities --- ---

Auxiliary buildings --- ---

Technology setup costs (labor, assembly, testing) $4,100 $8,000 

Transportation of EDA system $1,500 $3,000 

Total Site and Facility Preparation Costs $5,600 $11,000 

Permitting and Regulatory Costs 

Permits --- ---

System monitoring requirements --- ---

Development of monitoring and protocols --- ---

Total Permitting and Regulatory Costs --- ---

Equipment Costs 

Power Supply (DC) $2,000 $2,000 

Control computer and data acquisition $1,200 $1,200 

Sensors and signal conditioners $400 $400 

Tanks (other than ETU Cells) $1,000 $1,000 

3-3
 
Treatment Unit Pilot Study Full-Scale 

Study 

Treatment Volume per Batch (tons) 5 25 

Number of Batches 1 20 

Tanks (other than ETU Cells) $1,000 $1,000 

Cells (5) $5,000 $5,000 

Pumps (all) $2,000 $2,000 

Plumbing and hardware $700 $700 

Safety Equipment $1,000 $1,000 

Transformer (480V to 120V) $1,000 $1,000 

Total Equipment Costs $14,300 $14,300 

Startup and Fixed Costs 

Working capital --- ---

Insurance and taxes --- ---

Initiation of monitoring programs --- ---

Contingency --- ---

Total Startup and Fixed Costs --- ---

Labor Costs 

Operator (Field Technician) $10,000 $161,300 

Chemist/supervisor $4,000 $32,200 

Total Labor Costs $14,000 $193,500 

Supplies and Consumables Costs 

Health and Safety $200 $2,100 

Chemicals $0 $0 

3-4
 
Treatment Unit 

Treatment Volume per Batch (tons) 

Number of Batches 

Spare Parts 

Total Supplies and Consumables Costs 

Utilities Costs 

Electricity 

Water 

Total Utilities Cost 

Pilot Study 

5 

1 

$300 

$500 

$300 

$0 

$300 

Full-Scale 

Study 

25 

20 

$2,400 

$4,500 

$2,400 

$0 

Residuals and Waste Shipping, Handling and Transport 

Costs 

Effluent Treatment and Disposal Costs 

On-site facility costs 

Off-site facility costs 

-recovered metal 

-solution disposal 

Total Effluent Treatment and Disposal Costs 

--- ---

--- ---

$0 $0 

$15,000 $15,000 

$15,000 $15,000 

---

---

Total Residuals and Waste Shipping, Handling and 

Transport Costs 

Preparation 

PPE, drops cloths, and small equipment 

Shipping & Handling 

$200 

$100 

---

---

$1,600 

$1,600 

3-5
 
Treatment Unit Pilot Study Full-Scale 

Study 

Treatment Volume per Batch (tons) 5 25 

Number of Batches 1 20 

Analytical Costs 

Operations (laboratory) $2,000 $14,500 

Environmental monitoring (regulatory) --- ---

Total Analytical Costs $2,000 $14,500 

Facility Modification, Repair, and Replacement Costs 

Design adjustments --- ---

Routine maintenance (material and labor)a $0a $0a 

Total Facility Modification, Repair, and Replacement 

Costs 

$0 $0 

Site Restoration Costs 

Equipment demobilization $6,000 $12,000 

Transportation $2,000 $4,000 

Total Site Restoration Costs $8,000 $16,000 

TOTAL OPERATING COSTS $59,900 $272,800 

COST PER TON $11,980 $546 

a Maintenance labor is included in the operating labor. 

3-6
 
Table 3-2 Estimated Cost Percentages for Treatment Using the EDA Lead Recovery
 

Technology
 

Treatment Unit Pilot Study Full-Scale Study 

Total Treatment Volume (tons) 5 25 

Number of Batches 1 

% 

20 

% 

Site Facility Preparation Costs $5,600 9.3 $11,000 4.0 

Permitting and Regulatory Costs --- --- --- ---

Equipment Costs $14,300 23.9 $14,300 5.2 

Startup and Fixed Costs --- --- --- ---

Labor Costs $14,000 23.4 $193,500 70.9 

Supplies and Consumable Costs $500 0.8 $4,500 1.6 

Utilities Costs $300 0.5 $2,400 0.9 

Effluent Treatment and Disposal Costs $15,000 25 $15,000 5.5 

Residuals Shipping, Handling and 

Transport Costs 

$200 0.3 $1,600 0.6 

Analytical Costs $2,000 3.3 $14,500 5.3 

Facility Modifications, Repair, and 

Replacement Costs 

$0 0.0 $0 0.0 

Site Restoration Costs $8,000 13.4 $16,000 5.9 

Total Costs $59,900 $272,800 

a Maintenance labor is included under operating costs 

3-7
 
Analytical Site Restoration 

$400 per ton $1,600 per ton 

Site Facility Preparation 

$1,120 per ton 

Labor 

$2,800 per ton 

Residuals, Shipping, 

Handling, and Transport 

$40 per ton Equipm

$2,860 pe

Effluent Treatment & 

Disposal 

$3,000 per ton

Utilities Supplies and Consumables $60 per ton $100 per ton 

Figure 3-1 Estimated Treatment Costs for 5 Tons of Soil Using EDA Le

Removal Technology 

* Permitting & Regulatory Costs were not included in the economic analysis.**Facility Modifications, Repair, & Replacement Costs were included under Labor Costs and Equipment Costs.

3-8
Analytical Costs 

$32 per ton Costs Site Facility Preparation $3 per ton 

Effluent Treatment & 

Disposal $30 per ton 

Labor 

$387 per ton 

Equipme

$29 per t

$22 per ton 

Residuals Shipping, $29 per ton Site Restoration

Handling, and Transport 

Utilities

$5 per ton

Supplies and Consumables 

Costs

$9 per ton

Figure 3-2 Estimated Treatment Cost for 500 Tons of Soil Using the EDA 

Removal Technology 

* Permitting & Regulatory Costs were not included in the economic analysis.**Facility Modifications, Repair, & Replacement Costs were included under Labor Costs and Equipment Costs.

3-9
3.4 BASIS FOR ECONOMIC ANALYSIS 

In order to compare the cost-effectiveness of technologies in the SITE Program, EPA breaks down costs 

into 12 categories (Evans 1990): 

• Site and facility preparation costs 

• Permitting and regulatory costs 

• Equipment costs 

• Start-up and fixed costs 

• Labor costs 

• Supplies and consumable Costs 

• Utilities costs 

• Effluent treatment and disposal costs 

• Residuals and waste shipping, handling, and transport costs 

• Analytical costs 

• Facility modification, repair, and replacement costs 

• Site restoration costs 

These 12 cost categories reflect typical clean-up activities encountered at Superfund sites. The clean-up 

activities are defined below, and form the basis for the detailed estimated costs presented in Tables 3-1 

and 3-2. 

3.4.1 Site and Facility Preparation Cost 

Site preparation costs include administrative, treatment area preparation, treatability study, and system 

design costs. For the purposes of these cost calculations, "site" refers to the location where the EDA 

technology is treating lead-contaminated soil. It is assumed that preliminary site preparation and soil 

excavation will be performed by the responsible party. The amount of preliminary site preparation 

required will depend on the site. Site preparation tasks include site design and layout, surveying,, legal 

research, obtaining access rights, preparations for support and decontamination facilities, utility 

3-10
 
connections, fixed auxiliary buildings, and excavation and stockpiling the soil. Since these costs are sitespecific, they are not included as part of the site preparation costs in this cost estimate. 

Only technology-specific site preparation costs are included. These are limited to transportation and setup 

of the EDA system. For this cost estimate, it is assumed that the site is 1,000 miles away and that 

treatment will be outdoors. Transportation to the site for the ETU unit used in the pilot-study case 

includes one trailer and a mileage rate of $1.50 per mile for a total of $1,500. The full-scale study 

assumes two trailers. 

Technology-specific site preparation labor costs are required for setting up the equipment when it arrives 

on site and are based on estimates by EDA and observations during the SITE evaluation. Labor to setup 

the equipment and perform shakedown testing was $4,100 for the pilot study and $8,000 for the full-scale 

study. 

3.4.2 Permitting and Regulatory Costs 

Permitting and regulatory costs are generally the obligation of the responsible party (or site owner), not 

that of the vendor. These costs may include actual permit costs, system monitoring requirements, the 

development of monitoring and analytical protocols, and health and safety monitoring. No permitting and 

regulatory costs are included in Table 3.1. Permitting and regulatory costs can vary greatly because they 

are generally specific to the site and particular waste. Permitting costs are not included in this analysis. 

3.4.3 Equipment Costs 

Equipment costs for the pilot and full-scale studies incorporates recent data from the evaluation completed 

in Hawaii. Equipment costs for both studies are assumed to be the same. 

3-11
 
3.4.4 Start-up and Fixed costs 

The Lead recovery technology does require shakedown testing, since the lead recovery modules need to 

be connected following transport to a site. However, the equipment will be checked for proper assembly 

after setup. Shakedown testing is included under technology-specific site preparation. 

The cost for the initiation of monitoring programs has not been included in this estimate. Depending on 

the site and the location of the system, however, local authorities may impose specific guidelines for 

monitoring programs. The stringency and frequency of monitoring required may have significant impact 

on the project costs. 

Contingency costs allow for any unforeseen or unpredictable cost conditions, such as strikes, storms, 

floods, and price variations (Peters 1980) (Garrett 1989). Contingency costs, as well as annualized 

insurance and taxes are not included. 

3.4.5 Labor Costs 

Once the system is functioning, it is assumed to operate continuously at the designed flow rate except 

during routine maintenance, which EDA conducts (see Section 3.4.11 Facility Modification, Repair and 

Replacement Costs). One operator trained by EDA performs routine equipment monitoring and sampling 

activities. Under normal operating conditions, an operator is required to monitor the system 2 hours per 

day during the pilot study. This analysis assumes that the work is conducted by a full-time employee of 

the site owner who is assigned to be the primary operator to the perform system monitoring and sampling 

duty. Full-scale application will require two full-time operators. Operator labor costs are $50 per hour. 

Chemist/supervisory labor is assumed to be $70 per hour. 

Based on SITE demonstration on Bin 4, it is assumed 18 weeks of operation are required during the pilot 

test to achieve the regulatory threshold limit, and 52 weeks of operation are required during the full-scale 

study to reach the same desired limit. 

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3.4.6 Supplies and Consumable Costs 

Supplies costs are limited to health and safety supplies and drums for residuals and waste storage. Supply 

costs are assumed to be $4 to $15 per worker per operational day. Drums are estimated to cost $35 per 

drum, including freight charges. A total of 10 drums and 200 drums are assumed for the pilot study and 

full-scale study, respectively. Consumables are limited to chemicals and spare parts. Based on the SITE 

study, chemical cost is minimal and was not included. Spare parts include 2 to 4 replacement pumps at 

$500 per pump and $400 of miscellaneous items. 

3.4.7 Utilities Costs 

Utilities required are limited to electricity and water for the EDA lead recovery technology. For the pilot 

study, it was assumed that 1,000 kiloWatt-hours (kWh) are used weekly based on the demonstration 

project. Electricity rates are assumed to be $0.08/kWh. Water is required for the technology to be 

properly implemented. Water is assumed to cost $0.08 per 1,000 gallons and is included with the 

electricity estimate. 

3.4.8 Effluent Treatment and Disposal Costs 

Effluent treatment and disposal is limited to scrubber water. Effluent volumes are based on the capacity 

of the scrubber tank module for lead recovery technology. An estimated 55 to 1,100 gallons of scrubber 

water effluent will require disposal. 

3.4.9 Residuals and Waste Shipping, Handling, and Transport Costs 

It is assumed that the only residuals or solid wastes generated from this process will be used health and 

safety and miscellaneous solid waste, including debris from the treatment process (such as drop clothes), 

as well as small equipment. The disposal cost for solid waste is estimated at $200 per 55-gallon drum. 

3-13
 
3.4.10 Analytical Costs 

Required sampling frequencies are highly site specific and are based on treatment goals and contaminant 

concentrations. Analytical costs associated with an electrokinetics treatment project include the costs of 

laboratory analyses, data reduction, and QA/QC. This analysis assumes that samples were collected 

from each days operation, for each soil flush,; and 12 pre-treatment soil samples, 12 post-treatment soil 

samples, and associated QC samples (trip blanks, field duplicates, and matrix spike/matrix spike 

duplicates) will be analyzed for total lead and TCLP lead concentrations. The total analytical costs are 

estimated to be $2,000 for the pilot study and $14,500 for the full-scale study. 

The analytical costs associated with environmental monitoring have not been included in this estimate due 

to the fact that monitoring programs are not typically initiated by EDA. Local authorities may, however, 

impose specific sampling and monitoring criteria whose analytical requirements could contribute 

significantly to the cost of the project. 

3.4.11 Facility Modification, Repair and Replacement Costs 

Maintenance costs are assumed to consist of maintenance labor and maintenance materials. 

Maintenance costs are not included, since they are assumed to be routine for the Lead recovery 

technology and are incorporated into the treatment time that accounts for an 80 percent run time 

efficiency. This assumption is made because the Lead recovery equipment is maintained by the operators 

during the runs and should require little to no repairs in addition to the 80 percent run-time efficiency. In 

addition, maintenance labor is included in the operating labor and the replacement part costs and tools are 

included in the total equipment cost lump sum so no additional replacement part costs are included. 

3.4.12 Site Restoration Costs 

Site restoration requirements will vary depending on the future use of the soil and are assumed to be the 

obligation of the responsible party. Therefore, the only site restoration costs included are for the 

demobilization and transportation of the recovery equipment, estimated at 2 man weeks for the pilot study 

and 4 man weeks for the full-scale study. 

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4.0 TREATMENT EFFECTIVENESS
 

This section addresses the effectiveness of the EDA lead recovery technology for treating soil 

contaminated with lead. Because the SITE demonstration provided extensive data on the EDA 

technology, the evaluation of the technology’s effectiveness is based primarily on the demonstration 

results. This section provides an overview of the evaluation procedures and sampling/analytical 

methods; summarizes the evaluation objectives, and results; presents the conclusion of the EDA lead 

recovery treatment evaluation; and briefly discusses the data quality. Vendor claims regarding the 

treatment effectiveness of the EDA lead recovery technology are included in the appendix. 

4.1 BACKGROUND 

The EDA lead recovery technology was evaluated in two phases. Phase I was conducted from August 8 

to September 28, 2001. Phase II was conducted from April 1 to July 22, 2002. During Phase I of the 

evaluation, pre-treatment soil samples were collected and analyzed for lead. Three bins (1, 2, and 4) 

were treated during the evaluation. Bin 1 was treated and sampled during Phase I, and bins 2 and 4 were 

treated and sampled during Phase II. 

4.1.1 Site Description 

The system was set up and maintained by EDA. Soil to be treated was characterized by AMEC based 

during the RI. The volume and extent of soil requiring remediation was defined during the EE/CA for 

the subject site (Ogden 1995, 1996); and by Tetra Tech during pre-treatment sampling for the proposed 

in-situ technology evaluation. Tetra Tech excavated approximately 20 cubic yards of soil to fill the five 

treatment bins for this demonstration; however, only three of the five bins were treated due to 

PACNAVENGCOM funding limitations. 

4-1
 
4.1.2 Evaluation Objectives and Approach 

Primary objectives were considered critical for evaluating the lead recovery technology. The primary 

objectives (P) of the SITE demonstration were to validate EDA’s performance claims for the technology. 

These objectives focused on the ability of the lead recovery technology to remove the lead from the soil. 

Three primary objectives were selected for the SITE evaluation as follows: 

P1 

P2 

Determine if the technology is able to reduce soil lead concentrations to less than 

the regulatory threshold limit of 2,000 mg/kg 

Determine the removal efficiency of the EDA technology for lead within the soil 

treatment bin 

P3 Determine whether the post-demonstration soil meets the RCRA landban 

standards of 5.0 milligrams per liter (mg/L) for TCLP lead concentrations 

Secondary objectives (S) provided additional information that was useful, but not critical, for the 

evaluation of the lead recovery technology. The secondary objectives of the demonstration were to 

collect and evaluate data that are useful in assessing system performance, cost, and applicability to other 

sites. Three secondary objectives were selected for the SITE evaluation as follows: 

S1 Evaluate the mass of lead recovered by the ESMS and estimate the recovery 

efficiency of the ESMS. 

S2 Document specific EDA system operation and maintenance parameters. 

S3 Estimate capital and operating costs for constructing a full-scale EDA system. 

4.2 EVALUATION PROCEDURES 

4.2.1 Evaluation Preparation 

Tetra Tech excavated soil from different portions of the site in order to have soil with varying lead 

concentrations within each of the five proposed treatment batches. The goal was to have two high 

concentration batches, two medium concentration batches, and one low concentration batch. High, 

medium, and low concentrations are defined as the following: 

4-2
 
1.	 High Soil Lead Concentration: 100,000 to 150,000 mg/kg lead 

2.	 Medium Soil Lead Concentration: 25,000 to 50,000 mg/kg lead 

3.	 Low Soil Lead Concentration: 10,000 to 20,000 mg/kg lead 

4.2.2	 Evaluation Design 

The data analysis, like the sampling plan, was designed to address the objectives of the project. To 

evaluate the data, descriptive statistics, statistical tests, or construction of confidence intervals were used 

to evaluate the populations from which the samples were collected. Descriptive statistics included 

calculation of the range, upper and lower values, mean, median, and variance. 

P1 Determine if the technology is able to reduce soil lead concentrations to less than the 

regulatory threshold limit of 2,000 mg/kg. 

Twelve post-demonstration samples were collected from within each treatment batch. Samples were 

analyzed for total lead and the data was used to determine the post-treatment lead concentration in each 

sub-cell; concentrations were not averaged to obtain a mean concentration of lead within each grid-cell 

column. All samples must exhibit analytical lead concentrations less than 2,000 mg/kg, for the 

technology to be considered successful in removing lead from contaminated soils. 

P2	 Determine the removal efficiency of the EDA technology for lead within the 

treatment tank. 

Twelve pre-treatment samples were collected from within the treatment tank. Samples were analyzed for 

total lead and the data were used to estimate the pre-treatment lead concentration in each sub-cell. The 

data was combined with the post-treatment data obtained for primary objective P1 in order to provide a 

total of 12 data pairs (before and after treatment lead concentrations for each sampled sub-cell). The RE 

of each sub-cell was calculated according to the following formula: 

4-3
 
Where: 

RE 	 = Removal efficiency (%) 

Cpre	 = The concentration of lead in each sub-cell within a pre-treatment grid-cell 

column 

Cpost = The concentration of lead in each sub-cell within a post-treatment grid-cell 

column 

The laboratory reporting limit for lead in soil is 10 mg/kg. Given that the soil used for this demonstration 

has previously been characterized as possessing very high lead concentrations, it was unlikely that many 

results below this reporting limit would be obtained. 

P3	 Determine whether the post-demonstration soil meets the RCRA landban standards for 

TCLP lead concentrations. 

To determine whether the TCLP lead concentrations in the post-demonstration samples meet RCRA 

landban standards, post-demonstration samples were compared to the TCLP regulatory limit of 5.0 mg/ 

L. A successful result required that all TCLP extracts are below 5.0 mg/L. 

S1 	 Determine the mass of lead recovered by the ESMS and estimate the recovery efficiency of 

the ESMS. 

The mass of lead removed by the system was determined by summing the weight of all metal 

electroplated out of solution for each test run and analyzing a composite sample of the metal for lead 

purity. Based on the weight of the plated out metal and its purity (lead concentration), the mass of solid 

lead removed is calculated for each test run. The mass of solid lead removed from the ESMS was 

calculated using the following equation: 

Where: 

Mp = Calculated mass of solid lead plated out from the ESMS 

W = Total weight of metal removed from the ESMS 

C = The purity of lead in the composite metal sample 

In addition, the recovery efficiency of the ESMS was estimated. Samples of electrolyte solution were 

collected before the electrolyte solution entered the ESMS, and after the electrolyte solution exited the 

4-4
 
ESMS. The concentrations of lead in solution entering and exiting the ESMS were used to estimate the 

recovery efficiency of the ESMS. 

The recovery efficiency for each sampling event was calculated using the following equation, which was 

based on concentration since the flow volume in and out of the ESMS is the same: 

Where: 

RCE = Recovery efficiency (%)
 

Cinfluent = Concentration of lead in the influent stream composite sample
 

Ceffluent = Concentration of lead in the effluent stream composite sample 
 

i = {1, 2, ..., m} and m is the total number of sampling events
 

4.2.3 Sampling Methods 

Each treatment tank was subdivided into 18 4-foot grid-cells and each grid-cell was assigned a unique 

number from 1 to 18. The sampling program for each treatment tank or batch included collecting 

samples from 6 of the 18 grid-cells. A single sampling location near the center of six randomly selected 

grid-cells was used to collect the pre-treatment samples. The total treatment depth was 4 feet; therefore, 

2-foot core samples were collected from each 1-foot by 2-foot interval, or sub-cell, within each grid-cell. 

Each 2-foot core sample was fully homogenized in the field and then submitted to the laboratory for total 

lead analysis on a dry weight basis. The lead concentration measured in each sample represented the 

lead concentration for that sub-cell. 

Post-treatment samples were collected as close to the proximity of the pre-treatment sample locations as 

possible. This variance was due to health and safety risks caused by sampling too close to the edge of the 

treatment bin siding. In treatment bin 1, post-treatment sample 9 was collected from grid-cell 8, posttreatment sample 12 was collected from grid-cell 11, and post-treatment sample 15 was collected from 

grid-cell 12. In treatment bin 2, post-treatment sample 9 was collected from grid-cell 8, post-treatment 12 

was collected from grid cell 11, and post-treatment sample 15 was collected from grid-cell 12. In 

4-5
 
treatment bin 4, post-treatment sample 9 was collected from grid-cell 8, post-treatment sample 12 was 

collected from grid-cell 11, and post-treatment sample 15 was collected from grid-cell 12. 

The same homogenization procedures were conducted for the post-demonstration samples to obtain a 

representative sample for each sub-cell after the demonstration. The data were used to determine if posttreatment lead concentrations within the treatment zone were less than the regulatory threshold and to 

determine the removal efficiency for lead within the treatment zone. 

Separate post-treatment soil samples were collected from randomly-selected grid-cells within the 

treatment zone and analyzed for TCLP lead. These data were used to evaluate whether post-treatment 

TCLP lead concentrations meet RCRA landban regulatory criteria. 

Electroplated Metal Weighing and Sampling 

The total mass of metal electroplated out of the electrolyte solution was determined each time the 

electroplated metal was removed from the electrochemical cells for disposal. Prior to and after each 

batch treatment, each substrate was weighed and the weights recorded. After each batch treatment, the 

metal on each substrate was manually removed by EDA. The recovered lead was weighed directly. In 

general, 1 to 3 kilograms (kg) was recovered from each effort. Recovered material was kept in a tared 

container and allowed to dry for at least 18 hours before weighing. The lead scrapings were then placed 

in a container labeled with the date and the mass recovered. At the end of the project, all individual 

containers were emptied into lined, 5-gallons pails, and transported to a lead recycling facility. A sample 

of the metal removed from the substrates (approximately 5-10 grams) was collected and composited in a 

glass jar. The composite sample of metal was analyzed to determine lead purity, and the mass of lead 

recovered by the ESMS was calculated for Treatment Bin 4. The composite sample of lead for bins 1 

and 2 was not completed in the field. 

Electrolyte Solution Sampling 

A small volume of electrolyte solution was extracted from the electrolyte streams entering and exiting the 

ESMS on a 4-hour interval and composited over each batch run. Electrolyte solution was extracted from 

both streams using an in-line automatic sampling device. Volumes extracted from each stream were 

4-6
 
composited separately in two separate holding containers. For each batch run, a representative grab 

sample was collected from each electrolyte solution composite batch. Samples were submitted to the 

laboratory and analyzed for total lead. Recovery efficiencies were calculated for each sampling event 

and an averaged total for each treatment batch. 

4.2.3.1 Total Lead Analysis 

Total lead analysis was determined by ICP-AES analysis in accordance with EPA SW-846 method 

6010B. Soil samples and electrolyte solution samples were analyzed for lead only. 

4.2.4 Quality Assurance and Quality Control Program 

The overall QA objective for this evaluation was to produce well-documented data of known quality. 

Quality was measured by monitoring data precision and accuracy, completeness, representativeness, 

comparability, and reporting limits for the analytical methods. All laboratory data met the quality control 

criteria specified in the QAPP. 

4.2.4.1 Field Quality Control Program 

Field QC checks were collected to determine the quality of field activities, including sample collection, 

homogenization, handling, and shipment. In general, the QC checks assessed the representativeness of 

the samples and ensured that the degree to which the analytical data was representative of actual site 

conditions was known and documented. Field QC checks consisted of equipment blanks, field blanks, 

and field sample duplicates. 

4.2.4.2 Laboratory Quality Control Checks 

Laboratory QC checks were designed to determine analytical precision and accuracy, demonstrate the 

absence of interferences and contamination from glassware and reagents, and ensure the comparability of 

data. Laboratory QC checks consisted of laboratory control sample/ laboratory control sample duplicates 

(LCS/LCSD), method blank samples, matrix spike/matrix spike duplicates (MS/MSD) samples, and other 

checks specified in the methods section of the QAPP. The laboratory also completed the initial 

4-7
 
calibrations and continued throughout the process with calibration checks. Laboratory internal QC 

checks for critical parameters are summarized on a method-specific basis in the QAPP. 

4.2.4.3 Field and Laboratory Audits 

For this project, an internal technical systems audit (TSA) of field sampling and measurements systems 

was not conducted. The field audit conducted during the pre-treatment sampling event for the originally 

planned in-situ demonstration. Since the sampling and measurement methods for the proposed ex-situ 

demonstration are generally the same, the first field audit was considered adequate. The field audit was 

conducted by Dr. Greg Swanson, Tetra Tech’s SITE QA Manager. Recommendations made by Dr. 

Swanson based on audit observations were implemented during the sampling events, or by modification 

to the QAPP. No significant findings were identified in the field audit. 

Tetra Tech conducted laboratory audit of Severn Trent on May 10 and 11, 1999. Mr. John Schendel, the 

project chemist, performed the audit. No significant findings were identified. Nine minor observations 

were documented and discussed with laboratory staff. Appropriate corrective action was taken in 

response to all observations noted in the audit report. 

4.3 EVALUATION RESULTS AND CONCLUSIONS 

This section presents the performance data gathered for this evaluation by the testing methodology 

described above. The data analysis procedures and results associated with each of the project objectives 

are presented. 

4-8
 
Table 4-1: Treatment Bin 1 

SAMPLE DEPTH INTERVAL 

& ANALYSIS GRID-CELL NUMBER 

Depth Analysis & Results 4 6 11 14 16 

(bts) Pre Post Pre Post Pre Post* Pre Post Pre Post P

0 to 2 

Lead (mg/kg) 20,100 15,400 17,300 5,770 18,500 6,620 19,600 9,390 14,600 13,300 18TCLP (mg/L) 8.1 71.5 NA NA 7.6 35.0 NA NA NA NA Dup (mg/kg) NA NA NA NA NA NA NA NA NA NA moisture (%) 15.8 16.8 15.1 17.6 15.0 17.4 15.0 18.2 18.9 21.4 1Lead Reduction 4,700 11,530 11,880 10,210 1,300 Removal Efficiency 23.4 66.6 64.2 52.1 8.9 

2 to 4 

Lead (mg/kg) 17,000 10,800 19,200 9,540 17,000 8,990 15,400 10,100 17,600 9,740 19TCLP (mg/L) 7.4 73.8 NA NA 7.8 76.8 NA NA NA NA Dup (mg/kg) NA NA 17,500 8,990 NA NA 19,000 8,930 NA NA moisture (%) 13.9 17.7 16.7 18.8 17.1 16.6 16.2 16.5 21.8 20.8 1Lead Reduction 6,200 9,660 8,010 5,300 7,860 Removal Efficiency 36.5 50.3 47.1 34.4 44.7 

Notes: bts Below top of surface mg/kg Milligram per kilogram mg/L milligram per liter TCLP Toxic Characteristics Leaching Procedure Dup Duplicate Pre Pre-treatment sample Post Post-treatment sample NA Not analyzed * Post Treatment sample 12 was taken from grid-cell 11 due to safety issues. 

4-9
Table 4-2: Treatment Bin 2 

SAMPLE DEPTH INTERVAL 

& ANALYSIS GRID-CELL NUMBER* 

Depth Analysis & Results 1 2 8 14 12 

(bts) Pre Post Pre Post Pre Post* Pre Post Pre Post* Pre 

0 to 2 

Lead (mg/kg) 18500 3,720 19,600 9,460 19,600 19,200 23,700 41,500 13,600 15,400 12,100 TCLP (mg/L) 7.5 25.1 NA NA 8.2 78.9 NA NA NA NA 8.0 Dup (mg/kg) NA NA NA NA NA NA NA NA NA NA NA moisture (%) 15.2 18.0 11.8 20.2 13.6 21.8 15.8 7.8 10.8 13.6 12.7 Lead Reduction 14,780 10,140 400 -17,800 -1,800 1Removal Efficiency 79.9 51.7 2.0 -75.1 -13.2 

2 to 4 

Lead (mg/kg) 23300 5,940 36,500 7,060 26,800 12,600 26,500 7,020 37,400 10,900 12,600 TCLP (mg/L) 7.3 23.8 NA NA 6.8 86.4 NA NA NA NA 9.4 Dup (mg/kg) NA NA 32,800 4,350 NA NA 27,200 8,110 NA NA NA moisture (%) 12.6 20.8 16.8 21.3 17.5 31.2 16.2 8.0 16.7 14.5 11.7 Lead Reduction 17,360 29,440 14,200 19,480 26,500 3Removal Efficiency 74.5 80.7 53.0 73.5 70.9 2

Notes: bts Below top of surface mg/kg Milligram per kilogram mg/L milligram per liter TCLP Toxic Characteristics Leaching Procedure Dup Duplicate Pre Pre-treatment sample Post Post-treatment sample NA Not analyzed 

* Post treatment sample 9 was taken from grid-cell 8 and Post Treatment sample 15 was taken from grid-cell 12 due to safety issues. 

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Table 4-3: Treatment Bin 4 

SAMPLE DEPTH INTERVAL 

& ANALYSIS GRID-CELL NUMBER 

Depth Analysis & Results 1 9 12 14 15 1

(bts) Pre Post Pre Post Pre Post* Pre Post Pre Post Pre 

0 to 2 

Lead (mg/kg) 8270 2,080 53,900 2,620 21,100 6,390 18,400 3,630 21,000 2,520 23,100 TCLP (mg/L) 5.4 1.6 NA NA 9.3 2.9 NA NA NA NA 13.9 Dup (mg/kg) NA NA NA NA NA NA NA NA NA NA NA moisture (%) 6.7 12.7 17.0 11.2 11.2 13.7 11.9 13.6 13.1 13.3 12.3 Lead Reduction 6,190 51,280 14,710 14,770 18,480 21Removal Efficiency 74.8 95.1 69.7 80.3 88.0 9

2 to 4 

Lead (mg/kg) 24300 5,870 82,300 12,100 43,100 9,070 35,100 16,200 23,300 1,880 30,500 TCLP (mg/L) 10.6 2.3 NA NA 15.3 13.5 NA NA NA NA 13.1 Dup (mg/kg) NA NA 42,500 8,180 NA NA 45,600 7,580 NA NA NA moisture (%) 12.2 17.9 16.3 21.4 17.4 16.6 15.1 15.8 13.3 9.2 14.9 Lead Reduction 18,430 70,200 34,030 18,900 21,420 26Removal Efficiency 75.8 85.3 79.0 53.8 91.9 8

Notes: bts Below top of surface mg/kg Milligram per kilogram mg/L milligram per liter TCLP Toxic Characteristics Leaching Procedure Dup Duplicate Pre Pre-treatment sample Post Post-treatment sample NA Not analyzed * Post Treatment sample 15 was taken from grid-cell 12 due to safety issues. 

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4.3.1	 Primary Objectives 

To assess all of the primary objectives, 12 pre-treatment and post-treatment soil samples, from each of 

the three treatment bins, were collected and analyzed by EPA Method 6010B for total lead and TCLP. 

Details of the primary objective relating to the soil lead treatment efficiency are described below. 

P1	 Determine if the technology is able to reduce soil lead concentrations to less than the regulatory 

threshold limit of 2,000 mg/kg. 

The primary objective was address by comparing the post-treatment soil samples for Total Lead to the 

regulatory threshold of 2,000 mg/kg. Twelve post-demonstration samples were collected from within 

each treatment batch. In Treatment Bin 1, post-treatment soil samples ranged from 5,770 mg/kg to 

15,400 mg/kg. In Treatment Bin 2, post-treatment soil samples ranged from 3,720 to 41,500 mg/kg. In 

Treatment Bin 4, post-treatment soil samples ranged from 1,880 to 16,200 mg/kg (see Table 4-4). One of 

the post-treatment soil samples collected from the Treatment Bin 4 met the regulatory threshold. The 

average post-soil lead concentration for each bin was 17,285 mg/kg for Bin 1, 22,517 mg/kg for Bin 2, 

and 5,672 mg/kg for Bin 4. 

Because the treatment goal was not achieved for 17 of the 18 post-treatment grid-cells, the primary 

objective was not met. 

Table 4-4Results for Lead using EPA Method 6010B 

Treatment Bin 

Number 

Post-Treatment Range 

(mg/kg) 

Grid-cells Meeting 

Regulatory Threshold 

(2,000 mg/kg) 

1* 5,770 to 15,400 0 of 6 

2* 3,720 to 41,500 0 of 6 

4** 1,880 to 16,200 1 of 6 

Notes:	 * Bin 1 and 2 was flushed with an EDTA solution originally mixed at 0.1M 

** Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution. 

4-12 
P2	 Determine the removal efficiency of the EDA technology for lead within the treatment tank. 

The second primary objective was to determine the treatment efficiency of the EDA lead recovery 

technology for lead in the soil samples. The EDA lead recovery treatment process removed an average of 

59 percent lead for all three bins. Bins 1 and 2 were treated with an EDTA solution with a 0.1M. Bin 4 

was treated with an EDTA solution with an increased molarity of 0.2. In Bin 4, nine cycles were made, 

an increased amount of flush cycles. The average removal efficiency was lower in Bins 1 and 2, with 

percentages of 44.5 and 51.6, respectively. The average removal efficiency for treatment Bin 4 was 81.1 

percent (See Table 4-5). 

Table 4-5 Average Removal Efficiencies 

Treatment Bin 

Number 

Pre-Treatment Range 

(mg/kg) 

Post-Treatment 

Range (mg/kg) 

Average Removal 

Efficiency (%) 

1* 14,600 to 20,100 5,770 to 15,400 44.5 

2* 12,100 to 37,400 3,720 to 41,500 51.6 

4** 8,270 to 82,300 1,880 to 16,200 81.1 

Notes:	 * Bin 1 and 2 was flushed with an EDTA solution originally mixed at 0.1M 

** Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution. 

P3	 Determine whether the post-demonstration soil meets the RCRA landban standards for TCLP 

lead concentrations. 

To determine whether the TCLP lead concentrations in the post-demonstration samples meet RCRA 

landban standard, the TCLP extract lead concentration in each of the four post-demonstration samples 

from each batch were compared to the regulatory limit of 5.0 mg/L. Of 18 cells in the 3 treatment bins, 

only 5 of 6 grids from Bin 4 met the RCRA landban standards for lead by TCLP analysis. Bin 4 was 

flushed with water extensively (600 gallons) in comparison to procedures used for the other two bins. 

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Table 4-6 Results for Lead using TCLP 

Treatment Bin 

Number 

Pre-Treatment Range 

(mg/L) 

Post-Treatment 

Range 

(mg/L) 

Grid-cells Meeting 

TCLP Threshold 

(5 mg/L) 

1* 7.4 - 9.8 35 - 105 0 of 6 

2* 6.8 - 9.4 23.8 - 117 0 of 6 

4** 5.4 - 15.3 0.6 - 13.5 5 of 6 

Notes:	 * Bin 1 and 2 was flushed with an EDTA solution originally mixed at 0.1M 

** Bin 4 was extensively flushed with water, and a 0.2M concentration of EDTA solution. 

4.3.2	 Secondary Objectives 

Three secondary objectives were established to evaluate the lead recovery system. The secondary 

objectives are described below. 

S1	 Evaluate the mass of lead recovered by the ESMS and estimate the recovery efficiency of the 

ESMS. 

Due to missing composite metal samples from Treatment Bins 1 and 2, the purity of lead is unknown. 

Thus, the mass of lead recovered for these bins could not be calculated. The mass of lead recovered by 

the ESMS was 12.8 kg for Treatment Bin 4 (see Table 4-7). 

Table 4-7 Mass of Solid Lead Recovered by the ESMS 

Treatment Bin 

Number 

Total Weight of Metal 

Removed from the 

ESMS (kg) 

Purity of Lead 

(mg/kg) 

Mass of Solid Lead 

Plated Out from the 

ESMS (kg) 

1 2.1 --- NA 

2 58 --- NA 

4 75.2 17%J 12.8 

Notes:	 J Method blan k contamin ation. The asso ciated method blank conta ins the target analyte at a report able level 

kg	 kilogram mg/kg	 milligram per kilogram —	 missing sample data 

NA	 not available 

The recovery efficiency of the ESMS system has been calculated for each sampling event, during the 

different flushing cycles (See Table 4-8). 

4-14 
Table 4-8 The Recovery Efficiency of the ESMS 

Treatment 

Bin 

Number 

Number 

of 

Cycles 

Electrolyte 

Solution 

Enterin g Bin

 (μg/L) 

Concentrati 

on of Lead 

in the 

Influent 

Stream 

(μg/L) 

Conc entratio 

n of Lea d in 

the Effluent 

Stream 

(μg/L) 

Recovery 

Efficiency 

(%) 

Average 

Total 

Recovery 

Efficiency 

(%) 

1 1 159,000 179,000 154,000 14.0 14.0 

2 1 197,000 1,390,000 1,290,000 7.2 

2 1,310,000 1,250,000 1,190,000 4.8 

3 402,000 432,000 509,000 -17.8 

4 991,000 873,000 1,150,000 -31.7 

5 124,000 261,000 L 422,000 L -61.7 

5 440,000 L 344,000 L 21.8 

5 532,000 L 390,000 L 26.7 -7.2 

4 1 20,100 L 307,000 388,000 -26.4 

1 415,000 286,000 31.1 

1 914,000 265,000 71.0 

2 269,000 

2 340,000 262,000 369,000 -40.8 

3 8,640,000 8,580,000 0.7 

3 7,630,000 7,550,000 1.1 

3 9,050,000 8,350,000 7.7 

3 7,500,000 7,360,000 1.9 

3 7,350,000 7,300,000 0.7 

3 6,290,000 6,320,000 -0.5 

3 5,670,000 5,590,000 1.4 

3 4,960,000 4,890,000 1.4 

3 6,320,000 7,700,000 -21.8 

4 4,320,000 

4-15
 
Table 4-8 The Recovery Efficiency of the ESMS 

Treatment 

Bin 

Number 

Number 

of 

Cycles 

Electrolyte 

Solution 

Enterin g Bin

 (μg/L) 

Concentrati 

on of Lead 

in the 

Influent 

Stream 

(μg/L) 

Conc entratio 

n of Lea d in 

the Effluent 

Stream 

(μg/L) 

Recovery 

Efficiency 

(%) 

Average 

Total 

Recovery 

Efficiency 

(%) 

4 4 4,310,000 6,120,000 5,950,000 2.8 

4 5,670,000 5,120,000 9.7 

4 4,510,000 4,550,000 -1.0 

4 4,080,000 3,680,000 9.8 

4 3,200,000 3,120,000 2.5 

5 2,990,000 5,110,000 5,470,000 -7.1 

5 4,690,000 4,370,000 6.8 

5 582,000 J 664,000 J -14.1 

5 804,000 J 857,000 J -6.6 

5 676,000 J 580,000 J 14.2 

5 772,000 J 911,000 J -18.0 

6 860,000 J 

6 1,230,000 J 659,000 J 453,000 J 31.3 

6 646,000 J 526,000 J 18.6 

6 497,000 J 612,000 J -23.1 

6 527,000 J 665,000 J -26.2 

7 514,000 J 

7 514,000 J 818,000 J 911,000 J -11.4 

8 603,000 J 525,000 J 12.9 

8 277,000 J 805,000 J -190.6 

9 579,000 J 

9 706,000 J 530,000 J 154,000 J 70.9 

9 998,000 J 847,000 J 15.1 

4-16
 
Table 4-8 The Recovery Efficiency of the ESMS 

Treatment 

Bin 

Number 

Number 

of 

Cycles 

Electrolyte 

Solution 

Enterin g Bin

 (μg/L) 

Concentrati 

on of Lead 

in the 

Influent 

Stream 

(μg/L) 

Conc entratio 

n of Lea d in 

the Effluent 

Stream 

(μg/L) 

Recovery 

Efficiency 

(%) 

Average 

Total 

Recovery 

Efficiency 

(%) 

4 9 743,000 J 692,000 J 6.9 

9 795,000 J 711,000 J 10.6 

10 439,000 J 

10 562,000 J 179,000 J 

10 117,000 J 239,000 J -104.3 

10 42,800 J 48,500 J -13.3 

10 37,200 J 214,000 J -475.3 

10 91,400 J 53,400 J 41.6 -15.6 

Notes: L Serial dilution of a digestate in the analytical batch indicates that physical and chemical interferences are present 

μg/L micrograms per li ter 

J method blank contaminat ion. The associ ated method b lank contai ns the target an alyte at a reportab le level 

S2 Document specific EDA system operation and maintenance parameters. 

During the technology demonstration, the vendor collected and recorded data to monitor the proper 

operation and maintenance parameters of the technology. The operating parameters are those parameters 

that can be varied during the treatment process to achieve desired results and treatment goals. EDA 

claims the ETU system is able to run reliably with one daily visit requiring about 2 hours on-site. The 

principal factor affecting the lead recovery system performance is the rate lead is plated out of the soil 

and the maximum current used without causing other limitations to the system. 

A normal amount or maintenance and repair activities of the system were performed during the SITE 

demonstration, requiring approximately 4 hours weekly. Spare parts included: replacement pumps, 

solenoid valves, motor valves, signal conditioners, and SSRs. Between one or two of each item was 

necessary to have on-site to minimize the replacement time to the system. Minor leakages in plumbing 

systems were expected and encountered, requiring small amounts of time for repair. 

4-17
 
Maintenance of a full-scale system is estimated to require 8 hours weekly. This estimate is based on the 

assumption that the design of parts of the system that caused frequent shutdowns during the SITE 

demonstration, such as bladders and float switches, would be modified to eliminate problems. 

S3 Estimate capital and operating costs for constructing a full-scale EDA system. 

A detailed discussion of costs is included in Section 3.0 of this report. 

4.3.3 Data Quality 

A data quality review was conducted by Tetra Tech to evaluate the field and laboratory QC results, 

evaluate the implications of QC data on the overall data quality, document data use limitations for data 

users, and remove unusable values from the demonstration data sets. The results of this review were 

used to produce the final data sets used to assess the treatment technology and to draw conclusions. The 

QC data were evaluated with respect to the QA objectives defined in the project quality assurance project 

plan (QAPP [Tetra Tech 2001]). 

The analytical data for the samples collected during the SITE demonstration were reviewed to ensure that 

they are scientifically valid, defensible, and comparable. A data quality review was conducted using both 

field QC samples and laboratory QC samples. The field QC samples included field blanks, rinseate 

blanks, trip blanks, MS/MSD, and sample duplicates. Laboratory QC checks included laboratory blanks, 

surrogate spikes, and LCS/LCSD. Initial and continuing calibration results were also reviewed to assure 

the quality of the data and that proper procedures were used. The review focused on assessing the 

precision, accuracy, completeness, representativeness, and comparability of the data. In addition to the 

above QC checks, reviews of sample chains of custody, holding times, and critical parameter 

identification and quantification were performed. All laboratory data met the quality control criteria 

specified in the QAPP. Please refer to the Technology Evaluation Report for data tables that present 

analytical results for field QC samples and MS/MSD results. 

4-18
 
4.3.4	 Conclusions 

The primary evaluation objectives were to determine whether the lead recovery technology removed lead 

from soil, and if so, how efficiently they were moved. 

•	 Approximately six percent of the total post-treatment soil samples met the regulatory 

threshold lead concentration of 2,000 mg/kg or less (1 of 18 post treatment samples). 

•	 The average lead removal efficiency was 59 percent for all three bins. Due to variations 

in the treatment process for Bin 4, which included changing the concentration of the 

EDTA solution and extensively flushing the soil with water, the removal efficiency was 

81 percent. 

•	 TCLP lead concentrations did not meet the RCRA landban standard of the 5.0 mg/L for 

samples collected from Bin 1 and Bin 2 due to adsorption of the Pb-EDTA2- complex to 

soil particles during infiltration. Extensive flushing of water in Bin 4 effectively 

removed sorbed solution, which resulted in a reduction in TCLP lead concentrations and 

attainment of the RCRA landban standard. 

4-19
 
5.0 TECHNOLOGY STATUS
 

The EDA lead recovery system SITE demonstration was modified several times over the history of the 

project. Data obtained from the demonstration allowed EDA to continue the engineering development 

for electrokinetic remediaiton. This will enhance the speed of the EDA lead recovery system. EDA has 

a goal of treating one ton of soil per hour. 

Site information pertinent to electrokinetic remediation includes the following: 

General Information 

1. Contaminated area size and depth 

2. Utilities layout 

3. Soil type and moisture content profile 

Chemical information 

1. Contaminant type 

2. Contaminant concentrations and distribution 

3. Soil permeability 

Other information 

1. Maximum amount of electrical current 

2. Surface area of electrode plates
 

At this time, the recovery process is not available on the open market. 
 

5-1
 
6.0 REFERENCES 

Acar, Y.B.; Alshawabkeb, A.; Gale, R.J. Waste Management, 13, 141, 1993 

Acar, Y.B.; Alshawabkeb, A.; Hamed, J.; Gale, R.J., “Cd(II) Removal From Saturated Kaolinite by 

Application of Electrical Current,” Geotechnique, 44(3), pp 239-254, 1994. 

ECHOS, Environmental Cost Handling Options and Solutions. 2001. “Environmental Remediation Cost 

Data - Assemblies.” R.S. Means Company and Talisman Partners, Ltd. 7th Annual Edition. 

ECHOS, Environmental Cost Handling Options and Solutions. 2001. “Environmental Remediation Cost 

Data - Unit Price.” R.S. Means Company and Talisman Partners, Ltd. 7th Annual Edition. 

Freeze, R., A., and J. A., Cherry. 1979. Water. Prentise-Hall, Inc. p. 60. 

Geokinetics International, Inc. (GII). 1998a. “Bench Scale Electrokinetics Remediation Study. The 

Electrokinetic Removal of Lead from the Soil of Building 394 Battery Shop at Pearl Harbor”. 

Produced for Ogden Environmental and Energy Services Co., Inc. April. 

GII. 1998b. Personal Communication between Dr. Steven Clarke, President of GII, and Bob Breglio, 

Tetra Tech. 

GII. 2002. Personal Communication between Scott Stevenson of GII, and Lauren Loberg of Tetra Tech. 

Gray, D.H., and Mitchell, J.K., “Fundamental Aspects of Electro-Osmosis in Soil,” Journal of the Soil 

Mechanics and Fundamental Division, ASCE, SM 6, pp. 206-236, 1967. 

Hamed, J.; Acar, Y.B.; Gale, R.J., “Pb(II) Removal from Kaolinite by Electrokinetics,” Journal of 

Geotechnical Engineering Division, ASCE, Vol. 117, No. 2, pp 241-271, 1991. 

Ogden Environmental and Energy Services Company, Inc. (Ogden). 1995. “Remedial Investigation 

Report for Building 394, Pearl Harbor Naval Shipyard, Pearl Harbor, Hawaii”. Contract No. 

N62742-90-D-0019, Contract Task Order (CTO) No. 0045. September. 

Ogden. 1996. “Engineering Evaluation/Cost Analysis Report for Building 394 Battery Shop, U.S. 

Naval Shipyard, Pearl Harbor, Hawaii.” Contract No. N62742-90-D-0019, CTO No. 018. 

February. 

Pamuchu, S., and Whittle, J.K., “Electrochemical removal of Selected Heavy Metals From Soil,” 

Environmental Progress, AIChE, Vol. 11, No3, pp 241-250, 1992. 

Renaud, P.C.; Prostein, R.F., PCH, Physiochemical. Hydrodynamics. 1987, 9, 345. 

Tetra Tech EM Inc. (Tetra Tech). 1997a. “Results of Characterization Sampling at the Building 394 Site 

for the SITE Demonstration of the Geokinetics International Inc. Electrokinetics Soil 

Remediation Technology.” Contract No. 68-C5-0037, Work Assignment (WA) No. 0-27. 

September. 
Tetra Tech. 1998. “Results of the Geotechnical Sampling at the Building 394 Site for the SITE 

Demonstration of the Geokinetics International, Inc. Electrokinetics Soil Remediation 

Technology.” Contract No. 68-C5-0037, Work Assignment No. 0-27. November. 

Tetra Tech. 1999. “Health and Safety Plan; Geokinetics International, Inc. Electrokinetics 

Technology Evaluation at the Building 394 Battery Shop, Pearl Harbor Naval Shipyard, 

Honolulu, Hawaii.” Contract No. 68-C5-0037, Work Assignment No. 0-27. January. 

U.S. Environmental Protection Agency (EPA). 1996. 	Test Methods for Evaluating Solid Waste, 

Volumes IA-IC: Laboratory Manual,Physical/Chemical Methods; and Volume II: Field Manual, 

Physical/Chemical Methods, SW-846, Third Edition, Revision IV. Office of Solid Waste and 

Emergency Response, Washington, D.C. 

EPA. 1998. Methods for Chemical Analysis of Water and Wastes. EPA-600/4-79-020 and 

Subsequent EPA-600/4 Technical Additions. Environmental Monitoring and Support 

Laboratory, Cincinnati, Ohio. 

EPA. 1998a. Guidance for Data Quality Assessment. EPA QA/G-9, EPA/600/R-96/084. January. 

EPA. 1991. Preparation Aid for the Development of Category II Quality Assurance Project Plans. 

Office of Research and Development. EPA/600/8-91/004 
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