The DNAPL Remediation 

Challenge: Is There a Case 

for Source Depletion?

DNAPL

Source

Zone

Dissolved

Plume

Control Plane Compliance Plane

Dissolved

Plume

Depleted

DNAPL

Source

Zone
EPA/600/R-03/143

December 2003

The DNAPL Remediation Challenge:

Is There a Case for Source Depletion?

by 

Expert Panel on DNAPL Remediation

Michael C. Kavanaugh, Co-Chair

Malcolm Pirnie, Inc.

and

P. Suresh C. Rao, Co-Chair

Purdue University

Other Panel Members

 Linda Abriola Charles Newell 

 University of Michigan Groundwater Services, Inc.

John Cherry Thomas Sale 

 University of Waterloo Colorado State University

 Georgia Destouni Stephen Shoemaker

Royal Institute of Technology (KTH), Sweden DuPont

Ronald Falta Robert Siegrist

Clemson University Colorado School of Mines

 David Major Georg Teutsch

 Geosyntec University of Tuebingen, Germany

James Mercer Kent Udell

GeoTrans, Inc. University of California, Berkeley

EPA Contract No. 68-C-02-092

Project Offi cer

David S. Burden, Ph.D.

Ground Water and Ecosystems Restoration Division

National Risk Management Research Laboratory

Ada, Oklahoma 74820

National Risk Management Research Laboratory

Offi ce of Research and Development

U.S. Environmental Protection Agency

Cincinnati, Ohio 45268
ii

Notice

The U.S. Environmental Protection Agency through its Offi ce of Research and Development funded and managed the research described here under EPA Contract No. 

68-C-02-092 to Dynamac Corporation, Ada, Oklahoma. It has been subjected to the 

Agency’s peer and administrative review and has been approved for publication as an 

EPA document. Mention of trade names or commercial products does not constitute 

endorsement or recommendation for use.

All research projects making conclusions or recommendations based on environmental data and funded by the U.S. Environmental Protection Agency are required to 

participate in the Agency Quality Assurance Program. This project did not involve the 

collection or use of environmental data and, as such, did not require a Quality Assurance Plan.
iii

Foreword

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

resources. Under a mandate of national environmental laws, the Agency strives to formulate and implement actions 

leading to a compatible balance between human activities and the ability of natural systems to support and nurture life. To 

meet this mandate, EPA’s research program is providing data and technical support for solving environmental problems 

today and building a science knowledge base necessary to manage our ecological resources wisely, understand how 

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

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

and management approaches for preventing and reducing risks from pollution that threatens human health and the 

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

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

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

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

that reduce the cost of compliance and to anticipate emerging problems. NRMRL’s research provides solutions to 

environmental problems by: developing and promoting technologies that protect and improve the environment; advancing 

scientifi c and engineering information to support regulatory and policy decisions; and providing the technical support 

and information transfer to ensure implementation of environmental regulations and strategies at the national, state, 

and community levels.

At many hazardous waste sites contaminants reside in the subsurface as separate dense non-aqueous phase liquids 

(DNAPL). These DNAPL serve as persistent sources of dissolved phase contamination and are a major impediment 

to successful and cost-effective cleanup of sites. Commonly used pump-and-treat remediation systems have not been 

effective in removing DNAPL from these subsurface source areas or in restoring down-gradient contaminated groundwater 

to desired levels of cleanliness. However, fi eld-scale research has demonstrated that a high percentage of the DNAPL 

mass can be removed by implementing aggressive in-situ technologies such as thermal or chemical fl ooding. These 

studies have shown that while a signifi cant fraction of the DNAPL mass can be effi ciently removed in a short period, the 

effi ciency of DNAPL extraction often decays exponentially with increasing mass removal. As a result, there is currently 

no consensus in the academic, technical and regulatory communities on the ecological or environmental benefi ts of 

DNAPL source treatment or on the appropriate metrics for quantifying these benefi ts. To provide technical guidance 

regarding these critical environmental issues the US EPA convened a panel of national and international scientists and 

practitioners to conduct a critical, independent review of DNAPL remediation issues. This document contains the fi ndings 

and recommendations of the panel. This report does not necessarily represent Agency views or policies and should 

not be interpreted as such. However, the information may be useful in developing appropriate research strategies and 

plans for solving this important environmental problem.

 

Stephen G. Schmelling, Director

 Ground Water and Ecosystems Restoration Division

 National Risk Management Research Laboratory
iv
v

Contents

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

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

Acknowledgments ......................................................................................................................... ix

Executive Summary ....................................................................................................................... x

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

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

1.2 Expert Panel Formation ...................................................................................................2

1.3 Organization of the Report ..............................................................................................3

2.0 Problem Description .................................................................................................................5

2.1 DNAPLs as a Source of Groundwater Contamination .....................................................5

2.2 Magnitude of the Problem .................................................................................................5

2.3 Regulatory Framework ......................................................................................................6

2.4 Technical Framework ........................................................................................................7

3.0 Questions ................................................................................................................................11

3.1 Question 1: What are the Potential Benefi ts and Potential Adverse Impacts 

 of DNAPL Source Depletion as a Remediation Strategy? ............................................11

3.1.1 Potential Benefi ts of Partial Source Depletion ......................................................11

3.1.2 Potential Adverse Impacts from Use of Aggressive Technologies for 

 Source Depletion ..................................................................................................14

3.1.3 Summary ..............................................................................................................15

3.2 Question 2: What are the Appropriate Performance Metrics for Assessment 

 of DNAPL Source Depletion Technologies? ..................................................................16

3.2.1 Type I Metrics ........................................................................................................16

3.2.2 Type II Metrics .......................................................................................................17

3.2.3 Type III Metrics ......................................................................................................18

3.2.4 Summary ..............................................................................................................18

3.3 Question 3: Are Available Technologies Adequate for DNAPL Source 

 Characterization to Select and Evaluate Depletion Options? ........................................18

3.3.1 Innovations in Site Characterization Approaches .................................................19

3.3.2 Innovations in Site Characterization Tools ............................................................19

3.3.3 Summary ..............................................................................................................23

3.4 Question 4: What Performance can be Anticipated from DNAPL Source-Zone 

Depletion Technologies? ........................................................................................................23

3.4.1 Status of Development and Deployment of DNAPL Source-Zone 

 Depletion Technologies .........................................................................................24

3.4.2 Anticipated Effectiveness of DNAPL Source-Zone Depletion Technologies .........29

3.4.3 Cost of DNAPL Source Depletion Technologies ...................................................31

3.4.4 Summary ..............................................................................................................32

3.5 Question 5: Are Currently Available Tools Adequate to Predict the 

 Performance of Source Depletion Options? ..................................................................32

3.5.1 Numerical Models: Deterministic Approaches ......................................................32

3.5.2 Numerical/Analytical Models: Stochastic Approaches ..........................................33

3.5.3 Guidance Documents ...........................................................................................34
vi

3.5.4 Case Studies and Pilot Tests ................................................................................34

3.5.5 Limitations of Existing Tools ..................................................................................35

3.5.6 Summary ..............................................................................................................36

3.6 Question 6: What are the Factors Limiting the Effective and Appropriate 

 Application of Source Depletion Technologies? ............................................................36

3.6.1 Defi nition of Remedial Objectives Requiring Restoration in 

 Source Zones .......................................................................................................36

3.6.2 Uncertainty in Predicting Likelihood of Success at a Given Cost ..........................36

3.6.3 Lack of Well-Documented Successes ..................................................................37

3.6.4 Availability and Cost of Insurance .........................................................................37

3.6.5 Limited Number of Qualifi ed Vendors ...................................................................37

3.7 Question 7: How Should Decisions be Made Whether to Undertake 

 DNAPL Source Depletion? ............................................................................................38

4.0 Knowledge Gaps and Research Needs ................................................................................41

4.1 Introduction ...................................................................................................................41

4.2 Performance Metrics ......................................................................................................41

4.2.1 Knowledge Gaps ...................................................................................................41

4.2.2 Research Needs ....................................................................................................41

4.3 Site Characterization .....................................................................................................41

4.3.1 Knowledge Gaps ...................................................................................................41

4.3.2 Research Needs ...................................................................................................41

4.4 DNAPL Source-Zone Depletion Technologies ...............................................................42

4.4.1 Knowledge Gaps ...................................................................................................42

4.4.2 Research Needs ...................................................................................................42

4.5 Performance Prediction Tools ........................................................................................42

4.5.1 Knowledge Gaps ...................................................................................................42

4.5.2 Research Needs ...................................................................................................43

4.6 Decision Analysis Tools .................................................................................................43

4.6.1 Knowledge Gaps ...................................................................................................43

4.6.2 Research Needs ...................................................................................................43

5.0 Conclusions and Recommendations .....................................................................................45

5.1 Conclusions ...................................................................................................................45

5.2 Recommendations .........................................................................................................47

6.0 List of References and Bibliography ......................................................................................49

Appendices

A Case Studies .................................................................................................................59

B Biosketches of Panel Members .....................................................................................97

C Workshop Agenda – Dallas, TX ...................................................................................104

D List of Attendees – Dallas, TX .....................................................................................107
vii

Figures

2.1 Schematic representation of an unconsolidated heterogeneous 

 geologic setting ..............................................................................................................8

2.2 Schematic representation of fractured media site contamination DNAPL ....................9

3.1 Schematic representation of a control plane, and a defi nition of the 

 source strength (Md) and local values for groundwater fl ux (qi), and 

 contaminant fl ux (Ji

) .....................................................................................................13

3.2 Decision chart: Benefi ts from full-scale applications of source depletion ...................39

3.3 Schematic of quantitative decision framework .............................................................40
viii

Tables

1-1 Panel Participants ...........................................................................................................2

1-2 Questions ........................................................................................................................3

3-1 Advantages and Limitations of Various Site Characterization Technologies .................21

3-2 Summary of DNAPL Source Depletion Technologies Currently Available or 

 Under Development .....................................................................................................25

3-3 Status of Development and Deployment of DNAPL Depletion Technologies ..............29

3-4 Potential Applicability of Various Source Depletion Technologies in Two 

 Generic Hydrogeologic Situations ................................................................................30

3-5 Net Present Value of Annual O&M Costs for Pump-and-Treat Technologies ..............31
ix

Acknowledgments

This document was a joint effort of the Expert Panel on DNAPL Source Remediation consisting of the following members 

appointed by U.S. EPA.

Expert Panel on DNAPL Remediation 

Michael C. Kavanaugh, Co-Chair, Malcolm Pirnie, Inc.

and

P. Suresh C. Rao, Co-Chair, Purdue University

Other Panel Members

 Linda Abriola Charles Newell 

 University of Michigan Groundwater Services, Inc.

 John Cherry Thomas Sale 

 University of Waterloo Colorado State University

 Georgia Destouni Stephen Shoemaker

 Stockholm University, Sweden DuPont

 Ronald Falta Robert Siegrist

 Clemson University Colorado School of Mines

 David Major Georg Teutsch

 Geosyntec University of Tuebingen, Germany

 James Mercer Kent Udell

 GeoTrans, Inc. University of California, Berkeley

The Panel is indebted to Drs. Lynn Wood and Robert Puls at the U.S. EPA National Risk Management Research Laboratory, 

Ada, OK, and Mr. James Cummings, U.S. EPA Technology Innovation Offi ce, Washington, DC, for their leadership in 

recognizing the need, and continued support for the Panel’s efforts. In addition, their understanding and patience as 

the Panel’s deliberations progressed somewhat slowly at times, are especially appreciated by the Panel Co-Chairs.

The Panel members also acknowledge the administrative support provided by Dynamac Corporation, Ada, Oklahoma. 

Their efforts to make sure that the Dallas Workshop and the Panel meeting in Orlando were successful are appreciated. 

We wish also to acknowledge the word processing support of Ms. Rosario Varrella from Malcolm Pirnie, Inc.

The Panel also appreciates the enthusiastic participation and active engagement in discussions by a large number of 

colleagues at the Dallas workshop. The insights gained and input provided stimulated and informed our discussions, 

and infl uenced the contents of this report.

The Panel also wishes to acknowledge the thoughtful and constructive criticisms provided by reviewers selected by 

the U.S. EPA. While the Panel was commissioned and funded by the U.S. EPA, who also defi ned its general charge, 

the views expressed in this report refl ect only the views of the Panel members, and not the offi cial views of EPA or any 

other government agency, or Dynamac Corporation.

The Panel Co-Chairs extend their thanks to the Panel members for engaging in spirited debates about contentious issues, 

for providing insights based on their considerable experience and expertise, and for contribution and review of written 

material that formed the basis for the fi nal report. The Panel Co-Chairs served as the editors for the fi nal version, and 

made an attempt to represent divergent views on some topics when consensus could not be reached.
x

Executive Summary

Introduction

Releases of Dense Non-Aqueous Phase Liquids (DNAPLs) at a large number of public and private sector sites in the 

United States pose signifi cant challenges in site remediation and long-term site management. Extensive contamination 

of groundwater occurs as a result of signifi cant dissolved plumes generated from these DNAPL source zones that 

vary in size and complexity depending on site characteristics and DNAPL properties and distribution. Risk and liability 

management, consistent with regulatory compliance requirements, could involve remediation of the source zone as well 

as management of the dissolved plume. The source zone is defi ned here as the groundwater region (volume) in which 

DNAPL is present as a separate phase, either as randomly distributed sub-zones at residual saturations or “pools” of 

accumulation above confi ning units and includes the volume of the aquifer that has had contact with free-phase DNAPL 

at one time, but where all of the DNAPL mass is now present only in the dissolved or sorbed phases or diffused into 

the matrix in fractured systems. Over the past two decades, innovations in site characterization and remediation 

technologies have been developed and deployed at DNAPL sites. Several in-situ technologies are available which can 

achieve substantial DNAPL source depletion either by extraction or destruction. However, because of the risk of failure 

in achieving certain regulatory targets after implementing a source-depletion technology (e.g., MCLs in the source 

zone), combined with uncertainties in site characterization (i.e., the location and amount of DNAPL in groundwater at 

a site), in forecasting potential benefi ts and adverse impacts of partial source depletion, in prediction of life cycle costs, 

and uncertainties regarding the acceptability of alternative clean-up levels, many site owners have been reluctant to 

undertake aggressive source-depletion technologies. Thus, at the majority of DNAPL sites, containment of the source 

zone and/or management of the dissolved plume for cost-effective risk/liability reduction and regulatory compliance 

have been the dominant strategies of choice. 

Charge to the Panel

As the continued annual costs and uncertainties associated with long-term management of DNAPL sites become more 

apparent, a reassessment of the factors controlling decisions on whether to implement DNAPL source depletion actions is 

needed. The long-term cost, reliability, and institutional requirements of the containment strategy for DNAPL source zones 

are thus topics of current scientifi c and policy debates, which provided the primary impetus for the U.S. Environmental 

Protection Agency (U.S. EPA) to establish an Expert Panel on these issues. In the summer of 2001, U.S. EPA formed an 

Expert Panel (“Panel”) consisting of twelve recognized experts on DNAPL fate and transport and DNAPL site remediation 

to examine four specifi c issues regarding DNAPL source-zone treatment and management:

A. Status of technology development and deployment for DNAPL source remediation.

B. Assessment of source remediation performance goals and metrics.

C. Evaluation of costs and benefi ts of source remediation.

D. Research issues and needs. 

In order to gather technical information and diverse views, the Panel participated in a two-day workshop involving Panel 

members and other invited experts (October 19 – 20, 2001; Dallas, TX), and then the Panel met for two days (February 

2002; Orlando, FL) to deliberate. The Panel’s discussions resulted in the identifi cation of seven questions that cover three 

of the four issues for which EPA had sought guidance. Charge D, Research Issues and Needs, is addressed directly in 

Section 4.0 of this Report. These questions are as follows:

1. What are the potential benefi ts and the potential adverse impacts of DNAPL source depletion as a remediation 

strategy? (Charges A and C)

2. What are the appropriate performance metrics for assessment of DNAPL source depletion technologies? 

(Charge B)

3. Are available technologies adequate for DNAPL source characterization to select and evaluate depletion options? 

(Charges A and B)
xi

4. What performance can be anticipated from source-zone mass depletion technologies? (Charge A)

5. Are currently available tools adequate to predict the performance of source depletion options? (Charges A and 

C)

6. What are the factors restricting the effective and appropriate application of source depletion technologies? 

(Charge A)

7. How should the decision be made whether to undertake source depletion? (Charge C)

Potential Benefi ts and Adverse Impacts of DNAPL Mass Depletion in the Source Zone 

The potential benefi ts of DNAPL source depletion have been the subject of signifi cant on-going technical and policy 

debates. Private site owners generally weigh remedies in terms of their risk management benefi ts and potential for 

reducing the total life-cycle cost to achieve site closure, assuming that the remedies under consideration meet all 

regulatory requirements for protection of human health and the environment. Government site owners, such as the 

Department of Defense (DOD), the Department of Energy (DOE), and EPA Superfund-lead sites generally follow a similar 

process, although the details of the remedy selection process may differ from decision processes at private sector sites, 

particularly with respect to assumptions regarding site institutional controls and the time value of money. 

Regardless of the site owner, there is a range of benefi ts, from a risk management perspective, that may result from 

DNAPL source-zone depletion. These include explicit benefi ts such as: 1) mitigating the future potential for human 

contact and exposure through long-term reduction of volume, toxicity, and mobility of the DNAPL, 2) mitigating the future 

potential for unacceptable ecological impacts, 3) reducing the duration and cost of other technologies employed in 

conjunction with the source removal technology, and 4) reducing the life-cycle cost of site cleanup. These benefi ts can 

be achieved if the source depletion option can result in the following outcomes: 1) reduction of DNAPL mobility, if mobile 

DNAPL is present, 2) reduction in environmental risk to receptors; 3) reduced longevity of groundwater remediation, and 

4) reduction of the rate of mass discharged from the DNAPL source zone. These outcomes could then lead to enhanced 

effi ciency of complimentary technologies used for groundwater remediation as well as potential reduction in life-cycle 

costs. Implicit benefi ts of DNAPL source-zone depletion include: 1) minimizing risks of failure of long-term containment 

strategies, 2) mitigating public stakeholders' concerns, 3) enhancing a company’s “green image” as stewards of the 

environment, and 4) minimizing future uncertain transaction costs associated with management of the site. 

Adverse impacts of DNAPL source depletion could include: 1) expansion of the DNAPL source zone due to mobilization 

of the residual DNAPL, 2) undesirable changes in the DNAPL distribution (i.e., DNAPL architecture), and 3) undesirable 

changes in the physical, geochemical and microbial conditions that may cause long-term aquifer degradation, and/or 

may adversely impact subsequent remediation technologies. All of these adverse impacts could increase life-cycle costs 

of site cleanup. 

Quantitative predictions of these potential benefi ts and adverse impacts to aid decision making on whether to implement 

DNAPL source depletion actions are highly uncertain. These uncertainties remain as signifi cant barriers to more 

widespread use of source depletion options.

Appropriate Metrics for Performance Assessment

The Panel assessed the technical basis for using drinking water standards, such as Maximum Contaminant Levels 

(MCLs), as the single performance goal for successful DNAPL source-zone remediation and the use of chemical analyses 

in groundwater samples from monitoring wells as the primary metric by which to judge performance of groundwater 

remediation systems. Although an MCL goal may be consistent with prevailing state and federal laws for all groundwater 

considered a potential source of drinking water and is a goal that is easily comprehended by the public, this goal is not 

likely to be achieved within a reasonable time frame in source zones at the vast majority of DNAPL sites. Thus, the 

exclusive reliance on this goal inhibits the application of source depletion technologies because achieving MCLs in the 

source zone is beyond the capabilities of currently available in-situ technologies in most geologic settings.

In recent years, there has been a trend towards the adoption of a more pragmatic regulatory approach by some regulatory 

agencies that are considering alternate or intermediate performance goals and phased remedial action approaches 

for cleanup of contaminated sites. Such fl exibility may result in implementing alternative strategies for groundwater 

cleanup, including: 1) establishment of management zones where cleanup goals other than drinking water standards 

may be applied, 2) groundwater classifi cation schemes that permit alternative remedial action goals, and 3) other 

fl exible regulatory approaches that do not impose non-degradation requirements or drinking water standards in DNAPL 

source zones. These new federal and state regulatory policies provide a more encouraging climate for implementation 

of innovative source-depletion technologies, in those situations where partial depletion of DNAPL sources is deemed 

an intermediate goal as a part of phased site cleanup. 
xii

In addition to alternative goals applied to DNAPL source zones, alternative metrics other than single-point measurements 

from groundwater monitoring wells should also be considered. One of the alternative metrics for judging the performance 

of source-mass depletion technologies is contaminant mass discharge, defi ned as the summation at a point in time 

of point values of contaminant mass fl ux (mass per time per area) across a vertical control plane encompassing the 

plume and perpendicular to the mean groundwater fl ow direction at a location downgradient of the DNAPL source 

zone. Both theoretical analyses and limited fi eld data indicate that partial DNAPL mass depletion in the source zone 

reduces contaminant mass discharge. The magnitude and timing of such reduction are strongly governed by the 

site hydrogeology, the contaminant mass distribution (DNAPL and non-DNAPL masses), and the type and method of 

application of the source-depletion technology. Because a suffi cient knowledge base does not yet exist to specify the 

level of mass discharge reduction needed to achieve site-specifi c benefi ts, such as risk reduction and reduction of the 

time lag between source remediation and mass discharge reduction, additional research will be necessary before this 

metric can be used to quantify the benefi ts of DNAPL source depletion. 

Adequacy of Site Characterization Technologies

Site characterization tools are available to measure most of the performance metrics discussed. Because of the inherent 

complexities of DNAPL migration and distribution in subsurface environments, none of the available characterization 

tools is without limitations on suitability and accuracy. The current status of site characterization tools has been 

thoroughly reviewed in the literature, and several recent summaries provide adequate information for selection of the 

appropriate site characterization tools for the purposes of selection, design, and performance assessment of DNAPL 

source depletion technologies. 

The Panel concluded that available technologies are adequate to locate and delineate the suspected DNAPL source 

zones. However, in practice, locating the DNAPL source zone and determining the actual mass and spatial distribution 

of the DNAPL mass is very diffi cult, and will only be possible with extensive sampling at the majority of sites. The cost 

and level of accuracy achievable by source-zone characterization tools can only be answered on a site-specifi c basis. 

Further investment by EPA and other governmental agencies in determining the level of accuracy required for sourcezone characterization tools as a function of subsurface geologic conditions, DNAPL characteristics and distribution, and 

a specifi c DNAPL depletion technology is warranted. 

New techniques for monitoring groundwater fl ow and contaminant mass fl ux and mass discharge rate have been 

developed, but to date, these methods have not been fi eld tested at suffi ciently diverse sites. Further guidance on the 

reliability, accuracy, and cost of mass fl ux and mass discharge rate monitoring techniques may be forthcoming based 

on research funded by DOD and other agencies. 

Performance of Source-Zone Mass Depletion Technologies

Over the past two decades, a large body of information has been developed on the performance of source-zone mass 

depletion technologies. Hundreds of pilot-scale site trials using innovative in-situ technologies have been conducted 

in DNAPL source zones, although a much smaller number of full-scale source depletion projects have been reported. 

In addition, various federal (EPA, DOE, DOD) and state agencies (e.g., Interstate Technology Regulatory Council, 

“ITRC”) have compiled information on source depletion technologies and case studies of the application of DNAPL 

source depletion technologies, and this information is available on the respective web sites of these organizations. 

Additional information on the cost and effectiveness of source-zone depletion technologies is expected within the next 

year based on reported surveys conducted by the U.S. Navy (at over 170 sites) and the ITRC committee on DNAPL 

source remediation case studies. 

Many of these studies report that substantial quantities of DNAPL mass have been removed from the subsurface. A 

few case studies are included in this Report where Panel members had fi rst-hand knowledge. Based on this body 

of knowledge, the Panel concluded that several technologies are suffi ciently developed and ready for deployment at 

DNAPL-impacted sites. These include thermal technologies, in-situ surfactant/cosolvent fl ushing, and in-situ chemical 

oxidation. In-situ biodegradation is the one technology evaluated that is still in an early developmental stage although 

even this technology has been implemented as a fi nal remedy at several DNAPL sites. Combinations of different source 

depletion technologies have also not been widely tested or evaluated. 

Although the Panel did not have the resources to evaluate this information on technology performance and costs in 

detail, it is clear that large quantities of DNAPL can be removed from source zones, with the magnitude of the removal 

highly dependent on site-specifi c and technology-specifi c factors. However, it is highly uncertain that MCLs can be 

achieved in source zones impacted with DNAPLs in most geologic settings. Nonetheless, a number of DNAPL sites 

have received no further action letters, indicating that regulators were satisfi ed that the remedial action objectives had 

been achieved in the source zone. It is clear that site closure of DNAPL-impacted sites may be possible depending 

upon site conditions, but such cases may be the exceptions rather than the rule at this time. 
xiii

Source-zone containment has been a goal adopted at a large number of DNAPL sites, and groundwater pump-andtreat, cut-off walls, or permeable reactive barriers have been effectively implemented. In the long term, containment has 

the disadvantage of requiring continued maintenance of effectiveness and the associated perpetual fi nancial burden. 

In addition, long-term effectiveness of the containment strategies is not assured. The Panel found only a few case 

studies where rigorous monitoring data have been used to assess the benefi ts of source containment for long-term 

plume management. 

Although source depletion technologies are capable of removing substantial amounts of the DNAPL in source zones 

at sites with favorable hydrogeologic conditions (i.e., less heterogeneous and more permeable subsurface conditions), 

achievement of drinking water MCLs in these source zones as well as source zones in more challenging heterogeneous 

hydrogeologic conditions (e.g., bedrock, karst systems, multiple stratigraphic units) is unlikely. However, these technologies

are capable of achieving partial DNAPL depletion, which may provide other performance benefi ts, including eliminating 

the mobility of the DNAPL, and reduction in the mass discharge rate of DNAPL constituents from the source zone, 

which may reduce environmental risks and life cycle costs. 

Factors Limiting Application of Source Depletion Technologies

Several obstacles have prevented widespread application of source-zone depletion technologies. These include: 1) setting 

of remedial action objectives (such as achieving MCLs in the source zone) that are likely to be technically impractical 

within a reasonable time frame, 2) uncertainty of the long-term effectiveness and cost of source depletion and length 

of time before site closure, 3) the lack of well-documented case studies that could reduce the uncertainties regarding 

the effectiveness of source depletion technologies, 4) lack of availability of insurance to mitigate the risks of failure of 

source-zone remedial actions, and 5) the limited number of technology vendors, which adds to uncertainties of cost, risk 

of failure, and risk of bankruptcy by the vendor. An additional uncertainty at most sites is the fraction of the contaminant 

mass in the DNAPL source zone that may be present in diffusion-controlled, low-permeability zones. If the metric for 

successful remediation is achievement of MCLs, the source depletion goal must include depletion of the dissolved 

and sorbed phase mass in addition to the DNAPL mass. In-situ technologies for source-zone depletion are generally 

limited in their ability to remove contaminant mass from these low-permeability zones; however, thermal technologies 

may overcome this limitation at some sites. On the other hand, it is likely that continued release of contaminants from 

these low-permeability zones will be at mass discharge rates substantially lower than those prior to source depletion. 

Whether this reduction in source-zone mass discharge would be suffi cient to warrant implementation of the source 

depletion technology is not currently predictable, and remains an important research topic.

Adequacy of Tools to Predict Performance

Reliable (validated) modeling codes and decision tools along with associated data are not currently available to: 

1) predict the performance of DNAPL source-zone remediation technologies, 2) predict the benefi cial and adverse 

impacts after the remediation is attempted, and 3) guide the decision process for selecting technologies or end points. 

The Panel concluded that quantifi cation of explicit benefi ts, such as the reduction of risks and cost liabilities after partial

source depletion, is an exceptionally diffi cult task and that much of the diffi culty results from the inherent uncertainty in 

determining the magnitude and distribution of the DNAPL source zone mass prior to remediation. 

Uncertainties in predicting remedial performance, life cycle costs, and benefi ts confound both economic and technical 

analyses and comparison of technical options for DNAPL source-zone depletion. A strategy for achieving benefi ts from 

partial source mass depletion would be to reduce contaminant mass discharge to a level less than the natural attenuation 

capacity within the dissolved plume. Under such conditions, the contaminant mass discharge for the DNAPL constituents 

becomes less than the rate of contaminant degradation in the plume and, as a result, the plume gradually shrinks 

until a new, smaller steady state plume is achieved. Such a strategy is most likely to be benefi cial for small DNAPL 

source zones at sites that are inactive. However, at many chlorinated solvent sites, natural attenuation by microbial 

degradation is ineffective because of inadequate microbial and geochemical conditions in the plume, and modifi cations 

of these conditions will be necessary to achieve acceptable degradation rates or dispersion to be protective of potential 

receptors. 

On Making the Decision to Undertake Source Depletion

The Panel recognizes that the decision to implement source-zone depletion technologies for DNAPL site remediation 

is based on highly site-specifi c conditions and criteria, and that numerous regulatory, technology, and stakeholder 

factors must be considered. The current decision process, as practiced in the U.S., has generally resulted in selection 

of containment over source depletion. The Panel concluded that new approaches to this decision process are needed. 

Therefore, the Panel considered two distinct options for developing an improved decision analysis framework: one 

based on a qualitative, semi-empirical analysis, and the other based on a quantitative model-based analysis. The Panel 

recognizes that neither of these options has been formally used at DNAPL sites for decisions on whether to implement 

source-depletion technologies, but the Panel urges EPA to consider the utility of qualitative approaches as a screening 

level tool for evaluating the appropriateness of source depletion compared to containment, and to assess the feasibility 
xiv

of developing a quantitative model that can account for a broad range of potential costs, benefi ts, and negative impacts 

from implementing DNAPL source-depletion technologies.

Knowledge Gaps and Research Needs

The Panel found that although much information on DNAPL source depletion has been developed, knowledge gaps 

still exist regarding the effectiveness and cost of these technologies for DNAPL source removal in a wide range of 

hydrogeologic settings. Research is needed on the following topics: 1) development, verifi cation, and comparison of 

alternative technologies for measuring mass fl ux and mass discharge from DNAPL source areas before and after source 

depletion, 2) development of improved predictive tools to estimate the benefi ts and adverse effects of partial source 

depletion for a range of DNAPL treatment technologies and DNAPL distribution and geologic scenarios, 3) continued 

fi eld testing of DNAPL source-depletion technologies incorporating more than one technology (e.g., thermal, in-situ 

fl ushing, or in-situ chemical oxidation combined with biodegradation), 4) development of guidance on the conditions in 

which source depletion is not likely to be an effective strategy, 5) assessment of the long-term water quality impacts of 

source-depletion technologies, and 6) development of quantitative decision analysis tools that will permit an accounting 

of all potential costs, benefi ts, and adverse impacts of partial DNAPL source depletion. 

A key knowledge gap is estimating the fraction of the total universe of DNAPL-impacted sites that would benefi t from 

partial DNAPL depletion from the source zone. The Panel consensus was that partial DNAPL source depletion will have 

benefi ts at a portion of DNAPL-impacted sites, but the Panel did not have suffi cient information to reach consensus, 

and was not willing to speculate. Resolution of this knowledge gap is a major research need and would provide the 

necessary foundation for expanded support of research and development programs on the issues raised in this Report. 

In the meantime, market forces and regulatory mandates will likely determine the extent to which DNAPL source-zone 

depletion technologies will be applied. 

In the past decade, major advances have been made in technologies for characterization and performance assessment 

of remedial actions of DNAPL source zones, but there is need for additional advances. Part of the cost of applying an 

innovative technology for source mass depletion includes the cost of additional site characterization needed for technology 

selection and remedial design based on the choice of performance metrics. A major challenge is the identifi cation of 

the degree of characterization and post-remediation monitoring necessary for effective application of each of the in-situ 

source depletion technologies. Research is needed to establish guidance for practical source-zone characterization 

keyed to the available technologies. 

Conclusions

In the fi nal analysis, the Panel concluded that partial mass depletion from DNAPL source zones has been a viable 

remediation strategy at certain sites and is likely to provide benefi ts at a number of additional sites. However, barriers 

to more widespread use of DNAPL source-zone technologies persist. Additional theoretical analysis and assessment 

tools (performance prediction tools; cost-benefi t assessment tools; technology failure analysis; reliability of long-term 

management), improved monitoring techniques (site characterization; performance assessment), and fi eld scale 

demonstrations that elucidate benefi ts of partial source depletion are needed to provide a more informed basis for 

decision-making on whether to undertake DNAPL source-zone depletion at both sites with a containment remedy in 

place and at new DNAPL sites. This information will also provide a basis to estimate the proportion of DNAPL-impacted 

sites that would be candidates for implementation of source-depletion technologies. At some DNAPL sites, containment 

may be the only viable remedial action, and at such sites, containment may be considered a “presumptive remedy” 

eliminating the need for costly additional studies. The Panel urges EPA to provide appropriate guidance for defi ning the 

conditions under which DNAPL source remediation would be a viable option for site cleanup compared to a containmentonly option using the broader defi nition of benefi ts of this strategy as discussed in this Report. 

The current strategy of source-zone containment has generally proven reliable for limiting routes of human and ecological 

exposure to chemical contaminants emanating from DNAPL-impacted sites, provided that the containment system (e.g., 

pump-and-treat, or permeable barriers) has been properly designed and maintained. However, this strategy poses longterm risks, transfers the burden of site management to future generations, and requires long-term fi nancial stability of 

the responsible parties. Furthermore, these long-term risks are generally diffi cult or impossible to quantify accurately. It 

is thus imperative that suffi cient resources be devoted to resolving the many uncertainties that this Panel has identifi ed 

in DNAPL source-zone characterization and depletion technologies to ensure that source depletion at DNAPL sites is 

implemented to the maximum extent practicable. 

Recommendations

The Panel’s specifi c recommendations to EPA are as follows:

1. Expand the existing EPA program for research, demonstration projects, and technology transfer to address and 

reduce the uncertainties in predicting and verifying the benefi ts and undesirable impacts from application of 

DNAPL source-zone depletion technologies.
xv

2. Continue to support demonstration efforts to develop, test, and validate the most promising innovative and 

emerging technologies for DNAPL source-zone characterization and mass depletion. 

3. Develop a new guidance document for source-zone response actions at DNAPL sites that provides a road map 

for decision makers to determine if implementation of source depletion technologies is appropriate.

4. Conduct a thorough and independent review of a selected number of DNAPL sites where suffi cient documentation is available to assess the performance of source depletion using multiple metrics. 

5. Develop and validate technologies for cost-effective and accurate measurement of mass fl ux and mass discharge 

from DNAPL source zones, and determine how these measurements relate to risk management decisions.

6. Evaluate impacts of source depletion technologies on long-term aquifer water quality.

7. Develop and validate cost-minimization and net benefi t-maximization decision models suitable for evaluating the 

complete spectrum of costs, benefi ts, and negative impacts of source-depletion technologies.
1

1.0 Introduction

1.1 Background

It is well recognized by stakeholders that remediation of soil and groundwater contaminated by organic chemicals in 

the form of dense non-aqueous phase liquids (DNAPLs) represents major technical, economic, and institutional challenges. While the consequences of DNAPL releases on groundwater quality are easily observed and have been widely 

documented, the characterization and remediation of DNAPLs in groundwater remain problematic. At most sites, characterization of the location, distribution, and amount of DNAPL causing continued groundwater contamination is diffi cult, 

and often inaccurate. Removal or in-situ destruction of DNAPL, even when reasonably well characterized, has proven 

diffi cult in saturated zones with any signifi cant degree of heterogeneity. 

Since the early 1980s, the U.S. Environmental Protection Agency (U.S. EPA), the Department of Energy (DOE), the 

Department of Defense (DOD), and various private organizations have recognized that DNAPL site remediation entails 

signifi cant technical challenges. For example, through fundamental and applied research directed by the Robert S. Kerr 

Environmental Research Center, in Ada, Oklahoma, the U.S. EPA prepared numerous technical guidance documents to 

advise stakeholders on characterization and remediation of DNAPL sites (U.S. EPA, 1994, DNAPL Site Characterization 

Quick Reference Fact Sheet, EPA/540/F-94/049). In addition to relevant guidance documents, EPA also developed policy 

guidance in recognition of the technical challenges confronting cleanup of DNAPL sites. The technical impracticability (TI) guidance document published in 1993 provided EPA’s recommended approach for assessing the feasibility of 

meeting established performance goals at Superfund and RCRA sites where remediation was considered impracticable 

from “an engineering perspective, taking cost into consideration” (U.S. EPA, 1993, TI Guidance Document). However, 

since 1990 this policy instrument has been infrequently used and as of this date, only 48 TI waivers have been granted 

from a universe of approximately 1,500 Superfund sites. The number of TI applications over this period is unknown. 

Nonetheless, many Records of Decision at Superfund sites include containment remedies and as such likely contain 

analyses that are consistent with the technical bases presented in the TI guidance. 

 In 1994, a committee established by the National Research Council prepared a report on Alternatives for Groundwater 

Cleanup (NRC, 1994) summarizing the research knowledge and practical experiences of the past two decades on the 

use of the so-called “pump-and-treat” technology, the dominant approach at that time to remediation of groundwater 

contaminated by DNAPLs. Groundwater sites impacted by DNAPL were considered to be the most diffi cult sites to 

remediate, and at that time, none of the known or suspected DNAPL sites had achieved required cleanup levels. 

While signifi cant technical advances in DNAPL site characterization and remediation technologies have been achieved, 

there is still a lack of consensus regarding the ability of available technologies to achieve groundwater remediation performance goals at DNAPL sites within a reasonable time frame and at a cost commensurate with perceived benefi ts or 

risk reduction. In particular, there is a lack of consensus regarding the appropriateness of applying intensive and often 

costly remediation technologies for DNAPL extraction or destruction in the source zone, if such partial mass removal 

will not have a quantifi able and substantial impact on the duration and life-cycle cost of a containment remedy, such 

as pump-and-treat. Given the uncertainties associated with the application of innovative technologies and the risk of 

inadequate performance, combined with the diffi culties of predicting the benefi ts of partial DNAPL source depletion, 

many potentially responsible parties in both the private sector (industry) and the public sector (government) are reluctant 

to undertake intensive source-zone remediation. 

The current practical consequence of this lack of consensus is that for the vast majority of groundwater-contaminated 

sites where DNAPL is suspected or known to be present, site remediation strategies are dominated by containment 

technologies, coupled with long-term monitoring. This strategy has been effective at limiting the spread of contaminants 

at these sites and signifi cantly reducing the risk of human and ecological exposures to these chemicals, but the failure 

to remove the DNAPL source from the groundwater requires that both long-term institutional controls and assurances 

of suffi cient fi nancial resources to maintain these controls must be in place. Stakeholder concerns over the long-term 

stability of these engineering and/or institutional controls, coupled with continuing issues related to natural resource 

damage claims, continue to provide a powerful incentive for improving our capabilities to remove or destroy DNAPLs 

found in soil and groundwater. 
2

1.2 Expert Panel Formation

In the context of this debate regarding DNAPL source remediation, EPA, through its Ground Water and Ecosystems 

Restoration Division (GWERD), formed a DNAPL Expert Panel (“Panel”) to advise EPA on a number of key issues 

related to remediation of DNAPL source zones. The members of the Expert Panel and their affi liations are shown in 

Table 1-1, and short biographical sketches of the Panel members are included in Appendix B.

In the summer of 2001, the U.S. EPA’s Robert S. Kerr Environmental Research Center in Ada, Oklahoma, organized 

the Panel to provide independent advice to EPA on a series of issues regarding DNAPL source remediation. These 

four issues included the following:

A) Status of technology development and deployment for DNAPL source remediation.

B) Assessment of source remediation performance goals and metrics.

C) Evaluation of costs and benefi t of source remediation.

D) Research issues and needs.

Table 1-1 Panel Participants

 Name Affi liation

 Kavanaugh, Michael, Panel Co-Chair Malcolm Pirnie, Inc.

mkavanaugh@pirnie.com

 Rao, Suresh, Panel Co-Chair Purdue University School of Civil Engineering

pscr@ecn.purdue.edu

 Abriola, Linda University of Michigan, Dept. Civil & Environmental Engineering

abriola@engin.umich.edu (Note: Currently at Tufts University) 

 Cherry, John University of Waterloo Dept. of Earth Sciences

cherryja@sciborg.uwaterloo.ca

 Destouni, Georgia Stockholm University

georgia.destouni@natgeo.su.se Dept. of Physical Geography & Quaternay Geology

 Stockholm, Sweden 

 Falta, Ronald Clemson University

faltar@clemson.edu Dept. Environmental Engineering & Science

 Major, David Geosyntec

dmajor@geosyntec.com

 Mercer, James GeoTrans, Inc.

Jmercer@geotransinc.com

 Newell, Charles Groundwater Services, Inc.

cjnewell@gsi-net.com

 Sale, Thomas Colorado State University

tsale@lamar.Colostate.edu Department of Civil Engineering 

 Shoemaker, Stephen DuPont 

stephen.h.shoemaker@usa.dupont.com

 Siegrist, Robert Colorado School of Mines

siegrist@mines.edu Environmental Science & Engineering 

 Teutsch, Georg University of Tuebingen,

georg.teutsch@uni-tuebingen.de Germany Center for Applied Geoscience

 Udell, Kent University of California, Berkeley

udell@me.berkeley.edu 
3

The Panel fi rst participated in a two-day workshop organized by Dynamac Corporation for EPA in October 2001 in Dallas, Texas. The agenda for the two-day workshop is also included in Appendix C, and a list of attendees is included in 

Appendix D. Subsequently, the Panel held a two-day meeting in Orlando, Florida, in February 2002. The Panel decided 

at that meeting to defi ne the technical issues as “DNAPL source-zone depletion” refl ecting the general consensus that 

although complete or 100 percent DNAPL removal from source zones in the saturated zone is technically impracticable 

at all sites, partial DNAPL source depletion may be suffi cient to meet site-specifi c remedial action objectives. In response to the charges from EPA to address the four key issues, the Panel generated a series of questions summarized 

in Table 1-2. Shown also in this table is the relationship between the questions posed and three of the four issues 

presented by EPA. Charge D, Research Needs, is the focus of Section 4.0 in the Report. 

Table 1-2 Questions

Question 1: What are the potential benefi ts and potential negative impacts of DNAPL source depletion as a 

remediation strategy? (Charges A and C)

Question 2: What are the appropriate performance metrics for evaluation of source depletion technologies? 

(Charge B)

Question 3: Are available technologies adequate for DNAPL source characterization to select and evaluate 

source depletion options? (Charges A and B)

Question 4: What performance can be anticipated from source-zone mass depletion technologies? (Charge 

A)

Question 5: Are currently available tools adequate to predict the performance of source depletion options? 

(Charges A and C)

Question 6: What are the factors restricting the effective and appropriate application of source depletion strategies? (Charge A)

Question 7: How should the decision be made whether to undertake source depletion? (Charge C)

1.3 Organization of the Report

Based on review of the information provided at the October workshop, the knowledge and experience of the Panel 

members, and results of the Panel process, the Panel has prepared the following Report to the U.S. EPA (“Report”). 

To ensure common understanding in discussing DNAPL source remediation, Section 2.0 of this Report begins with an 

overview of the DNAPL problem. Section 3.0 presents the Panel’s response to the seven questions generated to address 

each of the four issues raised by EPA in the charge to the Panel. In general, except where noted, these responses 

represent a consensus of the Panel. The fi nal two sections of the Report summarize knowledge gaps and research 

needs, Section 4.0 (Charge D) and provide the Panel’s conclusions and recommendations to EPA (Section 5.0).
4
5

2.0 Problem Description

2.1 DNAPLs as a Source of Groundwater Contamination

Dense Non-Aqueous Phase Liquids (DNAPLs) are water-immiscible organic liquids with a density greater than that of 

water at ambient temperature and pressure. The most prevalent types of DNAPLs are the halogenated organic solvents 

(including trichloroethene, “TCE”, and tetrachloroethene, “PCE”), but many sites are contaminated with other types of 

DNAPLs including coal tar and creosotes (complex hydrocarbon mixtures consisting of polycyclic aromatic hydrocarbons 

and other aromatic hydrocarbons), polychlorinated biphenyl (PCBs), and certain pesticides (Cohen and Mercer, 1993). 

Numerous references provide detailed information on the physical and chemical properties of DNAPLs (e.g., Hunt et 

al., 1988; Mercer and Cohen, 1990; Cohen and Mercer, 1993; Pankow and Cherry, 1996; and U.S. EPA, 1991). 

 Although there was broad recognition of groundwater contamination from chlorinated solvents in the 1970s and early 

1980s, the crucial role of DNAPLs as the primary source of this contamination was overlooked until the mid-1980s. The 

pioneering work on the fate of DNAPLs in the subsurface conducted by Schwille and his colleagues in Germany set 

the stage for an explosion in our understanding of the role of DNAPLs in groundwater contamination (Schwille, 1988). 

Pankow and Cherry (1996) provide a comprehensive history of the growth of knowledge regarding the role of DNAPLs 

in groundwater contamination. Since the early 1990s, however, the signifi cance of the presence of DNAPL on the 

effectiveness of groundwater remediation has been fully recognized. 

As is now well understood, the physical, chemical, and biotic degradation properties of DNAPLs determine the threats 

that such organic chemicals pose to the environment (Pankow and Cherry, 1996). DNAPLs can migrate relatively easily 

in the saturated zone under gravity forces, penetrate deeply into aquifers, and in some cases, travel substantial horizontal 

distances away from the original source area. Rates of migration are dependent on the properties of the DNAPLs 

(viscosity, density, interfacial tension), and the geologic characteristics of the subsurface (e.g., see Pankow and Cherry, 

1996, for a review of the physics of DNAPL fl ow in various subsurface environments). DNAPLs exhibit relatively low 

aqueous solubility (typically in the milligrams per liter range or parts per million [ppm]), but the solubility levels generally 

exceed drinking water standards (typically in the microgram per liter range or parts per billion, ppb) by several orders of 

magnitude. Some DNAPL compounds, such as chlorinated solvents, are relatively volatile in pure phase, and can thus 

partition into soil gas, causing further migration of those DNAPL constituents in the vadose zone, and posing potential 

threats to air quality in confi ned spaces, an issue that has received national attention and has been addressed in recent 

regulatory guidance (see for example, http://www.epa.gov/epaoswer/hazwaste/ca/eis/vapor.htm).

DNAPL constituents slowly partition into the aqueous phase (Eberhardt and Grathwohl, 2002), usually under mass 

transfer controlled conditions (see e.g., Frind et al., 1999) thus causing the development of a dissolved groundwater 

contaminant plume. In addition, under natural biogeochemical conditions found within dissolved plumes at most sites, 

chemical constituents of some DNAPLs (chlorinated solvents such as PCE and TCE) do not easily or rapidly degrade 

either biotically or abiotically. As a consequence, large and relatively mobile plumes of these chemicals will form and 

can migrate signifi cant distances from the location of the original DNAPL release(s). Partial (biotic/abiotic) degradation 

of chlorinated solvents can transform the parent compound to by-products that are potentially of greater environmental 

concern (e.g., vinyl chloride and DCE). For coal tars and creosote DNAPLs, the primary constituents of concern are 

the polyaromatic hydrocarbons (PAHs), with a broad range of solubilities and susceptibility to biological degradation. 

2.2 Magnitude of the Problem

Although DNAPL contamination of soil and groundwater is now widely recognized, there are few studies that have 

bounded the magnitude of the problem. EPA analyses (U.S. EPA, 1993) suggest that DNAPL is present at approximately 

60 percent of Superfund sites where organic chemicals have been detected. However, the presence of DNAPLs is rarely 

observed directly, and must be inferred by comparing the maximum levels detected in soil or groundwater samples 

to the effective solubility in water or the residual saturation in soil of the DNAPL chemical of concern. It is probable, 

however, that DNAPLs are present at many sites where DNAPL constituents have been detected even with maximum 

concentrations in samples taken from groundwater monitoring wells below one percent of the effective aqueous solubility, 
6

which is generally used as a rule of thumb to infer the presence of the DNAPL at a site (Feenstra and Cherry, 1988; 

U.S. EPA, 1992). It should be noted that this widely used rule-of-thumb has no fundamental theoretical basis, but it is 

consistent with empirical observations and the impacts of dispersion on concentrations of chemicals dissolving from 

a DNAPL into water fl owing past the material. Nonetheless, the presence of organic contaminants at levels below or 

above this threshold may or may not demonstrate the presence of DNAPLs.

 The NRC study (NRC, 1994) on Alternatives for Groundwater Cleanup summarized various published estimates 

on the number of sites in the U.S. where groundwater was likely contaminated. The estimated number of sites with 

suspected groundwater contamination, excluding leaking underground storage tanks, which primarily contain petroleum 

hydrocarbons, ranged from 30,000 to 50,000 sites (NRC, 1994). For example, the State Coalition for Remediation of 

Drycleaners estimates that up to 75 percent of the 36,000 active dry cleaning establishments in the U.S. have experienced 

releases of PCE or other dry cleaning solvents (http://www.drycleancoalition.org/pubs.cfm “Conducting Contamination 

Assessment Work at Drycleaning Sites”). If one assumes that approximately 80 percent of the 30,000 to 50,000 sites 

with impacted groundwater are contaminated with organic chemicals, and of those organic chemicals, approximately 

60 percent are DNAPLs as estimated by EPA, the total number of DNAPL impacted sites in the U.S. could range from 

15,000 to 25,000 sites. 

The annual and life cycle costs to remediate the DNAPL sites could be quite high. Currently, at the majority of these 

sites, hydraulic containment using the conventional groundwater pump-and-treat technology is the dominant remedial 

technology of choice, without implementation of source depletion technologies. If pump-and-treat technologies remained 

in operation, or were applied to all DNAPL sites in the future, annual costs would be substantial. Based on data collected 

by EPA (U.S. EPA, 1999a), and on the experience of Panel members (see also, NRC, 1994), annual costs for operation 

and maintenance of pump-and-treat systems range from $30,000 to $4,000,000 per year, with a median value of 

roughly $180,000 (1999 dollars) per site, based on the EPA 28 Site Study (U.S. EPA, 1999a). Thus, using this median 

value, annual O&M costs for the 15,000 to 25,000 sites in the U.S. with DNAPL contamination could range from $2.7 

to $4.5 billion dollars per year if all sites relied on groundwater pump-and-treat only as a containment remedy. The total 

life cycle costs for this remediation strategy depend on assumptions of equipment replacement frequency and costs 

and the net discount rate. The estimated life cycle costs for cleanup of DNAPL sites, assuming a net present value 

estimate based on 30 years of operation, would range from $50 to $100 billion dollars for discount rates ranging from 

5 to 10 percent. (It should be noted that the discount rate in public sector accounting could be as low as 3.9 percent 

compared to private sector present value discount rates ranging up to 12 percent). 

Although a precise estimate of the total life cycle costs for remediation of DNAPL sites using a containment strategy 

is lacking, these order of magnitude estimates clearly show that the cleanup of groundwater DNAPL sites will require 

signifi cant annual expenditures for the next several decades if hydraulic containment is the dominant strategy for 

groundwater remediation at these sites. These order of magnitude cost estimates suggest that development or 

implementation of existing and emerging source-depletion technologies could potentially reduce this annual liability by 

depleting the DNAPL source zone, resulting in reductions in life-cycle costs at those DNAPL sites with a containment 

remedy in place such as groundwater pump-and-treat as well as at those sites where no remedial actions have yet 

been selected. In addition to potential cost savings, source depletion would provide other benefi ts to site owners and 

the public, as discussed subsequently in this report. 

2.3 Regulatory Framework

Among the principal drivers for undertaking remedial actions at groundwater sites contaminated with DNAPLs are federal 

and state statutes that have established methodologies for setting cleanup standards at sites managed under various 

regulatory regimes (see e.g., U.S. EPA, 1996). Source control is a critical component of site remediation strategies aimed 

at returning groundwater to maximum benefi cial uses in a reasonable time frame and for achieving pollution prevention 

goals (see U.S. EPA, 2002; www.epa.gov/correctiveaction). For example, the CERCLA statute requires remedial actions 

to attain drinking water standards established under the Safe Drinking Water Act, or water quality criteria established 

under the Clean Water Act,“...where such goals or criteria are relevant and appropriate under the circumstances of 

the release.” Superfund regulations, contained in the NCP (Final National Oil and Hazardous Substances Pollution 

Contingency Plan) establish that the cleanup goal for contaminated ground water is: “...to return usable ground waters 

to their benefi cial uses wherever practicable, within a timeframe that is reasonable given the particular circumstances 

of the site.” Superfund guidance further clarifi es that drinking water standards are to be used as cleanup levels for 

ground waters that are determined to be current or potential sources of drinking water. For sites regulated under RCRA 

Corrective Action, similar fi nal cleanup goals are established, although the point of compliance (POC) and various 

short-term and intermediate goals may be defi ned for the site (see U.S. EPA, 2002; www.epa.gov/correctiveaction). The 

regulatory context for groundwater cleanups is further complicated by state and local laws, which generally must be at 

least as stringent as federal requirements. 
7

In recent years, however, many states have begun to adopt a more pragmatic regulatory approach, based on alternate or 

intermediate performance goals and phased remedial actions, for cleanup of contaminated sites. For example, revisions 

to Arizona state laws in 1997 now allow the Arizona Department of Environmental Quality (“ADEQ”) increased fl exibility 

in selection of groundwater cleanup methods and levels. ADEQ is “authorized to adopt rules for remedy selection that 

incorporate analysis of a range of cleanup alternatives, from remediation of the contamination to no action.” Signifi cantly, 

the statute clarifi es that cleanup need not always result in achievement of drinking water standards in the aquifer itself. 

States such as Vermont, California, and New York among others are implementing alternative approaches to groundwater 

cleanup including establishment of management zones where cleanup goals other than drinking water standards may be 

applied, groundwater classifi cation schemes that permit alternative remedial action goals, and other fl exible regulatory 

approaches that do not impose non-degradation requirements or drinking water standards in source zones. These new 

federal and state regulatory policies and practices provide a more encouraging climate for implementation of innovative 

source-depletion technologies in those situations where partial depletion of DNAPL sources may be deemed an acceptable 

intermediate goal as a part of phased site cleanup. On the other hand, regulatory policies are also constrained by public 

concerns over leaving contamination in place and concerns over natural resource damages, and there is currently no 

accepted regulatory defi nition of qualitative terms such as “mass removal to the extent practicable.” This results in 

signifi cant uncertainty as to the extent of mass depletion that may be required in a DNAPL source zone. 

The Panel has not undertaken an assessment of all new regulatory practices or changes in policies, but it is the experience 

of the consultants on the Panel that for groundwaters considered potential sources of drinking water, requirements 

for restoration or achieving MCLs in a source zone are the dominant regulatory approach across the country. Where 

alternative metrics or remedial actions are considered acceptable by the regulatory agency (e.g., remove mass to the 

extent practicable, eliminate DNAPL mobility, or achieve levels higher than MCLs), the potential for partial DNAPL source 

depletion to meet site-specifi c remedial action objectives is increased. 

In addition to regulatory drivers, remedial actions in source zones may also be undertaken to eliminate long-term liability. 

Responsible parties can potentially be held liable for tort liability (e.g., human health impacts, nuisance, trespass, 

diminution of property values). Furthermore, as specifi ed under CERCLA, states may sue responsible parties for natural 

resource damages, increasing the long-term risks that failure to cleanup a site would result in signifi cant claims against 

such parties. 

2.4 Technical Framework 

To provide a consistent technical framework for addressing the four issues presented by EPA to the Panel, the following 

discussion addresses key factors that the Panel considers essential for a comprehensive understanding of the DNAPL 

source-zone remediation challenge. Before addressing questions such as what benefi ts can be obtained by depleting 

DNAPL mass from source zones, or which technology or technologies work best, it must fi rst be recognized that source 

zones at DNAPL-impacted sites differ in important ways. These differences can have profound impacts on the technical 

and institutional approaches taken to groundwater remediation that are: 1) consistent with regulatory requirements, 

2) mitigate stakeholder concerns, and 3) balance the benefi ts of risk reduction against life cycle costs. Benefi t/cost 

balancing and the resultant risk management decisions related to the implementation of source depletion technologies 

can best be understood in the context of the technical framework presented below. 

For purposes of this Report, the source zone has been defi ned as the groundwater region in which DNAPL is present 

as a separate phase, either as randomly distributed sub-zones at residual saturations or “pools” of accumulation above 

confi ning units (Mackay and Cherry, 1989; Cohen and Mercer, 1993; Feenstra et al., 1996). This earlier defi nition is 

extended here to include the volume of the aquifer that has had contact with free-phase DNAPL. This refl ects the 

observation that diffusion can drive substantial contaminant mass into stagnant zones (e.g., clay) adjacent to DNAPL 

(Parker, et al., 1994; Parker, et al., 1997; Reynolds and Kueper, 2002). After depletion of DNAPL, back diffusion of 

sorbed and dissolved contaminants from stagnant zones can sustain plume concentrations (Liu and Ball, 2002). A 

good example of the cases to be included by this expanded defi nition is the source zones in fractured media discussed 

in the following paragraphs. The term source-zone architecture (Sale and McWhorter, 2001) is used to describe the 

geometry (shapes, sizes, spatial distribution, inter-connections) and DNAPL content of the sub-zones. The source-zone 

DNAPL architecture impacts the source strength (i.e., mass discharge rate), the evolution of the dissolved plume, and 

the effi ciency of remediation. DNAPL sources in the vadose zone are not considered in this report.

The Panel determined that the primary factors differentiating source zones from other zones in the contaminated aquifer 

such as the dissolved plume include: a) site hydrogeology; b) DNAPL spatial distribution; c) size of the site and DNAPL 

release(s); d) composition and properties of the DNAPL (single- or multi-component); and e) the degree of ground 

surface interferences.
8

Site Hydrogeology: Hydrogeologic features—such as lithology and permeability—have a dominant effect on the 

rate and direction of groundwater fl ow and contaminant transport. DNAPL migration and distribution subsequent to a 

release are also strongly controlled by the hydrogeologic features. Two primary geologic conditions can be identifi ed: 

1) unconsolidated porous media, and 2) consolidated (fractured) porous media. For the unconsolidated media, we 

are particularly interested in three features of the medium: 1) the permeability, as represented by the mean hydraulic 

conductivity, 2) the degree of hydrologic heterogeneity, as represented by the variance of the distribution of values for 

the saturated hydraulic conductivity, and 3) the extent of anisotropy and spatial correlation, as represented by the ratio 

of the correlation lengths. For consolidated fractured media, advective transport occurs primarily in the fracture network, 

while the porosity of the rock matrix serves as stagnant zones connected to the advective fl ow paths via molecular 

diffusion; thus, these stagnant zones serve as long-term diffusion sinks/sources. Three specifi c features are of particular 

importance for fractured systems: 1) the porosity of the rock matrix, which gives an indication of the fraction of the pore 

volume that serves as the diffusive sink/source for contaminant transport, 2) the spatial organization of the fracture 

network, with an emphasis on the inter-connectedness of the fractures, and 3) the fracture-size distribution.

A typical heterogeneous unconsolidated medium is represented in Figure 2.1, and examples include deltaic deposits 

(e.g., Southeastern coastal plains hydrogeology; Garber Wellington Aquifer, Central Oklahoma) and glacial outwash. 

Such aquifer materials generally exhibit anisotropy in permeability (Ksat) values; that is, saturated hydraulic conductivity 

values in the x- or y-directions may be much larger than those in the z-direction, and as a result, preferential orientation 

of the stratigraphic layers occurs. This anisotropy is characterized by the ratio of the spatial correlation lengths in the 

x (or y) and z directions. Note that the larger the ratio, the more pronounced is the horizontal orientation of the layers, 

whereas, as the correlation length increases, the characteristic lengths of the inclusions increase.

Figure 2.1 Schematic representation of an unconsolidated heterogeneous geologic setting.

Fractured media may be grouped into two distinctly different types based on the porosity of the rock matrix (Pankow 

and Cherry, 1996). The fi rst type has large matrix porosity, while the second type has small matrix porosity. The term 

“fractures” is used to evoke scenarios in which the bulk capacity to transmit fl uids is primarily associated with fl aws (e.g., 

fractures) in an otherwise low-permeability matrix. The porosity of the fractures is typically a very small fraction of the 

overall material volume. With large matrix porosity, contaminants (DNAPL and dissolved phase) are depleted from the 

fracture via diffusion into the matrix. Within the matrix, contaminant mass is stored as aqueous and sorbed phases. 

Molecular diffusion initially retards contaminant migration via advection, as the rock-matrix porosity serves as a sink. 

However, once the source is removed and the contaminant concentrations in the fracture network decrease, diffusion 

out of these stagnant intra-matrix regions can sustain contaminant concentration in the advective fl ow paths within the 

fracture network. Examples of such geologic media include limestone (e.g., the Niagara Escarpment, Niagara Falls, 

New York) and Lacustrine Clays (e.g., Sarnia, Ontario). 
9

Alternatively, contaminants transmitted along fractures in matrix material with low matrix porosity are not attenuated by 

molecular diffusion. This limits the formation of an in-situ diffusion source. Unfortunately, it also allows contaminants to 

migrate much faster than in an equivalent fractured medium with large rock-matrix porosity. Examples of such geologic 

media include crystalline rock in the Piedmont region of the eastern U.S., and granitic bodies in the Rocky Mountains. A 

hypothetical depiction of a DNAPL source zone in a fractured medium is shown in Figure 2.2, after Davis and DeWeist 

(1996).

Figure 2.2 Schematic representation of fractured media site contamination DNAPL. 

DNAPL Spatial Distribution: For a given DNAPL release scenario, very different spatial distributions of the DNAPL 

will occur depending upon the size of the release and the hydrogeologic settings. DNAPLs are present either as a free 

phase, and therefore, mobile liquid, or as residual liquids. Following the release(s), DNAPL constituents may partition 

into the water phase, the aquifer solids, or the soil vapor. Thus, DNAPL in a source zone may be distributed among four 

phases: 1) pure DNAPL, 2) DNAPL constituents sorbed on the surfaces of the aquifer solids, 3) dissolved in pore water, 

and 4) in soil vapor. Here, we do not consider the vapor-phase because remediation of DNAPL in the vadose zone is 

not the focus of this Report. Free-phase DNAPL may occur either as “pools” of an accumulation occupying most (but, 

not all) of void spaces in more-permeable zones or at “residual saturation” where disconnected globules are trapped 

by capillary forces (see e.g., Imhoff et al., 2003). 

Size of the Site and DNAPL Release Volume: The size and frequency (release history) of DNAPL release(s) have a 

dominant effect in determining the distribution of “pools” and regions of residual saturation. The DNAPL source-zone 

architecture represents sizes, shapes, volumes, and connections of these DNAPL sub-zones and their hydrodynamic 

interactions with the more-permeable regions within the aquifers. That is, “architecture” defi nes both the morphological 

features (such as spatial distribution patterns, NAPL content, etc.) of the sub-zones and their “functions” in terms of 

hydrodynamic accessibility (i.e., rate of release by aqueous dissolution). DNAPL mass in stagnant regions (e.g., clay 

inclusions in unconsolidated media, intra-matrix porosity in fractured media) is stored primarily in the sorbed and 

dissolved phases, and mass-transfer via molecular diffusion is the primary transport mechanism (see e.g., Parker et 

al., 1994; Parker et al., 1997). It should be recognized that the source-zone architecture can and does change over 

time, especially when source remediation technologies are implemented; such changes have signifi cant infl uence on 

the “source strength” (defi ned as the total mass discharge rate; MT-1) and the manner in which the plume responds. 

Properties and Composition of the DNAPL: Physical and chemical properties of the DNAPL, such as solubility, 

density, viscosity, interfacial tension, and composition, also play an important role in: 1) multi-phase fl ow behavior, which 

governs DNAPL source-zone architecture, 2) generation of a dissolved plume, and 3) performance of the remediation 

technologies. While many DNAPLs of interest are single-component liquids (e.g., chlorinated solvents, such as PCE or 

TCE), multi-component DNAPLs (e.g., creosote and coal tars) are also of signifi cant practical interest. At many sites, 

chlorinated solvents are often found as mixtures, either with other hydrocarbons (e.g., fuels) or other solvents used in 

industrial operations, or may be released as spent solvents that contain a variety of chemical constituents. 
10

 While chlorinated solvents are generally considered to be non-wetting with respect to the aquifer solids, the presence 

of minor constituents (e.g., surfactants, organic acids) or “aging” after release can alter the interfacial tension and 

wetting behavior of a DNAPL (Powers and Tamblin, 1995; Lord et al., 1997a,b). Complex DNAPLs, such as coal tars 

and creosotes, also tend to behave as a wetting phase. Wetting DNAPLs are likely to be found at larger residual 

saturations, tend to exist as coatings rather than as dispersed globules, and are able to penetrate into low-permeability 

stagnant zones (Abriola and Bradford, 1998; Bradford and Abriola, 2001; Abriola et al., 2002). Such dramatic alterations 

in source-zone architecture must be evaluated in site assessment and remedial designs.

Degree of Surface Interferences: Surface structures including buildings, tanks, process units, buried utilities, and/or 

roadways limit access for investigation and installation of DNAPL source-zone depletion technologies. Generally, at 

sites with larger numbers of such interferences or “active” sites with on-going operations, one is more likely to encounter 

problems in deploying a selected source depletion technology.

In summary, the above fi ve factors must be considered when evaluating appropriate technical and institutional strategies 

for groundwater remediation at DNAPL sites. The characteristics of individual sites must be carefully evaluated when 

considering site characterization efforts and potential remedial actions including the implementation of source-zone 

depletion technologies. 
11

3.0 Questions

The following section summarizes responses to seven questions generated by the Panel in response to the charge 

from EPA on the issue of source-zone remediation at DNAPL sites. 

3.1 Question 1: What are the Potential Benefi ts and Potential Adverse Impacts of 

DNAPL Source Depletion as a Remediation Strategy?

The potential benefi ts and the potential adverse impacts of DNAPL source-zone depletion have been the subject 

of on-going debates in the remediation fi eld. The potential positive and negative outcomes discussed below are 

based on either theoretical considerations or laboratory and fi eld data. However, the magnitude of these outcomes 

and the probability of their occurrence need to be determined from site-specifi c analysis. Analysis here is limited to a 

more generic description, and certain remediation technologies are mentioned only to illustrate potential outcomes. 

Furthermore, the intensity and persistence of the adverse impacts resulting from aggressive source-zone treatment are 

poorly understood, as is the resilience of a treated source zone to recover from such impacts. Similarly, experience 

with partial source depletion has not been suffi cient to determine whether the benefi ts of partial source removal 

are seen only for a short duration before a rebound occurs to conditions similar to the pre-remediation scenario 

or some other unacceptable condition, as has often been the case when applying pump-and-treat technologies to 

DNAPL-impacted groundwater sites. 

3.1.1 Potential Benefi ts of Partial Source Depletion

In many respects, the actual or perceived benefi ts of DNAPL source depletion depend on the view of the particular 

stakeholder. Private site owners generally weigh remedies in terms of their risk management benefi ts and potential 

for reducing the total life-cycle cost to achieve site closure, assuming that the remedies under consideration meet 

all regulatory requirements for protection of human health and the environment. Government site owners, such as 

the Department of Defense (DOD) or the Department of Energy (DOE) generally follow a similar process, although 

the details of the remedy selection process may differ from decision processes at private sector sites, particularly 

with respect to the time value of money. 

In all cases, regardless of the site owner, there is a range of benefi ts, from a risk management perspective, that 

may result from source depletion. These include explicit benefi ts such as: 1) mitigating the future potential for human 

contact and exposure through long-term reduction of volume, toxicity, and mobility of the DNAPL, 2) mitigating 

the future potential for unacceptable ecological impacts, 3) reducing the duration and cost of other technologies 

employed in conjunction with the source depletion technology, and 4) reducing the life-cycle cost of site cleanup. 

These benefi ts can be achieved if the source depletion option can result in the following outcomes: 1) reduction of 

DNAPL mobility, if mobile DNAPL is present, 2) reduction in environmental risk to receptors; c) reduced longevity 

of groundwater remediation, and 3) reduction of the rate of mass discharged from the DNAPL source zone. These 

outcomes could then lead to enhanced effi ciency of complimentary technologies used for groundwater remediation 

as well as reduction in life-cycle costs. Implicit risk management benefi ts include: 1) minimizing risks of failure of 

containment strategies, 2) mitigating public stakeholders' concerns, 3) enhancing a company’s “green image” as 

stewards of the environment, and 4) minimizing future uncertain transaction costs associated with management of 

the site. In contrast to explicit benefi ts, these implicit benefi ts are often diffi cult to quantify in monetary terms. The 

following is a brief discussion of some of these benefi ts that may arise from mass depletion in a DNAPL source 

zone.

Reduction of DNAPL Mobility

The potential benefi t of source depletion (such as by pumping free-phase DNAPL) to reduce free-phase DNAPL 

mobility and mitigate further spread of the source is clear. In some cases, free product mass removal may be 

necessary to prevent or reverse direct discharge of DNAPL to the land surface or surface water and thereby mitigate 

the associated risk potential to human and/or ecological receptors. The goal in such a case is to deplete the source 
12

suffi ciently to reduce DNAPL to a residual saturation level, or at least to a point of relative stability. It may be possible, 

at least in principal, to achieve this objective through physical containment measures. However, the experience of the 

Panel has been that containment of DNAPL through physical measures (e.g., sheet pile barriers, slurry walls, etc.) is 

challenging and presents uncertainties regarding long-term reliability. 

EPA (1998) evaluated the performance of subsurface engineered barriers, assessed 36 sites in detail, and concluded that 

if properly designed, such systems are effective containment systems primarily of the dissolved plume for the short and 

middle term, duration undefi ned. Presumably, “middle term” refers to a period of less than 10 years. However, at four 

of the 36 sites, contaminant leaks were detected at the interface between the barrier and anchor materials (i.e., barrier 

key), and at four other sites, evidence suggested that the containment objective had not been met. Two of the 36 sites 

had barrier walls installed with the objective to “contain” DNAPL, but the data were not suffi cient to verify the success 

of these barriers, although at one barrier, EPA concluded that the containment objective may have been achieved. In 

those cases where source-zone containment is the goal, one uncertainty is whether the source zone containing DNAPL 

has been accurately defi ned. Thus, the success of physical containment strategies for mobile DNAPL is certainly not 

assured, and uncertainties remain regarding longer-term performance (>10 years).

In such cases, free product removal may provide an advantage by reducing the risks of barrier failure. In evaluating 

this benefi t, however, the Panel concluded that at the vast majority of sites impacted with chlorinated solvent DNAPLs, 

the presence of highly mobile separate free phase cases is the exception rather than the rule since most chlorinated 

DNAPLs (PCE, TCE) generally come into hydraulic equilibrium relatively quickly following release. However, sites with 

wetting DNAPLs may be an exception to this general rule, and the Panel is aware of several reports of continued mobility 

of DNAPLS such as creosote and coal tars even though disposal may have occurred decades earlier. 

Reduced Longevity

Source depletion provides a potential benefi t in reducing the longevity of the DNAPL source and the associated dissolved 

plume. This potentially translates into risk reduction by shortening the time frame for site closure and thus reducing 

the overall potential for human or ecological exposure to the site DNAPL contaminants. The magnitude of this benefi t 

is highly site-specifi c and will depend primarily on the degree of subsurface heterogeneity, DNAPL source distribution 

within the saturated zone (e.g., see previous discussion in Section 2.0), the extent of source depletion from high- and 

low-permeability zones, and the rate of other attenuation processes occurring at the site. 

This potential benefi t is common to all source depletion strategies, but diffi cult to predict and quantify at present due 

primarily to: 1) uncertainties in estimates of the initial and the residual DNAPL mass, and 2) characterization of the 

distribution of the DNAPL after source depletion has been implemented. These uncertainties are an inherent characteristic 

of subsurface systems because of highly heterogeneous geologic properties of all aquifers.

In tandem with risk management benefi ts, the potential value of source depletion in the view of the site owner may be 

in reducing the life cycle cost to achieve cleanup goals and site closure. For contaminated groundwater, the classic risk 

management approach has been to institute hydraulic controls (e.g., a pump-and-treat remedy) to stop plume growth 

coupled with restriction of groundwater use to prevent public exposure (U.S. EPA, 1996; NRC, 1994; U.S. EPA, 2001). 

This approach has generally been an effective risk management strategy, preventing unacceptable exposure to DNAPL 

chemicals, and containing plume migration. Long-term success of this strategy, however, depends on providing the 

appropriate controls and restrictions effectively over very long time frames (i.e., many decades). 

On the other hand, this strategy of long-term management is often expensive. The current default assumption is that 

DNAPL sites will require several decades to centuries of plume management with signifi cant cost and future uncertainty. 

Adding to the site owner’s liability is the potential for permanently reduced land value for DNAPL-contaminated property 

as well as threats of natural resource damage claims. Viewed in these terms, source mass depletion has the potential 

benefi t of reducing the time required for maintaining active controls and the associated life cycle cost of cleanup at a 

DNAPL site. This evaluation can be looked at from the standpoint of balancing the upfront cost and effectiveness of 

source removal vs. the long-term cost of controls, compared on a present worth cost basis. A brief discussion of this 

balancing process is presented under Question 4. 

Reduction of Contaminant Mass Discharge to Receptors

Depleting the DNAPL source zone may result in near-term reduction in contaminant mass discharge rate, which is 

the total contaminant mass leaving the source zone per unit time. This mass discharge rate can be thought of as the 

source strength (Md) and is defi ned as the mass of contaminant per unit time migrating across a hypothetical vertical 

cross section (a “control” plane) in the aquifer downgradient of the source zone, and perpendicular to the direction of 

groundwater fl ow (See Figure 3.1). This mass discharge rate divided by the total cross-sectional area of the source 

control plane yields an estimate of the average contaminant fl ux (M L-2 T-1). 
13

Figure 3.1 Schematic representation of a control plane, and a defi nition of the source strength (Md) and local values 

for ground-water fl ux (qi), and contaminant fl ux (Ji).

A classic example is the case of a dissolved-phase plume emanating from a DNAPL source discharging to a surface 

water body or public water supply well. Depleting the mass of DNAPL in the source zone may be useful in eventually 

reducing the total mass discharge rate to the surface water body or supply well, thereby mitigating the risks of unacceptable 

human or ecological exposure to the chemicals of concern from the site. Reduction of the mass discharge rate leaving 

the source zone may also result in near-term plume assimilation and enhanced effi cacy of a natural attenuation remedy 

vs. active plume control measures. 

Recent theoretical analyses (Rao and Jawitz, 2003; Rao et al., 2001) and fi eld experiments (Brooks et al., 2002) 

suggest that partial depletion of DNAPL mass by in-situ fl ushing within the source zone located in unconsolidated 

heterogeneous geologic media can also result in a measurable reduction of the contaminant mass discharge rate at 

the downgradient control planes. In contrast, other modeling analyses have indicated that nearly complete removal of 

DNAPL in homogeneous geologic media is required before measurable reduction in the mass discharge rate is observed

(Sale and McWhorter, 2001). However, more recent analytical and numerical analyses concluded that mass discharge 

rates are expected to decline as the DNAPL mass is depleted (Falta, 2003). Thus, benefi ts from partial source depletion 

are uncertain, and measurement of the mass discharge rate achieved as a function of the degree of source depletion 

achieved becomes a critical issue for evaluating this benefi t when considering source depletion options. The changes 

in the spatial distribution of the local contaminant fl uxes and the magnitude of the resulting mass discharge rate are 

explicitly related to the hydrologic heterogeneity, the initial DNAPL architecture, and the correlation between hydraulic 

conductivity and the DNAPL saturation at the local scale. 

In general, the relationship between the fractional reduction in source-zone contaminant mass (X) and the fractional 

reduction in contaminant mass discharge rate (Y) may be described using an empirical relationship (Rao et al., 2001): 

Y = X 1/β

. The β value represents the “effi ciency” of remediation in terms of mass discharge reduction. Its value (β > 0) 

depends on the degree of heterogeneity of the fl ow fi eld, source-zone architecture (correlation between DNAPL content 

and permeability), and the remediation technology and its implementation. Note that small values of β represent low 

effi ciency (usually the case for the less heterogeneous media), while larger values of β indicate more effi cient contaminant 

mass discharge-rate reduction with mass removal, as is the case for more heterogeneous media. More recent theoretical 

analyses (Enfi eld et al., 2003; personal communication) suggest that these curves can take on more complex shapes, 

depending on the nature of the interactions between hydrogeologic heterogeneity and the source architecture. 

While the benefi ts of a reduction in contaminant mass discharge rate are not necessarily unique to source depletion 

strategies (e.g., source containment could generate similar results), the opportunity for permanence at least conceptually 

should be considered as a potential unique risk management benefi t for source depletion options. Additionally, the potential 

benefi ts in reducing the costs of complementary groundwater remediation technologies should also be accounted for 

as discussed below: 

Enhanced Effi ciency and Effectiveness of Complementary Technologies

Source depletion coupled with attenuation processes to reduce or eliminate receptor concentrations is a prime example, 

but not the only example, of potential benefi ts of DNAPL source removal. The most important attenuation processes 

of interest for DNAPLs include biodegradation and hydrodynamic dispersion. Another benefi t is the reduction in the 
14

contaminant mass discharge rates entering a permeable reactive barrier used for plume containment. This reduction 

may increase the life of a permeable reactive barrier, thereby reducing the frequency (and costs) of barrier replacement 

or regeneration. The thickness of the permeable barrier and thus its capital costs might also be reduced if the overall 

mass discharge rate from the source zone was reduced. The potential for preferential pathways must be accounted 

for, however. In addition, a reduction in mass discharge rate from the source zone may reduce the costs of ex-situ 

groundwater treatment in those cases where hydraulic containment continues to be required to meet regulatory cleanup 

standards at downgradient points of compliance.

Economic Benefi ts

The economic benefi ts of source depletion could include the following: 

• early site closure and return of the groundwater to benefi cial use (the defi nition of site closure will vary 

depending on the site, from unrestricted to restricted use); 

• lower annual overall life-cycle costs (i.e., reduction in annual and long-term operation and maintenance 

(O&M), or creating conditions that allow application of more passive remediation technologies);

• removal of long-term liability and accrued reserves for remediation;

• enhanced land value through reduction or removal of contingencies that reduce land value; and

• land transactions that would not otherwise occur due to the restrictions on land use, or need to retain liability 

and access associated with remedies requiring long-term management.

Although these potential economic benefi ts of source depletion could provide cost savings, generally, source depletion 

technologies will not likely be implemented unless the cost to achieve the benefi t will be less than the benefi cial value 

recovered, taking the risk of failure of the depletion technology into account. Also, the differences between the respective 

accounting practices of government entities (e.g., cost-to-completion) and commercial organizations (e.g., net present 

value) for the reporting of environmental liabilities to their stakeholders can lead to different conclusions on the economic 

benefi ts of the application of source depletion options. In addition, the private sector and the public sector use widely 

different net discount rates when conducting net present value analyses. For commercial organizations, an additional 

factor is the tax consequences of different remediation options, since O&M costs are considered deductible business 

expenses (NRC, 1997a). These two factors will lead to very different conclusions regarding the economic benefi ts of 

source depletion, as will be illustrated in Question 4. 

Environmental Stewardship

Stewardship implies “good governance,” which when well executed yields both intangible and tangible benefi ts. Major 

tangible benefi ts include the following: 1) the earlier recovery of natural resources and placing those resources at 

the disposal of current and future generations, 2) removing a long-term risk, and 3) reducing the likelihood of natural 

resource damage assessments and subsequent claims. Intangible benefi ts are more aligned with features associated 

with leadership versus management. “Picking the right thing to do” is a leadership quality, while “doing the right thing 

well” is associated with management. Responsible parties perceived by the public as picking the right thing to do, and 

being transparent in their decision-making will be supported, and this could be transferred into improved market share, 

increased share value, or support of their policies and positions. 

3.1.2 Potential Adverse Impacts from Use of Aggressive Technologies for Source Depletion 

Here, we consider a range of negative impacts that are possible or likely when aggressive technologies for DNAPL 

source depletion are implemented. Since source containment is not a depletion strategy, we exclude this from our 

discussion, and focus below on various in-situ, innovative technologies that involve some type of aggressive treatment 

of the source zone.

Expansion of the Source Zone

Injection of remedial fl uids containing surfactants or co-solvents, or thermal treatments (e.g., steam, resistive heating) 

has the potential to expand the source zone if adequate hydraulic controls are not in place, or if unexpected mobilization 

of otherwise trapped DNAPL occurs. For example, lowering the interfacial tension by adding surfactants or co-solvents 

may lead to mobilization of DNAPL into zones previously not contaminated. Penetration into low-permeability zones or 

transport to deeper permeable zones is of concern to practitioners, regulators, and site owners. 

Changes in DNAPL Architecture

It is possible that certain in-situ remediation technologies can alter the DNAPL architecture in undesirable ways, causing 

either an increase in DNAPL mass transfer to fl owing groundwater or a reduction in the potential for DNAPL mass 

removal. Mobilization of DNAPL at residual saturations can result in pools of new accumulations above confi ning units, 

thus potentially decreasing effi ciency of mass removal. Injection of certain oxidants (e.g., permanganate) can result in 
15

formation of precipitates (e.g., MnO2) that can form coatings on DNAPL ganglia or pools; this also diminishes access 

to DNAPL mass, thus reducing mass removal effi ciency. Alternatively, removal of some DNAPL mass can actually 

enhance access by altering the permeability distribution, which, in turn, results in an increased contaminant fl ux and 

concentrations (at least, temporarily). This is viewed, by some, as a negative consequence. However, this may only 

be a transient effect.

Changes in Physical Conditions

Aggressive treatment of source zone can, in some cases, result in signifi cant changes in physical properties of the 

treated aquifer zone. For example, in-situ chemical oxidation can lead to formation of precipitates (e.g., MnO2) and 

mobilization of colloidal particles; in both cases, plugging of the permeable zones can reduce formation permeability, thus 

leading to diffi culties in maintaining subsurface fl uids delivery or access to remaining DNAPL mass. Bio-fouling during 

bioremediation can have similar undesirable consequences. Heating may cause the formation of mineral deposits as low 

permeability layers or hard pancakes depending on the geochemistry, as observed at the NASA LC34 demonstration.

Changes in Geochemical Conditions

The injected remedial agents (e.g., chemical, heat) can also alter the geochemical properties within the treated 

zone and downgradient within the dissolved plume. For example, introduction of oxidants and reductants or electron 

acceptors/donors can modify redox conditions (Eh) or pH or salinity. Similarly, byproducts of the intended reactions 

(e.g., organic acids from partial degradation of DNAPL constituents) may also alter geochemistry. Such modifi cations 

can limit (or enhance) microbial processes, enhance mobilization of colloids, and in some cases, promote transport of 

certain metals whose solubility and retardation are strongly dependent on pH and the oxidation/reduction conditions. 

Formation of degradation by-products that are more toxic than the parent compounds is also a concern when altering 

the geochemical environment; for example, the formation of vinyl chloride during reductive dehalogenation of chlorinated 

solvents, PCE and TCE. 

Additional concerns include trace elements present in injected solutions. For example, permanganate-based solutions 

can contain trace amounts of chromium, which could result in unacceptable concentrations of this heavy metal in the 

groundwater. Adverse effects can be mitigated by selection of solutions with acceptably low levels of trace elements and 

applications of these solutions at sites where the geochemical conditions will immobilize/attenuate these constituents. 

Changes in Microbial Ecology

Aggressive treatment of source zones can, in some cases, lead to at least a temporary reduction in microbial biomass, 

biodiversity, or functions. Technologies particularly prone to such adverse effects are in-situ chemical oxidation and 

thermal technologies. Flushing with surfactants and co-solvents can also result in alteration of microbiological processes. 

Limited data are available in assessing such changes, and how, if any, recovery occurs from an initial “insult.” For 

example, KMnO4 residuals can inhibit the formation of anaerobic zones after treatment and increase the time required 

to re-establish biological reductive dechlorination processes. In contrast, residual amounts of remedial agents left in 

the source zone may actually be benefi cial to microbial processes, as is the case with residual ethanol or surfactant 

fermentation products acting as electron donors to promote reductive dechlorination of chlorinated solvents (e.g., see 

discussion on Sages and Bachman sites, Appendix A). Reduction in contaminant concentrations may reduce “toxic” 

effects and permit faster degradation of certain contaminant classes as well.

Deleterious Impacts on the Deployment of Other Technologies

Some or all of the above-discussed potential adverse effects may inhibit or limit the use of other, perhaps less-aggressive 

“polishing,” technologies. For example, if geochemical and microbial alterations are too severe, long-term natural 

attenuation capacity may actually decrease. That being the case, either more source-mass depletion would be required, 

or the dissolved plumes would be longer for a given contaminant mass discharge.

Additional negative impacts could conceivably include the following: 1) inability to commercially develop or use the site, 

both during remediation and even after, if desired endpoints are not reached or adverse effects are deemed too great; 

2) fi nancial and legal consequences of failure to meet target endpoints, and 3) stakeholder concerns when remediation 

of source is judged to have “failed” by not reaching target endpoint in a projected timeline.

3.1.3 Summary 

In summary, source-zone depletion of DNAPL has both potential benefi ts and potential adverse impacts. Careful 

consideration of all intended and unintended consequences, as a part of the remedial design process, is essential for 

successful application of source-zone depletion technologies and further assessment of both the desired and undesired 

consequences of implementing DNAPL source-zone depletion technologies is needed. Quantifi cation of these positive 
16

and negative consequences will signifi cantly improve the quality of decision-making when considering DNAPL 

source depletion options. 

3.2 Question 2: What are the Appropriate Performance Metrics for Assessment of 

DNAPL Source Depletion Technologies?

Choosing and quantifying the appropriate metrics for evaluating the performance of DNAPL source depletion 

technologies is a critical, but diffi cult, task. The Panel is aware of a wide variety of goals and metrics that have been 

applied to address the issue of determining if a remedial action is successful. These goals have included: 1) halting 

migration of contaminants beyond a property boundary, 2) removing mass to the extent “practical,” 3) removing a 

certain fraction of the initial mass, and demonstrating plume stability, and 4) reducing overall human health and 

environmental risks to levels commensurate with the planned land use. 

The metrics used to confi rm these goals are usually estimated from measurements of DNAPL constituents in 

soil and groundwater using standard site characterization techniques. For DNAPL sites where the groundwater 

is considered a potential source of drinking water, the concentration of the chemicals of concern in samples from 

individual groundwater monitoring wells located at agreed upon points of compliance is the current approach for 

assessing success. Generally, these concentrations must be at or below the agreed upon cleanup criteria (e.g., 

MCLs) for some fi xed period of time, determined by site-specifi c conditions. While the Panel realizes that this metric 

will remain a keystone metric in evaluating the success of any remedial strategy on a site-wide basis, exclusive 

reliance on this single metric may be misleading in assessing the performance and potential benefi ts of source 

depletion technologies. Other performance metrics may also be appropriate, especially if they are included as 

assessment tools in determining progress towards the desired end states, as milestones in “pay for performance” 

contracts, and to defi ne intermediate remedial action goals.

The Panel offers the following general considerations related to selection of the most appropriate source depletion 

performance metrics:

• No single metric by itself is likely to be adequate for assessing the performance and potential benefi ts 

of DNAPL source depletion technologies; thus, conjunctive use of multiple metrics should be used to 

evaluate performance. However, the relative signifi cance or “weight” of each metric as it relates to 

decisions on site closure has yet to be developed.

• Some metrics are inherently more variable than others; thus, they are subject to greater uncertainty in 

measurement. The degree of uncertainty may also not be known.

• Often, performance metrics must be inferred from other data. That is, performance metrics are 

determined using primary data from characterization or monitoring efforts. Error propagation must be 

considered.

• Accuracy and reliability of techniques to measure the metrics must be considered when selecting 

metrics for performance assessment (i.e., agreement between multiple methods or validity of a single 

method).

• For a few metrics, multiple measurement methods are available, but for others, methods are not proven, 

and are currently under development. 

• Some performance metrics, while desirable or appropriate, may be prohibitively expensive to measure. 

Thus, methods to estimate these metrics indirectly may be necessary. In such cases, the issue of 

reliability must be considered. 

The last point is especially important. There are several types of distributed and integrated measures of source 

depletion performance assessment that are theoretically possible. It must be recognized, however, that it may not 

be feasible to measure some of these quantities under fi eld conditions, due to cost or implementation constraints.

With this background, performance metrics are grouped below into three categories: Type I metrics that can usually 

be measured reliably, and are commonly used; Type II metrics that can sometimes be measured, but are not in 

wide use; and Type III metrics that are theoretically possible and are under development, but that have not yet been 

demonstrated at multiple fi eld sites.

3.2.1 Type I Metrics

a. Source Mass Removal 

This metric is defi ned as the contaminant mass recovered or destroyed during source depletion. Direct 

measurement is not possible for destruction, and the mass destroyed must be inferred from either mass balance 

of the byproducts generated or based on the difference between the estimated initial and fi nal DNAPL mass. 

This metric may be less important than the mass remaining, but it is easier to quantify in most cases. There 
17

are a number of source depletion technologies that remove mass (as opposed to in-situ destruction). For these 

technologies, quantifying mass removal should be attempted. Although relatively simple to quantify, the relationship 

between this metric and the prediction of long-term success is diffi cult due to inherent uncertainties in estimates 

of the original mass, and the distribution of that DNAPL mass, as well as limitations in modeling tools as will be 

discussed in response to Question 5. 

b. Change in Dissolved Concentrations Within and Downgradient from the Source Zone of DNAPL 

constituents 

This metric is relatively easy to measure using multiple methods, but can be highly variable in space and time. In 

heterogeneous formations, this metric is not linearly related either to the mass remaining in the source zone or to 

the contaminant mass discharge rate. The interpretation of the data from use of this metric is complicated by the 

three-dimensional nature of the contaminated zones in the subsurface, the potential presence of preferential fl ow 

pathways, and fl uctuations in the rate and direction of groundwater fl ow. This is the most common metric used to 

measure performance of a remediation system addressing groundwater contamination. 

3.2.2 Type II Metrics 

a. Mass Remaining (Parent and Byproducts) 

This metric is defi ned as the contaminant mass not recovered (or byproducts created) following implementation 

of a source depletion technology. Contaminant mass can include DNAPL sorbed phase contaminants in stagnant 

zones and dissolved phase contaminants in stagnant zones in addition to the free or residual DNAPL phase. Direct 

and indirect measurement techniques for determining this metric are subject to large errors as discussed under 

Question 3. 

b. Change in DNAPL Distribution Relative to Geological Features (i.e., the DNAPL Architecture)

Direct contact with or diffusive mass transfer from the DNAPL sub-zones to the primary groundwater fl ow channels 

is critical to downgradient impacts in the dissolved plume. In a quantitative approach, source-zone architecture may 

be characterized by multiple parameters that defi ne the spatial statistics of the DNAPL distribution (e.g., mean, 

variance, correlation length) as well as the spatial cross-correlation between the distribution of DNAPL content, 

hydraulic conductivity, lithology, and other aquifer characteristics. In practice, however, it is either diffi cult or too 

expensive to measure such statistical parameters to describe quantitatively the source-zone architecture.

The spatial distribution of NAPL content within the source zone can be determined either by intensive soil-core 

sampling (Rao et al., 1997; Meinardus et al., 2002) or sampling at a number of multilevel sampling locations during 

partitioning interwell tracer tests (PITT) (Sillan et al., 1998; Meinardus et al., 2002). The inference of NAPL spatial 

distribution from inverse stochastic modeling of PITT tracer data has also been attempted (James et al., 1997; 

Zhang and Graham, 2001). 

c. Change in DNAPL Composition and Properties

Some remediation technologies can change the composition and behavior of DNAPLs, making them more or less 

mobile, soluble, volatile, and more or less recalcitrant or toxic with changing composition. For multi-component 

DNAPLs, total mass reduction may not necessarily be the relevant objective. Rather, the removal of certain target 

compounds from the mixture may be more appropriate. For example, for coal tar source zones, thermal or fl ushing 

techniques can generally lead to selective removal of the more soluble or more volatile constituents, leaving behind 

some components (usually of higher molecular weight) as the residuals. The environmental and health risks posed 

by these residuals need to be considered in assessing the likely benefi ts of source-zone mass depletion. For 

example, bioavailability of some chemicals may decrease after source depletion, reducing the environmental risks 

of the remaining mass of chemicals of concern.

d. Physical, Microbial, and Geochemical Changes

As performance metrics, measurement of these parameters is useful to assess the ability to apply follow-on 

technologies, or to evaluate the effect of natural degradation processes on the remaining DNAPL source and 

corresponding mass fl ux. Aggressive source depletion activities may cause changes in the physical, chemical, and 

microbial subsurface environment. The changes may occur in the source zone, as well as downstream of the source 

zone. Changes in these three types of parameters can be assessed through physical examination of cores and 

hydraulic measurements (for assessment of physical changes), groundwater samples for geochemical/microbial 

analysis using conventional analytical techniques for geochemical analysis, and traditional and molecular techniques 

for microbial evaluations. These changes may be benefi cial (e.g., improved porosity to fl ush reactants or nutrients), 

neutral, or negative (e.g., decreased porosity, or decimation of key microbial species). They may be short-term 

effects, or they may be permanent. These changes may also interfere with measurement of other performance 

metrics. 
18

3.2.3 Type III Metrics 

Type III metrics are theoretically possible, but technologies to quantify these metrics are still under development and 

have not yet been widely demonstrated in the fi eld. 

a. Change in Contaminant Mass Flux Distribution Downstream of the Source Zone 

Contaminant mass fl ux is the locally defi ned contaminant discharge per unit area (the product of the mass 

concentration and the Darcy fl ux). The change of the contaminant mass fl ux can have a large impact on local 

biogeochemical reactions downgradient of the source. Currently, mass fl ux as a metric is being evaluated in a 

number of research settings, and as discussed under Question 1, a number of innovative approaches to quantifying 

this parameter are under investigation. However, it must be stressed that the use of the reduction of mass fl ux as 

a performance metric to evaluate source depletion technologies is not generally accepted practice, and has not yet 

been embraced by the regulatory community. State regulators, working through the ITRC, have expressed interest in 

this metric and are currently (2003) preparing a guidance document on the application of mass fl ux measurements 

to performance assessment of source-zone depletion technologies (see ITRC website for details). However, the 

majority of regulators still consider point measurements of contaminant concentrations as the primary metric for 

determining the success of any remedial action. In addition, the feasibility of measuring mass fl ux distributions in 

some geologic settings such as fractured systems is still uncertain, and research efforts are needed to address 

these uncertainties regarding the accuracy and feasibility of quantifying this metric. 

b. Change in Mass Discharge Rate Downstream 

This metric provides information on the total rate of contaminant mass discharge from the source to the groundwater. 

The mass discharge rate is calculated using the measured spatial integral of the contaminant fl ux distribution (Hatfi eld 

et al., 2001, 2002), or measured using pumping wells that capture the dissolved plume (Bockelmann et al., 2001; 

Ptak and Teutsch, 2000). The contaminant mass discharge rate, in units of mass per time, can be used to calculate 

the fl ux-weighted averaged concentration over the control plane of interest. Measurement at multiple control planes 

in a plume can be used to infer the attenuation rate and to distinguish the attenuation mechanisms, differentiating 

between dilution and degradation processes (Bockelmann et al., 2001; Ptak and Teutsch, 2000).

c. Change in Stable Isotopes

Technologies that destroy DNAPL mass may also enrich carbon isotopes of the parent chemicals. Comparing the 

composition of products and reactants in the dissolved phase (near or downgradient of the source) can be used to 

estimate the amount of source depletion. 

3.2.4 Summary

Determining the most appropriate metrics for performance assessment of DNAPL depletion technologies compared to 

selected remedial action goals is a non-trivial task. Regulators are likely to continue to rely on point measurements at 

points of compliance as the primary metric of success when the remedial action goal in a source zone is specifi ed as 

the concentration of the chemical of concern in groundwater. Use of this point measurement as the only metric does not 

provide suffi cient information to assess the overall performance and thus overall benefi ts of source depletion technologies 

as it relates to life cycle costs and overall risk reduction. The Panel urges EPA to consider other performance metrics 

as discussed above to ensure that a broader range of potential benefi ts of source depletion can be quantifi ed. Details 

of the Panel’s recommendation on this matter are presented in Section 4.0. 

3.3 Question 3: Are Available Technologies Adequate for DNAPL Source Characterization 

to Select and Evaluate Depletion Options?

Pre- and post-remediation characterization of the DNAPL source zones is an essential component of contaminated site 

assessment and selection/implementation of remedial options. Investment of time and resources in site characterization 

provides: 1) more reliable risk assessments, 2) more informed decisions being made about choices among remedial 

options, 3) development of optimal designs for remediation, 4) more effi cient deployment of remediation technologies, 

and 5) more accurate post-remediation audits to judge performance and achievement of the interim cleanup goals or 

the fi nal end points required for full closure.

Locating the DNAPL is required in order to characterize and remediate it. Over the last few years, several tools have 

been developed and signifi cant advances have been made in the characterization of DNAPL sites. However, given 

historical and potentially large and multiple releases combined with complex subsurface DNAPL migration patterns, 

DNAPL sources are still diffi cult to characterize with the available tools, and the level of uncertainty can be as high as 

an order of magnitude or more.
19

3.3.1 Innovations in Site Characterization Approaches

Traditional, phased approaches to site characterization – constrained by the use of prescriptive protocols and analytical 

methods – have placed an undue emphasis on the process rather than the purpose of site characterization. Such 

approaches have, in the recent past, limited the faster adoption of innovative site characterization and remediation 

technologies, and have often added to the costs and delays in undertaking site remediation at contaminated sites. 

Even when prompt decisions have been made, various types of uncertainties in characterization data have contributed 

to concerns about the quality of the decisions made. In a linear process, where the site characterization issues are 

decoupled from the remedial design and assessment, decisions made tend to be sub-optimal, both in terms of costeffectiveness and the achievement of target remediation goals in a timely fashion.

An ideal approach to site characterization should have the following elements (see Crumbling, 2001; EPA 542-R-01-

016): 1) emphasis on achieving performance (e.g., meeting remedial goals), not on a regimented process and check 

lists, 2) uses transparent, logical reasoning to develop site plans, 3) engages multi-disciplinary teams to manage the 

complex issues, 4) requires continual education and training of the teams engaged in site work, 5) site professionals 

deal with various uncertainties and can evaluate the appropriateness of using innovative technologies, 6) rewards 

responsible risk-taking, and 7) uses the concept of “keeping the end in mind” to improve decision-making on the extent 

of characterization required. 

The Triad approach (Crumbling, 2001; Crumbling et al., 2001) to site characterization attempts to incorporate these 

elements by integrating systematic planning, dynamic work plans, and real-time analyses into a comprehensive and 

more effective approach. Planning engages multi-disciplinary teams to develop and articulate multiple project goals, and 

involves the identifi cation of various uncertainties that can infl uence decision-making. Dynamic work plans (also referred 

to as accelerated, or adaptive, or expedited characterization) are “choreographed” by the project’s multi-disciplinary 

teams. 

3.3.2 Innovations in Site Characterization Tools

The fi rst step in locating DNAPL sources is development of the site history concerning chemical storage, usage, and 

disposal. The next step is to characterize subsurface conditions away from any potential DNAPL sources. This is 

referred to as an “outside-in” approach. Such an approach allows development of an understanding of stratigraphy, 

groundwater fl ow, and contaminant distribution while minimizing the risk of cross contamination by drilling through a 

DNAPL zone. Dissolved concentrations in groundwater, which is an integrator of contamination, can be used along with 

site history information to “backtrack” to potential DNAPL source zones. The next step in the characterization process 

is to characterize the DNAPL zone, if appropriate, where the focus is more on soil data. Characterization will likely 

continue into the remediation stage.

During this initial work, a realistic site conceptual model is developed based on stratigraphy. Noninvasive and minimally 

invasive methods are used fi rst, and plume information is used to infer up-hydraulic gradient source conditions. Source 

investigation methods are then selected that provide desired remediation data and minimize the risk of DNAPL mobilization. 

The following discussion provides a summary of available tools for site characterization in DNAPL source zones. A 

compilation of literature citations and information sources for site characterization is provided in Section 6.0.

Non-Invasive Tools: Non-invasive tools that can be used for DNAPL characterization include: 1) site history information 

(e.g., chemical use, inventory and disposal records), 2) historical aerial photographs, 3) geological fractures and outcrops, 

4) soil gas analysis, 5) surface geophysics, 6) site infrastructure information (e.g., sewers) and 7) employee/witness 

interviews. Soil gas surveys can be either passive or active. For DNAPL source identifi cation, old releases, particularly 

in hot environments, may have a limited soil gas signal due to weathering. Measurement of naturally occurring radon 

(radon-222), which partitions into DNAPL, has been used at a few sites to infer DNAPL presence. Conventional surface 

geophysical methods are used to delineate stratigraphy, buried metal and conductive fl uids. Subsurface DNAPL is a 

poor target for geophysical methods; thus, direct detection of DNAPL is unlikely by this technology.

Invasive Tools: Invasive tools that can be used for DNAPL characterization include: 1) test pits, 2) probing and drilling, 

3) soil examination methods, 4) downhole methods, 5) groundwater quality profi ling using direct push (DP) and multilevel 

wells, 6) well measurements for DNAPL distribution, 7) characterization of DNAPL samples, 8) borehole geophysics, and 

9) partitioning interwell tracer tests (PITTs). Test pits are an effi cient way to observe shallow stratigraphy and DNAPL 

contamination distribution. All of these tools with the exception of the PITT have been widely used to characterize 

DNAPL zones. The PITT has also received extensive testing and demonstration, but its high cost tends to limit the 

widespread deployment of this technology except at very large sites such as DNAPL source areas at DOE or DOD 

facilities. Also, uncertainties still persist on the accuracy of the PITT where signifi cant DNAPL mass may be present in 

low permeability zones in the subsurface. Other invasive tools are discussed below.
20

For probing, two widely used direct-push (DP) sampling techniques are rotary hammer or percussion methods 

(Geoprobe®) and cone penetration testing (CPT). The benefi ts of direct-push sampling include: 1) a variety of tools 

that can be used, 2) rapid stratigraphic logging and contaminant detection using sensor systems, 3) rapid, depth-discrete 

sampling of soil, soil gas, and water, 4) no drill cuttings and little investigation-derived waste (IDW), 5) minimally invasive

with effective grouting and sealing capabilities, 6) reduced potential for contaminant drag-down, and 7) the availability 

of standard methods (ASTM D-6282 for direct-push soil sampling, ASTM D-6001 for direct-push groundwater sampling, 

and ASTM D-3441 for cone penetration testing). The advantages and limitations of the direct push sampling techniques 

are listed in Table 3-1. 

For drilling, there are several technologies available. One newer drilling technology is rotasonic drilling. It employs use 

of high-frequency mechanical vibration and limited rotary power to drill. This technology is fast, can provide excellent 

quality, large diameter, relatively undisturbed cores of soil and rock for characterization, and minimizes IDW. Contaminant 

drag-down is a reduced concern because an outer casing is advanced as drilling proceeds, but the technology has limited 

availability and relatively high cost and may bias sampling because of heat generated during the drilling process.

Methods to examine soil cuttings/core above ground include: 1) organic vapor analysis (OVA), 2) ultraviolet (UV) 

fl uorescence, 3) hydrophobic dye shake test, 4) Ribbon NAPL Sampler (RNS) core strip test, and 5) chemical and 

partitioning analyses. Chlorinated solvents do not fl uoresce unless they are mixed with petroleum products (e.g., cutting 

oil), coal tar, or naturally occurring humic compounds that do fl uoresce. The hydrophobic dye shake test involves mixing 

the soil sample with water and hydrophobic dye powder (e.g., Sudan IV). The RNS cover is a hydrophobic dye-striped 

tubular fabric designed to contact soil core extruded from a core barrel. Advantages and limitations of these methods 

are listed in Table 3-1. 

For chemical analysis of soil core samples, it is important to minimize volatility losses (e.g., by using methanol as 

a preservative – EPA SW846 Method 5035). Equilibrium partitioning calculations can then be performed using the 

code NAPLANAL www.dnapl.com/publications.html) or similar methods to infer NAPL presence. Based on equilibrium 

partitioning calculations, the presence of DNAPL may be inferred from soil concentrations as low as a few hundred 

mg/kg.

Down-hole Methods for Detecting DNAPLs: Down-hole methods include 1) membrane interface probe (MIP), 2) RNS 

(aka NAPL FLUTe), and 3) cone penetrometer technology (CPT)/laser induced fl uorescence (LIF). The MIP is a direct 

push-logging tool that records continuous relative VOC concentrations. It is used in combination with the electrical 

conductivity to provide rapid, real-time, detailed characterization of stratigraphy and VOC contamination. The RNS uses 

a pressurized fl exible liner to support and seal a borehole and force a dye-striped NAPL absorbent ribbon against the 

borehole wall. Advantages and limitations of these methods are listed in Table 3-1. 

Three different downhole fl uorescence detection systems have been developed: 1) Site Characterization and Analysis 

cone Penetrometer Systems (SCAPS), 2) Rapid Optical Screening Tool (ROST), and 3) Fuel Fluorescence Detector 

(FFD). CPT uses strain gauges to measure soil behavior properties while LIF provides real-time logging of fl uorescent 

contaminants. Thus, like MIP, CPT/LIF provides real-time characterization of stratigraphy and fl uorescent contamination. 

The SCAPS CPT/LIF was developed by the Navy, Army, Air Force, and DOE; there are approximately eight units 

available for federal government use. ROST was developed by Dakota Technologies, Inc. (DTI) and marketed by Fugro, 

which operates seven ROST systems in the U.S. and Europe. FFD was developed by Applied Research Associates 

(ARA), which operates more than 20 FFD units in the U.S. Advantages and limitations of these systems are listed in 

Table 3-1. 

Groundwater Profi ling: Groundwater profi ling downgradient of DNAPL source areas is used to backtrack to the source 

area. The profi ling can be performed with either DP tools or multilevel wells. DP tools are used to collect multiple discrete 

groundwater samples from coarse sediments at multiple depths in a single hole. Available tools include 1) Waterloo 

Profi ler®, 2) Geoprobe® Dual Tube and GW Profi lers, and 3) VERTEK ConeSipperTM. In order to apply these tools, 

one needs to know the stratigraphy to select sampling zones. Advantages and limitations of these tools are listed in 

Table 3-1. 

For measuring groundwater quality, hydraulic head, and hydraulic conductivity in overburden and bedrock over time, 

multilevel groundwater monitoring systems can be used. Multilevel groundwater monitoring systems include: 1) conventional 

well clusters, 2) Continuous Multichannel TubingTM(www.solinst.com), 3) Waterloo Multilevel System (www.solinst.

com), and 4) Westbay MP System® (www.westbay.com), and 5) Water FLUTeTM(www.fl ut.com). Interpreting dissolved 

concentrations may be diffi cult due to non-uniform DNAPL distribution, mixing of groundwater in the well (a function of 

the well screen length), and effective solubility when dealing with multi-component DNAPLs. For conventional wells, 

the general guidance is that concentrations greater than 1% of the effective solubility suggest the presence of DNAPL, 

and concentrations exceeding 10% of the effective solubility indicate a very high probability of DNAPL. Unfortunately, 

the exact location of the DNAPL is not easily inferred from the aqueous phase concentration data, and estimates of the 

source-zone volume may be overestimated using these empirical rules of thumb regarding DNAPL presence. 
21

Table 3-1. Advantages and Limitations of Various Site Characterization Technologies 

TOOL ADVANTAGES LIMITATIONS

Percussion Probing 

(Geoprobe®) 

-Less expensive 

-More mobile and available 

-Well developed sampling tools 

-Availability of certain sensors 

-Difficult to penetrate hard dense soils 

-Depth limitation 

Cone penetration -Greater depth penetration 

-Certain sensors better developed 

 (LIF, tip resistance, sleeve friction, etc.) 

-More expensive 

-Less available 

-Less maneuverable 

Organic vapor 

analysis 

Screening of soil 

cores 

-Rapid and inexpensive 

-High concentrations of VOCs associated 

with NAPL presence 

-Useful to focus sampling 

-Readings sensitive to effective 

contaminant volatility, water content, 

sample temperature, and sample handling 

UV fluorescence 

detection methods 

-Quick and inexpensive 

-Many NAPLs fluoresce 

-Can provide detailed information on 

relationship between stratigraphy and 

contaminant distribution 

-Can document using a digital camera 

-Requires fluorescent NAPL 

-Indiscriminant 

-Interfere from non-target fluorescent 

materials (such as shell fragments in 

coastal sediment) 

-Significant potential for false positives 

and false negatives 

Hydrophobic dye 

shake 

Test use and 

limitations 

-Simple, quick, and inexpensive field 

methods for qualitative assessment and 

visual confirmation 

-Does not require analytical equipment 

-Known background and NAPLcontaminated samples should be 

examined to check for interference and 

site-specific response 

-Can only detect NAPL if present in 

samples 

-Potential for false positives (reaction with 

other organic matter) and false negatives 

(not enough NAPL present) 

-Visual contrast can be difficult to discern 

in dark soil 

Using RNS strips to 

detect NAPL in soil 

core 

-Relatively simple, direct, and cost-effective 

(~$4/ft for hydrophobic dye-impregnated 

cover) 

-Can provide detailed information on 

relationship between stratigraphy and 

contaminant distribution 

-Amendable to rapid documentation via 

photography 

-Minor discoloration of liner associated 

with handling and contact with plastic 

core sleeves 

-Relatively faint reaction to some NAPLs 

-Color fading and/or non detection due to 

evaporation 

-Potential for false positives and false 

negatives 

-Potential for cross contamination (open 

hole) 

Membrane interface 

probe (MIP) 

-Widely available 

-Simultaneous log of VOCs and soil 

conductivity 

-Operates in vadose zone and soil 

conductivity 

-Useful for delineating NAPL source zones 

-Rapid site screening (100s of feet per day). 

-Cost savings 

-High detection limits, qualitative 

analytical data 

-Designed for volatile contaminants 

-Contaminant carryover can be high 

-Penetration resistance limitations 

-Shallow use 
22

Table 3-1. Advantages and Limitations of Various Site Characterization Technologies, continued 

TOOL ADVANTAGES LIMITATIONS

Downhole RNS 

(aka NAPL FLUTeTM) 

-Provides continuous record of NAPL 

distribution with depth at borehole location 

-Can be deployed in variety of hole types 

-Can provide cost savings 

-Heterogeneity may limit value of 

information 

-Relatively ambiguous reaction to some 

NAPLs may be difficult to interpret 

-Wicking may exaggerate NAPL presence 

-Potential for false positives and false 

negatives 

-Potential for cross contamination 

CPT/LIF UV 

fluorescence probes 

-Real-time delineation of stratigraphy and 

fluorescent contamination 

-Typical daily productivity of 300 to 400 feet 

at 10 to 15 locations 

-LIF waveforms offer product 

identification/verification and rejection of 

non-contaminant fluorescence 

-Reduced IDW and exposure to site 

contaminants 

-Potential cost savings 

-Primarily applicable to PAHs 

-Subject to interferences 

-NAPL has to be adjacent to sapphire 

window 

-Limited availability 

-Cost 

DP groundwater 

profiling 

-No drill cuttings and little purge water 

-Can pump clean water out through screen 

during advancement to minimize clogging 

and drag-down of contaminants 

-Can collect multiple samples (at any 

spacing) with depth using peristaltic or 

pneumatic low-flow pumping methods 

-Can perform K tests 

-Can develop well screen 

-Holes can be grouted through rods 

-Provides detailed concentration profiles 

that can be used for backtracking to NAPL 

source 

-Rapid and relatively cost-effective 

-Limited by lithology (clogging, turbidity, 

and lack of yield problematic in finegrained sediments) and depth (depending 

on drilling and sample collection methods) 

-Only provides a snapshot in time of water

quality 

-Concentrations of metals and 

hydrophobic compounds likely to be 

biased due to sample turbidity 

-Vertical hydraulic gradients can 

impact backtracking interpretation 

-Due to heterogeneity and dilution 

effects can still be difficult to define 

morphology of DNAPL sources 

-Concentration > effective solubility 

 indicates NAPL in sample 

-Concentration < effective solubility 

requires interpretation 

PITT -Can estimate DNAPL saturation -Need to know DNAPL location 

-Need sufficient hydraulic conductivity for 

tracer test 

-Need small enough source to allow 

adequate well spacing to conduct tracer 

test in reasonable time frame 

-The presence of natural organic carbon 

may cause some difficulty with the 

interpretation of the results 

-For heterogeneous DNAPL distribution 

(especially pools), underestimates 

DNAPL volume 

-Expensive and regulatory concerns may 

require recovery of tracers 

 
23

DNAPL Mass and Distribution: If DNAPL does fl ow into a well, it is important to determine DNAPL thickness and 

collect a DNAPL sample to determine its properties (e.g., density, viscosity, composition, interfacial tension.). Other 

invasive tools include borehole geophysics. Unfortunately, DNAPL is a poor target for geophysical methods, and they 

are unlikely to detect DNAPL. Residual DNAPL saturations may be estimated using a PITT by comparing the retardation 

of tracers that partition into the DNAPL (e.g., alcohols) to tracers that are not retarded (e.g., bromide). Advantages and 

limitations of PITT are listed in Table 3-1. Another way to estimate DNAPL saturation is the push-pull partitioning tracer 

test using naturally occurring radon-222 (Davis et al., 2003).

DNAPL Mass Discharge Rate and Flux Distribution: As discussed in earlier sections, it is important to estimate 

the downgradient contaminant mass discharge rate or fl ux distribution. This estimate could be important as a metric 

to assess DNAPL source remediation and/or as a key input to evaluate monitored natural attenuation. There are three 

methods to estimate mass fl ux: 1) use water quality data from transects (multiple location and depths) combined with 

groundwater velocity, 2) use downgradient aquifer tests in a transect of wells, tracking mass pumped, and 3) use sorptive 

permeable media placed in downgradient wells to intercept contaminated groundwater and release resident tracers. 

Additional information on these approaches was discussed in Question 2. 

3.3.3 Summary

DNAPL site characterization tools are available to collect data and information for most of the performance metrics 

identifi ed in Question 2. Because of the inherent complexities of DNAPL migration and distribution in subsurface 

environments, as discussed in Section 2.0, none of the characterization tools is without accuracy limitations. This topic 

has been thoroughly reviewed in the literature, and several recent summaries provide adequate information for selection 

of the appropriate site characterization tools for the purposes of selection, design, and performance assessment of 

DNAPL source depletion technologies. 

The Panel concluded that although available technologies are adequate to locate DNAPL source zones (e.g., footprint of 

the suspected source zone), in practice, delineating the DNAPL source zone and determining the actual mass of DNAPL 

is very diffi cult, particularly in fractured systems, and will only be possible with extensive sampling at the majority of 

sites. This could involve soil-core analysis on a very small interval, perhaps as small as a few inches in the vertical and 

a few feet in the horizontal. As the geological setting becomes more complex, and the scale of the potential source area 

increases, this level of detailed sampling becomes impractical, resulting in uncertainty in source-zone characterization. 

The cost and level of accuracy achievable by source-zone characterization tools can only be answered on a site- specifi c 

basis. Further investment by EPA in determining the level of accuracy required for source-zone characterization tools 

as a function of subsurface geologic conditions, the specifi c DNAPL depletion technology, and the remediation goals 

and metrics is warranted. 

New techniques for monitoring groundwater fl ow and contaminant mass discharge rate or local mass fl uxes have been 

developed, but to date, these methods have been fi eld tested at a limited number of sites. Comparative testing of these 

new methods is just getting underway with funding from SERDP and other agencies. Further guidance on reliability of 

mass fl ux and discharge rate monitoring must wait for completion of these investigations. EPA support of these efforts 

is encouraged. 

To better evaluate the success of source-zone depletion technologies at DNAPL sites, a set of diagnostic tools is needed 

for application at hydrogeologically distinct sites employing a range of innovative in-situ chemical, biological, and thermal 

treatment technologies. Mass fl ux or discharge rate measurement may serve as a useful metric of overall system 

performance, independent of the mass depletion technology used, because these measurements can demonstrate a 

reduction in the rate of contaminant mass release from the treated zone. Innovative technology-specifi c tools (e.g., 

molecular tools for in-situ bioremediation), and geology-specifi c tools are also needed for a real-time diagnosis of 

remedial technology performance. 

3.4 Question 4: What Performance can be Anticipated from DNAPL Source-Zone Depletion 

Technologies? 

EPA asked the Panel to assess the “status of technology development and deployment for DNAPL source remediation” 

and to evaluate the costs of using these technologies. In addressing these issues, the Panel recognizes that many 

technologies have been implemented for DNAPL source-zone remediation as a component of site groundwater remediation 

strategies, and substantial information is available on the effectiveness and costs of these systems. The Panel is also 

familiar with the substantial efforts of various federal agencies to document DNAPL remediation projects. EPA’s Offi ce 

of Research and Development (ORD) has funded research on the development of new technologies for DNAPL source 

remediation through EPA labs, the SITE program, or through university research programs. Development and deployment 

of DNAPL source-zone technologies have also been supported by the DOE, the Department of Defense (DOD) through 

the Strategic Environmental Research and Development Program (SERDP), and various international agencies.
24

Over the past two decades, a number of technologies have emerged with the potential to achieve substantial reduction 

in the mass of DNAPLs found in either the vadose zone or the saturated zone, depending on the geologic conditions in 

the subsurface. EPA’s Technology Innovation Offi ce (TIO) and EPA’s SITE program have compiled numerous reports and 

other documentation on the effectiveness of these technologies for remediation of DNAPL impacted sites. The DOE has 

also documented DNAPL removal technology demonstrations at DOE facilities (see e.g., NRC, 1999). Since 1994, several 

committees of the National Research Council have also compiled summaries of groundwater remediation technologies 

(NRC, 1994; 1997; 1999; 2003) with some focus on source remediation options (NRC, 1997b; 1999; 2003). 

Other sources of information on the status of technology development and deployment of source remediation technologies 

include the peer-reviewed literature and vendor or consultant non-peer reviewed reports. Numerous web sites also provide 

access to large amounts of information on source depletion options (e.g., Interstate Technology Regulatory Council, 

[ITRC], www.itrcweb.org; the Strategic Environmental Research and Development Program, [SERDP], www.serdp.org; 

Federal Remediation Technologies Roundtable, [FRTR], www.frtr.gov; Ground-Water Remediation Technologies Analysis 

Center, [GWRTAC], www.gwrtac.org.; various EPA web sites, including Technology Innovation Offi ce [TIO]). 

However, the Panel was not provided the resources to undertake a thorough assessment of this extensive body of 

information. Instead, we provide here the collective judgment of the Panel on three issues related to the performance 

of technologies for DNAPL source-zone mass depletion, namely, a) the status of development and deployment of the 

technologies, b) the anticipated performance of these technologies for different DNAPL release and distribution scenarios, 

and c) a brief commentary on cost of these technologies relative to containment options. 

3.4.1 Status of Development and Deployment of DNAPL Source-Zone Depletion 

Technologies

In addition to DNAPL pumping, the four major generic categories of technologies applicable to DNAPL source depletion 

are fl uid fl ushing and recovery technologies, thermal technologies, chemical degradation (oxidation or reduction) 

technologies, and biodegradation technologies. Table 3-2 lists some of the specifi c technologies within these categories 

that have been deployed in either small scale controlled fi eld experiments, pilot studies at DNAPL-impacted sites, or 

as part of a fi nal remedial action at the full fi eld scale level. Several of the listed technologies have demonstrated the 

potential to achieve substantial DNAPL depletion from source zones. 

The following material presents a brief technical description of each of these technologies.

Water Floods: Water fl oods involve the injection of water to mobilize DNAPL towards an extraction well and to improve 

the rate of DNAPL dissolution. We consider this technology, which has been widely used in the petroleum industry, 

to be suffi ciently developed and available for deployment in DNAPL source depletion applications. The technology is 

applicable at sites where DNAPL may be mobile, such as coal tar and creosote sites (e.g., see Sale and Applegate, 

1997). The technology may be suitable for source-zone applications if stabilization of the DNAPL mass is one of the 

remedial action objectives since the mobile DNAPL will then be extracted. The technology is not capable of removing 

residual DNAPL. 

Steam Enhanced Extraction: Steam enhanced extraction (SEE) is a thermal technology that utilizes steam to heat 

the subsurface environment, combined with vapor and liquid extraction to recover vapors, contaminated water, and 

DNAPL. Air co-injection with the steam increases the recovery rate of volatile DNAPLs during the time between the 

beginning of steam injection and the arrival of the thermal front to the extraction wells (see Hunt et al., 1988; Udell et 

al., 1997). Because the injected air facilitates the removal of the DNAPL mass as a vapor, remobilization of NAPL due 

to condensation at the edge of the heated zone can be minimized. Steam injection can achieve uniform heating of 

the source zone to the steam temperature that causes complete vaporization of the more volatile DNAPLs including 

chlorinated solvents (such as PCE) with boiling points greater than that of water. This technology is most applicable to 

hydraulically accessible media with DNAPL in pools of signifi cant mass and DNAPL distributed as residuals with small 

total mass. For hydraulically inaccessible zones that can be heated to steam temperature (modest thickness heated 

from two sides), it is also applicable to DNAPL of signifi cant mass and signifi cant dissolved mass. 

In Appendix A, one case study of SEE is presented. Substantial amounts of a mixture of LNAPLs and DNAPLs were 

removed, but MCLs in the source zone were not achieved at the conclusion of the SEE demonstration. Subsequent 

monitoring appears to show that chemicals of concern have decreased below detection limits within the remediation 

zone (Udell, 2002). Cost data were not available for this case study.

Another case study of the use of steam-enhanced extraction is the Visalia Pole Yard Site in California. This site is a 

former wood-treating facility that exhibited extensive creosote and pentachlorophenol contamination in the saturated zone. 

Over 170,000 gallons of DNAPL have been removed or destroyed at this site where the source zone is approximately 

1.8 acres in areal extent. Reportedly, concentrations of chemicals of concern at the site are not yet below regulatory 

levels at all points of compliance, but site managers are optimistic that site closeout will be achieved within the next 

few years (Sciarrota, 2002; see also TIO website for more details). The cost to date appears to exceed $25 million 
25

CATEGORY TECHNOLOGY PRIMARY MODE OF ACTION

Fluid Flushing Water Flooding and Extraction Removal of mobile DNAPL through application 

of sufficient hydraulic forces for DNAPL 

recovery, commonly used for oil recovery.

Surfactants/Cosolvents Solubilization/mobilization and recovery via 

extraction wells with use of a variety of 

surfactants, foams, cosolvents.

Air Sparging Injection of air into saturated zone, and 

volatilization of DNAPL with recovery of vapors 

by soil vapor extraction.

Thermal Steam Steam injection into saturated zone, heating of 

groundwater to steam temperature, 

mobilization/volatilization of DNAPL and 

recovery via water and vapor extraction wells.

Electrical Resistance Heating - Vertical 

Electrodes

Three-phase or six-phase electrode arrays to 

provide thermal energy to subsurface formation 

(soil or groundwater), with recovery of fluids by 

vapor extraction or fluid extraction wells. 

Conductive Heating - Thermal Blankets or 

Thermal Wells

Electrical heating via thermal "blankets" placed 

horizontally at ground surface or vertical 

thermal wells. 

Chemical Chemical Oxidation with Various Chemical 

Solutions

Abiotic direct chemical oxidation of DNAPL by 

chemical solutions (sodium or potassium 

permanganate, persulfate, Fenton's reagent) 

injected into subsurface.

Zone Source Encapsulation and Chemical 

Reduction

Injection of clay/zero valent iron into source 

zone to produce hydraulically inaccessible 

zone, reduction of DNAPL by diffusion and 

reaction with zero valent iron.

Microbial In-situ Biodegradation Injection of electron donor solutions (e.g., 

lactate) in source zone for stimulation of 

indigenous anaerobic dechlorination microbes 

that accelerate dissolution of DNAPL and 

subsequent microbial reduction of chemicals.

Combined Cosolvent Flushing and Enhanced 

Microbial Anaerobic Reduction

DNAPL removal by solubilization/ mobilization 

followed by enhanced anaerobic dechlorination 

to ethene.

Steam with Air/Oxygen Injection Hydrolysis/pyrolysis technology for DNAPL 

removal and abiotic oxidation of DNAPL 

constituents.

Thermal Methods Combined with Microbial 

Degradation

Steam, conductive or resistive heating followed 

by microbial degradation at appropriate 

temperatures.

dollars. Independent verifi cation of these costs has not been reported. Final projected costs to site closure have also 

not been reported. 

EPA’s Technology Innovation Offi ce (TIO) of the Offi ce of Solid Waste and Emergency Response (OSWER) recently 

published a compilation of case studies on the use of thermal technologies for soil and groundwater remediation at 

chlorinated solvent impacted sites (U.S. EPA, 2003). This report provides case studies on several full-scale SEE case 

studies involving chlorinated solvents in unconsolidated media and indicates that SEE has been implemented for DNAPL 

depletion in source zones at 14 sites in either full- or pilot-scale. At these sites substantial amounts of chlorinated solvent

DNAPLs were removed, and for a few sites, no further action letters were issued by regulators.

Table 3-2 Summary of DNAPL Source Depletion Technologies Currently Available or Under Development
26

Electrical Resistance and Thermal Conductive Heating: Introduction of thermal energy into the subsurface through 

conductive heating by placement of electrodes, and application of AC voltage (typically 440V), has been used as a 

thermal-based source depletion technology at several DNAPL sites. Electrical resistance heating (ERH) technologies 

utilize vertical electrodes to introduce thermal energy. Heating by electrical current has been applied using three-phase 

AC, six-phase AC, and DC voltage. (See TIO website for details; also see U.S. EPA, 1999b). Thermal Conductive 

Heating (TCH) technologies use horizontal electrodes placed on the ground surface to inject heat into the subsurface by 

conduction through the soil. Since the electrical current follows the most conductive pathway, and the heat dissipation 

occurs in zones of high current density, electrical heating by conduction is independent of the hydraulic properties of 

the aquifer material. 

One of the THC technologies, known as In-Situ Thermal Desorption (ISTD), has been primarily used to remove organic 

contamination in the vadose zone (see e.g., Stegemeier and Vinegar, 2001). Signifi cant removals of DNAPLs in soils 

have been demonstrated. Soil temperatures can reach levels of several hundred degrees Celsius using this technology. 

There is also compelling data that suggests that accelerated oxidation of chlorinated compounds may occur at elevated 

temperatures, giving rise to the possibility of abiotic destruction after heating has ceased. 

All of the electrical heating technologies are commercially available, and suffi cient information is available to conduct 

feasibility assessments on the use of these technologies for DNAPL source-zone depletion. 

One of the case studies in Appendix A (Cape Canaveral) evaluated the performance (effectiveness and cost) of electrical 

heating to remove TCE present as DNAPL from the aquifer. This study did not demonstrate that the ERH technology 

was likely to be a cost-effective approach to source depletion at this site. See Appendix A for details. Other reports 

including commercial literature from the vendors of these technologies indicate removal of large amounts of NAPL from 

several sites, and several case studies reported in the non-peer reviewed literature, (e.g., various Battelle Conference 

Proceedings) indicate that site closure has been achieved using electrical heating technologies. EPA’s recent report

(U.S. EPA, 2003) summarizes the use of these technologies for soil and groundwater at chlorinated solvent impacted 

sites. ERH technologies have reportedly been implemented at full scale at eight sites and at pilot scale at nine sites, 

with data through 2002. The ISTD technology reportedly was implemented at full scale at four sites. Both performance 

and cost data are provided. At least one of the sites using the ERH technology (Skokie, Illinois, see U.S. EPA, 1999b, 

U.S. EPA, 2003) reportedly received a no-further-action letter from Illinois regulators, and source-zone concentrations of 

TCE reportedly were reduced to levels below the target concentration of 25 ppb for TCE. Costs for this site are reported 

to be $1.1 million dollars, for a 0.6-acre site. 

Surfactant and Co-Solvent Flushing: Co-solvent and surfactant-enhanced extraction are fl ushing and recovery 

technologies that rely on mobilizing DNAPL by signifi cantly increasing the aqueous solubility of DNAPL components and 

reducing interfacial tension to increase the rate of DNAPL extraction. The cost-effectiveness of the technologies depends, 

in part, on recovery of the fl ushing solutions following extraction. A summary of recent surfactant enhanced aquifer 

remediation (SEAR) demonstration projects is provided by Simpkin et al. (1999). In the last few years, additional research 

work on these technologies has demonstrated signifi cant removal of chlorinated solvent DNAPLs in unconsolidated 

geologic settings (see e.g., Jawitz, 1998).

These technologies may be ready for deployment in some unconsolidated geologic settings, but to the Panel’s knowledge, 

neither fi eld-scale demonstrations nor full-scale applications have yet to achieve site closure at a DNAPL source zone. 

The Bachman Road and Sages sites, summarized in Appendix A, are examples of removing substantial amounts of 

DNAPL, with subsequent changes to the geochemical environment that enhance biodegradation of the remaining mass 

of DNAPL. These technologies are not likely to be effective at removing DNAPL present in low permeability source 

zones, such as fractured systems.

Air Sparging: Air sparging is a widely used technology for remediation of volatile organic compounds in the dissolved 

state in groundwater and has been widely used for groundwater cleanup at petroleum hydrocarbon release sites (Fields, 

et al., 2002). The technology is also potentially applicable to DNAPL source zones when the DNAPL constituents 

are suffi ciently volatile such as chlorinated solvent-impacted sites. The technology involves injection of air into the 

saturated zone through wells located to provide suffi cient areal coverage of the DNAPL source zone. Capture of the 

volatilized contaminants from the unsaturated zone is an essential component of this technology. This technology has 

been developed and is readily available for deployment. The technology may achieve signifi cant DNAPL depletion in 

the source zones that are hydraulically accessible, but it will not be effective when DNAPL is present in hydraulically 

inaccessible regions such as fractured clays or bedrock. No reports of successful cleanups of DNAPL source zones 

using air sparging have been found. 

Chemical Oxidation: Chemical oxidation using various chemical oxidants (e.g., sodium or potassium permanganate 

solutions, persulfate, Fenton’s reagent) is another promising process for source-zone depletion of some DNAPLs (see 

e.g., a recent survey by Siegrist, et al., 2000; Siegrist, et al., 2001). Known as In-Situ Chemical Oxidation (ISCO), 

chemical oxidation relies on rapid chemical reactions that will occur between the oxidant or oxidant-derived chemical 
27

species (e.g., hydroxyl radicals) and the chemical constituents in some DNAPLs. Pilot-scale demonstrations and fullscale applications have attempted in-situ treatment of low levels of chlorinated solvents and petrochemicals, and to a 

lesser degree, dense non-aqueous phase liquids (DNAPLs) using oxidant delivery by vertical injection probes (e.g., 

Siegrist et al., 1998a, 1998b; Moes et al., 2000; Nelson et al., 2000; Parker et al., 2002), deep soil mixing (e.g., Cline et 

al., 1997), fl ushing by vertical and horizontal groundwater wells (e.g., Schnarr et al., 1998; West et al., 1998a,b; Lowe 

et al., 2002), and reactive zone emplacement by hydraulic fracturing (e.g., Siegrist et al., 1999; Struse et al., 2002). 

Much is known about the reaction processes that govern chemical oxidation of many organics in aqueous solutions as 

well as the transport processes infl uencing application in-situ, but there are gaps in the current knowledge base regarding 

ISCO applications for DNAPL depletion in source zones, particularly in fractured systems. While there is a theoretical 

basis for the degradation of DNAPL residuals by ISCO, the expected realization of the high destruction effi ciencies of 

DNAPL source zones has remained elusive (see e.g., Urynowicz, 2000). 

For application of chemical oxidants to DNAPL source zones, the major factors controlling performance include: 

1) subsurface delivery and distribution of potentially large quantities of oxidant chemicals to degrade the DNAPL mass 

present and also satisfy any natural oxidant demand, 2) acceptable reaction rates between the DNAPL and the oxidant, 

and 3) undesirable secondary effects when large quantities of oxidant chemicals are added to the subsurface (e.g., 

gas evolution and fugitive emissions, particle formation and permeability loss, water quality deterioration due to metal 

impurities in oxidant solutions). In addition, the potential for development of interfacial mass transfer resistance (e.g., 

with MnO4

-

, a MnO2 skin can form at the DNAPL-water interface) and a resulting inability to oxidize the DNAPL must be 

considered. The latter mechanism even suggests an approach to in-situ immobilization of DNAPL mass. 

The three case studies included in Appendix A provide examples of the performance of the application of permanganate 

based ISCO for DNAPL source-zone depletion in sandy aquifers. In each of these cases, the DNAPLs are chlorinated 

solvents.

In summary, ISCO shows promise for DNAPL source-zone depletion in unconsolidated geologies, and may be suitable 

for attacking chlorinated solvent DNAPLs in fractured systems, but continued uncertainties on the effectiveness and cost 

of these technologies currently limit greater deployment of this technology for DNAPL source-zone depletion. DODfunded research is currently addressing some of these uncertainties, and useful results should be available within the 

next twelve to 24 months (See SERDP website for details). 

Chemical Reduction: Chemical reduction source treatment is based on the physical mixing of Zero Valent Iron (ZVI) 

into the DNAPL source zone to provide close contact between the DNAPL constituents and the ZVI to achieve reductive 

dehalogenation of the chemicals of concern. This technology is applicable for chlorinated solvent DNAPLs but is not 

suitable for creosote or coal tar DNAPLs. ZVI source treatment involves mixing a slurry of clay (generally kaolinite, 

though others have applied bentonite) and ZVI (e.g., 95:5 weight ratio of clay to ZVI) directly into the source zone. This 

is intended to create a relatively stagnant environment in the source zone within which slow diffusional processes may 

play an important function in transfer of the DNAPL constituent to ZVI particle surfaces. Complete treatment does not 

occur immediately but requires an extended time for various processes such as DNAPL dissolution, desorption, and 

diffusion to occur. The most appropriate application of the technology would involve a relatively small, well-defi ned source 

area consisting of residual/trapped DNAPL consisting of chlorohydrocarbons (e.g., PCE, TCE, carbon tetrachloride) 

amenable to ZVI reductive dechlorination. 

To allow mixing/delivery, the source zone needs to be composed of unconsolidated soils. The source zone may extend 

above and below the water table. The technology is limited to DNAPLs treatable by reductive processes, and would 

have limited applicability to fractured rock sources. It would be applicable to all types of media amenable to mixing. 

One case study discussed in Appendix A summarizes a recent experience with this source depletion technology. This 

patented technology is available for deployment, but has been tested at only a few sites. 

Another technology utilizing ZVI is a NASA-patented process using encapsulated micro- or nano-scale particles of ZVI 

within a micelle composed of water and oil/emulsifi ers. The micelles are attracted to the DNAPL phase and will form 

DNAPL/emulsifi ed ZVI mixtures. The VOCs will dissolve into the micelle and react with the ZVI. The composition of 

the micelle also supports biological reductive dechlorination as it decomposes. NASA has completed one test of the 

technology at the LC 34 complex in Florida, and the EPA SITE program has also evaluated the technology for source 

depletion at a TCE DNAPL site (see EPA SITE Program website for details). This technology is in an early stage of 

development and additional research is required to verify performance and cost. 

In-Situ Biodegradation for DNAPL Source Zones: Conceptually, biological treatment of DNAPL in source zones is 

based on the ability of microorganisms to transform chemical constituents within close proximity to the DNAPL surfaces 

(the order of 100 μm), thereby resulting in enhanced rate of dissolution of the DNAPL constituents. Laboratory results 

by Cope and Hughes (2001) and Yang and McCarty (2001) using completely mixed lab-scale systems have shown that 

the dissolution rate of PCE DNAPL can be enhanced by a factor of over 15 times compared to the rate of aqueous 
28

dissolution. Recently reported results from fi eld studies have shown signifi cantly lower rates of enhanced dissolution 

(Borden, 2003), however. 

This technology is being evaluated under the DOD Environmental Security Technology Certifi cation Program (ESTCP) 

and NASA SBIR programs. A recent pilot study at the DOE Laboratory in Idaho (INEEL) showed successful treatment 

of a presumed TCE DNAPL source, and full-scale application of the technology using lactate as the electron donor has 

been implemented at INEEL to replace the current pump-and-treat system (Sorenson et al., 2001). The key design 

factor is delivering suffi cient electron donors to the source zone to encourage microbial growth as close as possible 

to the DNAPL. Various organizations/researchers are investigating the use of food substrates that can partition into 

DNAPLs to enhance microbial degradation near the DNAPL/water interface. This technology may be applicable as a 

stand-alone source depletion technology, in conjunction with other source-zone treatment technologies or as a polishing 

step. It has the potential advantage of lower capital and O&M costs compared to alternative technologies, although a 

longer period of operation is likely compared to abiotic technologies. 

Although this technology is still in an early stage of development, it has been deployed as a full-scale technology at a 

few sites and is planned for several others. The technology is not yet widely deployed, however. Given the potential 

cost reductions using this technology, further research is needed to confi rm these potential benefi ts. 

Combined Depletion Technologies: Combinations of one or more of the above technologies can also be employed for 

DNAPL source depletion. Both the Sages Site and the Bachman Road site, presented in Appendix A, are examples of 

combining co-solvent or surfactant fl ushing for DNAPL removal from a source zone, followed by microbially mediated 

degradation of the remaining constituents. Another promising combination is the use of electrical heating and steam 

injection as a hybrid thermal technology, known as Dynamic Underground Stripping. This technology has been 

demonstrated at one site (LLNL Gas Pad) with less than 3% of the total energy input coming from electrical heating 

and has been employed at several DOE sites including Savannah River and also the Visalia site (see e.g., DOE, 2000).

Case studies for these sites are summarized in the recent EPA compilation (U.S. EPA, 2003). 

Other promising combinations include thermal technologies followed by microbial transformations, which may require 

bioaugmentation with cultures containing halo-respiring microorganisms. Thermal treatments will signifi cantly reduce 

the indigenous microbial populations. However, after temperatures have been reduced to more moderate ranges, the 

environment may provide little competition to the added microorganisms, allowing them to dominate the treated area and 

improve the degradation activity towards the residual chemicals. Additional research on these phenomena is needed. 

Chemical oxidation followed by biodegradation may also be an effective combined system for DNAPL source depletion. 

In general, these combination technologies have not been suffi ciently tested in pilot or fi eld studies to be considered 

as demonstrated technologies, and further research and assessment of these combinations as DNAPL source-zone 

depletion options is warranted. Combination technologies other than those listed should also be considered. 

Table 3-3 summarizes the consensus judgment of the Panel on the “status” of the development and deployment of 

selected DNAPL source-zone depletion technologies. (This Table includes most of the source-zone DNAPL depletion 

technologies familiar to Panel members and those that we consider the most developed, but it is not meant to cover 

all technologies available or to indicate any preference for one technology over another). A technology is considered 

“developed” and ready for “deployment” at DNAPL sites if it has moved past the proof-of-concept and laboratory studies 

stage of development, and if there is suffi cient information on performance and cost such that a feasibility level analysis, 

similar to that specifi ed in the National Contingency Plan (NCP), can be conducted to determine if source depletion 

should be undertaken, and to select one technology or combination of technologies compared to other options. We 

suggest that if the technology meets the following fi ve criteria, then that technology is now ready to be “deployed.” These 

fi ve criteria are as follows: 1) completion of numerous (more than 10) pilot-scale projects in representative geologic 

settings that verifi ably demonstrate substantial DNAPL source-zone depletion, 2) completion of at least fi ve (5) full-scale 

projects, 3) availability of non-research level predictive performance assessment tools that allow design scale-up from 

pilot studies, 4) adequate cost data to allow for feasibility level assessments in the context of selection of source-zone 

remedial strategies, and 5) more than two technology vendors available. 

It must be stressed that “deployment” does not imply that the technology is suitable for all DNAPL types, release scenarios, 

and observed DNAPL architectures. While a technology may be ready for “deployment” and in fact has already been 

deployed at full scale, signifi cant uncertainties persist on performance and cost that can only be resolved through sitespecifi c studies. The scale-up of these studies still represents a major technical challenge, however, because of the 

heterogeneous nature of the problem as discussed in Section 2.0 and other portions of this Report. 

Of the technologies listed in Table 3-3, biodegradation technologies and combined technologies have a more limited 

database of performance and cost data compared to thermal, surfactant/co-solvent fl ushing, and ISCO technologies. 

For these generic categories, several technologies satisfy criteria 1, 2, 4, and 5, noted above. However, as noted in 

response to Question 5, user-friendly, non-research level multiphase numerical models are not yet available for these 

source depletion technologies, although research level models have been developed and are deployed at some large 
29

Technology

Pilot 

Studies Full Scale

Predictive 

Models

Sufficient 

Cost Data

At Least 

One Site 

Closure

More 

than Two 

Vendors

Water Floods Y Y Y Y N Y

Surfactants/Co-solvents Y Y Y Y N Y

Air Sparging Y N N N N Y

Steam Injection Y Y Y Y Y Y

Electrical Resistance Y Y Y Y Y Y

Conductive Heating Y N Y N N N

Chemical Oxidation Y Y Y Y Y Y

ZVI/Clay Y N N N N N

Biodegradation Y N N N N Y

Combination - Co-solvent Y N N N N N

with Biodegradation

Combination - Thermal Y N N N Y N

with Chemical Oxidation

Note: Y = yes, meets criteria; N = no, does not meet criteria. 

Table 3-3 Status of Development and Deployment of DNAPL Depletion Technologies

DOE and DOD site studies. Further development of these models to produce more easily accessible modeling tools will 

provide a more reliable basis for technology selection, scale-up design from the results of pilot studies, and performance 

assessment. 

Finally, it must be stressed that much of the pilot- and full-scale experience with these technologies has been developed 

for chlorinated solvent DNAPLs in unconsolidated geologic settings. The experience base using these technologies 

to remove DNAPL from fractured systems is much more limited, and this represents an important data gap in our 

understanding of the performance of DNAPL source-zone depletion technologies. 

3.4.2 Anticipated Effectiveness of DNAPL Source-Zone Depletion Technologies

In Table 3-4, we summarize the Panel’s consensus opinions regarding the “effectiveness” of these technologies to 

achieve remedial action objectives in different DNAPL scenarios. This Table summarizes in a conceptual way, the 

potential effectiveness of DNAPL source-zone depletion technologies for representative DNAPL subsurface scenarios. 

Two different hydrogeologic scenarios are considered in this evaluation: hydraulically accessible (permeable zones 

hydraulically connected to wells), and hydraulically inaccessible (low permeability zones such as fractured systems 

or permeable zones not hydraulically connected to wells). For hydraulically accessible media, two different DNAPL 

distribution scenarios are considered: DNAPL in pools of signifi cant mass, and DNAPL distributed as residuals with 

relatively small total mass. DNAPL in pools of signifi cant mass implies free-phase, possibly mobile liquids, usually trapped 
30

above a major low-permeability capillary barrier. DNAPL distributed as residuals with small total mass represents 

a source-zone scenario with relatively small, discontinuous ganglia and diffused mass.

For hydraulically inaccessible zones (i.e., where advective fl ow is negligible), two distributions of mass loading are 

considered: the fi rst, more signifi cant scenario, is DNAPL of signifi cant mass typically resulting from gravity fl ow into 

high permeability regions through otherwise insignifi cant vertical pathways, media wetting DNAPLs imbibing into low 

permeability zones, and low-permeability media with signifi cant fracture volumes allowing substantial accumulation 

of DNAPL mass. Low-permeability media with signifi cant dissolved mass may also be considered to be part of the 

source zone; thus, depletion technologies are also evaluated for their applicability to those soils. 

The likely effectiveness of various source depletion technologies for an individual site can be inferred from current 

scientifi c understanding, laboratory tests, and past fi eld performance. Based on the judgment of Panel members, 

Table 3-4 includes a judgment on the level of certainty of the effectiveness ratings. These are: E - Expected to 

be effective based on laboratory data and scientifi c knowledge, P - Possibly effective based on current scientifi c 

knowledge, and U - Unlikely to be effective based on current scientifi c knowledge. 

The Table indicates that a number of technologies are capable of removing DNAPL from the saturated zone, 

depending upon the DNAPL distribution and the geologic conditions. Whether the technology will be successful 

depends in part on the remedial action objectives (RAOs) established for the source zone. If the RAO in the source 

zone is complete restoration (i.e, background levels of the DNAPL constituents), or MCLs, it is unlikely that any of the 

technologies currently available will be successful, except in situations involving small spills of DNAPL in relatively 

homogeneous saturated zones. However, if the RAOs focus on reduction of mass, reduction of mass discharge 

from a source area, or stabilization of the mobile DNAPL, several of these technologies could be candidates for 

implementation. Where signifi cant uncertainties persist with respect to performance and costs of these technologies, 

additional R&D will be warranted given the potential for these technologies to meet alternative RAOs for the source 

zone other than MCLs or complete restoration. 

Hydraulically Accessible 

(Permeable zones hydraulically 

connected to wells) 

Hydraulically Inaccessible 

(Low-permeability zones or 

permeable zones not 

hydraulically connected to wells) 

DNAPL in Pools, 

large mass (1)

DNAPL 

distributed as 

residuals with 

small mass (2)

DNAPL of 

substantial 

mass 

DNAPL 

distributed as 

residuals with 

small mass (2)

Co-Solvent P E U U 

Electrical 

Heating 

E-P E E P 

Oxidation P E U-P P 

Steam Injection E E P P 

Surfactants P E U U 

H2O Flood P U U U 

Chemical 

Reduction 

U-P P U-P P 

Biological U P-E P P 

E: Expected to be a candidate technology based on field and/or laboratory data and scientific knowledge 

P: Possibly a candidate technology based on current scientific knowledge 

U: Unlikely to be a candidate technology (i.e., impractical or not effective in a reasonable time frame) 

based on scientific knowledge 

(Where two designations are shown, Panel members had differing opinions.) 

(1) Defined as being free-phase and possibly mobile 

(2) Defined as residual/distributed pools, relatively small, discontinuous, not connected pools, and 

diffused mass 

Table 3-4 Potential Applicability of Various Source Depletion Technologies in Two Generic Hydrogeologic 

Situations 
31

3.4.3 Cost of DNAPL Source Depletion Technologies

Cost is a key factor in comparison of alternative remediation strategies at DNAPL sites. EPA and other organizations 

have compiled cost surveys on individual technologies, and information is available from the SITE Program and 

the TIO database, with cost data on most of the technologies discussed here. The recent EPA report on thermal 

technologies also provides some cost data for chlorinated solvent DNAPL-impacted sites. However, cost data are 

highly dependent on site-specifi c factors for all DNAPL source-zone depletion technologies. In addition, cost estimates 

are often provided by vendors without independent assessments of the accuracy of the reported numbers. 

A brief review of the recent EPA report on thermal technologies for chlorinated solvents in source zones illustrates 

this problem. This report provides detailed case study summaries on over 15 sites. Cost data, if reported, are 

presented as total costs and unit costs (e.g., dollars/cubic yard of material). Unit costs for chlorinated solvents in 

soil ranged from $13/cubic yard to $118/cubic yard. Costs based on a per acre basis ranged from less than $.5 

million to over $6.5 million per acre. In some cases, costs only included vendor costs, and costs incurred by the site 

(e.g., steam costs) were not included. At the Skokie site, which is one of the sites that has received a no-furtheraction letter, vendor-reported costs amounted to $1.8 million per acre ($1.1 million for an area of 0.6 acres). The 

estimated cost per acre for the Visalia site is currently about $15 million/acre. 

Because of the site-specifi c nature of any cost estimates and the lack of independent reviews of vendor-reported 

costs, generalizations regarding the unit costs or total life cycle costs for any of these technologies applied to DNAPL 

source-zone depletion are subject to signifi cant errors and can be misleading. In place of such an analysis, we 

present here a brief comparison of a source-zone depletion strategy compared to a hydraulic containment strategy 

for the Visalia DNAPL site. In this case study, information has been provided on both the costs for source depletion 

using steam-enhanced extraction combined with abiotic chemical oxidation and the costs for a pump-and-treat 

system in operation prior to the initiation of source removal. Reports provided by the Visalia operators indicate 

that the steam/oxidation technology has cost approximately $25 million to date. This investment may potentially 

eliminate the need for continued use of the hydraulic containment system costing $1.2 million annually. It is, 

therefore, instructive to compare the net present worth of these two alternatives, assuming that the cost data are 

accurate, and assuming that in the near future, the pump-and-treat system at Visalia will be shut down when the 

RAOs for the site are met. 

Table 3-5 contains a net present value (NPV) comparison for varying annual costs and varying interest rates, assuming 

100 years of O&M for the pump-and-treat system. While 30 years is the typical period used in such calculations, 

100 years is more appropriate for expected indefi nite operation of a hydraulic containment option. As shown in 

Table 3.5, for the $1.2 million annual costs, the NPV for the pump-and-treat system only exceeds the cost of the 

source depletion option if the interest rate decreases below 5 percent (a value of 3.9 percent is a typical value for 

the time value of money used by the public sector while 12 percent represents a typical discount rate used by the 

private sector to evaluate alternative investment options). Furthermore, O&M costs are tax-deductible expenses 

for private site owners and thus, even at an interest rate less than 5 percent, the annual O&M costs may have a 

net present value cost lower than the capital cost required for the thermal remedy. 

It should also be noted that for the median pump-and-treat site, with annual costs of $180,000 according to EPA’s 

28 site study (U.S. EPA, 2001), the net present value cost of a source depletion strategy would need to be less than 

$3.6 million at a 5 percent discount rate or less than $1.5 million at 12 percent to show positive economic benefi ts 

compared to the continued use of the hydraulic containment option. In the fi nal analysis, this comparison suggests 

2 3.9 5 12

$180,000 $7,779,953 $4,521,368 $3,575,490 $1,499,990

$500,000 $21,610,981 $12,559,355 $9,931,917 $4,166,639

$1,200,000 $51,866,353 $30,142,452 $23,836,601 $9,999,935

Annual Costs Interest Rate (%)

Table 3-5 Net Present Value of Annual O&M Costs for Pump-and-Treat Technologies
32

that for DNAPL-impacted sites where the source areas are small (less than a tenth of an acre), depth to groundwater 

is moderate (less than 20 feet), and the total source-zone volume is also moderate, with RAOs other than MCLs in the 

source-zone being acceptable to all parties, and the value of land is high (>$1 million per acre), a source-zone depletion 

strategy using the appropriate technology may be justifi ed on economic grounds. On the other hand, for large, complex 

sites, with fractured systems, and DNAPL at depth, costs for the source depletion strategy may not be justifi ed, and 

containment may be the logical option. Of course, there are other benefi ts to source depletion other than cost savings, 

and those benefi ts may shift the balance in favor of undertaking a source depletion remedy.

3.4.4 Summary

Over the past 15 years, a wide range of innovative in-situ technologies has been developed, and tested at the laboratory 

and small fi eld- or pilot-scale for removal or destruction of all types of DNAPLs in a variety of geologic settings for 

the source zones. Some of these technologies have also been applied at larger fi eld sites, although the number of 

such case studies is limited. These technologies can be broadly characterized as follows: fl ushing and fl uid recovery 

technologies, thermal technologies, chemical oxidation or reduction technologies, and biodegradation technologies. Of 

these general categories, only the biodegradation technologies are still in early stages of development compared to 

physical/chemical-based technologies, but some biodegradation technologies have been deployed or are planned for 

deployment at several DNAPL sites. Nonetheless, questions on effectiveness, cost, and applicability to DNAPLs other 

than chlorinated solvents are still unanswered. 

Based on the Panel’s experience and knowledge of the published and unpublished literature on DNAPL source 

depletion technologies, including the case studies presented in this Report, the Panel’s consensus position is that 

several technologies are clearly capable of removing substantial amounts of DNAPL from a selected range of geologic 

settings, primarily in unconsolidated media, regardless of the DNAPL properties. Thermal, surfactant fl ushing, and ISCO 

technologies are suffi ciently developed and tested such that they should be considered available for deployment, with 

suffi cient information on performance and cost to conduct feasibility level analyses for the purpose of remedial action 

decision-making. Cost and performance uncertainties for all technologies still persist, however, due to site-specifi c 

uncertainties at DNAPL-impacted sites, particularly with respect to DNAPL in fractured systems. 

3.5 Question 5: Are Currently Available Tools Adequate to Predict the Performance of 

Source Depletion Options?

Among the many challenges facing the remediation of DNAPL sites is the diffi culty in scaling up either laboratory- or 

pilot-scale investigations of DNAPL source-zone depletion technologies to the fi eld scale. This is, in part, due to site 

heterogeneities, and, in part, due to diffi culties in site characterization. In order to overcome this scaling problem, a 

number of tools have been developed to provide decision-makers with a quantitative basis for making decisions regarding 

the application of DNAPL source-zone depletion technologies. The adequacy of the currently available tools in forming 

the basis for these decisions is the focus of this section. 

Most source-zone remediation technologies rely on the delivery of remedial agents to the contaminated region. The 

injected agents may be designed to extract contaminants (e.g., water fl ooding, solvent/surfactant fl ushing, air sparging, 

steam fl ushing), or they may be injected to promote in-situ reactions (e.g., chemical oxidation, reductive dechlorination). 

The performance of any of these technologies will depend on effi ciently delivering the remedial agent (water, air, heat, 

surfactants, cosolvents, oxidants, electron donors, etc.), the extent of (local) contact with entrapped or pooled DNAPL 

within the swept zone, and the rates of reaction or inter-phase mass transfer subsequent to this contact. Various tools 

are available to the practitioner to assist in the design, fi eld implementation, and performance assessment of these 

source depletion technologies. These tools include computer models of varying sophistication and complexity, technical 

and regulatory guidance documents, and documentation of case studies including pilot testing at either the lab- or fi eldscale. Each of these tools provides a different type and level of information for better remedial design or performance 

prediction.

3.5.1 Numerical Models: Deterministic Approaches

The most quantitative tools for remediation design are numerical models. Although there is an enormous range in 

complexity among the various available models, all are based upon the solution of mass, momentum, and in some cases, 

energy conservation equations. The simplest and most well-documented models are those that describe single-phase, 

multi-dimensional fl uid fl ow in both homogeneous and heterogeneous unconsolidated media. The most complex are 

the models for DNAPL sources and plumes located in fractured media.

In the treatment of DNAPL sources within the saturated zone of unconsolidated media, several current models are 

useful for the hydraulic design of in-situ fl ushing schemes (water fl ooding, cosolvent or surfactant fl ushing, chemical 

oxidation, etc.). A number of commercial packages are available; most in common use are based upon the USGS 
33

fi nite-difference simulator MODFLOW. These packages are generally user-friendly and require parameter inputs that 

are familiar to most groundwater practitioners.

Implicit in the application of a single-phase, fl uid fl ow model to a DNAPL source-zone extraction (by fl ushing) scenario, 

are a number of assumptions that may be violated at a particular site or not applicable for the implementation of a 

specifi c remedial technology. One important assumption is that the resident groundwater and the injected fl ushing 

solution are (hydraulically) indistinguishable. If the injected fl uid has properties distinct from the resident groundwater 

(such as a different density or viscosity), prediction of the hydrodynamic sweep of the DNAPL source zone requires 

the application of a coupled, single-phase fl ow and transport simulators. Multi-contaminant transport simulation is also 

required if the technology performance ultimately depends on the delivered concentration of some remedial agent in 

the fl ushing fl uid. Contaminant transport simulators that incorporate the compositional dependence of fl uid density and 

viscosity are less commonly applied for the design of DNAPL source depletion technologies. A few codes, however, 

are commercially available and reasonably well documented (e.g., SUTRA). Although such codes can accommodate 

nonlinear reactions (e.g., sorption) and variable fl uid density, they have not generally been applied to DNAPL source-zone 

depletion scenarios. Thus, application of these codes to source-zone depletion may require substantial parameterization 

input from the user, and in some applications, may even require model source code adaptation. 

Application of a single-phase fl ow/transport model to a DNAPL site remediation scenario also implicitly assumes that 

the DNAPL is hydraulically immobile, and that its presence does not substantially infl uence the fl ow paths and rates 

of the injected fl uids. A class of computer models alternatively conceptualizes the source zone as a multiphase fl uid 

system. Codes within this class are the most complex and the most versatile of available modeling tools. A multiphase 

modeling approach is required for the design and evaluation of technologies based upon gas injection (e.g., air 

sparging, steam fl ooding) or technologies that attempt to mobilize the contaminants as a separate organic phase (e.g., 

low interfacial tension surfactant fl ushing). Although some commercial models are available (e.g., UTCHEM, TOUGH, 

MISER, COMPFLOW) for targeted multiphase remedial applications, use of these codes requires an experienced user 

and extensive site-specifi c information on system chemical and physical properties. Nonetheless, currently, some of 

these codes are being used to design and evaluate the performance of thermal and surfactant fl ushing DNAPL source 

depletion technologies, based on the experiences of the Panel. In addition, successful application of these codes requires 

site-specifi c data on permeability distribution and DNAPL distribution. An example application is the multiphase fl ow 

code, SWANFLOW, used to evaluate DNAPL behavior and recovery at the Hyde Park and S-Area landfi lls in Niagara 

Falls, NY (Faust et al., 1989). 

Application of the above models to predict effectiveness of the sweep of an identifi ed source zone can be relatively 

straightforward, particularly in a low-heterogeneity geologic setting. Model predictions of contaminant recovery or 

transformation within the source zone, however, are subject to a high level of uncertainty. The accuracy of such model 

predictions is predicated on knowledge of the total contaminant mass within the source zone and its spatial distribution, 

as well as the limiting rates of reaction or inter-phase mass exchange. In-situ rates of reaction or inter-phase mass 

exchange will generally be governed by a complex coupling of physical, chemical, and (sometimes) microbiological 

processes. The identifi cation and relative importance of these processes for a particular remedial application will 

depend upon site-specifi c conditions, such as local groundwater geochemical conditions, DNAPL architecture, microbial 

populations, and geologic heterogeneity. 

Another important debate (and a gap) in development and application of comprehensive simulation models deals with 

the need for a linkage of source-zone and plume-zone process models or alternatively the use a single code for modeling 

both regions of interest. The former strategy is perhaps the most optimal if the outputs from the source-zone model can 

be used as the input for the plume-zone model. Several attempts along these lines are currently the focus of several 

projects funded by SERDP under its DNAPL initiatives.

Although these models have been used at a limited number of research sites, or large DOE sites, the Panel believes that 

the models and modeling approaches are not yet suffi ciently validated for performance predictions in real fi eld situations. 

The models currently must be considered primarily as research tools, and are not yet widely deployed in practice. 

3.5.2 Numerical/Analytical Models: Stochastic Approaches

The modeling approaches described above might be labeled as “process-based deterministic.” Given the practical 

diffi culties in providing the required model parameters for all locations within the spatial domain of interest, alternate 

modeling strategies have been developed. Often, they are based on Lagrangian Stochastic Advective Reactive modeling 

approaches (e.g., Cvetkovic and Dagan, 1994). In such approaches, the fi rst goal is to predict the arrival-time distribution 

of non-reactive tracer at a selected control plane normal to the mean fl ow direction. Second, the dominant processes 

governing contaminant transport, retardation, and transformation along a single streamline, represented by one possible 

physical tracer arrival time, are modeled using process-based and deterministic approaches. Third, the stochastic pdf 

representation of physical tracer arrival time and possible other randomly variable transport and reaction variables is 

coupled to the deterministic single-streamline process description, to explicitly account for the spatial variability and the 
34

correlation structure of primary variables (e.g., hydraulic conductivity, retardation factor, DNAPL content, etc.). Model 

predictions may then provide expected values (i.e., mean), variances, and co-variances of outputs such as arrival times, 

concentrations, and fl uxes at any chosen downgradient control plane. 

Berglund (1997) was among the fi rst to employ this stochastic modeling approach for evaluating the effects of the spatial 

heterogeneity of hydraulic conductivity and its correlation to DNAPL content on the likely performance of pump-and-treat 

systems for groundwater remediation. Applications of such modeling approaches to predict performance of innovative 

source-zone remediation technologies have not been attempted to date. However, closely analogous approaches have 

been attempted in recent years (Enfi eld et al., 2000 and 2003; Jawitz et al., 2003). In these efforts, a basic assumption 

made is that the arrival-time probability density function (pdf) can be represented as a single or a superposition of 

multiple log-normal distributions, even though any other possible and site relevant arrival time pdf can equally well be 

used within the modeling approach. That the log-normal assumption is valid has been demonstrated from the results 

of numerical simulations using sophisticated 3-D fl ow/transport codes for heterogeneous, saturated, unconsolidated 

media (Demmy et al., 2001).

While some Lagrangian models may rely on knowledge of the spatial distribution of aquifer properties (e.g., hydraulic 

conductivity) for theoretically determining the required arrival time pdf, fi eld data from a tracer test (e.g., PITTs) may also

be used to infer (via inverse modeling) the parameters for the assumed log-normal distribution(s). Destouni et al. (2001) 

present and compare different possible ways to model analytically arrival time pdfs and also show that log-normal pdf 

is relevant. In the latter approach, site-specifi c parameters applicable only to the pumping strategy implemented during 

the tracer tests are estimated. Such values are then used in a forward model to predict remediation performance under 

the same pumping conditions, and these modeling approaches can predict remediation performance only in the tracersampled domain and only for injected remediation fl uids of the same physical characteristics as the tracer fl uids. Different 

chemical characteristics, however, may be investigated with the same physical arrival time pdf model, by coupling with 

different possible chemical reaction models along a single streamline (Cvetkovic and Dagan, 1996; Dagan and Cvetkovic, 

1996). Later model developments have also demonstrated the possibility to couple any site-relevant physical arrival 

time pdf to multi-component reaction models in complex geochemical environments (Yabusaki et al., 1998), including 

to the widely used and useful general geochemical model PHREEQC (Berglund et al., 2003).

Examples of such modeling approaches being specifi cally applied to the DNAPL remediation problem have been recently 

presented by Enfi eld et al. (2000 and 2003) and Jawitz et al. (2003) for in-situ fl ushing with surfactants and cosolvents. 

Data from lab-scale and fi eld tests were used to evaluate the utility of these stochastic modeling approaches. Models 

for other innovative technologies (e.g., oxidation) have not been reported, nor have the models for in-situ fl ushing been 

tested at other sites or compared with other models. 

3.5.3 Guidance Documents

A number of guidance documents have been developed in recent years for the application of innovative source-zone 

remediation technologies. Among these are a manual for the application of surfactant and co-solvent fl ushing (Simpkin, 

et al., 1999), draft guidance on air sparging, U.S. EPA Technology Innovation Offi ce guidance on in-situ bioremediation 

of chlorinated solvents (U.S. EPA 542-R-00-008, 2000), and the ITRC Group’s guidance document on in-situ chemical 

oxidation (ITRC, 2001), and in-situ surfactant/cosolvent fl ushing ITRC (2003). For other guidance documents on 

remediation technologies and site characterization, see the ITRC website (www.itrcweb.org). Guidance documents 

are typically subject to peer review and can provide good general information on state-of-the-art. These guidance 

documents typically provide a good overview of the technologies, some useful examples of case studies, a delineation 

of the steps for the design, application, and assessment of a technology at a site, and information on cost analysis and 

regulatory acceptance. 

While guidance documents are useful in highlighting important considerations for design and application of a particular 

remediation technology, they rarely offer quantitative approaches for performance prediction. 

3.5.4 Case Studies and Pilot Tests

Some information on remediation technology performance can also be obtained from documented case studies of fi eld 

applications or pilot tests under controlled lab or fi eld conditions. The documents on case studies of fi eld applications 

are typically lacking in detailed documentation and independent verifi cation of recovery claims. In many instances, 

unexplained technology failures are also reported. Relatively few well-documented case studies have appeared in the 

peer-reviewed literature, and those that have appeared tend to focus on pilot-scale demonstrations. Recent EPA efforts 

have provided more details on certain technologies, however (U.S. EPA, 2003).

It is important to recognize that the rules governing the level of documentation required and the suffi ciency of the evidence 

provided to support the claims of success of remediation technology testing depend on the intended readers or target 

audience. The level of documentation required to judge the adequacy or suffi ciency may be very different for professional 
35

practice (e.g., a project completion report submitted to an agency or a client) compared to a manuscript submitted for 

a scientifi c journal. In the former case, only the level of documentation that satisfi es the client(s) and is acceptable to 

the regulators is required. In the latter case, an independent panel of anonymous reviewers determines if the claims 

made are defensible and justifi ed based on the evidence furnished. This difference in expectations has contributed to 

a disagreement and debate among remediation technology practitioners working at “real” sites and academics working 

on innovative technology testing at smaller pilot test sites.

Another important issue is the scale of fi eld testing and the extent of data collection. The Panel has provided summaries 

of a few well-documented cases of small-scale pilot tests (Appendix A). Such pilot tests, are often undertaken at a small 

scale that may permit more detailed characterization of the source zone and remedial performance than is feasible at 

larger sites. Also, the small-scale fi eld tests offer more homogeneous conditions than are typical of most contaminated 

sites. Furthermore, some of the well-documented pilot tests were conducted after controlled NAPL releases, under 

conditions that may not be representative of older release sites. 

To be most useful for technology performance assessment, a case study would ideally contain the following 

components:

 1. An accurate site conceptual model and a summary of site characteristics, including a thorough description 

of the hydrogeologic, geochemical, and microbial settings. 

 2. An estimate of extent of the source zone, the total DNAPL mass, and its distribution in three dimensions 

within that zone.

 3. Pre-remediation spatial distributions of aqueous contaminant concentrations within the source zone.

 4. Pre-remediation estimates of contaminant mass discharge rate for the source zone and at downgradient 

control planes.

 5. A complete description of the technology implementation.

 6. Quantifi cation of contaminant mass recovery/destruction during operation.

 7. Post-remediation audit of the remaining DNAPL mass, source zone concentrations, and downstream 

contaminant mass discharge rate.

 8. Post-remediation assessment of hydrochemical and microbial conditions within the source and in the 

plume.

 9. Results of long-term monitoring of source-zone concentration levels and downstream plume behavior.

10. An independent assessment of capital and O&M costs.

3.5.5 Limitations of Existing Tools

The available performance assessment tools summarized briefl y above have a number of limitations that preclude 

their successful and widespread application for the fi eld design and assessment of innovative source-zone remedial 

technologies. These limitations relate both to an incomplete understanding of the process/technology and to model 

implementation. 

Numerical modeling tools are generally based upon laboratory and bench-scale observations of remedial performance in 

relatively homogeneous settings. While the simpler models have been verifi ed and validated at the laboratory scale, the 

more complex models, incorporating a number of nonlinear and coupled processes, have generally been verifi ed/validated 

for only a small subset of their intended range of application conditions. Furthermore, processes that dominate at the 

small scale may not be those processes that are signifi cant at a larger scale or under more complex geochemical and 

hydrologic conditions. It is also likely that reaction rates and rates of inter-phase mass transfer measured in a laboratory 

setting will have little predictive value at the fi eld scale. Unfortunately, to date, mathematical models have not been 

extensively applied or validated for DNAPL source-zone remedial design or performance assessment at the fi eld scale. 

The lack of well-documented case studies has necessarily led to a lack of data for model application and validation, 

particularly under a range of chemical and geologic settings.

Even if a process-based model has been numerically verifi ed and conceptually validated for a particular application 

scenario, it will generally have large data requirements that may be diffi cult to satisfy in a fi eld setting. While bench-scale 

treatability studies may provide some opportunity for parameter estimation, the spatial variability of geologic properties 

and the complexity of DNAPL mass distributions at a typical fi eld site calls for a highly detailed characterization of the 

site or a well-defi ned methodology to incorporate parameter uncertainty into model predictions. Unfortunately, there 

is very little guidance on fi eld-scale parameter selection for models, and most modeling has been conducted within a 

deterministic, rather than probabilistic, framework using ‘average’ uniform parameters. Model simulations based upon 

average, uniform conditions, however, can yield dramatically different results from high-resolution model simulations 
36

under more realistic and heterogeneous conditions. Diffi culties in parameter estimation are further compounded by the 

lack of knowledgeable and experienced model users within the engineering practitioner community. 

The above discussion highlights the need for well-documented case studies of remedial technology application and 

performance in a variety of geologic and chemical settings. There is also a critical need for the validation of processbased model performance predictions at the fi eld scale. More effort should also be directed toward the development 

of parameter estimation guidance and more simplifi ed modeling tools that can reliably predict remedial aggregate 

performance behavior and its associated uncertainty under diverse conditions.

3.5.6 Summary

While signifi cant progress has been made in the development of new numerical tools to predict DNAPL recovery/

destruction in the subsurface, in both the saturated and unsaturated zones, these models are not widely used in practice, 

and are still in need of further verifi cation/validation at the fi eld scale. Before these tools will become as common in use 

as MODFLOW and other numerical tools, further validation and technology transfer are needed. With respect to the 

use of case studies as tools for decision-making regarding DNAPL source-zone depletion, the utility of these studies 

must be improved by providing suffi cient technical details to provide independent verifi cation of the performance and 

cost data provided. 

3.6 Question 6: What are the Factors Limiting the Effective and Appropriate Application of 

Source Depletion Technologies?

DNAPL source depletion technologies at present are being applied infrequently, and long-term containment has been the 

alternative of choice at most DNAPL sites in the past, although anecdotal information indicates that there is a measurable 

increase in the deployment of source depletion technologies across the country. The Panel’s response to this question 

led to the identifi cation of the primary factors that have led to the current state of remediation practice regarding the 

application of available and emerging DNAPL source depletion technologies. Understanding these factors is critical 

to the future successful development and deployment of promising new source depletion technologies at sites where 

the strategy for groundwater cleanup has not yet been selected. Furthermore, understanding these barriers may open 

opportunities for implementation of source depletion technologies at sites where a pump-and-treat remedy is already in 

place. The Visalia site represents a case in point, where the site owners decided that source depletion was warranted 

given the high cost and minimal effectiveness of the pump-and-treat system in operation at the site. 

3.6.1 Defi nition of Remedial Objectives Requiring Restoration in Source Zones

The national goal for contaminated aquifers remains returning the contaminated zones to the highest benefi cial use, 

which is domestic drinking water supply in most cases; many states echo this goal through their individual state 

non-degradation policies. The diffi culty and cost of achieving complete restoration of DNAPL-affected aquifers is welldocumented (e.g., NRC, 1994), and in the early 1990s, EPA established the technical impracticability guidance setting 

aside the restoration goal where it is technically and/or economically justifi ed and allowing for the designation of alternative 

cleanup goals. Other regulatory programs (e.g., RCRA Corrective Action) have provided similar options to establish 

alternative cleanup levels. Since that time, the number of sites where technical impracticability has been used to revise 

restoration cleanup levels is limited as discussed earlier in Section 2.0 of this Report. With perceived uncertainties in 

the cost and performance of aggressive source depletion technologies, and the view that these technologies cannot 

provide cost-effective solutions to achieving the endpoints required for regulatory compliance, long-term source-zone 

and plume containment has evolved into the generally recognized low-cost default strategy, but the long-term success 

of such a choice is uncertain and poses some long-term risk.

The Panel considers the objective of restoration in DNAPL source areas as a barrier to more widespread use of DNAPL 

source depletion technologies because of technical impracticability of achieving this goal, taking cost into consideration. 

As discussed in Section 2.0, however, we note some changes in the regulatory policies towards establishing alternative 

remedial action objectives in the source zones, and the appreciation from regulators that partial DNAPL source depletion 

may have signifi cant benefi ts in lieu of complete restoration. Thus, a regulatory framework that is based on either 

relaxing the timelines, the compliance boundaries, or adopting alternative remedial action goals (such as reduction in the 

contaminant mass discharge rate) for evaluating the progress made towards the fi nal goal will allow for an assessment of 

the benefi ts of partial source removal in DNAPL source zones. This evolving regulatory framework may lead to greater 

deployment of source-zone depletion technologies. 

3.6.2 Uncertainty in Predicting Likelihood of Success at a Given Cost

Closely associated with the fi rst factor is the current diffi culty in predicting the likelihood of successful source depletion 

and the benefi cial impacts of source removal on plume longevity as discussed in response to Question 5. This diffi culty 

stems from two main factors. First, there are relatively few well-documented case studies relating the degree of DNAPL 
37

depletion achievable for the various technologies to the geologic setting, DNAPL characteristics, and the level of effort 

and cost required. Such a track record will be needed to give the user community confi dence that capital investments 

in source depletion strategies will achieve a desired level of success. Second, there is an even more limited experience 

record relating source depletion to mass discharge reduction from DNAPL source zones and positive plume impacts. 

While modeling approaches are evolving to facilitate this analysis, documented experience in the form of case studies will 

be needed to validate these modeling approaches and provide data for extension to other sites. In addition, integrated 

modeling tools relating mass discharge reduction to natural attenuation mechanisms will need to be developed and 

validated with actual site data to provide a comprehensive assessment of the overall benefi ts of partial source removal 

for a range of DNAPL/geologic scenarios. 

An integral part of such case studies must include better and more complete documentation of the costs to characterize 

sites and conduct source depletion. Without access to reliable tools to relate costs and benefi ts, site owners will be 

resistant to source depletion as a remedial objective. SERDP has recently funded a series of inter-related projects 

involving basic research, modeling, and fi eld-testing to address some of these problems, but attention to this issue by 

EPA is also recommended. 

3.6.3 Lack of Well-Documented Successes 

While the Panel can point to quite a number of reasonably well-documented pilot-scale applications (see the Case Studies 

in Appendix A as well as case studies compiled through the various websites referenced in Question 4), there has been 

a decided lack of documented full-scale applications in the literature to date. A few full-scale projects employing source 

depletion technologies have reported signifi cant mass removal from source areas, and have claimed signifi cant benefi ts 

from these efforts (see also the recent EPA study on thermal technologies [U.S. EPA, 2003]). Even in these cases, a 

careful assessment of the effectiveness of the project has not been published in peer-reviewed literature. However, in 

some of these cases, the lead regulatory agency has approved site closure.

Particularly lacking have been integrated studies of full-scale source depletion and the resultant benefi cial impact to the 

dissolved plume. Without such documented successes, site owners and regulators are reluctant to accept the risk of 

failure (or the perceived risk of making matters worse by destabilizing DNAPL or cutting off natural attenuation) given 

the potentially high costs involved. On the other hand, this knowledge will not be forthcoming without willingness by 

some to accept risk. 

In response to this issue, the Panel is aware of a recent study being conducted for the U.S Navy to survey site studies 

of DNAPL remediation technologies. This survey has been completed as of April 2003, and the results of the survey 

should be available later this year (2003) (Lebron, C., 2003, personal communication). Preliminary results indicate that 

of the 175 sites included in the survey, over 50 percent of the respondents (vendors, users, regulators) claimed that 

the use of a source depletion technology for DNAPL was “successful” though “success” measures varied. Thermal 

technologies and chemical oxidation with permanganate were the most widely used technologies. This survey combined 

with recent EPA compilation (U.S. EPA, 2003), hopefully will provide some of the necessary data to demonstrate the 

actual benefi ts from partial source depletion as well as indicating the conditions under which source depletion may not 

be a suitable site strategy. 

Another option to resolve the continued uncertainties regarding the performance of DNAPL source depletion technologies 

is investment in post-closure characterization to assess critically the performance of the technologies. Sites where 

remedial action objectives have been achieved in the source zone could be subjected to an additional level of site 

characterization to confi rm the claimed success. Independent assessments of the performance and cost success of 

partial source depletion at these sites would enhance the credibility of claims of success. 

3.6.4 Availability and Cost of Insurance 

A standard vehicle for mitigating risk in virtually any situation is insurance, and new insurance instruments have been 

developed for the environmental remediation market. However, the concept of insuring the risk of failure of source 

depletion technologies is new, and the track record of these technologies is limited. While the panel has little experience 

with this subject, given the lack of documented successes of source depletion technologies, it is likely that insurance, if 

available, would be expensive. As the track record develops, use of insurance instruments to reduce the fi nancial risks 

to site owners applying source depletion strategies may become a more realistic option. Certainly the growing use of 

fi xed price or performance based contracts accepted by remediation contractors in the U.S. suggests that this barrier 

may become less onerous, although unresolved issues remain regarding long-term liability in the event of failure to 

achieve site closure. 

3.6.5 Limited Number of Qualifi ed Vendors 

The limited number of qualifi ed vendors raises the cost and limits the access to a technology. In addition, lack of fi nancially 

stable vendors raises risks to site owners and presents a further barrier to technology use. The proprietary nature of 
38

the technologies and competition between few vendors also results in limited information sharing during the important 

development phase of the technologies. Again, as a positive track record develops, the situation should improve as 

additional vendors enter the market, and the economics improve. EPA should evaluate their role in this problem such 

that vendors of these technologies can have some assurance of fi nancial stability. This, of course, is a controversial 

approach in the U.S., but we recommend that EPA give some consideration to innovative ways to overcome the market 

problems faced by vendors of environmental technologies, whose diffi culties have been documented in several forums 

(see e.g., NRC, 1997).

3.7 Question 7: How Should Decisions Be Made Whether to Undertake DNAPL Source 

Depletion?

In addressing this question, the Panel recognizes that the decision to implement source-zone depletion technologies 

for DNAPL site remediation is a highly site-specifi c decision, and that numerous regulatory, technical, and stakeholder 

factors must be considered. The current decision process as practiced in the U.S. has generally resulted in selection of 

containment over source depletion, although as noted elsewhere, there is a growing number of DNAPL sites where source 

depletion technologies are being deployed. In addition, market forces in the remediation fi eld are shifting the decision 

process for cleanup of groundwater towards the use of performance-based or fi xed price remediation contracts, with the 

risk of failure covered by cost cap insurance policies. Whether this leads to a greater use of source depletion technologies 

at DNAPL sites is uncertain. The Panel concluded, however, that new approaches to this decision process are needed. 

Therefore, the Panel considered two distinct options for developing an improved decision analysis methodology, one 

based on a qualitative semi-empirical analysis, and the other based on a quantitative model-based analysis. 

An example of the qualitative decision approaches is the “weight-of-evidence” analysis where multiple factors important 

in reaching a decision are assigned relative weight factors or numerical scores (based on consensus expert opinion), 

and the aggregate score is used to guide the choice among multiple remediation options. Thus, this “weight of evidence” 

allows numerous factors to be considered, without letting a single factor control the decision analysis. Figure 3.2 illustrates

the qualitative approach to decisions regarding the selection of source depletion technologies for DNAPL sites instead 

of the selection of a containment remedy. Depending on the geologic conditions and the DNAPL architecture, the size 

of the release, and the extent of land use, a DNAPL source zone would have a greater or lesser potential to achieve 

benefi ts from source depletion. Use of this screening level tool requires considerable judgment, and application to 

site-specifi c decision-making, and further development is needed to confi rm its utility. Sale (Sale, 2003) also recently 

presented an example of the use of such “decision charts” based on an assessment of various benefi ts accrued from 

full-scale deployment of source depletion at LNAPL sites. 

In contrast to the qualitative decision approach, a quantitative decision framework would provide a basis for balancing 

all benefi ts and costs with the risks of failure of the proposed remedy. Such a framework is needed to determine the 

following: 1) how much remediation is needed to meet remediation objectives, 2) which technologies will be deployed 

to remediate the source, 3) how will performance be monitored, 4) how “benefi ts” accruing from source treatment will 

be assessed, 5) how the economic analysis will be performed, and 6) how “soft” or “intangible” factors (i.e., implicit 

benefi ts) will be considered.

Figure 3.3 presents a schematic fl owchart of components of a quantitative decision support system that (1) integrates 

existing and new knowledge, (2) utilizes stochastic simulators to predict performance, (3) incorporates cost functions 

(i.e., marginal cost per unit benefi t), and (4) considers cost-effi cient optimal solutions in developing decision alternatives.

Decision tools based on such a fundamental approach do not exist at this time, but are being developed and tested for 

selection of plume management options (e.g., Bayer et al., 2001; Andersson and Destouni, 2001; Teutsch and Finkel, 

2003). Once developed, these tools need to be fi eld-validated, especially for the assumed costs.

Quantitative decision approaches may provide more transparent and conceptually sound bases for decision-making 

regarding the selection of source depletion strategies. However, to the Panel’s knowledge, rigorous quantitative approaches 

have not been used for decision-making at DNAPL sites for choosing among multiple options for source-depletion and 

plume-containment strategies. The Panel recognizes that such rigorous cost-minimization and net-benefi t-maximization 

approaches are still at a research level and have so far only been applied to few environmental problems (e.g., National 

Research Council, 1997; Gren et al., 2000, 2002; Hart and Brady, 2002; Baresel et al., 2003), however, not including 

DNAPL source depletion because of lack of suffi cient data. It must be noted and understood that cost-minimization is 

different from net-benefi t maximization and that both these basic economic decision rules, and modeling approaches 

need to be developed and investigated. The potential value of rigorous quantitative approaches to making rational DNAPL 

remediation decisions should be evaluated. Application of such approaches could prove to be useful in clarifying relevant 

and dominant factors and identifying research gaps associated with making remediation decisions that are economically 

effi cient and consistent with remedial objectives required by state and/or federal regulations.
39

Figure 3.2 Decision chart: Benefi ts from full-scale applications of source depletion.

DESIRED REMEDIAL BENEFITS1

MORE NEED FOR SOURCE DEPLETION LESS NEED FOR SOURCE DEPLETION 

Reduce potential for DNAPL migration as separate phase 

1a. Expanding mobile DNAPL Zone (probably rare at chlorinated solvent sites)2

(containment addresses this problem too)

1b. Free-Phase DNAPL present but stable in stratigraphic traps 

1c. Immobile, residual DNAPL Zone 

Reduce source longevity, and reduce long-term management requirements 

2a. High life-cycle containment cost (for example, containment Net Present Value (NPV) >> cost of remediation) 3a. Low reliability of containment system 4a. High resource value that cannot be used due to DNAPL (for example, sole-source aquifer OR Well Yield > 144,000 gpd with TDS < 3000 mg/L)3

5a. High probability of a meaningful reduction in time to reach MCLs (for example, small sites with low complexity) 

2b. Moderate life-cycle containment cost 3b. Moderate reliability of containment system 4b. Moderate resource value 5b. Moderate probability of a meaningful reduction in time to MCLs 

2c. Low life-cycle containment cost (for example, containment Net Present Value (NPV) << cost of remediation) 3c. High reliability of containment system 4c. Low resource value (for example, resource not being used AND either Total Dissolved Solids > 10,000 mg/L or Well Yield < 150 gpd)4

5c. Low probability of meaningful reduction in time to reach MCLs (for example, large releases at complex sites) 

Near-term enhanced natural attenuation due to reduced dissolved phase loading 

6a. Expanding dissolved phase plume (source loading > assimilative capacity) (containment addresses this problem too) 

6b. Stable dissolved phase plume (source loading ~ assimilative capacity) 

6c. Shrinking dissolved phase plume (source loading < assimilative capacity) 

Near-term reductions in dissolved phase loading to receptors (e.g., a well or a stream) 

7a. Receptor impacted now or impacted soon (for example, < 2 years travel time)5 

(containment addresses this problem too)

7b. Potential longerterm risk to receptor (for example, >2 years travel time) 

7c. No risk to receptors now or in the future 

Near-term attainment of MCLs 

8a. Need for rapid cleanup (for example, impending property transfer) 

8b. Limited need for rapid cleanup 

8c. No users of resource within expected time frame needed for restoration of aquifer and no other exposure pathways likely, e.g., vapor migration 

Intangibles 9a. Desire for active remedy; desire to test new 

technologies; desire to reduce stewardship burden on future generations 

9b. Neutral on intangible issues. 

9c. Desire for low-impact remedy; desire to use proven technologies; desire to not expend financial resources for limited risk reduction benefits 

References and background sources: 1. Sale, T.C., 2001. 2. Pankow, J.F., and J.A. Cherry (Eds), 1996. 3. American Petroleum Institute, 2002. 4. Texas Council on Environmental Quality, 2003. 5. Aziz, et al., 2000. 
40

Figure 3.3 Schematic of quantitative decision framework (Teutsch and Finkel, 2003).

Site History

(e.g. Metal manufacturing & chemical storage: site

operation from 1962 through 1969; new facilities in the

North since 1973; hot spots (leaking storage tanks)

locations: x1, y1 & x2, y2: diffused contamination in the

facility centre (solvent sludges): 1980: elevated TCE

concentrations in a well 250 m from the 5’ site boundary:...)

Contaminant-Specific Fate &

Transport Infos

(Laboratory & site investigations, literature, ...)

Aquifer/Contamination Scenarios

Site Characteristics

(e.g. hydrogeological unit 1: m = 10-13 m, K = 0.5-4 m/day,

v = 0.1-0.2 m/day, in W direction, unit 2: m = 25-30 m, K =

3-20 m/day, v = 0.02-0.04 m/day in SW direction; 12

observation wells, monthly measurements, length of TCE

plume in unit 1-230m; minor contaminations in unit 2: ...)

Geostatistical

Description

(e.g. K-average = 2 m/day, variance =

0.89, 12 m; ...)

Conditional simulations (continuous

and/or categorical variables)

λ =

Cost-Functions

(e.g. well drilling = 800 /m1;hydraulic

trench cutter = 110 /m2; lab analysis

= 03 /sample; electriciy for dryer (air

stripping) = 10 /(day m3): pumping

costs = 20 /m3; site installation costs

= 12000 ,...)

Remediation Scenarios

(funnel-and-gate) (monitored NA) (pump-and-treat)

Groundwater

Modelling

(e.g. prediction of flow conditions for 80

pump-and-treat alternatives(1, 2, 3 or 4

wells at different locations & pumping

rates) for 100 aquifer/contamination

scenarios: determine the percentage of

particles reaching extraction wells; ...) Total Cost ( )

Total Cost ( )

Total Cost ( )

Operation Time: Operation Time: Operation Time:

5 years

30 years

50 years

5 years

30 years

50 years

5 years

30 years

50 years

Reliability Reliability Reliability

Cost-based

Optimisation

Optimised Cost-efficient Options

Decision Alternatives

Environmental Impact

Analysis

(land use, risk reduction, life-cycle analysis, ...)
41

4.0 Knowledge Gaps and Research Needs

4.1 Introduction

This Report has identifi ed a number of knowledge gaps and research needs related to the issue of DNAPL source 

depletion. The following section provides a brief summary of the gaps and research needs organized by the key 

questions addressed by the Panel, namely, a) performance metrics, b) site characterization, c) DNAPL source-zone 

depletion technologies, d) performance prediction tools, and e) decision-making tools. 

4.2 Performance Metrics

4.2.1 Knowledge Gaps

A wide variety of metrics are available to assess the performance of DNAPL source-zone depletion technologies. 

Reliance on the metric of DNAPL constituent concentrations in the aqueous phase overlooks other metrics that 

will provide a more accurate assessment of the benefi ts of partial source-zone depletion. The utility of additional 

performance metrics for decision-making, performance assessment, and quantifi cation of the benefi ts of partial 

source-zone depletion needs to be assessed. 

4.2.2 Research Needs

Research needs for performance metrics include the following:

1. Conduct in-depth assessments of alternative performance metrics, and prioritize those alternative 

metrics that will improve the quantitative assessment of the overall benefi ts of DNAPL source depletion. 

Candidate alternative metrics include a) changes to the mass fl ux and mass discharge emanating 

from DNAPL source areas after source depletion b) residual DNAPL remaining, and c) changes to the 

biogeochemical environment in and around the source zone. 

2. Conduct fi eld scale comparisons of multiple methods for measuring contaminant mass fl ux (local) and 

mass discharge rates for a broad spectrum of hydrogeologic conditions and for various DNAPL types 

and DNAPL distribution (i.e., the DNAPL “architecture”).

4.3 Site Characterization

4.3.1 Knowledge Gaps

Site characterization tools are reasonably well developed for purposes of characterizing the nature and extent of 

DNAPL in the source zones. The inherent heterogeneities in the subsurface frustrate accurate quantifi cation of 

the mass and distribution of DNAPL in many geologic systems, however. Some technologies are also prohibitively 

expensive for widespread use in DNAPL source-zone characterization and performance assessment. The key 

knowledge gaps in site characterization include: 1) continued need for low-cost characterization technologies to 

estimate DNAPL mass removal or destruction, 2) dealing with uncertainties in DNAPL characterization based on 

concentration measurements, and avoiding overestimation of the extent of DNAPL, and 3) advances in techniques 

to measure mass fl ux and mass discharge from DNAPL sources for a variety of DNAPL distribution scenarios. 

4.3.2 Research Needs

Research needs to address these knowledge gaps for source-zone characterization include the following:

1. Conduct appropriate research projects to develop reliable methods for estimation of DNAPL mass and 

source distribution (i.e., DNAPL architecture), at appropriate spatial resolutions, both before and after 

remediation.

2. Conduct appropriate research projects to develop methods for estimation of contaminant mass fl ux 

building on research work to date, and support fi eld verifi cations of these new mass fl ux technologies 

in a variety of hydrogeologic settings.
42

3. Provide updated guidance on interpretation of DNAPL source characterization based on water samples 

from appropriate sampling locations in the saturated zones for a variety of hydrogeologic settings. 

4. Conduct appropriate research and development projects for development of source-zone characterization 

techniques in fractured systems and other highly complex hydrogeologic settings. 

4.4 DNAPL Source-Zone Depletion Technologies 

4.4.1 Knowledge Gaps

As discussed under Question 4, much information has been generated over the past two decades on the performance 

of various DNAPL source depletion technologies. Knowledge gaps persist, however, in part because of the highly 

heterogeneous characteristics of the subsurface. Some of the key knowledge gaps regarding these technologies 

include: 1) uncertainties regarding the DNAPL mobilization potential of thermal and surfactant/co-solvent technologies, 

2) the impact of soil heating on the geotechnical properties of the soil horizon, and the impact of the heated subsurface 

on fate and transport of remaining constituents of the DNAPL, 3) long-term water quality impacts on source zones 

following aggressive source depletion, 4) effectiveness of any of the technologies in fractured clay, fractured bedrock, 

and karst saturated zones, 5) total life cycle costs of the technologies in complex geologic settings, 6) demonstration 

of the potential effectiveness of DNAPL source-zone bioremediation at the fi eld scale, and 7) uncertainties in scale-up 

of pilot-scale studies to full-scale DNAPL source zones. 

4.4.2 Research Needs

To address these knowledge gaps, the following research needs for source depletion technologies are suggested: 

1. Determine the conditions under which mobilization of the DNAPL and spreading of the source zone may 

occur for thermal and surfactant/cosolvent fl ushing technologies.

2. Conduct appropriate laboratory and fi eld-scale demonstrations of the most promising technology combinations 

for DNAPL source depletion. Support continued research and development efforts for those technologies 

not yet ready for deployment but with the potential for lower costs compared to thermal technologies such 

as in-situ biodegradation. Support development and assessment of low-cost, less-aggressive alternatives 

for source-mass depletion (e.g., ZVI mixing, oxidant mixing).

3. Conduct appropriate research studies on fate and transport of DNAPL constituents following sourcezone treatment in both the vadose zone and the saturated zone to quantify the potential benefi ts of 

combined technologies (e.g., thermal and biodegradation, surfactants and biodegradation, ISCO, and 

biodegradation).

4. Conduct appropriate laboratory and fi eld studies of alternative source depletion technologies in the most 

challenging hydrogeologic settings to determine the characteristics of the saturated zone that limit the 

effectiveness of these technologies in such settings (fractured systems, karst).

5. Conduct theoretical, laboratory, and fi eld studies on the long-term water quality impacts of technologies 

requiring the injection of signifi cant quantities of fl uids to achieve the desired remedial objectives. Long-term 

water quality impacts are uncertain for surfactant/cosolvent technologies, injection of chemical oxidants, 

and injection of electron donor solutions for enhanced DNAPL removal using in-situ biodegradation.

6. Advance the state of the art in scale-up procedures for small-scale pilot studies of source-zone depletion 

that will result in a greater level of accuracy in design of full-scale source depletion applications.

7. Conduct technology failure analyses for containment systems based on reported fi eld data and/or theoretical 

assessment of potential failure modes for containment technologies.

Technology transfer on DNAPL source depletion technologies is also desirable, and practitioners would benefi t from 

guidance documents to allow: (a) determination of whether or not source remediation is appropriate for the site under 

consideration, and (b) selection of the source-depletion technology or technologies most appropriate for the site-specifi c 

conditions and remedial action objectives.

4.5 Performance Prediction Tools 

4.5.1 Knowledge Gaps

In general, the Panel concluded that performance prediction tools were not suffi ciently developed to provide an accurate 

methodology for assessing the likely performance of source-zone depletion technologies under a variety of DNAPL 

distribution and hydrogeologic settings. Although such algorithms exist, the input data and computational requirements 

limit the use of these algorithms in practice. 
43

4.5.2 Research Needs

The primary research need is the development of more user-friendly prediction tools that provide a more reliable and 

accurate basis for assessing the likely performance of source-zone depletion technologies. This is especially important 

in the context of determining whether an existing hydraulic containment strategy should be changed after a remedy is 

in place and the benefi ts of source-zone depletion need to be quantifi ed. Other needs include the following:

1. Support research on improved theoretical approaches for more accurate estimating of model input 

parameters.

2. Provide funding to validate multiphase numerical tools capable of predicting performance of source depletion 

technologies.

3. Conduct a review of existing and more recent case studies at DNAPL sites to evaluate performance based 

on several metrics of success including total mass depletion, reduction in mass discharge rates from the 

source zone, and whether reductions have been suffi cient to transition the remedial strategy to natural 

attenuation. Publish this information in a form convenient for use by consultants and other decision-makers 

for assessing the applicability of source depletion technologies at their sites of interest. 

4.6 Decision Analysis Tools

4.6.1 Knowledge Gaps

The most widely used model for decision analysis regarding the deployment of DNAPL source-zone depletion technologies 

is based on the National Contingency Plan (NCP) approach for comparison of alternatives at those DNAPL sites where 

feasibility analyses are required. That is, the remedy selected must meet the nine criteria established in the NCP in order 

to be selected for implementation where the site is under state or federal oversight. This decision model for assessing 

the options for DNAPL source-zone depletion is limited by the lack of a quantitative decision analysis tool or tools that 

can account for all quantifi able benefi ts and costs, taking uncertainty into account. 

4.6.2 Research Needs

The Panel recommends that the feasibility of developing a quantitative decision analysis tool with the characteristics 

presented in response to Question 7 be evaluated. If such a tool can be shown to be reliable through testing against 

actual site conditions, EPA should support a research program to develop such a tool, and provide the necessary 

guidance and training for application of the tool to decision-making at DNAPL impacted sites, both those sites where a 

containment remedy is already in place, and sites where a remedy has not yet been selected. 
44
45

5.0 Conclusions and Recommendations

The DNAPL Expert Panel was charged with evaluating the following four key issues related to source remediation at 

DNAPL impacted sites: 

a) Status of technology development and deployment for DNAPL source remediation.

b) Assessment of source remediation performance goals and metrics.

c) Evaluation of costs and benefi ts of source remediation.

d) Research issues and needs.

In response to this charge, the Panel generated seven questions to provide the technical basis for addressing each 

of these issues and to provide recommendations on strategies to address the overarching issue posed in the title of 

this Report, namely, can a case be made for undertaking DNAPL source-zone depletion at sites with contaminated 

groundwater? Based on the Panel’s responses to those questions and other information presented in this Report, the 

Panel presents the following conclusions and recommendations. 

5.1 Conclusions

a) Status of Technology Development and Deployment for DNAPL Source Remediation

1. Substantial progress in development and deployment of technologies for DNAPL source-zone characterization and mass depletion has been made in North America and Europe over the past two decades.

2. Available site characterization technologies are capable of bounding the locations of DNAPL sources 

in the subsurface in both the horizontal and vertical directions. The accuracy of DNAPL source-zone 

defi nition, however, is highly site-specifi c.

3. Even when a large effort is conducted for DNAPL source-zone site characterization using the best available technologies, uncertainties in the estimate of the total DNAPL mass present in the source zone 

will be large at many DNAPL-impacted sites because of the effects of geologic heterogeneity and the 

spatial heterogeneities in DNAPL distribution. 

4. Even at those sites where DNAPL source zones have been delineated, and the initial mass of DNAPL 

present has been estimated within a factor of two to four, it is diffi cult to determine if the DNAPL mass 

has actually been depleted from the subsurface, degraded into other chemicals, or been moved or 

displaced to another subsurface location following source depletion. This problem has been clearly 

demonstrated from the results of highly controlled DNAPL release studies at the Borden and the Dover 

Air Force Base sites or the recent source depletion tests at the Cape Canaveral site as summarized in 

Appendix A. 

5. Both conventional technologies (pump-and-treat, excavation) as well as innovative in-situ technologies 

are capable of partial DNAPL source-zone depletion. In a large number of pilot-scale studies of sourcezone DNAPL removal as well as in numerous full-scale implementation projects, mass depletion greater 

than 90 percent has been claimed. However, the Panel cautions that reported mass depletion levels 

as a percentage of the initial mass are highly uncertain due to the uncertainty in estimating the initial 

mass of DNAPL prior to source depletion. 

6. As far as the Panel is aware, there is no documented, peer-reviewed case study of DNAPL source-zone 

depletion beneath the water table where U.S. drinking water standards or MCLs have been achieved 

and sustained throughout the affected subsurface volume, regardless of the in-situ technology applied. 

Nonetheless, at a number of DNAPL-impacted sites, closure of the sites has been reported signifying 

achievement of RAOs.

7. Although numerous site trials have been conducted by both private and government entities for DNAPL 

source-mass depletion using innovative technologies over the past 15 years, comprehensive documen-
46

tation on the effectiveness of source-mass depletion and resultant effects on groundwater quality within 

the source zone and in the downgradient plume is available for only a few sites. Documentation on 

plume improvements following source containment is also lacking. Such documentation would provide 

important insights on the benefi ts that could be achieved even with partial DNAPL source depletion. 

Recent EPA publications (U.S. EPA, 2003) and a recent (2003) survey being conducted by the U.S. 

Navy may fi ll some of the gaps in this information base.

8. Results of more recent laboratory and theoretical analyses have indicated that partial source depletion 

of DNAPL in certain geologic settings using available in-situ technologies may provide quantifi able 

benefi ts including: 1) more rapid achievement of conditions conducive to monitored natural attenuation 

as the accepted remedy for the groundwater at the site, and 2) lower life cycle costs associated with 

treatment trains used to remediate both the source zone and the dissolved plume. 

b) Assessment of Source Remediation Performance Goals and Metrics

1. Source remediation performance goals and metrics currently used to evaluate the “success” of source 

depletion technologies are limited in number. The dominant goal employed by the regulatory community 

for groundwater considered a potential source of drinking water is U.S. drinking water standards for all 

regulated chemicals. Thus, achieving MCLs in the source zone is the primary goal of DNAPL source 

depletion in the U.S., and verifi cation of achieving that goal is defi ned by groundwater point samples 

collected from compliance monitoring wells. 

2. Although the MCL goal may be consistent with prevailing state and federal laws, and easy to communicate to public stakeholders, this goal is not likely to be achieved at the vast majority of DNAPL sites in 

the source zones. Thus, the exclusive reliance on this goal inhibits the application of source depletion 

technologies because achieving this goal is generally beyond the capabilities of available in-situ technologies in most geologic settings. Changes in the regulatory climate based on increased knowledge 

of the technical impracticability of achieving MCLs in the source zone and knowledge of the potential 

benefi ts of partial DNAPL depletion should establish a context for increased consideration of DNAPL 

source-zone depletion technologies at sites with a containment remedy (e.g., pump-and-treat) in place 

as well as new sites with no remedy in place. 

3. The use of the MCL goal as the single measurement of “success” does not account for other potential benefi ts of DNAPL source depletion. These may include a number of risk management benefi ts 

including: a) reduction of DNAPL mobility, b) reduced longevity of the plume source, c) reduction in 

mass fl ux and mass discharge from the source zone, and d) enhanced effi ciency and effectiveness of 

complementary source-zone control technologies.

4. Although the Panel did not conduct a detailed review of regulatory requirements at DNAPL sites throughout the U.S., the Panel is aware of other goals that have sometimes been used at sites for remediation 

of DNAPL source zones. These have included: 1) mass removal goals, 2) removal of DNAPL “to the 

extent practicable,” and 3) removal or stabilization of “mobile” DNAPL. It also appears that regulatory 

agencies at the state and local level are proposing more fl exible regulatory strategies for DNAPL source 

zones, which may result in a greater range of acceptable remedial action objectives for the source zone 

other than meeting MCLs throughout the contaminated zone. The Panel cannot confi rm how widespread 

this new fl exibility exists, but at the least, regulators are becoming fully aware of the need to consider 

benefi ts of partial source depletion other than meeting MCLs in the source zones. 

5. Multiple metrics will provide a more comprehensive basis for performance assessment of DNAPL 

source-zone depletion technologies. Use of alternative metrics such as reduction in mass fl ux and mass 

discharge from the source area is conceptually and scientifi cally appealing, but use of this metric is 

still in a research mode. This metric has not yet been embraced by the regulatory community for various reasons including uncertainties in the reliability and accuracy of current measurement techniques. 

Recently, regulators have expressed increased interest in these metrics, and efforts are now underway 

to assess their applicability for compliance and performance assessment purposes.

6. For a few metrics, multiple measurement methods are available, but for others, including mass fl ux and 

mass discharge, the methods are not proven, and are currently under development.

c) Evaluation of Costs and Benefi ts of Source Remediation

1. DNAPL source-zone depletion can provide explicit and implicit risk management benefi ts. Explicit benefi ts 

include: a) mitigating the potential for human contact and exposure, and the potential for unacceptable 

ecological impacts, b) reducing the duration and cost of other technologies employed in conjunction 

with the source removal technology, and c) reducing the life-cycle cost of site cleanup. Implicit benefi ts 

may include: a) minimizing risks of failure of containment strategies, b) satisfying public stakeholders' 
47

concerns, c) enhancing companies' “green image” as stewards of the environment, and d) minimizing 

future uncertain transaction costs associated with management of the site.

2. Information on the costs and benefi ts of source depletion is limited. Cost data for source depletion are 

available from governmental agencies and from technology vendors, but it is diffi cult to translate these 

costs from one site to another. In addition, it is not yet possible to estimate life-cycle costs following 

source depletion because of uncertainties in predicting the impact of source depletion on duration of 

the groundwater remedial action. 

3. Few, if any, studies on source-zone depletion have evaluated all costs associated with source-zone 

remediation. Because few DNAPL-impacted sites have achieved site closure, information on capital 

and annual O&M costs for successful source-zone remediation is limited. 

4. Cost data can be obtained from vendors for several of the source-zone depletion technologies, and 

these data allow for the economic comparison of alternative strategies for remediation of the source 

zone. A simple engineering economics analysis presented in this Report compares the costs of DNAPL 

(creosote) source removal at the Visalia site with the life cycle costs of the pump-and-treat system previously employed for source containment. The relative economic benefi ts of source depletion options 

are strongly dependent on the net discount rate assumed when considering the time value of money. 

In a low discount rate environment, source depletion may be cost-effective, but at interest rates above 

fi ve percent, the life cycle costs of the containment option appear to be lower than the costs for source 

depletion. Use of this simple engineering economics approach is helpful in bounding the range of costs 

for source depletion technologies that would potentially be cost-effective compared to containment 

remedies. An assessment of economic benefi ts is only one of the potential benefi ts that should be 

evaluated when making a source remediation decision. 

5. Risk management benefi ts are diffi cult to quantify because of inherent uncertainties in predictions 

related to the effectiveness of source-zone depletion and the impact of DNAPL source-zone depletion 

on overall site closure. Translation of implicit risk management benefi ts into monetary terms presents 

even greater challenges that have not yet been addressed. 

6. Because of the limitations in available tools for predicting the effectiveness of source depletion technologies, estimating the monetary value of all explicit and implicit benefi ts, and estimating the overall 

cost impact of applying these source-zone depletion technologies, decision-making based on classic 

risk/benefi t calculations is inherently limited. The degree of uncertainty in the costs and benefi ts of 

applying source depletion technologies is currently at levels that discourage widespread use of the 

available source depletion technologies at DNAPL sites. 

5.2 Recommendations 

The Panel provides the following recommendations to the U.S. EPA.

1. Fund research, demonstration projects, and technology transfer to address and reduce the uncertainties in quantifying the benefi ts from source-zone depletion.

Uncertainties in quantifying the economic benefi ts of DNAPL source-zone depletion are a major barrier to the use 

of source remediation technologies. The research needs identifi ed in Section 4.0 should be part of EPA’s program 

to address these uncertainties. To determine the appropriate level of funding, EPA should conduct an inventory 

of DNAPL sites throughout the U.S. to confi rm the magnitude of the problem and to assess the potential reduction 

in life-cycle costs from increased application of source depletion technologies compared to containment strategies. 

EPA should build on the results of the recent survey conducted by the U.S. Navy on the use of DNAPL source 

depletion technologies at over 175 sites. 

2. EPA, in cooperation with other agencies and private industry, should continue support of demonstration efforts to develop, test, and validate the most promising technologies for DNAPL source-zone 

characterization and mass depletion. 

Cost-effective and reliable technologies are needed to improve the accuracy of locating DNAPL sources, estimating the magnitude of the DNAPL source, and quantifying the distribution of the DNAPL. Current techniques show 

promise but are limited in accuracy and/or are costly. All of the in-situ source depletion technologies have advantages 

and disadvantages, depending on the site-specifi c conditions. Knowledge of the effectiveness and cost of thermal 

technologies, surfactant and co-solvent technologies, and ISCO is most advanced for DNAPL source depletion. 

However, uncertainties persist, and additional demonstration projects that are fully documented are needed. There 

is a particular need for performance and cost data for DNAPL source-zone depletion technologies in fractured 

systems. 
48

3. EPA should provide a new guidance document for source-zone response actions at DNAPL sites 

that provides a road map for decision-makers to determine if implementation of source depletion 

technologies is appropriate.

Given the sparse use of the TI waiver policy at DNAPL sites, and the limited number of source removal actions that 

have been undertaken, a new guidance document should be prepared for use by decision-makers to determine 

if source depletion technologies should be implemented given site conditions and the institutional setting. This 

document should build on the large amount of information compiled by various federal agencies, state agencies, 

universities, and private sector initiatives on the cost and effectiveness of DNAPL source depletion technologies. The 

document should include detailed guidance on how to conduct technology demonstrations in a credible manner. EPA 

should develop protocols to permit a quantitative assessment of the appropriate potential remediation category in 

which to assign a DNAPL site. As part of this protocol development, EPA should review a representative sample of 

DNAPL sites in the U.S. to determine the estimated proportion of sites that would be considered for three categories, namely: a) strong candidate for DNAPL source depletion, b) potential candidate for DNAPL source depletion, 

and c) not suitable for application of DNAPL source depletion technologies. The guidance document should also 

discuss the use of alternative remedial action goals other than achievement of target cleanup levels in the source 

zone and the value in using alternative performance assessment metrics. 

4. Conduct a thorough and independent review of a selected number of DNAPL sites where suffi cient 

documentation is available to assess the performance of source depletion using a multiple of metrics. 

The need for well-documented case studies of remedial technology application and performance in a variety of 

geologic and DNAPL distribution scenarios is apparent. The currently available documentation on these studies is 

substantial, but limitations in the performance evaluation and accuracy of cost estimates contribute to the reluctance 

by decision-makers to implement source depletion technologies at many DNAPL sites. There is also a critical need 

for the validation of process-based model performance predictions at the fi eld scale. Without these models, the 

long-term benefi ts of source depletion cannot be quantifi ed in any meaningful way. This effort should include the 

development of parameter estimation guidance, guidance on scale-up of pilot scale studies, and more simplifi ed 

modeling tools that can reliably predict remedial aggregate performance and its associated uncertainty under diverse 

geologic and chemical conditions.

5. Develop and validate technologies for cost-effective and accurate measurement of mass fl ux and 

mass discharge from DNAPL sources zones.

Measurements of the distribution of mass fl ux and the mass discharge from a source zone may provide new metrics for assessing the performance of source-zone depletion technologies. Research into technologies to measure 

these metrics accurately has only recently begun. Field experiments are needed to verify theoretical predictions 

that DNAPL removal from the more permeable zones in an aquifer may substantially reduce mass discharge from 

source zones. Furthermore, the benefi ts of this reduction as they relate to risk reduction must be quantifi ed. EPA 

should support the development and validation of these technologies, building on research efforts currently funded by 

the Department of Defense through the Strategic Environmental Research and Development Program (SERDP). 

6. Evaluate impacts of source depletion technologies on long-term aquifer water quality. 

Demonstration projects conducted over the past decade have focused primarily on the effectiveness of DNAPL mass 

removal by candidate source depletion technologies. Few projects have considered the long-term water quality impacts 

of source depletion technologies. EPA should conduct necessary post-remediation studies to verify that long-term 

impacts of source depletion technologies will not be deleterious to future benefi cial uses of the groundwater.

7. Develop and assess the suitability of cost-minimization and net-benefi t maximization decision models for evaluating the complete spectrum of costs and benefi ts of source depletion technologies.

Current economic and fi nancial models, used to make decisions on whether source depletion should be undertaken, have a number of limitations as discussed in this Report. The development and validation of a much more 

comprehensive economic model such as a cost-minimization or net-benefi t maximization approach may provide 

important insights into the current tradeoffs between DNAPL source containment and long-term institutional controls compared to the generally signifi cant capital cost of source depletion technologies. The practical benefi ts of 

this approach should be assessed by EPA, and if found to be feasible, such a model should be further developed, 

validated, and made available for practitioners and regulators.
49

6.0 List of References and Bibliography

References Cited in Text

Abriola, L.M., D.M. O’Carroll, S.A. Bradford, and T.J. Phelan. 2002. Compositional effects on interfacial properties in 

contaminated systems: Implications for organic liquid migration and recovery. In: Computational Methods in Water 

Resources, Vol. 1, Proc. of the XIV Intl. Conf., June 23-28, Delft, The Netherlands, Developments in Water Science 

47. Hassanizadeh, S.M., R.J. Schotting, W.G. Gray, and G.F. Pinder (Eds). Elsevier, Amsterdam, The Netherlands 

(plenary paper). pp. 795-802.

 Abriola, L.M., and S.A. Bradford. 1998. Experimental investigations of the entrapment and persistence of organic liquid 

contaminants in the subsurface environment. Environmental Health Perspectives, 106(S4), August.

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fractured geologic media. Ground Water, 32(5):805-820. 

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resistivity. In: Proceedings of Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, 

and Restoration, National Water Well Association, American Petroleum Institute, Houston, TX, pp. 284-305. 

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http://www.clu-in.org/download/frtr/dnapls.pdf

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in sand-and-gravel aquifers, Ground Water Monitoring Review, 13(3):129-138.

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and Analysis, May/June:25-32.

LaPlante, L. 2002. Innovative strategy to locate VOC sources deep in the subsurface. In: A.R. Gavaskar and 

A.S.C. Chen (Eds). Remediation of Chlorinated and Recalcitrant Compounds – 2002. Proceedings of the Third 

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ISBN 1-57477-132-9, published by Battelle Press, Columbus, OH. 
56

Marrin, D.L. 1987. Soil gas sampling strategies: Deep vs. shallow aquifers. In: Proceedings of 1st National Outdoor 

Action Conference on Aquifer Restoration, Ground Water Monitoring and Geophysical Methods, National Water 

Well Association, Dublin, OH, pp. 437-454.

Pitchford, A.M., A.T. Mazzella, and K.R. Scarborough. 1989. Soil-Gas and Geophysical Techniques for Detection of 

Subsurface Organic Contamination, U.S. EPA Report: http://www.hanford.gov/dqo/project/level5/01erg.pdf

Semprini, L., M. Cantaloub, S. Gottipati, O. Hopkins, and J. Istok. 1998. Radon-222 as a tracer for quantifying and 

monitoring NAPL remediation. In: Proceedings of the First International Conference on Remediation of Chlorinated 

and Recalcitrant Compounds, Non-Aqueous-Phase Liquids, Columbus, Ohio: Battelle Press. pp.137-142. 

Davis, B.M., J.D. Istok, and L. Semprini. 2002. Push-pull partitioning tracer tests using radon-222 to quantify non-aqueous 

phase liquid contamination. J. Contam. Hydrol. 58:129-146.

Direct Push Methods

Applied Research Associates Vertek Manufacturing Group: http://www.vertek.ara.com/

Geoprobe Systems: http://www.geoprobe.com/

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profi ler. Ground Water Monitoring Review, Spring:122-131.

Pitkin, S.E. 2002. Waterloo profi ling and lab environmental services presentation, Stone Environmental, Inc.

Precision Sampling Inc.: http://www.precisionsampling.com/

Solinst Canada Ltd.: http://www.solinst.com/

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http://www.wes.army.mil/el/scaps.html

USDOE. 1996. Cone Penetrometer, Innovative Technology Summary Report. DOE/EM-0309, 22 pp: 

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USDOE. 2001. Wireline Cone Penetrometer System for Multiple Tool Usage. Innovative Technology Summary Report 

DOE/EM-0617, 20 pp: http://apps.em.doe.gov/OST/pubs/itsrs/itsr2222.pdf

USDOE. 2002. Cone Permeameter Technology Summary Report. DOE/EM-0632, 28 pp: 

http://apps.em.doe.gov/OST/pubs/itsrs/itsr307.pdf

Fluorescence Methods

Applied Research Associates Vertek Fuel Fluorescence Detector: http://vertek.ara.com/products/probes_index.html

Bujewski, G., and B. Rutherford. 1996. The Rapid Optical Screening Tool (ROST) Laser-Induced Fluorescence (LIF) 

System for Screening of Petroleum Hydrocarbons in Subsurface Soils. Sandia National Labs Report, 86 pp: 

http://costperformance.org/complete_docs/ROSTLIF_2.pdf

Dakota Technologies, Inc. website: http://www.dakotatechnologies.com/LIF/LIFinfo.htm

Fugro Geosciences Inc., ROST information: http://www.geo.fugro.com/html/rost.htm

Lee, P-K. D., and A. A. Keller. 1998. Fluorescent Delineation of DNAPL Subsurface Contamination: 

http://www.icess.ucsb.edu/esrg/ess_sum97/Students_ESS.1997/Dennis_Lee/paper_dennis.html

Lieberman, S.H. 2001. SCAPS presentation, 29 pp: http://www.epa.gov/tio/tsp/download/lieberman.pdf

USDOE. 2002. Induced Fluorescence Sensors for Direct Push Systems. Innovative Technology Report EM-0638, 39 pp: 

http://apps.em.doe.gov/OST/pubs/itsrs/itsr2237.pdf

U.S. EPA, 1995. Site Characterization Analysis Penetrometer System (SCAPS). EPA/540/R-95/520, 68 pp: 

http://www.epa.gov/ORD/SITE/reports/540_R-95_520.PDF

U.S. EPA, 1995. Rapid Optical Screen Tool (ROST) Innovative Technology Report. EPA/540/R-95/519, 80 pp: 

http://www.epa.gov/ORD/SITE/reports/540_R-95_519.pdf

U.S. EPA web site: http://fate.clu-in.org/LIF.asp?techtypeid=93

Membrane Interface Probe

Christy, T.M. 1996. A permeable membrane sensor for the detection of volatile compounds in soil, In: NGWA Outdoor 

Action Conference Proceedings, 8 pp.

Geoprobe Systems website: http://www.geoprobe.com/products/tools/direct_sensing/mipdesc.htm
57

NavFac Engineering Command Southern Division. 2001. MIP presentation: 

http://enviro.nfesc.navy.mil/erb/erb_a/support/cleanup_conf/2001conf/2001cd/a37mip.ppt

Soil Chemical Analysis to Determine NAPL

Duke Engineering and Services, Inc. 1997. Soil sampling and NAPLANAL Navy RITS presentation, 28 pp: 

http://enviro.nfesc.navy.mil/erb/erb_a/restoration/technologies/remed/phys_chem/sear/03-sear-soil-sampling.pdf

Feenstra, S., D.M. Mackay, and J.A. Cherry. 1991. Presence of residual NAPL base on organic chemical concentrations 

in soil samples. Ground Water Monitoring Review, 11(2):128-136. 

Mariner, P.E., M. Jin, and R.E. Jackson. 1997. An algorithm for the estimation of NAPL saturation and composition from 

typical soil chemical analyses. Ground Water Monitoring Review, 17(2):122-129.

Mott, H.V. 1995. A model for determination of phase distribution of petroleum hydrocarbons at release sites. Ground 

Water Monitoring Review,15(3):157-167.

NAPLANAL code available at http://www.napl.net/publications.html

Multilevel Wells

CMT multilevel well system: http://www.solinst.com/Prod/403/403d2.html

Waterloo multilevel well system: http://www.solinst.com/Prod/401/401.html

Westbay MP multilevel well system: http://www.westbay.com/htm/products.html

Water FLUTE system: http://www.fl ut.com/sys_1.htm]

Ribbon NAPL Sampler

Flexible Liner Underground Technologies, Ltd. Web site: http://www.fl ut.com/app_10.htm

International Union of Operating Engineers National Hazmat Program. 2002. Human Factors Assessment Report, NAPL 

Ribbon Sampler, 16 pp: http://www.iuoeiettc.org/hfaet/TechTypeII/DNAPL/Ribbon NAPL Final 5-6-02.pdf

Keller, C., et al. 2000. Utility of fl exible liners installed via push rods. In: Proc. 3rd Int. Symp. Integrated Technical 

Approaches to Site Characterization, Chicago, IL, Sept. 12-14, 2000. 5 pp: 

http://www.quicksite.anl.gov/quicksite/pdfs/keller2000.pdf

USDOE. 2000. Ribbon NAPL Sampler, Innovative Technology Summary Report. EM-0522, 19 pp: 

http://costperformance.org/complete_docs/itsr2238.pdf

Partitioning Interwell Tracer Test

Dai, D., F.T. Barranco, Jr., and T.H. Illangasekare. 2001. Partitioning and interfacial tracers for differentiating NAPL 

entrapment confi guration: column-scale investigation. Environ. Sci. Technol., 35:4894-4899. 

Deeds, N.E., D.C. McKinney, and G.A. Pope. 1999. Vadose zone characterization at a contaminated fi eld site using 

partitioning interwell tracer technology. Environ. Sci. Technol., 33(16):2745-2751.

Duke Engineering. 1999. DNAPL Site Characterization Using a Partitioning Interwell Tracer Test at Site 88, Marine 

Corps Base, Camp Lejeune, NC. Report to NavFac, 131 pp: 

http://enviro.nfesc.navy.mil/erb/erb_a/restoration/fcs_area/dnapl/dnapl-rpt_text.pdf

Dwarakanath, V., N. Deeds, and G.A. Pope. 1999. Analysis of partitioning interwell tracer tests. Environ. Sci. Technol., 

33(21):3829-3836.

Jin, M., G.W. Butler, R.E Jackson, P.E. Mariner, J.F. Pickens, G.A Pope, C.L. Brown, and D.C McKinney. 1997. Sensitivity 

models and design protocol for partitioning tracer tests in alluvial aquifers. Ground Water, 35(6):964-972. 

Jin, M., M. Delshad, V. Dwarakanath, D.C. McKinney, G.A. Pope, K. Sepehrnoori, C.E. Tilford, and R.E. Jackson. 1995. 

Partitioning tracer test for detection, estimation and remediation performance assessment of subsurface nonaqueous 

phase liquids. Water Resour. Res., 31(5):1201-1211.

Nelson, N.T., M. Oostrom, T.W. Wiestma, and M.L. Brusseau. 1999. Partitioning tracer method for the in situ measurement 

and sample method. Environ, Sci. Technol., 33:4046-4053.

Mariner, P.E., M. Jin, J.E. Studer, and G.A. Pope. 1999. The fi rst vadose zone partitioning interwell tracer test for 

nonaqueous phase liquid and water residual. Environ. Sci. Technol., 33(16):2825-2828.

Young, C.M., R.E. Jackson, M. Jin, J.T. Londergan, P.E. Mariner, G.A. Pope, F.J. Anderson, and T. Houk. 1999. 
58

Characterization of a TCE DNAPL zone in alluvium by partitioning tracers. Ground Water Monitoring and Remediation,

XIX(1):Winter 1999.

Mass Flux

Bockelmann, A., T. Ptak, and G. Teutsch. 2001. An analytical quantifi cation of mass fl uxes and natural attenuation rate 

constants at a former gasworks site. J. Contam. Hydrol., 53:429-453. 

Enfi eld, C.G. 2001. Source reduction by fl ushing presentation, DNAPL Source Remediation Workshop, Dallas, TX.

Hatfi eld, K., M.D. Annable, S. Kuhn, P.S. Rao, and T. Campbell. 2001. A new method for quantifying contaminant fl ux 

at hazardous waste site, GQ2001 Conference, Sheffi eld, UK. 
59

APPENDIX A - CASE STUDIES
60

CASE STUDY

Application of Steam Enhanced Extraction 

Site 5, Alameda Point, California
61

Application of Steam Enhanced Extraction, Site 5 

Alameda Point, California

Introduction

The feasibility of Steam Enhanced Extraction (SEE) to remove chlorinated hydrocarbons from a Non-Aqueous Phase 

Liquid (NAPL) waste solvent source found in shallow fi ll soils was tested on a pilot scale at Site 5, Alameda Point, 

Alameda, California. The goals were to reduce chlorinated solvent concentrations in the groundwater in the treated 

zone to values comparable to the groundwater concentrations upgradient of the treatment zone, and to reduce soil 

petroleum hydrocarbon concentrations to levels which minimize migration potential. Without source removal, the NAPL 

mass was estimated to feed the groundwater plume for at least 600 years based on maximum aqueous solubilities of 

TCE dissolving from the multicomponent NAPL, the measured hydraulic gradients, measured transmissivities, upperlimit NAPL projected cross-sectional area, and measured TCE mass removed using SEE. Since this time frame was 

considered to be too long-term for monitored natural attenuation to be a viable option, source depletion was requested 

as a means of shortening the natural attenuation time frame of the site.

Application of SEE

The NAPL source zone was surrounded by six injection well clusters as shown in Figure A.1, with separate injection 

completions in the vadose zone and in the saturated zone. A single extraction well in the center of the hexagonal pattern 

was used to extract water, NAPL, and hot vapors. The surface concrete served as the cap for the process. The extracted 

fl uids were cooled, separated, and treated. The NAPL was collected and stored in drums for eventual recycling, and the 

vapor and water streams were passed through carbon for treatment before discharge to the atmosphere and sewer, 

respectively. 

In order to decrease the potential for NAPL condensation under the concrete cap, steam was fi rst injected into the vadose 

zone for 10 days until hot vapors were observed in the extraction well. Steam was then injected into both the vadose 

and saturated zones at maximum rates possible for an additional 40 days until contaminant recovery rates dropped. 

Thereafter, and until the end of operations 20 days later, the injections and extractions occurred cyclically with a goal 

of inducing fl uid pressure changes in the pores of the soil. Pressure reduction has been shown to induce in-situ boiling 

of water from soils of a wide range of permeabilities, which steam-strips VOC from the aqueous phase in a relatively 

homogeneous manner.

Operational data were collected to allow the quantifi cation of the rates of removal of masses of solvents and other 

petroleum hydrocarbons from the subsurface. One hundred sixteen subsurface temperatures were measured daily and 

analyzed to track the development of the subsurface temperature fi eld. Steam injection rates were closely monitored, 

and energy balances were tracked. Groundwater samples were taken from multipoint sampling locations before, and 

two months after, the application of SEE. Soil samples were taken aseptically before and after the steaming process 

to ascertain the impact of the steaming on microbial populations. All analytical data were obtained from analysis by an 

external certifi ed laboratory, or analyzed at U.C. Berkeley, under the direction of an independent QAQC offi cer.

Results

A mass of 1,950 kilograms (kg), (or the equivalent of 600 gallons of hydrocarbon liquids), was removed during the 

operation of SEE. Of that mass, 83% was collected as NAPL and recycled, 2% was adsorbed on carbon in the water 

treatment system, and 15% was adsorbed on carbon in the vapor treatment line. The recovered TCE was mostly found 

in the gases exiting the last vapor/liquid separator, accounting for a mass of 192 kg. An additional 22 kg was removed 

in the water stream entering the treatment carbon. Only 18 kg of TCE was found in the recovered NAPL. 

Soil concentrations of extractable petroleum hydrocarbons were reduced by about an order of magnitude by SEE with only 

low volatility components remaining in the soils that experienced ample steam fl uxes. Only trace amounts of chlorinated 

compounds could be found in the steamed soils in shallow soils near the surface cap. Groundwater concentrations in 

the treatment zone were generally reduced to values about an order of magnitude lower than typical values found in the 

up-gradient groundwater. The VOC concentrations in water at the locations where NAPLs were observed before SEE 

decreased over two orders of magnitude from their initial concentrations (see Figure A.2). Microbial population counts 

in the steamed soils showed microbial rebound to pre-steaming levels upon cooling.
62

Figure A.1 NAPL extent, sampling locations, injection well location, and extraction well location.

Figure A.2 Pre- and Post-Steam TCE concentrations in ground water (ppb).
63

Discussion

The treatability test showed that SEE can remove VOC constituents from a NAPL source and can reduce groundwater 

VOC concentrations in the source zone to levels below those of the surrounding plume. This result implies that sourcezone depletion using SEE has the potential of reducing the site problem from one source zone existing for hundreds 

of years, to one where short-term monitored natural attenuation of the plume may be suffi cient for long-term remedial 

needs. 

The residual hydrocarbons (maximum soil concentration of 2000 mg/kg soil) remaining after the application of SEE 

had compositions similar to motor oils and greases. Those compounds have greatly reduced mobilities given their low 

volatilities and solubilities as compared to the initial mixture of volatile solvent wastes. The rebound of active microbial 

populations in soils taken from the steamed zone to levels near those found in un-steamed soils implies that natural 

attenuation processes will probably continue at this site in the zones that were steamed.
64

CASE STUDY

A Pilot-Scale Demonstration of Surfactant Enhanced PCE 

Recovery at the Bachman Road Site
65

A Pilot-Scale Demonstation of Surfactant Enhanced PCE Recovery at the 

Bachman Road Site

This brief summarizes results of a pilot-scale technology demonstration of surfactant enhanced aquifer remediation 

(SEAR) at the site of a former dry cleaning facility in Oscoda, MI. The demonstration was funded by the Michigan 

Department of Environmental Quality and involved researchers from the University of Michigan and Georgia Institute 

of Technology, in partnership with HSI Geotrans. 

Site Description 

The Bachman Road site is underlain by an unconfi ned aquifer composed of relatively homogeneous fi ne- to mediumgrained glacial outwash sands. The aquifer has a saturated thickness of approximately 15 feet and is confi ned below by 

a thick clay layer. A sand/silt transition layer exists immediately above the clay. The shallow water table is at a depth of 

11 feet. A narrow tetrachloroethylene (PCE) plume emanates from a suspected DNAPL source area, beneath a former 

dry cleaning building and discharges into Lake Huron, approximately 700 feet downgradient (Figure A.3). There are no 

co-contaminants at the site, and the aquifer sands are extremely low in organic carbon. PCE degradation by-products 

are essentially absent from the plume, suggesting little natural attenuation. 

Figure A.3 Advective plume Bachman road SEAR pilot-scale test location. Shown is simulated contaminant advective fl ow to Lake Huron from suspected source zone.

Contamination from volatile organic contaminants was fi rst detected in private water supply wells in the Bachman Road 

subdivision in 1980. In the mid-late 1980s, a remedial investigation was initiated by the MI DNR. Four groundwater 

plumes were delineated. The PCE plume described above was designated as Plume B. Additional characterization work 

was undertaken in 1992-94, including monitoring well installation and collection of water and unsaturated soil samples. 

Although free-phase PCE was not detected, aqueous PCE concentrations as high as 88 ppm were measured in front 

of the former dry cleaning facility (currently a printing business, with an adjacent private residence). 

In 1999, additional site characterization work was undertaken in the vicinity of the former dry cleaning facility to 

explore the feasibility of applying SEAR at the site and to design a pilot-scale test. Intact cores were taken along eight 

vertical and angled borings. Cores were analyzed for PCE and sub-sampled for hydraulic conductivity and grain size 

distribution measurements. Hydraulic conductivity estimates ranged from 15-150 feet per day. Additional drive point 

and monitoring well samples indicated that the likely source of contamination was beneath the northwest corner of the 

former dry cleaning building, and this area was selected for the SEAR pilot-scale treatment zone. Further core sampling 

within the treatment zone (for installation of multilevel samplers) indicated that PCE contamination varied with depth. 

High PCE contamination levels were found consistently in two regions, about one to two feet beneath the water table 

and immediately above the aquitard. Only two soil sub-samples within the treatment zone conclusively indicated the 

presence of free-phase PCE. A small amount of free product was also detected in one multilevel sample prior to the 
66

start of the test. No PCE pools were encountered in site characterization, and meaningful mass estimation from core 

sampling was not possible. 

SEAR Test Design

Tween 80, an ethoxylated sorbitan ester surfactant, was selected for the SEAR demonstration, based upon its high 

solubilization potential for PCE and its biodegradability. It performed well in laboratory tests with site materials. The 

pilot-scale test design (Figure A.4) consisted of a single extraction well (19.7 L min-1), a row of three water injection 

wells (3.8 L min-1 each) to establish a fl ow fi eld through the source zone, and a gallery of three surfactant injection wells 

(1.9 L min-1 each) positioned between the water supply and extraction wells. The selected pumping schedule involved 

start-up of the extraction well, followed shortly by all injection wells. For estimation of PCE mass within the swept zone, 

surfactant injection was preceded by a short-term partitioning tracer test (PITT). Following the PITT test, injection of a 

6% (by volume) surfactant solution was initiated over the entire saturated thickness for fi ve days. Operation of well S1 

was then discontinued and a targeted injection of surfactant continued for an additional fi ve days in wells S2 and S3, 

screened over the top and bottom 1.2 m of saturated depth. Simulations predicted that this targeted injection scheme 

would effi ciently deliver surfactant to suspected highly contaminated regions and reduce overall surfactant cost. In 

total, 1.5 pore volumes of surfactant solution were injected. Water injection was continued for an additional two days 

after surfactant shut off, and the extraction well was then operated for one month to ensure surfactant and solubilized 

plume capture. Total test operation time was 60 days. Effl uent from the extraction well was treated in above ground 

air strippers, and the treated fl uid was then discharged to the community sewer system. Approximately 4,500 aqueous 

samples (excluding duplicates) were collected from the multilevel samplers during the test and analyzed for dissolved 

constituents (alcohols, PCE, and Tween 80) at the University of Michigan analytical laboratories (Figure A.4). 

Figure A.4 Bachman road SEAR pilot-scale test site plan. SEAR treatment zone is shaded. Vertical depths for 

each monitoring point are shown.

Test Results

During the SEAR test, hydraulic capture of the solubilized plume was demonstrated with more than 95% of the 

injected surfactant recovered during the test. Surfactant sweep of the test zone was confi rmed by multilevel sampler 

measurements of surfactant breakthrough. Approximately 19 L of PCE were extracted from the swept zone. This volume 

was consistent with results from the PITT test that indicated low average saturations of PCE (0.03% to 0.60%) within 

the swept volume. Signifi cant PCE aqueous concentration tailing (at a level of 15 ppm) was observed in the extraction 

well, subsequent to surfactant plume capture. It is likely that these high tailing concentrations are associated with an 

additional DNAPL source region within the capture zone of the extraction well. This hypothesis has been confi rmed 
67

by follow-on aqueous sampling within the surfactant swept region. Aqueous samples from the multilevels within this 

region have revealed a two order-of-magnitude reduction in aqueous concentrations subsequent to treatment. Highest 

concentrations, once nearing 100 ppm, are now below 1 ppm, with most sampling points below 0.1 ppm. (Note that 

these concentrations still exceed MCLs). Higher PCE concentrations appear to be associated with areas of persistent 

higher Tween 80 concentrations, suggesting stagnant zones within the source region. To date, no concentration rebound 

has been observed within the swept zone. PCE degradations products (TCE and cis-DCE) have recently been detected 

in signifi cant concentrations within and downstream of the treatment zone, suggesting that the addition of the Tween 

80 has stimulated microbial activity. (Neither ethene nor vinyl chloride have been detected to date). A halorespiration 

investigation and in-situ stimulation of halorespirers is ongoing at a near-by mixed BTX/PCE plume.

Contractor costs for the pilot-scale test totaled approximately $390,000. This included preliminary and fi nal design 

costs, limited source characterization work, installation of multilevel piezometers for monitoring, system construction, 

system operation and maintenance (including treatment system sampling), treated effl uent discharge costs, and system 

shutdown. This total excludes the costs for the intensive aqueous sampling of the swept zone and associated chemical 

analyses. 

The MI DEQ has been encouraged by the pilot-scale test results, and a full-scale SEAR implementation for the site is 

currently being designed. 
68

CASE STUDY

In-Situ Alcohol Flushing for Enhanced Remediation of 

PCE Source Zone: Sages Dry Cleaner Site
69

In-Situ Alcohol Flushing for Enhanced Remediation of

PCE Source Zone: Sages Dry Cleaner Site

Sillan (1998) and Jawitz et al. (1998) reported on a pilot-scale fi eld test of in-situ alcohol fl ushing for enhanced 

remediation of a DNAPL source zone where isolation of the test zone was achieved entirely by hydraulic containment 

(i.e., no sheet–pile walls). This fi eld study was conducted at the site of a former dry cleaning operation in Jacksonville, 

FL, where the shallow, unconfi ned, sandy aquifer had become contaminated with tetrachloroethylene (PCE). The goals 

of the in-situ alcohol fl ushing strategy were to maximize the effi ciency of DNAPL extraction, minimize the potential for 

DNAPL mobilization or fugitive emissions, and minimize waste disposal costs within the given fi nancial and regulatory 

constraints.

The DNAPL source zone was delineated using soil cores, groundwater samples, partitioning tracer tests, and direct push 

cone penetrometer methods. Enhanced DNAPL solubilization was achieved by in-situ fl ushing with two pore volumes (PV) 

of a 95% ethanol/5% water mixture. The pilot test described here is the fi rst fi eld-scale demonstration of in-situ alcohol 

fl ushing for enhanced remediation of a DNAPL source zone. This pilot study was conducted and funded jointly by LFR 

Levine Fricke (Tallahassee, FL), the University of Florida, Florida Center for Solid and Hazardous Waste Management, 

Florida Department of Environmental Protection, and U.S. EPA (NRMRL, Ada, OK; TIO, Washington, DC).

Field Site 

Fine to very fi ne sand occurred at the site to a depth of approximately 9 m below ground surface (bgs), below which a 

1.7 m layer of very fi ne to silty sand was encountered. A thin discontinuous clay layer (0.15 to 0.3 m thick) was detected 

at approximately 10.7 m bgs in most soil borings. Very fi ne sand to silty fi ne sand was observed beneath the clay layer. 

The water table was approximately 3 m bgs, and the natural hydraulic gradient was measured to be approximately 

0.0025. The average saturated hydraulic conductivity, estimated from slug test data, was about 6 m/day in the upper 

sand unit (0-9 m bgs) and about 3 m/day in the lower sand to silty sand zone (9-10.7 m bgs). The PCE release history 

at this site was unknown. Concentrations of PCE in groundwater samples collected from existing monitoring wells 

during the initial site assessment ranged from 70 to 150 mg/L. About 15 cm of free-phase PCE were detected in the 

former supply well.

Source-Zone Characterization

Preliminary CPT coring identifi ed an oblong PCE source area of approximately 7.3 m × 2.7 m in the depth range of 7.9 

m to 9.4 m bgs. The target DNAPL source zone was further characterized both before and after alcohol fl ushing using 

soil cores and inter-well partitioning tracer tests. Soil cores were collected using hollow-stem auger and split-spoon 

barrel methods during installation of the wells, and using CPT methods during installation of the multilevel samplers 

(MLSs). Soil cores were collected every 60 cm and sub-sampled at 3 cm intervals for methylene chloride extraction. 

A total of 196 sub-samples were collected from 16 borings (three injection wells; six recovery wells; and seven MLSs) 

prior to alcohol fl ooding while 61 sub-samples were collected from six CPT borings following alcohol fl ushing.

Partitioning tracer tests were conducted before and after alcohol fl ushing. In the pre-fl ushing tracer test, methanol 

was used as a non-partitioning tracer, and n-hexanol; 2,4-dimethyl-3-pentanol; and 2-ethyl-1-hexanol were used as 

partitioning tracers. For both the pre- and post-fl ushing tracer tests, a tracer pulse of approximately 0.20 pore volumes 

(3.8 hrs) was delivered to the IWs during steady water fl ow using the fl ow distribution described above. Throughout the 

tracer injection and displacement periods, samples were collected from the recovery wells (RWs), injection wells (IWs), 

and MLSs at frequent intervals (ranging from one to eight hrs). Data from analyses of these samples yielded tracer 

breakthrough curves (BTCs). Temporal moment analysis was applied, and the average PCE saturation, SN, within the 

swept volume of each recovery well was determined. 

Numerical simulations indicated that a well confi guration of three IWs and six RWs would provide effective hydraulic 

containment and achieve adequate coverage of the NAPL source zone (Figure A.5). A total fl ow of 15.1 L/min was 

distributed equally to the three IWs. The interior wells (RWs 3, 4, 6, and 7) had extraction rates of 5.9 L/min, and the 

outer two wells (RWs 2 and 5) were assigned extraction rates of 3.4 L/min, resulting in a 2:1 extraction to injection ratio. 

The three IWs were screened from 7.6 to 9.9 m bgs, while the six RWs were screened from 7.9 to 9.6 m bgs. This 

design was selected to promote upward fl ow of the injected fl uids. Seven MLSs were installed within the NAPL source 

zone, with fi ve sampling depths at each MLS.
70

In-situ Flushing Protocols

A total of 34 kL (2 PV) of 95% ethanol was delivered to the three IWs during a period of about three days. A neoprenerubber well packer was placed in each injection well in order to focus delivery of the alcohol to zones of high SN. Alcohol 

was injected below the packer while potable water was injected above the packer to limit migration of the alcohol into 

the aquifer above the packer. The combined fl ow rate of water and alcohol was held constant at 4.2 L/min for IW-1 and 

IW-3 and at 6.8 L/min for IW-2. Initially, the packer height was set at 0.3 m in order to fl ush alcohol immediately below 

the deepest detected free-phase PCE. By fl ooding this region with alcohol before fl ushing the PCE-contaminated zone, 

a barrier to downward mobilization of free-phase PCE was established. Thus, if free-phase mobilization of PCE from 

the contaminated region above occurred at the alcohol injection front, a layer of alcohol solution was available below 

to solubilize the PCE that may have migrated from the contaminated region.

The ethanol concentration in the injection fl uid was ramped from 0 to 95% over 10 hrs (0.5 PV) using a continuously 

stirred tank reactor (CSTR) that had a tank volume of 340 L. The gradient injection of alcohol was implemented to 

minimize fl uid density differences between the resident groundwater and the injected fl uids as a means of reducing fl ow 

instability effects. The 95% ethanol/5% water mixture was injected below the initial packer height for six hrs (0.3 PV), 

and the packers were then raised at a rate of approximately 15 cm/hr to a maximum height of 1.7 m at IW-1 and IW-2 

and 0.9 m at IW-3. The maximum packer heights were chosen based on the locations of PCE detected in soil cores. 

After 70 hrs of fl ushing (3.73 PV), the packers were lowered at the same rate to a fi nal height of 30 cm. This scheme 

was employed at the latter stages of the ethanol fl ood to facilitate the subsequent removal of the ethanol mixture from 

the swept zone by minimizing the potential for gravitational segregation of the ethanol mixture and the displacing 

water. Water fl ooding was initiated after 3.5 days (4.48 PV) to remove the remaining ethanol and was continued for 4.5 

days (5.75 PV). Note that because of the efforts to minimize the potential for fl ow instabilities and uncontrolled NAPL 

migration, approximately 76 kL of water and ethanol were fl ushed through the NAPL source zone in order to deliver 

34 kL of ethanol.

In order to minimize costs associated with the disposal of waste containing high levels of PCE, a macro-porous polymer 

extraction (MPPE) system, developed by Akzo Nobel, was used to separate PCE from the effl uent solution that contained 

ethanol, water, and dissolved PCE. This technology uses a porous polyolefi n material with a proprietary extraction fl uid 

Figure A.5 PCE source zone with the well and sampling design used for in-situ alcohol fl ushing pilot Test at the 

Sages dry cleaner site, Jacksonville, Florida.
71

immobilized within its structure. During treatment, the waste stream was passed through a column containing MPPE 

material into which the PCE preferentially partitioned. After loading with PCE, the columns were regenerated with lowpressure steam stripping. The steam extracted the PCE from the MPPE material and was then condensed and separated 

into free-phase PCE for disposal. Waste fl uids containing greater than 1% ethanol were transported for off-site disposal, 

while those containing less than 1% ethanol were processed through an air stripper and discharged on site.

Results

The high-frequency sub-sampling technique delineated thin (5 to 8 cm thick) layers of PCE that did not appear to 

be horizontally continuous over the extent of the target zone. The average concentration of PCE in the soil samples 

collected was 2,809 mg PCE/g soil with a standard deviation of 11,050 mg PCE/g soil (n = 147 samples). These data 

suggest a high degree of variability in the areal and vertical extent of the discontinuous NAPL source zone. Such source 

architecture—with a limited volume fraction with DNAPL— is fairly typical of DNAPL source zones. Thus, detection of 

source zones is diffi cult, and in-situ fl ushing remediation is likely to be an ineffi cient process. The tracer data suggest 

that the total estimated volume of PCE within the swept zone of the wells was approximately 69 L, equivalent to an 

overall average SN of 0.004. The largest quantities of PCE (>50% of the total) were found in the swept volumes of two 

wells (RWs 3 and 7); these two wells were on opposite sides of a sump that was the suspected point of PCE entry 

into the subsurface. The total amount of PCE extracted was approximately 42 L (67 kg), determined from numerical 

integration of the PCE breakthrough curves at all extraction wells. Substantially more PCE was extracted from RWs 3, 6, 

and 7 than from RWs 2, 4, and 5, in general agreement with the pre-fl ushing partitioning tracer estimates of the amount 

of PCE within the swept volume of each well. Numerical integration of the ethanol BTCs indicated that approximately 

92% of the injected alcohol had been recovered by the end of the 5.75 PV water fl ood. The 2:1 extraction ratio resulted 

in considerable dilution at the RWs and, consequently, produced a large volume of extracted groundwater containing 

ethanol, PCE, and tracers requiring considerable costs and management for treatment and disposal. Approximately 35 

L of PCE were separated from the waste stream by the MPPE system, representing a recovery of 83% (the effl uent 

contained approximately 42 L of PCE). The treated fl uids had high ethanol contents but could not be re-injected 

because of state regulatory constraints. About 640 kL of waste liquid were transported off-site to an industrial wastewater 

treatment facility.

Performance Assessment

The average concentration of PCE in the 61 soil samples collected from six post-fl ushing borings was 936 mg PCE/g 

soil, with a standard deviation of 3200 mg PCE/g soil. Based on soil core data, the PCE removal effectiveness, defi ned 

as the fraction reduction in the amount of PCE initially present, was calculated to be 0.67. The post-fl ushing tracer 

tests indicated the total volume of PCE remaining in the swept volume was about 26 L, equivalent to an average SN

of 0.0014. Both the soil core and partitioning tracer data indicated that approximately 60% of the PCE was removed 

through two PV of in-situ alcohol fl ushing. However, a comparison between the concentrations of PCE in groundwater 

samples collected from the MLSs before and after the alcohol fl ood showed that the aqueous PCE concentrations were 

similar before and after alcohol fl ushing. This is the result of the presence of enough DNAPL to maintain elevated PCE 

concentrations. More recent monitoring data indicate that the average PCE concentration in multilevel source-zone 

sampler was about 49 mg/L, and after one year, the average concentration for PCE was reduced to about 26 mg/L. 

The estimated mass reduction was 62%, compared to an estimated reduction in mass discharge from the source zone 

of 47%, based on calculations completed by the University of Florida. 

The goal of this study was the removal of a signifi cant amount of PCE from the DNAPL source zone, and not necessarily 

the reduction of aqueous PCE concentrations in the NAPL source zone to below regulatory limits. A related objective 

was to monitor the source zone and the dissolved plume for an extended period (approximately two years) following 

in-situ fl ushing to examine changes in the geochemical processes and microbial dechlorination of PCE. Mravik et al. 

(2000) report the results of long-term monitoring to assess the decreases in PCE concentrations resulting from enhanced 

reductive dechlorination, possibly enhanced by the presence of ethanol serving as an electron donor. Such secondary 

benefi ts of source removal merit further careful evaluation.
72

CASE STUDY

In-situ Treatment of a TCE Source Area 

Using a Jetted Slurry of ZVI and Clay
73

In-situ Treatment of a TCE Source Area

Using a Jetted Slurry of ZVI and Clay

Introduction

In September 1999, a project was completed at DuPont’s Kinston, NC, plant involving use of high-pressure jetting to 

emplace a slurry of zero-valent iron (ZVI) and kaolinite into a small, well-defi ned trichloroethene (TCE) source area. This 

pilot scale project was completed in conjunction with emplacement of a thin ZVI permeable reactive barrier (PRB) across 

the plume downgradient of the source, also using high pressure jetting. Groundwater has been monitored periodically 

to track performance of the source treatment and PRB. In addition, source area soils were re-sampled approximately 

one year after emplacement to measure treatment effectiveness.

Site Description

The project site is a TCE plume in the Central Manufacturing Area at DuPont’s Kinston facility. Figure A.6 shows a 

plume map from May 1998 as well as location of an existing groundwater extraction system that was put in operation in 

1993. The plume originated in a relatively small source area near monitoring well MW-30A, apparently resulting from 

undocumented waste handling activity prior to 1980. Figure A.7 provides a geologic cross section through the source 

area. The water table lies at a depth of about four to fi ve feet below ground surface. Based on average gradients and 

hydraulic conductivities from slug tests in the area, the average linear groundwater velocity is estimated to be 0.05 to 

0.1 feet/day. The TCE plume is roughly 500 feet long and is 250 to 300 feet wide at a downgradient distance of 300 feet. 

Peak groundwater concentration in the source region prior to treatment was in the range of 50 to 60 mg/L (at BW-1), 

while peak concentration in the distal reach of the plume was roughly 100 to 150 mg/L (at MW-29).

The impacted zone is limited to a surfi cial sand unit roughly 15 feet deep overlying a thick mudstone confi ning layer. In 

May 1998, Geoprobe sampling was performed to better defi ne soil TCE concentrations in the source area. Soil cores 

were collected from two soil depth intervals (near base of light grey sand horizon and near base of black silty sand 

horizon, respectively – refer to cross section) at 16 locations in the vicinity of the suspected source. Core samples were 

placed on ice and analyzed by GC/MS (EPA Method 8260) within an hour of collection in a mobile on-site lab. Results 

are shown in Figure A.8. TCE concentrations in the source ranged from roughly 10 mg/kg to 100 mg/kg (on a wet 

weight basis) with higher concentrations generally observed at the light grey sand/silty black sand horizon about two to 

three feet above the mudstone interface. No free-phase or residual-phase DNAPL was observed. From the results of 

this work, it was concluded that the source area apparently was limited to a 25-foot diameter area.

Technology Description

The dechlorinating properties of zero-valent iron for in-situ groundwater treatment of chloroethenes and other 

chlorocarbons are well documented. The technology applied at Kinston by DuPont involved mixing a water-based 

slurry of ZVI and kaolinite clay into the TCE-impacted source area sands as a “reactive stabilization” measure. Figure 

A.9 illustrates this concept. Unlike the standard PRB application of ZVI, groundwater velocity and reaction rate are 

not the overriding design concern since the addition of clay provides a relatively low hydraulic conductivity diffusional 

environment in which the treatment can take place. Given adequate mixing and suffi cient ZVI relative to source mass, 

the treatment can proceed at any reasonable pace provided an acceptable treatment endpoint is reached consistent 

with site strategy and remedial objectives.

The slurry emplacement/mixing method chosen for Kinston was high-pressure jetting applied in an interlocking column 

confi guration. Jetting uses a high-pressure stream of fl uid to cut through soil and emplace slurry. The columnar jetting 

process is illustrated in Figure A.10. The process begins by drilling to the desired depth, in the Kinston case to the top 

of the mudstone horizon. Once at depth, the jetting process is activated. A small diameter, high-pressure jet of fl uid 

exits from jetting nozzles located just above the tip of the drill string. Upon starting this process, the drill string is slowly 

rotated and extracted leaving a column of soil and entrained slurry in place. Some portion of the jetted material and 

native soil will come to the surface as spoil. At Kinston, this excess spoil was containerized in roll-offs and held until 

treatment rendered TCE concentrations non-detect.
74

Figure A.6 Map of impacted area.

Figure A.7 Geologic cross section.
75

Figure A.8 Source-zone concentration map.

Figure A.9 Concept of treating DNAPL source area.
76

Design and Application

The slurry applied at Kinston consisted of 95% kaolinite and 5% Peerless ZVI (-50 mesh) on a dry weight basis. In 

September 1999, a total of 11 treatment columns were emplaced to depths ranging from 15 to 18 feet. The estimated 

treatment column diameters ranged from fi ve to six feet, and columns were placed at centerline distances of four to 

fi ve feet. In addition, a low hydraulic conductivity cofferdam of jetted clay/ZVI slurry was placed completely around the 

source area perimeter. This was accomplished using the thin diaphragm wall emplacement technique in which the 

drill string is held stationary during extraction to emplace panels instead of columns. The cofferdam jetting centers 

were placed nine feet apart to create interlocking panels. Figure A.11 shows the layout of the treatment columns and 

cofferdam. Hayward-Baker of Baltimore, MD, was the jetting contractor.

As part of the same project, jetting was used to emplace a 400-foot long thin wall of ZVI across the distal portion of the 

plume about 300 feet downgradient of the source area. The PRB was accomplished using the thin wall emplacement 

technique similar to the cofferdam. However, the slurry design was changed to consist of –50 mesh Peerless ZVI in a 

guar gum slurry. The resulting PRB consisted of an effective thickness of two to three inches of ZVI. 

Results

The source area was resampled by Geoprobe coring about 11 months after treatment. The resampling effort consisted 

of taking post-treatment cores at the same source area locations sampled in 1998 prior to treatment. Soil cores were 

screened immediately in the fi eld by OVA followed by Encore sample collection and placement on ice. Lab analysis 

was conducted for TCE and daughter products by GC/MS EPA Method 8260. Figure A.12 shows results of the posttreatment samples side-by-side with the pre-treatment results. Only two out of 16 contained signifi cant TCE and/or 

breakdown products in the post-treatment cores. Direct observation of cores indicates that intimate mixing on a particle 

scale was not achieved, but rather the mixing of entrained slurry within host soils was on the scale of inches. However, 

jetting appears to have been effective overall in creating suffi cient mixing to achieve treatment through most of the 

source region. 

Figure A.10 Columnar jetting process.
77

Periodic sampling of monitoring wells downgradient of the source has been ongoing since 1999. While TCE concentrations 

have declined generally, concentrations remain elevated. This result to date is not surprising considering the slow 

groundwater velocity through the area and relatively short time since treatment. Monitoring will continue in order to 

evaluate the long-term effectiveness of treatment on improving groundwater quality.

Figure A.11 Source-Zone treatment layout.

Figure A.12 Post-treatment coring (one year).
78

CASE STUDY

In-situ Chemical Oxidation of TCE 

Using KMnO4 at the DOE Portsmouth X-701B Site
79

In-situ Chemical Oxidation of TCE using KMnO4 at the 

DOE Portsmouth X-701B Site

Introduction

A fi eld-scale test of in-situ chemical oxidation (ISCO) using KMnO4 was completed at the DOE Portsmouth Gaseous 

Diffusion Plant in Piketon, OH, as part of the environmental restoration program at that site (West et al., 1998a,b). Oak 

Ridge National Laboratory (ORNL) coordinated the demonstration in collaboration with the site operating contractor, 

Lockheed Martin Energy Systems (LMES). Assistance with facets of the demonstration was provided by Carus Chemical 

and Schumacher Filters America. The fi eld-scale ISCO test was implemented near the X-701B pond which was a source 

area for TCE DNAPLs and an associated 2000-ft long TCE plume with ground water concentrations of ~1000 mg/L 

near the source declining to 32 mg/L at the distal end of the plume (Figure A.13). The ISCO system utilized a pair of 

previously installed parallel horizontal wells that were 90 ft apart and had 200-ft screened sections consisting of 5-in. 

diameter, high-density porous polyethylene well screens (500 μm pore size). The horizontal wells were installed using 

directional drilling methods such that the screened sections were on top of the Sunbury shale and within the Gallia 

water-bearing unit. The goal of the fi eld test was to determine the effi cacy of fl ushing 2.5 to 4.0 wt.% KMnO4 through 

the groundwater in the Gallia to degrade TCE DNAPL contamination. The fi eld test was designed to use the existing 

wells and to occur over a duration of four weeks, and thus, cleanup of the entire zone between the horizontal wells 

was not a test objective. ISCO performance with respect to TCE degradation effi ciency was evaluated by comparing 

pre- and post-treatment soil and groundwater TCE concentrations within the region between and just downgradient of 

the horizontal wells.

Figure A.13 Plan view of the X-701B site and the 2000-ft long TCE ground water plume.
80

Site Description

The stratigraphy underlying the X-701B site consists of the following layers proceeding downward from the surface 

(1) Minford silt and clay with a thickness of 25 to 30 ft, (2) Gallia silty gravel with a thickness varying from 2 to 10 ft, 

(3) Sunbury shale which is the fi rst bedrock layer and consists of a 10 to 15-ft thick, moderately hard shale that often 

exhibits an upper weathered zone of gray, highly plastic clay, and (4) Berea sandstone which is present at an approximate 

depth of 47 ft in this area. The Minford silt and Sunbury shale layers have very low conductivities, while the Gallia and 

Berea layers are the main water-bearing units. Past characterization has shown TCE contamination to be present at 

high levels in the Minford, Gallia, and upper weathered region of the Sunbury shale, suggesting DNAPLs within the 

subsurface (Table A-1). The subsurface between the two horizontal wells encompassed an aquifer region where 1 pore 

volume was equal to ~ 1 million L.

Table A-1 TCE Concentrations in Pre-ISCO Samples from the X701B Site (West et al., 1998a,b)

Media and No. of Trichloroethylene concentration 

layer samples Average Std. Dev. Median Min. Max.

Soil: (μg/kg)** (μg/kg) (μg/kg) (μg/kg) (μg/kg)

Minford * 90 19,493 21,770 10,002 nondetect#

 80,471

Gallia 163 53,596 52,713 43,320 nondetect 302,237

Sunbury* 13 132,405 269,791 46,932 32 1,048,174

Groundwater (μg/L) (μg/L) (μg/L) (μg/L) (μg/L)

Gallia 26 wells 176,400 241,300 119,800 nondetect 820,600

* Minford based on samples at > 20 ft. bgs. Sunbury based on samples from the top weathered region. **Based on wet soil 

weight (avg. water content = 16%). #

 not detected at an approximate detection limit of 5 μg/kg or 5 μg/L. 

ISCO System Implementation

Prior to design and implementation of the fi eld application, a column-scale treatability test was completed at ORNL 

to test the fl ushing of KMnO4 solution through a sandy media contaminated with DNAPL TCE. Results indicated a 

TCE treatment effi ciency of nearly 99% with a KMnO4 natural oxidant demand of 3.6 g-KMnO4 per g-TCE. During the 

implementation of ISCO at the X-701B site, water extracted from the west (upgradient) horizontal well was sent through 

a nearby groundwater treatment facility before the addition of KMnO4 (this was done to ensure compliance with the 

regulatory requirement that TCE in the re-injected groundwater was <5 ppb). Water for the oxidant injection solution 

was taken from a portion of the groundwater treatment facility effl uent, and mixed with crystalline KMnO4 using a solids 

feeder. The oxidant-laden water (~2.5 wt.%) was then injected without pressurization into the east horizontal well. As 

such, fl ow between the horizontal wells was opposite the direction of ambient groundwater fl ow. Extraction from the 

west horizontal well was set to ~10 gpm by fl ow regulators. The target injection fl ow rate at the east horizontal well 

was 10 gpm. However, this well could only take a maximum of 6 gpm as water backed up to the ground surface when 

higher injection fl ow rates were attempted. ISCO between the horizontal wells began operation on July 26, 1997, and 

continued through August 21, 1997. Simultaneous injections in the east horizontal well and a nearby vertical well (74G) 

were initiated on August 20, 1997, to attempt greater coverage of permanganate injection. Well 74G was selected 

because it is centrally located within the treatment region and had high levels of TCE (734 mg/L in groundwater) prior 

to the beginning of the ISCO fi eld test. Injection and extraction from the horizontal wells were halted on August 21, 

1997, while oxidant injection into well 74G was continued through August 28, 1997, approximately four weeks after the 

ISCO fi eld test was initiated. As mentioned previously, the fi eld test duration was preset at four weeks. The oxidant fl ow 

rate into 74G was 2 gpm. Thus, injection into well 74G, which had a screened section of 5 ft, was signifi cantly more 

than injection into the 200-ft horizontal well that could only be sustained at a maximum of 6 gpm. A total of ~12,700 

kg of KMnO4

 was delivered to the treatment region, 1,960 kg of which were introduced through vertical well 74G. Of 

the 206,000 gallons of oxidant solution, 14,000 gallons were delivered through well 74G. In total, the oxidant delivery 

was equal to ~0.8 pore volumes of the aquifer between the horizontal wells. At the completion of the oxidant fl ushing 

operation, there were increasing levels of colloidal particles coming from the extraction well, which the groundwater 
81

Figure A.14 Distribution of KMnO4 in ground water at the ISCO fi eld test site 32 days after initiation of oxidant delivery (West et al. 1998a,b). (Note: Oxidant delivery was initially conducted using the eastern and western horizontal wells for injection and extraction, respectively. Oxidant was injected into vertical well 74G 

toward the latter part of the fi eld test).
82

treatment facility was not prepared to handle. These particles, on the order of 1 micron in size, were identifi ed using a 

scanning electron microscope and energy dispersive x-ray as amorphous manganese oxides. The total cost of the fi eld 

test was $562K (1997 dollars) divided among planning and management (~12%), pre-ISCO sampling and mobilization 

(~29%), ISCO operations (~29%), resistivity monitoring (~12%), and post-ISCO sampling and demobilization (~18%).

Operation and Performance Results

The process control and performance of the ISCO system were monitored through collection of water samples from 

the infl uent and effl uent streams (daily) and from monitoring wells (daily to every three days) in the vicinity of the 

treatment region. The delivery of oxidant solution through the east horizontal well was not uniform through the length 

of the treatment region. After 21 days, the oxidant had been detected in all the monitoring wells that were within ~15-

ft of the injection wells, except one well (Figure A.14). The oxidant was detected in the central area of the treatment 

zone after oxidant injection in vertical well 74G was initiated. The non-uniform distribution of MnO4

-

 was probably due 

to spatially variable hydraulic conductivities that ranged from 24 to 411 ft/day as measured in monitoring wells within 

the treatment zone. The highest conductivity of 411 ft/day corresponds with the rapid detection of KMnO4 in the wells 

in the southern portion of the treatment zone. 

Overall, whenever MnO4

-

 was detected in groundwater samples from the monitoring wells, TCE concentrations dropped 

to non-detectable (<5 μg/L) or low ppb levels (Table A-2). While this drop in groundwater TCE concentrations may be 

due to the degradation or removal of TCE, it could also be due in part to displacement of contaminated groundwater 

from the pore space and non-equilibrium between the pore water and residual TCE in the sediments at the time of 

sampling. Approximately two weeks after the ISCO fi eld test ended, boreholes were drilled in locations where MnO4

-

was detected during treatment operations. All post-treatment boreholes revealed that TCE soil concentrations were 

signifi cantly reduced in the Gallia layer wherever MnO4

-

 was able to permeate. In the Minford silt and Sunbury shale 

layers, TCE levels did not signifi cantly change with treatment because MnO4

-

 did not permeate into those areas during 

the ISCO fl ushing. However, MnO4

-

 was still detected at up to 93 mg/L in some of the monitoring wells more than three 

years after the ISCO fi eld test, and subsequent diffusion of the oxidant into the Minford and Sunbury layers could have 

occurred.

Table A-2 TCE Concentrations in Post-ISCO Samples from the X701B Site (after West et al., 1998a)

Operation No. of Trichloroethylene Concentration (μg/L) * 

Date Wells Average Std. Dev. C.V. Median Min. Max.

Pre-ISCO 25 183,400 243,600 1.33 129,400 5 820,600 

Post-ISCO: 

0 weeks 24 107,500 234,300 2.18 6 5 797,700 

2 weeks 19 41,000 90,900 2.22 230 32 339,500 

8 weeks 22 65,200 158,100 2.43 5 5 621,500 

12 weeks 23 98,500 238,200 2.42 5 5 923,300 

20 weeks 23 54,900 82,100 1.50 5 5 220,800 

* 5 indicates not detected at an approximate detection limit of 5 μg/L. 
83

CASE STUDY

Cape Canaveral Launch Complex 34
84

Cape Canaveral Launch Complex 34

Introduction

The Interagency DNAPL Consortium (IDC), a group consisting of the U.S. Department of Energy (DOE), U.S. 

Environmental Protection Agency (EPA), U.S. Department of Defense (DOD), U.S. Navy, and National Aeronautic and 

Space Administration (NASA), has completed two demonstrations and is currently conducting a third demonstration of 

innovative DNAPL remediation technologies at Launch Complex 34 (LC34), Cape Canaveral Air Station (CCAS), Florida. 

The demonstrations are carried out in adjacent 50 ft. by 75 ft. plots (<0.1 acre) and have taken place over a three-year 

period from 1998 to 2001. The technologies demonstrated at LC34 are potassium permanganate oxidation, Six-Phase 

HeatingTM (SPH), and steam/air co-injection (in progress). Information on the Cape Canaveral project is available at 

http://www.getf.org/ dnaplguest/, then click on <Library>.

Several trichloroethene (TCE) hot spots have been identifi ed at LC34. The one adjacent to the Engineering Support 

Bldg. (ESB) was selected for this technology demonstration. The subsurface at LC34 consists, in descending order, of 

(1) an upper sand unit, (2) a middle fi ne-grained unit, (3) a lower sand unit, (4) a lower clay unit, and (5) a lower confi ned 

aquifer. The targeted depth for the demonstration was above the lower clay unit, which consisted primarily of sandy 

material. Depth to groundwater is about six feet. The water table is fairly fl at with a slight southeasterly fl ow direction 

in the vicinity of the test plots. The TCE distribution within the treatment zone had been fairly well characterized prior 

to the demonstrations; DNAPL TCE presence was estimated to correspond to soil concentrations >300 mg/kg.

The following discussion focuses on chemical oxidation and SPH. It illustrates the diffi culties and uncertainties in 

performing technology demonstrations.

Chemical Oxidation

In the chemical oxidation plot, the initial DNAPL mass was estimated at 13,000 lbs (using soil boring data). Seventyfi ve tons (150,653 lbs) of potassium permanganate were injected into the plot using 841,650 gallons of solution, which 

is equivalent to 3.5 pore volumes. Such a large volume has the potential to cause displacement from the plot. The 

oxidation treatment generated 9,300 lbs of sludge (primarily insoluble permanganate reagent impurities). The total 

cost for the chemical oxidation demonstration (including preliminary design, fi eld analytical support, utilities, and waste 

disposal) was $1,128,312. 

Initially following treatment, there was signifi cant reduction of TCE soil concentrations with some rebound after nine 

months. This is partly explained by soil sample variability. There was much less signifi cant reduction of TCE groundwater 

concentrations, with TCE concentrations greater than 400,000 μg/L remaining. DNAPL TCE was still present in the plot. 

In addition, displacement occurred causing DNAPL migration outside the plot. This is based on (1) DNAPL detection 

in perimeter wells following treatment1

 and (2) signifi cant increases in dissolved TCE detected outside the plot, (e.g., 

at PA-8D, TCE increased 1,322 mg/L)2. Calculated mass reduction is provided in Table A-3. As noted, these mass 

reduction calculations do not include TCE mass displaced (but not destroyed) from the plot. In addition, the rebound 

after nine months may be due to a redistribution of mass in the plot, or it could represent a migration of mass into the 

plot from TCE that was outside the plot following treatment.

Positive results from the treatment include (1) some of the contaminant mass was destroyed (although the mass 

reduction is uncertain), (2) chloride concentrations in the groundwater increased, a possible result of TCE oxidation, 

and (3) the microbial evaluation indicated that although the application of a strong oxidant is detrimental to anaerobic 

microbial populations in the short term, in the longer term, some microbial populations are re-established. Unfavorable 

consequences of the chemical oxidation include (1) chromium levels increased from ND to more than 10 times MCL, (2) 

copper, zinc, nickel, and silver all increased above MCLs (Battelle, 2001b), (3) TCE concentrations increased in middle 

fi ne-grained unit leading to more diffi cult follow-up treatment, and (4) displacement of TCE outside the plot.

1

DNAPL was observed at PA-2I, PA-2D, and PA-11D; it is uncertain whether the DNAPL in these wells migrated from the SPH or oxidation plot, or 

both.

2

Thermal effects from the six-phase heating plot do not extend to PA-8D; the increase in TCE is due to the oxidation plot.
85

Table A-3 Oxidation (Permanganate) Plot Mass Reduction (Battelle, 2001b)

Computational Approach Mass Reduction1

Contouring (linear) TCE Total TCE DNAPL 

 Post demonstration 82% 84% 

 Extended (9 mo.) 77% 76% 

Statistical (kriging) 

 Post demonstration 62-84% NA 

 Extended (9 mo.) 49-68% NA 

1

Does not include TCE mass displaced from plot.

Six-Phase Heating 

In the SPH plot, the initial DNAPL mass was estimated to be 24,888 lbs. For the SPH demonstration, the total cost 

(including preliminary design, electricity, and waste disposal) was $647,719.

Following treatment, there was signifi cant reduction in soil TCE concentrations (soil sampling at one month after treatment 

is suspect due to elevated soil sample temperatures). There was insignifi cant reduction of TCE in groundwater. DNAPL 

migration outside the cell occurred or was suspected based on DNAPL (based on soil concentrations) detected in perimeter 

wells following treatment and DNAPL (based on soil concentrations) detected beneath the lower clay layer following 

treatment (not sampled prior to treatment). Estimated mass reduction in the SPH plot is provided in Table A-3.

As a result of the lateral and possible vertical TCE migration from the SPH plot, the amount of mass reduction is uncertain. 

Only 4,292 lbs of DNAPL were collected (19% of mass removal determined by contouring in Table A-4) by the extraction 

system. Some of the missing mass can be explained by surface vapor emissions (mass loss to the atmosphere), as 

verifi ed by fl ux chamber. Accounting for the disparity in the mass balance by in-situ destruction of TCE is uncertain 

for the following reasons: increases in cis-1,2 DCE/VC concentrations could be the result of redistribution; chloride 

concentration increases could be partly due to water evaporation. Adding to the uncertainty was a sudden rise in the 

water table following a hurricane, causing a surface release of TCE from the plot.

Table A-4 Six-phase Heating Plot Mass Reduction (Battelle, 2001b)

COMPUTATIONAL APPROACH Mass Reduction1,2

Contouring (linear) TCE Total TCE DNAPL 

 Post demonstration 90% 97% 

Statistical (kriging) 

 Post demonstration 80-93% NA 

1

Does not include TCE mass displaced from plot. 

2

Elevated temperature of soil cores, possible causing volatility loses causing mass reduction to be overestimated. 

Vertical DNAPL migration is even more uncertain. The lower confi ned aquifer was not characterized prior to the 

demonstration to avoid potential cross contamination. Therefore, it is uncertain if DNAPL penetrated the lower clay 

unit before or after the demonstration. Although heating and volatilization of TCE would cause upward migration in the 

plot, cooling and condensation at the fringes could cause downward migration. DNAPL was found only in the lower 

confi ned aquifer beneath the SPH plot, even though sand lens or lenses were observed in the confi ning layer under both 

the SPH and oxidation plots.3

 The post-demonstration boring on the SPH plot (SB-52/PA-22) is located in the northern 

quadrant of the plot near the pre-demonstration boring SB-11. Prior to the demonstration, SB-11 had a maximum TCE 

concentration of 167 mg/kg (26-28 ft); the maximum TCE concentration in SB-52 is 40,498 mg/kg (56-58 ft). Thus, if 

pre-demonstration vertical DNAPL migration occurred, there is no evidence of it. Therefore, vertical DNAPL migration 

uncertainty must be considered in any mass reduction calculation.

3

In addition, the aquitard is thinnest under the oxidation plot; however, no DNAPL was found under this plot.
86

Some uncertain quantity of contaminant mass was removed as a result of SPH. Unfavorable events/consequences of 

the SPH test include electrode and transformer failures, surface release of TCE following water table rise, surface vapor 

emissions requiring plenum installation, well fouling from mineral precipitation, potential vertical and horizontal DNAPL 

migration, and safety issues related to monitoring well over-pressurization.
87

CASE STUDY

Permanganate Oxidation in Fractured Media
88

Permanganate Oxidation in Fractured Media

Preamble 

The case study presented below, taken without modifi cation, from the Proceedings of the 3rd International Battelle 

Conference on Remediation of Chlorinated and Recalcitrant Compounds, May 2002, Monterey, CA, pertains to a small 

TCE-TCA DNAPL contamination site in Fort Lauderdale, FL, where a passive potassium permanganate method is being 

used for source mass depletion. This publication covers the fi rst phase of permanganate treatment that was conducted 

in 2000-2001. The purpose of this phase was to assess the performance of this technology applied at full scale during 

a time period specifi ed by the State of Florida. In this phase, which comprised three injection episodes spread several 

weeks apart, more than 90% of the volume of the DNAPL source zone was successfully treated. In this successfully 

treated portion of the DNAPL source zone, the maximum VOC concentrations were reduced from > 10,000 μg/L to less 

than 100 μg/L. In the remaining 10%, the maximum concentration was reduced from > 600,000 μg/L to < 40,000 μg/L. 

Based on these encouraging results, the Florida Department of Environmental Protection approved a plan for a second 

and fi nal phase of permanganate treatment. This fi nal phase comprises a single permanganate injection episode during 

a two-week period in late September/October 2002 followed by monitoring. This fi nal phase was in progress at the time 

of fi nalization of this Panel Report. The goal of this fi nal phase is complete treatment of the DNAPL source zone to VOC 

concentrations < 100 μg/L everywhere and less than the MCLs for TCE and TCA at nearly all locations. Preliminary 

results from this phase indicate that this goal will likely be achieved, and that no further injections will be required. 

The VOC distribution in groundwater prior to the initiation of fi nal permanganate injection episode was monitored in 

exceptional detail using a dense network of multilevel monitoring systems complemented with conventional monitoring 

wells. The TCE and TCA distributions following treatment, after a period allowing for rebound, will be determined in a 

manner that will enable the effects of the fi nal treatment to be established rigorously. 
89

Passive Permanganate Remediation of a Solvent DNAPL Source Zone

Beth L. Parker (blparker@uwaterloo.ca) and John A. Cherry

 (University of Waterloo, Waterloo, ON, Canada),

Tom A. Al (University of New Brunswick, Fredericton, NB, Canada)

Abstract

Permanganate remediation was conducted in southern Florida at a small industrial site with TCE and 1,1,1-TCA 

contamination down to 70 ft bgs in a sand aquifer. The permanganate solution was injected into the DNAPL source zone 

(30 ft diameter in plan view) where a small mass of residual TCE DNAPL caused this zone to have TCE concentrations 

exceeding 10,000 μg/L, with small zones approaching TCE saturation. This remediation project comprised three injection 

episodes, each occurring over several days during which small volumes of KMnO4 solution were injected at depths 

between 5 and 65 ft bgs in each of 6-8 direct push holes. During the 2-3 months allowed between injection episodes, 

the large initial density contrast caused the permanganate to spread out laterally and move downward while fi ngering 

and diffusion occurred. The combination of these migration and mixing processes caused complete KMnO4

 coverage 

of the source zone, even though the coverage immediately after each episode was only 1-8% of the total pore volume 

of this zone. By keeping the initial injection volumes small relative to the total aquifer pore space within the targeted 

treatment zone, displacement of TCE mass outward from the source zone was avoided. The post-treatment monitoring 

showed that the combined effect of the three permanganate injection episodes was a 90% reduction in the aquifer 

volume where TCE in groundwater was above 100 μg/L and an even larger reduction in volume above 10,000 μg/L. 

The injections caused the maximum TCE concentration in groundwater to drop from 635,000 μg/L to 56,000 μg/L, with 

this latter value occurring only in a very small zone. These results indicate that all, or nearly all, of the DNAPL has 

been destroyed. These encouraging results are based on groundwater sampling of an exceptionally detailed network 

of depth-discrete multilevel monitoring systems. Based on the results of this initial phase, we expect that complete 

remediation of the source zone will be achieved with one additional injection episode focused on the two small zones 

where moderate TCE concentrations exist.

Introduction 

Inadvertent releases of small volumes of free-product trichloroethene (TCE) and 1,1,1-trichloroethane (TCA) occurred 

between 1995-early 1997 in the vicinity of spigots on an outside wall of an industrial building used to manage waste 

solvents from a vapor degreaser that was housed in the building located in Broward County, Florida. The site is underlain 

by medium-grained sand with a shallow water table (< 3 feet bgs). TCE- and TCA-contaminated soil and groundwater 

were discovered in April 1997 at which time solvent use was discontinued and more extensive groundwater investigations 

were initiated. Initial direct-push (Geoprobe) sampling in 1997 was followed by installation and sampling of a network 

of conventional 2-inch diameter monitoring wells with 5 or 10-ft long screens to delineate the extent of contamination. 

This was followed by an attempt to remediate using in situ oxidation by injecting a Fenton’s-type reagent into 30-ft 

screened injection wells in 1998 and early 1999. The site owner discontinued this trial after detailed monitoring showed 

ineffectiveness of this method. 

This paper pertains to the next phase of remediation at this site in which the passive method of permanganate remediation 

was used for DNAPL source-zone remediation. This method was applied in combination with detailed depth-discrete 

monitoring to establish the pre-treatment conditions for design of the injections and for remediation progress tracking 

and post-treatment assessment. The permanganate injections accomplished near complete source-zone destruction 

of both TCE and TCA, and monitoring indicates that complete destruction can be expected with minimal addition of 

permanganate and effort.

Site Description and Background

The site is underlain by 85 ft of fi ne- and medium-grained sand resting on fossiliferous limestone. The sand has a nearshore marine origin and is nearly homogeneous, with hydraulic conductivity slightly greater than 10-2 cm/s. The upper 50 

ft are nearly devoid of carbonate minerals and at greater depth, gravel-size limestone fragments occur with increasing 

size and frequency down to the top of competent bedrock at 90 ft bgs. The carbonate mineral content ranges from 0.3 

to greater than 2% expressed as weight percent inorganic carbon.
90

Detailed site characterization was done in February 2000 to facilitate the design of the permanganate solution injections 

for remediation of the DNAPL source zone. Two continuous cores were collected from ground surface to direct-push 

refusal depth of 75 ft bgs. The cores were obtained using the piston coring technique described by Starr and Ingleton 

(1992) and Zapico et al. (1987). Detailed sampling of these cores for DNAPL detection using the Sudan IV dye method 

and quantitative VOC analyses by gas chromatography showed no DNAPL occurrences and highest TCE values at half 

TCE solubility. Also, detailed depth discrete groundwater sampling was done using multilevel monitoring systems (bundle 

wells) similar to those described by Cherry et al. (1983). The highest TCE value measured in the bundle wells prior to 

permanganate treatment was 625,500 μg/L, and the highest TCE value found previously by Geoprobe sampling was 

940,000 μg/L. These values are only slightly below the aqueous solubility for pure-phase TCE (1,100,000 to 1,400,000 

μg/L). Concentrations of TCA were an order of magnitude below TCE.

The persistence of high TCE concentrations beneath the TCE release area and the occurrence of highest TCE values 

deep in the sand aquifer (55-65 ft bgs) indicate that the TCE contamination is caused by DNAPL; however, the DNAPL is 

probably distributed sparsely as small globules that constitute extremely low residual saturations. Figure A.15 illustrates 

our conceptual model for the TCE contamination and also shows typical pre-treatment TCE results obtained from two 

bundle wells. DNAPL occurs in the source zone as dispersed globules representing the vertical trail of downward 

DNAPL migration. The DNAPL descended vertically until it entered a thin (8 in) coarse sand layer at 57 ft bgs. The 

larger permeability of the coarse sands likely caused the DNAPL to spread laterally with minimal DNAPL penetrating 

below this zone. All of the highest TCE and TCA concentrations found prior to permanganate treatment occurred within 

a near circular area with a radius of 10-15 ft. We refer to this area as the DNAPL source zone (Figure A.16). A zone of 

much lower TCE and TCA concentrations occurring beyond the source zone is the plume (Figure A.16). The horizontal 

gradient is slight, mainly stabilized by a locally controlled canal network and, therefore, the plume is small. The goal of 

the permanganate remediation is to oxidize the TCE mass in the DNAPL source zone so that the source for the plume 

no longer exists, allowing the plume to attenuate by natural processes. 

Figure A.15 Nature of the DNAPL source zone: a) geology and conceptualization of DNAPL occurrence, and b) TCE 

concentrations in two multilevel systems in the source zone prior to KMnO4

 treatment.
91

Passive Approach for KMnO4 Treatment

Our remediation approach used at the Broward County site is aimed at effective destruction of the TCE mass in the 

DNAPL source zone by KMnO4 injections while minimizing the displacement of groundwater with high TCE concentrations 

away from the source zone into the surrounding plume. These dual objectives were pursued through injection episodes 

in which many discrete zones of near-saturation KMnO4 solution were created at multiple depths in direct-push holes 

in the targeted zone (i.e., in the DNAPL source zone). At each injection point, a small volume of KMnO4 solution is 

injected laterally to form an initial local zone (i.e., disc or ellipsoid). Stacked discs with vertical gaps in between are 

created in each hole using a short-screen well-point (7.6 cm length and 3.8 cm diameter) driven with a direct push rig. 

The time taken to create several discs per hole in several locations is referred to as an injection episode. At the end of 

an injection episode, the pressure pulses in the aquifer quickly dissipate. However, density-driven advection combined 

with fi ngering and diffusion causes the KMnO4 solution to spread, which achieves the coverage in the targeted volume. 

In essence the dense permanganate solution sweeps through the source zone following each injection episode to cause 

destruction of TCE mass. A period of time is allowed after each injection episode for the redistribution and concurrent 

KMnO4 consumption as TCE is oxidized.

Figure A.16 Plan view of maximum TCE concentrations found at each monitoring location: a) prior to KMnO4 injections and b) three months after.
92

In the DNAPL source zone at the site, the injection point, attached to drill rods, was driven to 60 ft bgs using the model 

SD-2 direct push rig manufactured by Precision Sampling Inc. The injection tool and system used at the site were 

developed previously by Nelson et al. (2000, 2001) and used at the Borden, Ontario, research site. The remediation of the 

Broward County site was done using the inject-and-leave approach in three episodes, all in 2000. In the three episodes, 

a total of 2,791 pounds (1,266 Kg) of KMnO4 dissolved in 9,166 gallons of water (34,703 liters) at a concentration of 

40 g/L was injected into a total of 21 holes. The fi rst episode took place during March 31 to April 10 at 6 locations, the 

second during June 1 to 7 at 8 locations and the third during September 29 to October 4 at 7 locations. Each episode 

was followed by two sampling events of the detailed network of multilevel systems for measurement of KMnO4

, VOCs, 

and chloride concentrations for tracking remediation progress.

Results

The effectiveness of the KMnO4 treatment was demonstrated based on a before-and-after comparison of TCE and TCA 

concentrations in the detailed network of multilevel systems and conventional wells. Figure A.15 shows that, before 

KMnO4 treatment, all seven of the monitoring locations situated inside the 10,000 μg/L contour had TCE values above 

16,000 μg/L and as high as 625,500 μg/L. When the comprehensive post-treatment monitoring occurred three months 

after the last injection episode, only two of these seven locations showed high values, but at concentrations less than 

35,000 μg/L. Figure A.15 also shows two locations just outside of the 10,000 μg/L contour that had moderately high 

TCE values (3,560 and 7,650 μg/L) before treatment. After KMnO4 treatment, TCE values at these two locations were 

below 50 μg/L. Of the fi ve inside the initial 10,000 μg/L contour area that declined below 10,000 μg/L after treatment, 

three dropped below 150 μg/L, and the other two dropped to 1,300 and 670 μg/L. Therefore, this plan view comparison 

of the maximum before-and-after TCE values at monitoring locations shows clearly that the volume of aquifer with high 

TCE values diminished greatly after KMnO4 treatment.

Figure A.17 shows the large decline in TCE contamination in cross sectional view through the middle of the KMnO4

treatment zone three months after the last injection. Refer to Figure A.16 for the cross section location. The cross 

sectional area above 100 μg/L declined markedly to 10% of the before treatment area, and the area above 10,000 

μg/L declined to 3% of the before treatment area. Evidence for the TCE destruction is also established by the number 

of sampling points above specifi ed concentrations shown on the cross section. Figure A.17 shows that 20 sampling 

points had TCE in the 100 to 1,000 μg/L range before treatment; only four had such values after. Before treatment, 10 

sampling points had TCE values above 10,000 μg/L but after, only two were above 10,000 μg/L. Other vertical sections 

positioned across the former source area displayed similar large decreases in areas and number of sampling points 

above specifi ed values. Measurements of the carbon isotope (13/12C) ratio of TCE in groundwater before and after KMnO4

treatment provided confi rmation of TCE mass destruction. Large increases in 13C relative to 12C attributable only to 

oxidation were observed in the treatment zone (Hunkeler et al., 2002).

An issue that must be resolved when assessing treatment effectiveness is the role of displacement of contaminated 

water away from the injection points. Depending on sampling locations observed, post-injection declines might refl ect 

the displacement of contaminated water rather than actual TCE mass destruction. The before-and-after monitoring 

results at the site are not attributable to displacement because monitoring at all locations in the plume declined after the 

injections. If contaminated water had been displaced from the source zone into the plume, increases in TCE at one or 

more plume locations would be expected. Negligible displacement was ensured given the design of the injections. Another 

concern inherent in remediation performance assessment is the potential for rebound of contaminant concentrations 

in the treated zone as a result of persistent residual DNAPL dissolution. The comprehensive post-injection sampling 

described above was done three months after the last injection. Additional sampling of selected multilevel points was 

done three months later. These sampling events comprised several points in each of eight bundle wells within the former 

source area. Three of the bundle wells showed no increase, and in the fourth, one point at 60 feet bgs increased from 

34,500 to 50,400 μg/L. This small increase is consistent with the temporal variability expected from slight groundwater 

gradient changes causing shifts of the position of the highest concentration zone. The expected rebound would be much 

larger if appreciable DNAPL mass remained in this zone.

Discussion 

Success of the passive method involving episodic injections of small volumes of dense KMnO4 solution at multiple 

discrete depths depends on post-injection spreading and sinking of the solution. Density-driven advection combined with 

fi ngering and diffusion must cause invasion of the KMnO4 between injection points. Evidence of this invasion derives 

from the large decrease in volume of the TCE contaminated zone, described above, and from comprehensive sampling 

of the bundle wells for KMnO4 at various times following each injection episode. As expected, immediately after each 

injection episode, KMnO4 appeared in only a few sampling points because the volume input at each injection point was 

small. At later sampling times, nearly all sampling points in the target zone (i.e., inside the initial 10,000 μg/L contour) 

showed KMnO4 on one or more occasions. These occurrences were only temporary because the KMnO4 is continually 

moving, mixing, and being consumed by oxidation of TCE and reaction with natural aquifer components.
93

The distribution of monitoring points (wells and multilevels) that existed prior to the KMnO4 injection and during the 

comprehensive post-treatment sampling left uncertainty about the maximum depth of initial TCE occurrence and deep 

TCE treatment. Therefore, near the end of this study, a deep monitoring well was installed using rotosonic core drilling. 

This hole was drilled at the location where deepest TCE would most likely be found if present. Figure A.17 shows this 

well situated in the depth range of 81.3 to 86.3 ft bgs, which is directly below the zone of highest TCE in the 55-65 ft 

depth zone. This well showed no signifi cant TCE (12 μg/L). Resampling in February 2002 confi rmed the absence of 

TCE in this well (< 1 μg/L). These results indicate that the TCE source zone did not extend to this depth or that the 

sinking of KMnO4 below the deepest injection depth (60 ft bgs) destroyed any deep TCE.

The oxidation of TCE results in release of chloride ions (Cl-) from the TCE to the groundwater. The stoichiometry for 

this oxidation reaction specifi es that for each mole of TCE oxidized, three moles of Cl- are produced. The pre-injection 

Cl- values in the source zone ranged from 20 to 60 mg/L. The maximum post-treatment Cl- values were in the range of 

150-260 mg/L in the zone where the pre-treatment TCE values were generally between 100–300 mg/L. The stoichiometric 

view for Cl- production presented above considered only the dissolved-phase TCE in the source zone. We believe that 

Figure A.17 Comparison of TCE concentrations one month before and three months after KMnO4

 treatment observed along cross section through DNAPL source zone.
94

DNAPL residual also existed prior to treatment in the source zone, as dispersed globules spaced suffi ciently far apart 

to prevent TCE concentrations from approaching TCE solubility even at the small spatial scale used for groundwater 

monitoring. KMnO4 treatment oxidized dissolved phase TCE and as the dissolved phase TCE was destroyed, it was 

replenished by DNAPL dissolution. Therefore, one should expect that Cl-

 would accumulate in the treatment zone to cause 

a concentration rise above the concentrations expected when only the initial aqueous TCE distribution is considered. 

No such Cl- accumulation is indicated by the post-treatment Cl- distribution. However, the KMnO4 treatment system at 

the Broward site is an open system, with an outlet at the bottom. Density-driven sinking of the KMnO4 solution after 

each injection episode must cause downward transport of Cl- by the sinking KMnO4 solution. Therefore, some of the 

Cl- was probably transported below the maximum depth of Cl- monitoring (i.e., below 70 ft bgs).

The three episodes of KMnO4 injection caused a large reduction in the volume of groundwater with TCE concentrations 

above 100 μg/L and above 10,000 μg/L. These results indicate that it is reasonable to expect that an additional injection 

episode will bring the destruction of the DNAPL source zone to completion. The selection of three injection episodes 

for the initial phase of this project was arbitrary. The total initial TCE mass in the source was unknown, and therefore, 

there was no basis for specifying the number of injections and total mass needed to achieve complete remediation. It 

was intended that three injection episodes would be suffi cient to establish a trend that would serve as a basis for judging 

prospects for complete remediation. The trend from the three injections indicates that very little DNAPL remains in the 

source zone and that it exists in a very small volume, exemplifi ed by the small areas within the >10,000 μg/L contour 

Figures A.16 and A.17. Although not expected, the KMnO4 treatments reduced the concentrations and volume of TCA 

contaminated aquifer similar to the TCE reductions.

Conclusions

Signifi cant progress towards complete remediation was achieved by injecting small volumes of near-saturation KMnO4

solution at several depths in each of six to eight holes during each of three episodes. These injections created an initial 

condition of many small, stacked KMnO4 zones with large vertical gaps in between. Only 8% of the total pore volume 

in the lower half of the aquifer (high TCE concentration zone) was invaded by KMnO4 solution immediately after each 

injection episode. However, during the few weeks following each injection episode, these many small KMnO4 zones spread 

out and descended under the infl uence of density combined with fi ngering and diffusion to achieve complete coverage 

within the source zone. Use of this episodic, stacked-injection approach resulted in no observable displacement of 

high-concentration TCE water outward from the source zone into the surrounding plume. The post-treatment monitoring 

using an exceptionally detailed three-dimensional network of depth-discrete samplers showed the combined effect of 

the three permanganate injection episodes caused a 90% reduction in the aquifer volume where TCE in groundwater 

is above 100 μg/L, and an even greater reduction of the volume above 10,000 μg/L. Therefore, the passive approach 

achieved high-percentage remediation with minimal engineering effort that also minimized displacement.

Acknowledgments

The main crew from the University of Waterloo that conducted the fi eld work included Matthew Nelson and Colin 

Meldrum, who also performed most of the data compilation and display; and Robert Ingleton and Paul Johnson. The 

VOC analyses were done by Maria Gorecka. The project benefi ted from the planning advice of William Pence and Robert 

Osar. Joseph Ghiold coordinated on-site activities and provided logistical support and Sun Belt Precision Products, Inc. 

supplied project funding.
95

List of References 

References Cited in Appendix A

Battelle. 2001a. Seventh Interim Report on the IDC Demonstration at Launch Complex 34. Cape Canaveral Air Station, 

August. 

Battelle. 2001b. Sixth Interim Report, IDC’s Demonstration of Three Remediation Technologies at LC34. Cape Canaveral 

Air Station, February. 

Cherry, J.A., R.W. Gillham, E.G. Anderson, and P.E. Johnson. 1983. Hydrogeological studies of a sand aquifer at an 

abandoned landfi ll, 2: Groundwater monitoring devices. J. Hydrol., 63:31-49.

Hunkeler, D., R. Aravena, B.L. Parker and J.A. Cherry. 2002. Monitoring in situ oxidation of TCE by permanganate using 

carbon isotopes. In Remediation of Recalcitrant Compounds, Monterey, CA, May 20-23.

Jawitz, J.W., D.P. Dai, P.S.C. Rao, et al. 2003. Rate-limited solubilization of multicomponent nonaqueous-phase liquids 

by fl ushing with cosolvents and surfactants: modeling data from laboratory and fi eld experiments. Environ. Sci. 

Technol., (9):1983-1991. 

Jawitz, J.W., M.D. Annable, P.S.C. Rao, and R.D. Rhue. 1998. Field implementation of a Winsor type I surfactant/alcohol 

mixture for in-situ solubilization of a complex LNAPL as a single-phase microemulsion. Environ. Sci. Technol.,

32(4):523-530. 

Mravik, S.C., R.K. Sillan, A.L. Wood, and G.W. Sewell. 2003. Field evaluation of the solvent extraction residual biotreatment

technology. Environ. Sci. Technol. 37(21):5040-5049.

Nelson, M.D., B.L. Parker, T.A. Al, J.A. Cherry and D. Loomer. 2001. Geochemical reactions resulting from in situ oxidation 

of PCE DNAPL by KMnO4 in a sandy aquifer. Environ. Sci. Technol., 35(6):1266-1275.

Nelson, M.D., B.L. Parker, J.A. Cherry and T.A. Al. 2000. Passive destruction of PCE DNAPL by potassium permanganate 

in a sandy aquifer. In Remediation of Recalcitrant Compounds, Monterey, CA, May 22-25. pp.135-143.

Sillan, R.K., M.D. Annable, P.S.C. Rao, et al. 1998. Evaluation of in situ cosolvent fl ushing dynamics using a network of 

spatially distributed multilevel samplers. Water Resour. Res. 34(9):2191-2202. 

Starr, R.C., and R.A. Ingleton. 1992. A new method for collecting core samples without a drilling rig. Ground Water 

Monitoring Review, 12(1):91-95.

West, O.R., S.R. Cline, W.L. Holden, F.G. Gardner, B.M. Schlosser, J.E. Thate, D.A. Pickering, and T.C. Houk. 1998a. A 

Full-Scale Field Demonstration of In-Situ Chemical Oxidation through Recirculation at the X-701B Site. Oak Ridge 

National Laboratory Report, ORNL/TM-13556.

West, O.R., S.R. Cline, R.L. Siegrist, T.C. Houk, W.L. Holden, F.G. Gardner, and R.M. Schlosser. 1998b. A fi eld-scale 

test of in-situ chemical oxidation through recirculation. Proc. Spectrum ’98 International Conference on Nuclear 

and Hazardous Waste Management. Denver, CO, Sept. 13-18, pp. 1051-1057.

Zapico, M.M., S. Vales, and J.A. Cherry. 1987. A wireline piston core barrel for sampling cohesionless sand and gravel 

below the water table. Ground Water Monitoring Review, 7:74-84.
96
97

APPENDIX B - Biosketches of Panel Members
98

Linda M. Abriola

Horace Williams King Collegiate Professor of Civil and Environmental Engineering

Environmental and Water Resources Engineering

The University of Michigan

1351 Beal Ave., 116 EWRE Bldg.

Ann Arbor, MI 48109-2125

Phone: (734) 764-9406

Fax: (734) 763-2275

abriola@engin.umich.edu

Dr. Abriola is the Horace Williams King Collegiate Professor of Civil and Environmental Engineering at the University of 

Michigan. She received both Masters and Ph.D. degrees in Civil Engineering from Princeton University and a Bachelors 

degree in Civil Engineering from Drexel University. An author of more than 90 refereed publications, Dr. Abriola is an 

expert on the transport, fate, and recovery of dense nonaqueous phase contaminants in the subsurface. Her current 

and recent service activities include membership on the National Research Council Committee on Source Removal of 

Contaminants in the Subsurface and the DOE Natural and Accelerated Bioremediation Research Advisory Committee. 

Dr. Abriola has been the recipient of numerous awards, including the National Ground Water Association Distinguished 

Darcy Lecturer and the Association for Women Geoscientists’ Outstanding Educator Award. She is an ISI Highly Cited 

Author in Ecology/Environment, a Fellow of the American Geophysical Union, and a member of the National Academy 

of Engineering.

John A. Cherry, Ph.D.

University of Waterloo

Dept. of Earth Sciences

Waterloo, Ontario

Canada N2L 3G1

Phone: 519-888-4516 

cherryja@sciborg.underloo.ca

Dr. Cherry is a Professor and holder of the Chair in Contaminant Hydrogeology in the Department of Earth Sciences at 

the University of Waterloo. For his contributions to the study of groundwater contamination, he has received awards from 

professional organizations in the United States, Canada, and Britain. He began research on contaminants in fractured 

clayey aquitards in 1968, and since 1978, his studies have focused on fi eld aspects of DNAPLs in fractured rocks and 

clayey aquitards. He has consulted widely on DNAPL issues, and has served on expert and advisory panels for both 

the corporate and public sectors. He holds patents for technologies for site monitoring, emphasizing multilevel monitoring approaches, and for remediation. He has been the director of the University Consortium Solvents-in-Groundwater 

Research Program since 1988.

Georgia Destouni

Dept. of Physical Geography and Quaternary Geology 

Stockholm University 

SE-106 91 Stockholm, Sweden

Phone: +46 (0)8 16 4785

Fax: +46 (0)8 16 4818

georgia.destouni@natgeo.su.se (gia@kth.se)

Georgia Destouni has been a Professor of Engineering Hydrology at KTH since 1999, guest professor at Stockholm 

University from 2003, and a member of the Royal Academy of Sciences (KVA) and the Royal Academy of Engineering 

Sciences (IVA) in Sweden, both since 2003. She is the author of about 120 scientifi c papers, including 45 peer-reviewed 

publications in international journals and books, and 75 technical reports, conference papers, and popular science 

publications. She is/has been a reviewer for many international scientifi c journals and research funding organizations, 

and a member of several national and international scientifi c committees and expert panels.
99

Ronald Falta

Professor, Clemson University

Brackett Hall, Room 340C

Clemson, SC 29634-0919

Phone: 864-656-0125

Fax: 864-656-1041 

faltar@clemson.edu

Dr. Falta is Professor of Geology and Environmental Engineering at Clemson University. He received his B.S. and M.S. 

degrees in Civil Engineering from Auburn University, and his Ph.D. degree in Mineral Engineering from the University 

of California, Berkeley, in 1990. His research is primarily in the area of NAPL source zone remediation, including both 

fi eld testing and mathematical modeling of new cleanup methods.

Michael Kavanaugh

Malcom Pirnie, Inc.

2000 Powell Street, Suite 1180

Emeryville, CA 94608

Phone: 510/596-3060

mkavanaugh@PIRNIE.COM

Dr. Kavanaugh is Vice President and the National Science and Technology Leader of Malcolm Pirnie, Inc., a 1400-person 

U.S. based private consulting fi rm specializing in environmental science and engineering. He is a chemical and environmental engineer with 29 years of consulting experience, providing a broad range of consulting services to private and 

public sector clients. His areas of expertise include hazardous waste management, site remediation with particular focus 

on ground-water remediation, risk and decision analysis, fate and transport of contaminants in the environment, water 

quality, water treatment, potable and non-potable water reuse, industrial and municipal wastewater treatment, strategic 

environmental management, and technology evaluations, including patent reviews on environmental technologies. Dr. 

Kavanaugh also has extensive litigation experience, both as a testifying expert and a fact witness on engineering and 

hydrogeologic issues related to hazardous waste sites, as well as on other issues related to his areas of expertise. 

He also has broad experience with alternative dispute resolution methods for settling environmental disputes and has 

participated on several mediation and arbitration panels as a neutral technical expert. Dr. Kavanaugh has been project 

engineer, project manager, principal-in-charge, technical director, or technical reviewer on over 190 projects covering 

a broad range of environmental problems. He has authored or co-authored approximately 35 peer-reviewed technical publications, edited and contributed to three books on water quality, water treatment, and ground-water cleanup, 

respectively, and has made over 100 presentations to technical audiences as well as public groups including testimony 

before congressional and legislative committees.

In addition to his consulting practice, Dr. Kavanaugh has been an active participant in various national committees 

advising the U.S. Environmental Protection Agency, the Department of Defense, the Department of Energy, as well as 

participating on various Boards and committees of the National Research Council. Between 1988 and 1991, Dr. Kavanaugh chaired the Water Science and Technology Board. He chaired the Board on Radioactive Waste Management 

between 1996 and 2000. Between 1992 and 1994, he was the Chair of the National Research Council (NRC) committee 

on alternatives for ground-water cleanup. From 1997 to 2001, Dr. Kavanaugh served on the Integration Project Expert 

Panel at the DOE Hanford Site, established by the Department of Energy to accelerate cleanup of soils and ground 

water at Hanford. He currently is a member of the Science Advisory Board of DOD’s environmental research program, 

the Strategic Environmental Research and Development Program (SERDP). For his contributions to water quality and 

hazardous waste management, Dr. Kavanaugh was elected into the National Academy of Engineering in 1998.

Dr. Kavanaugh is a registered chemical engineer in California, Utah, and Michigan, and a Diplomate (DEE) of the 

American Academy of Environmental Engineers. He is also a consulting professor of Environmental Engineering at 

Stanford University. He has a Ph.D. in Civil/Environmental Engineering from the University of California at Berkeley, 

and B.S. and M.S. degrees in Chemical Engineering from Stanford and UC Berkeley, respectively.
100

David Major

GeoSyntec

130 Research Lane

Guelph, Ontario

Canada NIG 5G3

DMajor@GeoSyntec.com

Dr. Major is a Principal at GeoSyntec Consultants, and received his Doctorate from the University of Waterloo for his 

thesis on the anaerobic biodegradation of aromatic hydrocarbons in ground water. For the past 15 years, he has worked 

with clients, researchers, and regulators to develop practical biological and chemical solutions to remediate contaminated sites. He has extensive experience in providing technical direction to complex remediation projects, third-party 

review of feasibility evaluations, and litigation support. Dr. Major serves on the steering committee of the Bioremediation 

Consortium of the Remediation Technologies Development Forum (RTDF), a collaboration between industry and government to develop innovative remediation technologies for chlorinated solvent and DNAPL sites. He is a co-developer of 

ITRC/RTDF Courses on Monitored Natural Attenuation and Enhanced In-Situ Bioremediation of chlorinated solvents, 

which are sponsored in part by Department of Defense Environmental Security Technology Certifi cation Program (ESTCP). He is the Project Director/Principal Investigator of several ESTCP projects involving in situ remediation, including 

demonstrations of bioremediation/bioaugmentation with halorespiring microorganisms to enhance the dissolution rate 

of DNAPLs, and coupling in situ chemical oxidation (ISCO) with bioremediation. Dr. Major is also assisting the Navy to 

review DNAPL treatment technologies and case studies of their application. He is actively involved in the identifi cation 

and evaluation of emerging environmental technologies, and was instrumental in commercialization of EnviroMetal Inc., 

which holds the patent for use of zero-valent metal in permeable reactive barriers to dechlorinate chlorinated solvents. He 

is continuing to further develop leading-edge remedial technologies, evident through his management of two laboratory 

and fi eld demonstration projects, sponsored by NASA, to evaluate the application of bioaugmentation and emulsifi ed 

nano-scale iron to treat DNAPLs. 

James W. Mercer 

GeoTrans, Inc.

Hydrogeologist 

Sterling, VA 20166

Phone: 703-444-7000 

jmercer@geotransinc.com

Dr. Mercer is a hydrogeologist with GeoTrans, Inc. He received a B.S. from Florida State University and a M.S. and Ph.D. 

from the University of Illinois; all of his degrees are in geology. He spent eight years with the U.S. Geological Survey 

in the Northeastern Research Group working on contaminant and heat transport issues, including multiphase fl ow. He 

co-founded GeoTrans in 1979, and in 1980, began working on DNAPL issues at Love Canal. In 1985, Dr. Mercer received the Wesley W. Horner Award of the American Society of Civil Engineers for the work performed at Love Canal. 

Dr. Mercer continued to work on DNAPL issues and co-authored a book on DNAPL Site Evaluation in 1993. In 1994, 

he received the American Institute of Hydrology’s Theis Award for contributions to ground-water hydrology. Dr. Mercer 

has served on the National Research Council’s Water Science and Technology Board and was a member of the U.S. 

EPA Science Advisory Board.

Charles J. Newell, Ph.D., P.E., D.E.E.

Groundwater Services, Inc.

2211 Norfolk, Suite 1000

Houston, Texas 77098

Phone: 713-522-6300

Fax: 713-522-8010

cjn@gsi-net.com

Dr. Newell is a Vice President of Groundwater Services, Inc. He is a Diplomate in the American Academy of Environmental Engineers and is an Adjunct Professor at Rice University. He has co-authored three EPA publications, fi ve 
101

environmental decision support software systems, numerous technical articles, and two books: Natural Attenuation 

of Fuels and Chlorinated Solvents and Ground Water Contamination: Transport and Remediation. His professional 

expertise includes site characterization, ground-water modeling, non-aqueous phase liquids, risk assessment, natural 

attenuation, bioremediation, non-point source studies, software development, and long-term monitoring projects. 

He served on the EPA’s DNAPL Workshop in 1991 and was one of four speakers who presented the EPA’s Seminar 

on Characterizing and Remediating DNAPL at Hazardous Waste Sites in ten cities in 1993. He has also served as a 

nationwide Risk-Based Corrective Action (RCBA) trainer for the American Society for Testing and Materials (ASTM). 

Dr. Newell has been awarded the Hanson Excellence of Presentation Award by the American Association of Petroleum 

Geologists, the Outstanding Presentation Award by the American Institute of Chemical Engineers, and the 2001 Wesley 

W. Horner Award by the American Society of Civil Engineers (for the paper, “Modeling Natural Attenuation of Fuels with 

BIOPLUME III”). 

P. Suresh C. Rao

Purdue University, School of Civil Engineering

Purdue University

West Lafayette, IN 47907-1284

Phone: (765) 496-6554

pscr@ecn.purdue.edu

Dr. Rao is the Lee A. Rieth Chair & Distinguished Professor of Environmental Engineering in the School of Civil Engineering at Purdue University, and he holds a joint appointment in the Agronomy Department in the School of Agriculture. 

Prior to arriving at Purdue, Dr. Rao was on the faculty at the University of Florida for 24 years, where he now holds an 

appointment as an Emeritus Graduate Research Professor. He teaches contaminant hydrology and remediation engineering. His research has involved development of innovative technologies for characterization of hazardous waste 

sites, and for enhanced remediation of contaminated soils and aquifers.

Thomas Sale 

Colorado State University

Engineering Research Center

Fort Collins, CO 80523-1320

Phone: 970-491-8413

saletm@engr.colostate.edu

Dr. Sale is an Assistant Professor in Civil Engineering at Colorado State University and an independent consulting hydrogeologist. He has been actively involved in the characterization and remediation of subsurface releases of Nonaqueous 

Phase Liquids (NAPLs) since 1981. Currently Dr. Sale is working on NAPL-related projects for the American Petroleum 

Institute, Department of Defense, and Union Pacifi c Railroad. His primary focus areas are pragmatic expectations for 

NAPL remedies and passive strategies for management of NAPL releases. He received his Ph.D. in 1998 from Colorado 

State University (Department of Chemical and Bioresource Engineering). The focus of his dissertation research was 

the effect of fractional NAPL removal from NAPL source zones on downgradient water quality and source longevity. 

Stephen H. Shoemaker, P.E.

DuPont Company

6324 Fairview Road

Charlotte, NC 28210

Phone: 704-362-6638

Fax: 704-362-6636

stephen.h.shoemaker@usa.dupont.com

Mr. Shoemaker joined DuPont in 1987 and holds the title of Senior Consultant in DuPont’s Corporate Remediation Group. 

Mr. Shoemaker’s responsibilities include directing remediation projects and developing strategies for DuPont plant sites; 

negotiating remediation programs with state and federal agencies; and evaluating appropriate remedial technologies 

for use by DuPont. For ten years he led a multi-disciplinary network in DuPont tasked with evaluating, developing, and 
102

demonstrating new in situ remediation technologies with particular emphasis on chlorinated solvents, including DNAPLs. 

He was a founding member of the Remediation Technologies Development Forum (RTDF) and co-founded the RTDF 

Permeable Reactive Barriers workgroup. 

Mr. Shoemaker has over 24 years of experience in the study and remediation of subsurface contamination. He graduated from the University of Delaware in 1977 with a B.S. in Geology and from the University of Missouri-Rolla in 1978 

with an M.S. in Geological Engineering.

Robert L. Siegrist, Ph.D., P.E.

Professor and Division Director, Environmental Science & Engineering

Colorado School of Mines 

Golden, Colorado, USA 80401-1887

Phone: 303-273-3490, 

Fax: 303-273-3473

siegrist@mines.edu, 

Website: http://www.mines.edu/~rsiegris

Dr. Siegrist earned his B.S. and M.S. in Civil Engineering (High Honors, 1972; 1975) and his Ph.D. in Environmental 

Engineering (1986) at the University of Wisconsin. During 20 years of experience, he has held research and teaching 

appointments with the Colorado School of Mines, Oak Ridge National Laboratory, the University of Wisconsin, and the 

Agricultural University of Norway. He has been a faculty member with CSM since January 1995, where he is currently 

Professor and Director of the Environmental Science & Engineering Division. During the past 15 years, his research has 

focused on characterization, assessment, and in situ remediation technologies for contaminated land. His research has 

encompassed in situ treatment processes (e.g., chemical oxidation, redox reactive barriers, bioremediation) as well as 

subsurface manipulation methods (e.g., vertical and horizontal recovery and recirculation wells, lance permeation, deep 

soil mixing, hydraulic fracturing). In related work, he has also continued research into the hydrodynamic and purifi cation processes impacting land treatment and disposal of wastes. Since 1990, Dr. Siegrist has been leading a program 

of research concerning in situ chemical oxidation involving peroxide and permanganate systems. This program has 

involved fundamental studies of reaction chemistry, contaminant mass transfer, and oxidant delivery systems, as well as 

fi eld evaluations through pilot- and full-scale technology demonstrations. Dr. Siegrist’s research has been sponsored by 

DOE, EPA, DOD, NSF, and private industry, and he has published the results of his work in over 50 refereed articles and 

more than 150 conference proceedings and reports. He is a registered professional engineer and an active member of 

several national societies. He has served as an advisor and technical expert for state and federal agencies in the USA, 

Canada, Norway, and Sweden, and is currently a Fellow with the NATO Committee for Challenges to Modern Society. 

On the personal side, he is an expert rock climber and mountaineer, and has organized and led climbing expeditions 

to Alaska, Peru, and Nepal. 

Georg Teutsch

Applied Geoscience

Sigwartstr.10

D-72076 Tuebingen

GERMANY

49-(7071)2976468 Offi ce

georg.teutsch@uni-tuebingen.de

Prof. Dr. Teutsch completed his study in geology and hydrogeology at the Universities of Tüebingen and Birmingham 

in 1980 with a M.Sc. in Hydrogeology. Following the completion of his study, he worked for several years nationally 

and internationally as a hydrogeologist concentrating on problems of water resources and water planning. In 1988 he 

gained his Ph.D. in the fi eld of groundwater modeling in karst aquifers. Between 1986 and 1991 he led the ground-water 

research group at the University of Stuttgart. In 1991 he gained his post doctorate (Habilitation) thereafter becoming 

professor for Geohydrology at the University of Stuttgart. In 1993 he was appointed to the Chair of Applied Geology at 

the Geological Institute at the University of Tüebingen and is now in charge of the new Centre for Applied Geoscience 

which comprises more than 50 academics from different fi elds. 
103

His professional expertise comprises innovative subsurface investigation methods, the development of numerical and 

analytical models for the fl ow and contaminant transport in porous and fractured media, the design and optimisation of 

ground-water remediation schemes, and also aquifer analog studies. He has published more than 50 technical papers 

in reviewed journals and is consulting environmental authorities and industry in Germany, at EU level, and in the U.S. 

Kent Udell 

University of California, Berkeley

6147 Etcheverry Hall 

University of California 

Berkeley, CA 94720-1740

Phone: 510-642-2928 

udell@me.berkeley.edu

Dr. Udell is a Professor of the Department of Mechanical Engineering at the University of California at Berkeley. He 

received his B.S. degree in Mechanical Engineering from Utah State University, and his M.S. and Ph.D. degrees in 

Mechanical Engineering from the University of Utah in Salt Lake City, Utah. He has been the Director of the Berkeley 

Environmental Restoration Center since 1993. He received the EPA Outstanding Remediation Technology Award in 

1999 for technical excellence in the development of in situ thermal treatment technologies. He is presently a member 

of the Innovative Thermal Technology Advisory Panel for the U.S. EPA.
104

APPENDIX C - Workshop Agenda – Dallas, TX

DNAPL Source Remediation Workshop

 
105

Day 1

SESSION 1 Moderator - Bob Puls, U.S.EPA

 8:00 AM Introduction of Objectives and Perspectives for Workshop 

 Lynn Wood, U.S.EPA 

 James Cummings, U.S. EPA 

8:30 AM DNAPL Remediation Issues and Workshop / Panel Objectives –

 Establish framework or boundaries for workshop 

 Mike Kavanaugh, Malcolm Pirnie, Inc. 

SESSION 2 Moderator - Suresh Rao, Purdue University

8:45 AM Constraints to and Incentives for Source Remediation 

 Kevin Garon, Dupont TONA 

 Dick Willey, U.S. EPA 

 Jim Harrington, NYSDEC 

 Discussion 

 9:45 AM BREAK 

10:15 AM Overview of Source Remediation Technologies 

 Carl Enfi eld, U.S. EPA 

 Kent Udell, University of California, Berkley 

 Bob Siegrist, Colorado School of Mines 

 Discussion 

11:45 AM LUNCH

SESSION 3 Moderator - Mike Kavanaugh, Malcolm Pirnie, Inc.

1:00 PM Benefi ts of Source Mass Reduction

 Linda Abriola, University of Michigan 

 Tom Sale, Colorado State University 

 Ron Falta, Clemson University 

 Discussion 

 2:30 PM BREAK 

3:00 PM Integrated Remedial Approaches: Addressing the Residual Plume

 Susan Mravik, U.S. EPA 

 Guy Sewell, U.S. EPA 

 Frank Chapelle, U.S. Geological Survey 

 Chuck Newell, Groundwater Services, Inc. 
106

 Discussion 

4:50 PM Charge to Breakout Groups

 5:15 PM Adjourn for dinner

 7-9:00 PM Break Out Groups (3 sessions)

 Session 1: Remediation Technology Leader – John Cherry 

 Session 2: Integrated Approaches to Cleanup Leader – Steve Shoemaker 

 Session 3: Decision Analysis Leader - Georg Teutsch 

 

Day 2

SESSION 4

Moderator - Mike Kavanaugh, Malcolm Pirnie, Inc.

8:00 AM Metrics for Source Remediation

 Georg Teutsch , University of Tuebingen, Germany 

 Suresh Rao, Purdue University 

 Ken Lovelace, U.S. EPA 

 Discussion 

9:30 AM Break 

10:00 AM Reconvene Breakout Sessions 

 11:30 AM Lunch

SESSION 5

Moderators - Suresh Rao & Mike Kavanaugh

 1:00 PM Breakout Discussion Group Reports:

 Group 1 

 Group 2 

 Group 3 

 SERDP Panel Report 

 2:00 PM Discussion 

2:45 PM Closure (end of workshop)

Executive Session of the Panel with the Sponsors (closed meeting)

 3:15 PM Panel Discussion, Planning, Initial Report
107

APPENDIX D - List of Attendees - Dallas, Texas
108

Linda Abriola

University of Michigan

Dept. Civil & Environ. Engr.

1351 Beal Ave., 181 EWRE Bldg.

Ann Arbor, MI 48109-212 

734-763-1464

abriola@engin.umich.edu

Mike Annable

Univ. of Florida 

Dept. of Env. Eng. Sci. 

217 Black Hall (2nd Floor) 

Gainesville FL, 32611-6450 

352-392-3294

manna@engnet.ufl .edu

Ben Blaney

U.S. EPA Facilities 

26 West Martin Luther King Dr. 

Cincinnati, OH 45268

517-569-7852

blaney.ben@epa.gov

Cliff Casey

Department of Navy

843-820-5561

caseycc@efdsouth.navfac.navy.mil

Frank Chapelle

U.S. Geological Survey 

720 Gracern Rd. 

Columbia, MO 29210-7651

803-750-6116 

chapelle@usgs.gov

John Cherry 

University of Waterloo

Dept of Earth Sciences

Waterloo, Ontario

Canada N2L 3G1 

519-888-4516 x4516 

cherryja@sciborg.uwaterloo.ca

Jeff Cornell

AFCEE/ERT

3207 N Road, Bldg 532 

Brooks AFB, TX 78235-5363

210-536-4331 

jeff.cornell@brooks.af.mil

James Cummings 

U.S.EPA HQ, MC 5102 G

Ariel Rios Bldg.

1200 Pennsylvania Ave., NW

Washington, DC 20460 

703-603-7197

cummings.james@epamail.epa.gov

Eva Davis

U.S.EPA-NRMRL 

P.O. Box 1198 

Ada, OK 74820

580-436-8548

davis.eva@epa.gov

Georgia Destouni 

Dept. of Physical Geology & Quaternay

Stockholm University

Stockholm, Sweden 

+46 (0)8 164-785 

georgia.destouni@natgeo.su.se

 

Tom Early

DOE (contractor) 

Oak Ridge National Laboratory

P.O. Box 2008, Bldg 1509, MS-6400

Oak Ridge, TN 37831-6400

865-576-2103

eot@ornl.gov

Bobbi Eberly

Dynamac Corporation

3601 Oakridge Boulevard

Ada, OK 74820

580-436-5740

beberly@dynamac.com

 
109

Carl Enfi eld 

MC 235

U.S. EPA Facilities

26 West Martin Luther King Dr.

Cincinnati, OH 45268 

513-569-7489 

enfi eld.car@epa.gov

 

Ron Falta 

DOW 630

Dept. Geo. Eng. & Sci., MTU 

1400 Townsend Drive 

Houghton, MI 49931 

906-487-1756 

faltar@clemson.edu

 

Kevin Garon

Dupont TONA

6324 Fairview Rd.

Charlotte NC 28210 

704-362-6638

kevin.p.garon@usa.dupont.com

Jim Harrington 

NYSDEC, Div of Environ. Remediaton 

12th Floor, 625 Broadway 

Albany, NY 12233-7012 

518-457-0337

jbharrin@gw.dec.state.ny.us

Tissa Illangasekare

Colorado School of Mines 

1500 Illinois St. 

Golden, CO 80401

303-384-2126

tissa@mines.edu

Richard Jackson 

DE&S Geosciences 

9111 Research Blvd. 

Austin TX 78758 

phone: 512-425-2017 

rejacks1@dukeengineering.com

Jerry Jones

U.S.EPA-NRMRL 

P.O. Box 1198 

Ada, OK 74820

580-436-8593

jones.jerry@epamail.epa.gov

Mike Kavanaugh

Malcolm Pirnie, Inc. 

2000 Powell Street, Suite 1180 

Emeryville, CA 94608 

510-596-3060 

mkavanaugh@pirnie.com

 

Ken Lovelace 

5202 G, U.S. EPA HQ

Ariel Rios Bldg.

1200 Pennsylvania Ave., N.W.

Washington, DC 20460 

703-603-8787

lovelace.kenneth@epa.gov

 

Kira Lynch

Seattle District Corps, EC-TB-ET 

4735 East Marginal Way South 

Seattle WA 98134

206-764-6918

kira.p.lynch@NWS02.usace.army.mil

Steve Mangion

HBS U.S. EPA Region 1 

Congress Street Suite 1100 

Boston, MA 02114-2023 

617-918-1452

mangion.steve@EPA.gov

Jim Mercer 

GeoTrans, Inc

46050 Manekin Plaza, Suite 100

Sterling, VA 20166 

703-444-7000

fax 703-444-3478 

jmercer@geotransinc.com

 
110

Susan Mravik 

U.S. EPA-NRMRL

P.O. Box 1198

Ada, OK 74820

580-436-8553 

mravik.susan@epa.gov

Chuck Newell 

Groundwater Services, Inc.

2211 Norfolk, Suite 1000

Houston, TX 77098-4044 

713-522-6300 

cjnewell@gsi-net.com

 

Kurt Paschl 

Environmental Manager 

Beazer East, Inc. 

One Oxford Centre, Suite # 3000 

Pittsburgh, PA 15219 

412-208-8805 

paschlk@hansonle.com

Bob Puls

U.S.EPA-NRMRL 

P.O. Box 1198 

Ada, OK 74820

580-436-8543

puls.robert@epa.gov

Suresh Rao 

Purdue University

School of Civil Engineering 

Purdue University 

West Lafayette, IN 47907-1284 

765-496-6554 

pscr@ecn.purdue.edu

Tom Sale 

Colorado State University

Engineering Research Center 

Fort Collins, CO 80523-1320 

970-491-8413 

tsale@lamar.Colostate.edu

Steve Schmelling

U.S.EPA-NRMRL 

P.O. Box 1198 

Ada, OK 74820

580-436-8540

schmelling.steve@epa.gov

Guy Sewell 

U.S.EPA-NRMRL

P.O. Box 1198

Ada, OK 74820

580-436-8566 

sewell.guy@epa.gov

 

Hai Shen

Dynamac Corporation

3601 Oakridge Boulevard

Ada, OK 74820

580-436-6404

hshen@dynamac.com

 

Steve Shoemaker

Dupont TONA

6324 Fairview Rd.

Charlotte NC 28210 

704-362-6638 

stephen.h.shoemaker@usa.dupont.com

 

Bob Siegrist 

Colorado School of Mines 

Environmental Sci.& Engr. Division 

112 Coolbaugh Hall 

Golden, CO 80401-1887 USA

303-273-3490 

siegrist@mines.edu

 

Rich Steimle

MC 5102 G, U.S.EPA HQ 

Ariel Rios Bldg. 

1200 Pennsylvania Ave., NW 

Washington, DC 20460

703-603-7195

stiemle.rich@epa.gov
111

Hans Stroo

ThermoRetec 

1250 E 223rd St, Suite 117 

Carson, CA 90745 

310-522-9550 

hstroo@thermoretec.com

Georg Teutsch 

Applied Geoscience

Sigwartstr. 10 D-72076 

Tuebingen GERMANY 

49-(7071)2974692 

georg.teutsch@uni-tuebingen.de

 

Kent Udell 

University of California, Berkley

6147 Etcheverry Hall 

University of California 

Berkeley, CA 94720-1740

510-642-2928 

udell@me.berkeley.edu

 

Dick Willey 

HBS, U.S. EPA Region 1

1 Congress Street, Suite 1100

Boston, MA 02114-2023 

617-918-1266 

willey.dick@epa.gov

 

Barbara Wilson

Dynamac Corporation

3601 Oakridge Boulevard

Ada, OK 74820

580-436-6415

bwilson@dynamac.com

Kim Winton

Dynamac Corporation

3601 Oakridge Boulevard

Ada, OK 74820

580-436-6407

kwinton@dynamac.com

Lynn Wood 

U.S. EPA-NRMRL

P.O. Box 1198

Ada, OK 74820 

580-436-8552

wood.lynn@epa.gov

Bernie Woody 

MS 518 1 

United Technologies Corporation

Financial Plaza 

Hartford, CT 06101 

860-610-7212 

woodyba@corphq.utc.com
112
United States

Environmental Protection

Agency

EPA/600/R-03/143

December 2003

National Risk Management

 Research Laboratory

Cincinnati, OH 45268

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