Engineering Report

Alaskan Copper Facility Seattle,

May 15, 2015

Prepared for

Alaskan Copper

130 2nd Avenue South Edmonds, WA 98020 (425) 778-0907 TABLE OF CONTENTS Page

1.0 INTRODUCTION 1-1 1.1 BACKGROUND 1-1

2.0 STORMWATER TREATMENT DESIGN IMPROVEMENTS 2-1 2.1 PREVIOUSLY INSTALLED STORMWATER TREATMENT 2-1 2.2 PLANNED STORMWATER TREATMENT IMPROVEMENTS 2-1 2.3 ADDITIONAL POTENTIAL SOURCE CONTROL IMPROVEMENTS 2-2 2.4 OUTFALL ANALYSIS 2-2 2.5 PROVISIONS FOR BYPASS 2-2 2.6 SAMPLING METHODOLOGY 2-2 2.7 OPERATION AND MAINTENANCE 2-3 2.7.1 Disposal of Used Filter Media 2-3

3.0 USE OF THIS REPORT 3-1

FIGURES

Figure Title

1 Vicinity Map 2 Site Map 3 Stormwater Treatment South of Building 3300

TABLES Table Title

1 Facility Stormwater Analytical Data 2 Stormwater Treatment Testing Data for CB 330001

APPENDICES Appendix Title

A CleanWay MetalZorb™ Product Information

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This document presents an Engineering Report as part of a Level Three Corrective Action for the Alaskan Copper facility (Facility), located in Seattle, Washington, in accordance with the conditions of the National Pollutant Discharge Elimination System (NPDES) permit, specifically permit number WAR-000139 under the State of Washington’s Industrial Stormwater General Permit (Permit). This report presents the plans for stormwater treatment improvements with the goal to achieve benchmark concentrations of applicable parameters under the Permit. The Permit requires that water quality sampling of qualifying storm events be conducted once per quarter of each year. The Permit establishes benchmark concentrations for various parameters with increasing levels of response actions (i.e., Level One, Level Two, and Level Three) required based on the number of times the benchmarks are exceeded. Stormwater data collected in 2014 for copper triggered a Level 3 Corrective Action for evaluation and implementation of stormwater treatment by exceeding the benchmark value three or more quarters of the year.

1.1 BACKGROUND Alaskan Copper Works is located at 3200 6th Avenue South. Figure 1 shows the general vicinity of the Facility. Alaskan Copper performs dimensional steel and stainless steel pipe fabrication at the Facility. A site map that shows the Facility, its stormwater drainage features, and designated stormwater sampling location is presented on Figure 2. Some portions of the Facility drain to the City of Seattle’s combined sewer system. The stormwater discharge sampling location at the Facility, catch basin CB330001, is located south of Building 3300. Formerly, there was a second stormwater discharge sampling location at the facility at catch basin CB 331707, located south of former Building 3317 on the west side of 6th Avenue. However, Alaskan vacated that property in late 2014 and it is now occupied by another business. Stormwater analytical results at CB330001 since 2010 are presented in Table 1. Alaskan Copper had implemented stormwater treatment improvements in 2013. However, as can be seen from the data, the copper concentration was exceeded in all four quarters of 2014 and therefore stormwater treatment improvements are necessary.

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Past source evaluation work has been performed at the facility to identify sources of copper. The roofing materials of Building 3300 have not been identified to be significant sources of metals based on past roof downspout sampling and analysis. However, two small 55-gallon drum-size roof drain downspout “ garden” treatment units were installed there in 2011 to provide extra help in trying to achieve the copper benchmark at CB330001. Catch basin media filtration treatment has also been employed at CB330001.

2.1 PREVIOUSLY INSTALLED STORMWATER TREATMENT For the Building 3300 and CB330001 drainage basin, oyster shell chips were first installed in September 22 through 26, 2011 in a modified catch basin structure in order to provide pH buffering of the stormwater, adsorb dissolved copper, and also to help entrain and settle suspended solids. Oyster shell is capable of buffering pH levels in stormwater to a less acidic level, which is less favorable to the solubility of metals and helps to promote adsorption of metals onto the calcium carbonate matrix of the shell. The catch basin was modified with a pipe tee installed at the outlet pipe, with the pipe below the tee providing a perforated underdrain to ensure stormwater flow through the shell media before discharging through the outlet. The pipe extending above the tee provides access to allow for sampling and provides a path for bypass of stormwater during extreme rainfall events. Limited sampling results of both the influent and effluent of the oyster shell catch basin (Table 2) indicate that it can achieve over 70% removal of copper from stormwater. Further stormwater treatment improvements were installed on April 29, 2013 at location CB330001. The improvements consisted of replacing the coarse oyster shell with more finely crushed oyster shell and also using MetalZorb™ product available from CleanWay Environmental Partners as a component of the media mix in the catch basin for further enhanced removal of copper. The MetalZorb media is a sponge structure coated with a metals adsorptive material. Manufacturer’s literature and an EPA technology description paper from when the product was known as the Forager Sponge are included in Appendix A.

2.2 PLANNED STORMWATER TREATMENT IMPROVEMENTS The MetalZorb media is quite a bit more expensive per cubic foot than the crushed oyster shell media, but it has a higher adsorptive capacity for metals such as copper and zinc compared with oyster shell. The product literature (Appendix A) suggested that the MetalZorb media is not fouled or otherwise negatively impacted by calcium ions. However, it is possible that the reason only minimal improvement

5/15/15 P:\1198\001\FileRm\R\Engineering Reports\2015\AC Eng Rpt_05-15-15.docx LANDAU ASSOCIATES 2-1 in treatment removal efficiency was observed after MetalZorb was combined with oyster shell in CB330001 (see Table 2) is that the oyster shell presented much higher calcium concentrations than were previously tested with the product, and the calcium ions possibly did adsorb onto the surface of the media and interfere with the adsorption capacity for copper. Therefore, the current plan is to change the catch basin adsorptive media to use of 100% MetalZorb media, with no use of oyster shell. The higher adsorptive capacity and faster reaction kinetics of the MetalZorb media will further reduce the copper concentration in stormwater and is expected to allow attainment of the benchmark for copper. The MetalZorb sponge media is a much lower density material than oyster shell and at times can be slightly buoyant. A top screen is already in place at CB330001 in order to make sure that the MetalZorb media does not float and get accidentally washed into the outlet overflow pipe tee.

2.3 ADDITIONAL POTENTIAL SOURCE CONTROL IMPROVEMENTS In addition to the planned stormwater treatment improvements, Alaskan copper is looking for ways to minimize the exterior storage and exposure of metal materials to stormwater that drains to surface water. One option that is currently being examined is to be able to eliminate all industrial operations and storage of materials south of Building 3300 and to consolidate that material in other portions of the facility without connection to surface water discharge. Alaskan copper may be able to make that transition within the next year.

2.4 OUTFALL ANALYSIS No new stormwater outfalls to surface waterbodies will be constructed for these planned stormwater treatment improvements. There will be no significant net change to the stormwater volume discharged or to the flow rate of discharge.

2.5 PROVISIONS FOR BYPASS The structurally modified oyster shell media catch basin (CB330001) has an overflow pipe to allow storm flow from extreme rainfall events to bypass and to prevent flooding. The roof downspout treatment units also have the ability to overflow stormwater from extreme rainfall events.

2.6 SAMPLING METHODOLOGY Quarterly stormwater sampling will continue to be conducted in accordance with methods outlined in the Facility’s Stormwater Pollution Prevention Plan (SWPPP). The designated stormwater sample collection location will remain CB330001.

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2.7 OPERATION AND MAINTENANCE The operation and maintenance of stormwater treatment will consist of ongoing visual monitoring of storm drainage at the Facility. Monthly documentation of the condition of the CB330001 catch basin with MetalZorb treatment media and roof drain downspout treatment units is already part of the formal monthly facility inspections. The frequency of vactor truck servicing to remove the MetalZorb catch basin media at CB33001 will depend on the solids loading rate and whether a surface fabric filter is found to be effective as a pre- filter. It is anticipated that the MetalZorb media can provide good treatment for at least a 6-month period before needing to be replaced. Visual inspection observations and quarterly stormwater sampling results will help to determine the specific frequency of media replacement that will be required.

2.7.1 DISPOSAL OF USED FILTER MEDIA The stormwater filter media periodically needs to be replaced and the spent media disposed of. Spent filter media will be managed and disposed of per applicable laws and regulations. Given the known sources of copper and zinc at the facility, it is recommended that a sample of the spent filter media be analyzed for a standard suite of total metals for waste characterization (e.g., RCRA 8 metals), plus the additional analysis of total copper and zinc. It can then be confirmed that the used filter media do not exceed toxicity characteristics for either hazardous waste or state dangerous waste, and those analytical results would provide documentation that disposal to a Subtitle D municipal solid waste landfill is appropriate. Depending on the results of the analyses for total metals, toxic characteristic leaching procedure (TCLP) testing for metals might be necessary to confirm that the waste is not a hazardous waste due to metals toxicity. Past waste characterization sampling results of the mixed oyster shell and MetalZorb media may be adequate for future disposal, but Alaskan Copper may need to check with its waste disposal service company to confirm if new testing is required or how frequently they might want the waste stream retested.

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Metal Storage /" CB330001 Diesel AST with Spill Response Kit Legend Building Stormwater Discharge Point ID Storm Drains (to Surface Water) /" and Monitoring Location ID 3405 Drainage Mainline Stormwater Discharge Point (City of Seattle Maintained Drainage Lateral /" Catch Basin) Drain Lines to Sanitary Sewer Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, Stormwater Drainage Area Combined Mainlines CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo,Stormwater and the Surface GIS User Community King County Mainline Flow Direction Sanitary Mainline 0 200 400 Alaskan Copper Property Boundary Side Sewer Unpaved Areas Scale in Feet (All other areas not covered Note with buildings are paved) 1. Black and white reproduction of this color original may reduce Data Source: King County GIS; ESRI World Imagery; its effectiveness and lead to incorrect interpretation. Storm Drain Utilities: City of Seattle Facility and Storm Drainage

G:\Projects\1198\003\010\011\F02SiteMap.mxd 1/16/2015 NAD 1983 StatePlane Washington North FIPS 4601 Feet FIPS North StatePlane NAD 1/16/2015 1983 Washington G:\Projects\1198\003\010\011\F02SiteMap.mxd Figure Alaskan Copper Facility Seattle, Washington Site Map 2

Stormwater Downspout Filter “Rain Garden” Barrels “I” and “J” Installed in 2011

Catch Basin 330001 Modified to Hold Stormwater Treatment Filtration Media

Figure Alaskan Copper Stormwater Treatment Seattle, Washington South of Building 3300 3

TABLE 1 Page 1 of 1 FACILITY STORMWATER ANALYTICAL DATA ALASKAN COPPER FACILITY - SEATTLE, WASHINGTON

Sampling Location Total Total Total CB330001 TPH TurbidityField FieldpH Zinc Copper Lead Method NWTPH-Dx Meter Meter EPA-200.8 EPA-200.8 EPA-200.8 Reporting QtrBenchmarks: 10 25 5 - 9 117 14 81.6 (Date) Date mg/L NTU SU ug/L ug/L ug/L 1st Qtr 2010 2/11/2010 5.7 57.4 7.17 193 163 24.4 2nd Qtr 2010 6/2/2010 10.30 21.1 7.3 119 132 16.7 3rd Qtr 2010 8/31/2010 3.08 15.3 7.76 186 128 16.3 4th Qtr 2010 10/14/2010 2.6 8.1 8.31 101 99.3 6.53 1st Qtr 2011 3/10/2011 1.0 18.4 CA 83.5 119 CA 2nd Qtr 2011 4/25/2011 1.11 8.3 CA 45.2 33.5 CA 3rd Qtr 2011 7/25/2011 CA 14.7 CA 102 95.9 CA 4th Qtr 2011 10/3/2011 CA CA CA CA 32.7 CA 1st Qtr 2012 1/4/2012 CA CA 8.20 CA 13.2 CA 2nd Qtr 2012 5/21 & 6/5 CA CA 7.30 CA 35.3 CA 3rd Qtr 2012 NQSE NQSE NQSE NQSE NQSE NQSE NQSE 4th Qtr 2012 10/19/2012 0.3 U 5.51 8.5 38.8 35.4 1.77 1st Qtr 2013 1/30/2013 0.30 52.7 7.5 84.2 96.7 7.44 2nd Qtr 2013 6/20/2013 0.3 U 11.4 8.1 54.4 62.4 10 U 3rd Qtr 2013 8/2/2013 0.07 9.65 8.2 26.4 45.9 1 U 4th Qtr 2013 10/1/2013 0.611 1.22 8.1 37.5 36.2 3.52 1st Qtr 2014 1/8/2014 CA 17.58 6.6 CA 90.0 CA 2nd Qtr 2014 4/17/2014 CA 16.85 5.0 CA 96.4 CA 3rd Qtr 2014 7/23/2014 CA 6.88 8.3 CA 39.5 CA 4th Qtr 2014 10/15/2014 CA 6.93 5.5 CA 27.2 CA

Notes: = Exceedance of benchmark

= Not required to sample for this parameter due to consistent attainment. CA = Not Sampled Due to Consistent Attainment NQSE = No qualifying storm event; no representative discharge during normal business hours. mg/L = milligrams per liter. mg/L = micrograms per liter. Qtr = Quarter. U = Compound was analyzed for, but was not detected at the reported sample detection limit.

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Total Percent Copper Removal Date BMP Information (µg/L) (%) July 2011 Installed "I" 3300 Rain Garden August 2011 Installed "J" 3300 Rain Garden September 2011 Installed oyster shell in CB330001 Influent of catch basin oyster shell media 129 6/5/2012 73% Effluent of catch basin oyster shell media 35.3 4/29/2013 MetalZorb™ media added in with oyster shell Influent of catch basin oyster shell media 435 4/17/2014 78% Effluent of catch basin oyster shell media 96.4

Notes 1. Benchmark value for copper is 14 µg/L

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APPENDIX A

CleanWay MetalZorb™ Product Information

CleanWay Environmental Partners, Inc. PO Box 30087 10620 NE Marx Street Portland, Oregon 97294 Toll free 800-723-1373 Tel 503-280-5102 Fax 503-288-3658

MetalZorbTM Treated Sponge Product for the Removal of Heavy Metal Contaminants

General Properties Treated Sponge Products Type M and M-TU have selective affinity for heavy metals in cationic and anionic states in aqueous solution. MetalZorb functions by forming coordination complexes preferentially with ions of the transition group Heavy Metals, namely metals classified in groups IB through VIIIB of the Periodic Table of Elements; and generally characterized as having incomplete inner rings of electrons or otherwise capable of existing in more than one valence state.

By comparison, metals such as calcium, magnesium and aluminum, having complete inner rings of electors and single valence states, show poor affinity for the treated sponge. MetalZorb provides ligand sites that surround the metal and form a coordination complex. The order of its affinity for metals is influenced by solution parameters such as pH, temperature and total ionic content. However, the following affinity sequence of some representative ions can generally be expected to be:

+++ -2 ++ ++ -2 ++ ++ -3 -2 ++ Au > UO4 > Cd > Hg > Au(CN) > Cu > Pb > VO4 > MoO4 > Zn +++ -2 ++ -2 -3 ++ ++ +++ + +++ > Cr > CrO4 > Ni > SeO4 > AsO4 > Co > Mn > Fe > Ag > Al > Mg++ > K+

When employed as a stationary bed in a tank or column through which an aqueous stream flows, absorption bands are produced generally in accordance with the affinity sequence. In certain situations, strongly absorbed species will displace less strongly absorbed species. This characteristic may be employed to separate ions. When utilized in an upward flow fluidized bed or in rotating drums, simultaneous absorption of a number of ionic species will occur in amounts relative to the initial concentration and affinity sequence.

At saturation, the MetalZorb will contain between 6% and 15% (dry weight) of absorbed ions, depending on the affinity of the sponge product for the ion and its molecular weight. This represents an absorption capacity of about 1.0 – 2.0 molar equivalent of absorbed ion/dry gram of sponge product. The presence of commonly abundant innocuous ions such as Na+, K+, Ca++, Mg++, Al+++, CI-, SO4- - will not adversely affect the sponge’s absorption capacity.

Applications These treated sponge absorbents are highly effective for removing toxic species in low ppm and ppb concentrations from industrial wastewater, groundwater, stormwater, landfill leachate, municipal process streams and drainage waters. They are particularly useful in remediating waters that contain less than 20 ppm of targeted species, especially where treated effluent concentrations below 1 ppb are sought. Absorbent sponge is typically employed as a polishing operation following an upstream treatment such as a process. MetalZorb is uniquely capable of absorbing metals such as mercury, lead, nickel and cadmium, which are chelated by EDTA or other synthetic or naturally occurring chelating agents.

For applications where the solutions are high temperature or exposed to extreme pH ranges, please contact CleanWay for technical support.

Statement of Non-Warranty All data, statements and recommendations in this publication are based on the best information available and believed to be reliable. CleanWay assumes no obligation or liability, and makes no express or implied warranty with regard to the data, statements and recommendation given or applications covered or results obtained. All information is given and accepted at the user’s risk. Although no adverse physiological effects have been observed in the handling of the treated sponge product, users assume all risk of use and handling. No statement shall be taken as a recommendation of action or use without independent investigation. Users are reminded to practice such safety precautions as may be indicated in the particular circumstances to protect health and property.

Patents issued and pending.

© 2010 CleanWay Environmental Partners, Inc.

Stormwater Filtration Products cleanwayusa.com

United States Office of EPA 540/R-94/522a Environmental Protection Research and Development February 1995 Agency Clncinnatl, OH 45268

Introduction This capsule provides information on the Dynaphore, Inc. ForagerTM Sponge technology, a technology devel- In 1980, the U.S. Congress passed the Comprehen- oped to remove heavy metal contaminants from ground- sive Envlronmental Response, Compensation, and Liabil- water, surface waters, and process waters. The ForagerTM ity Act (CERCLA), also known as Superfund, committed Sponge process was evaluated under EPA’s SITE pro- to protecting human health and the environment from gram In April 1994, at the NL Industries, Inc. Superfund uncontrolled hazardous wastes sites. CERCLA was Site in Pedricktown, NJ. The site was originally a second- amended by the Superfund Amendments and Reautho- ary lead smelting facility. The groundwater at the facility rization Act (SARA) in 1986 - amendments that empha- Is contaminated with heavy metals, including lead, cad- size the achievement of long-term effectiveness and mium, and chromium in excess of NJ groundwater stan- permanence of remedies at Superfund sites. SARA man- dards. Information In the Capsule emphasizes specific dates implementing permanent solutions and using al- site characteristics and results of the SlTE field demon- ternative treatment technologies or resource recovery stration at the NL Industries, Inc. site. This capsule pre- technologies, to the maximum extent possible, to clean sents the following Information: up hazardous waste sites. l Abstract State and federal agencies, as well as private par- l Technology Description ties, are now exploring a growing number of innovative l Technology Applicability technologies for treating hazardous wastes. The sites on l Technology Limitiations the National Priorities List total over 1,700 and comprise a l Process Residuals broad spectrum of physical, chemical, and environmen- l Site Requirements tal conditions requiring varying types of remediation. The . Performance Data U.S. Environmental Protection Agency (EPA) has focused l Technology Status on policy, technical, and informational issues related to l Source of Further Information exploring and applying new remediatin technologies applicable to Superfund sites. One such initiative is EPA’s Abstract Superfund Innovative Technology Evaluation (SITE) pro- gram, which was established to accelerate develop- The ForagerTM Sponge is a volume reduction tech- ment, demonstration, and use of innovative technologies nology in which heavy metal contaminants from an for site cleanups. EPA SITE Technology Capsules summa- aqueous medium are selectively concentrated into a rize the latest information available on selected innova- smaller volume for facilitated disposal. The technology tive treatment and site remediation technologies and treats contaminated groundwater, surface waters, and related issues. These capsules are designed to help EPA process waters by absorbing dissolved ionic species onto remedial project managers, EPA on-scene coordinators, a sponge matrix. The sponge matrix can be directly contractors, and other site cleanup managers under- disposed, or regenerated with chemical solutions. The stand the types of data and site characteristics needed Sponge can remove toxic heavy metals from waters in to effectively evaluate a technology’s applicability for the presence of high concentrations of innocuous, natu- cleaning up Superfund sites. rally occurring dissolved inorganic species.

63 Printed on Recycled Paper The ForagerTM Sponge technology was demonstrated matrix. The functional groups in the polymer (i.e., amine under the SITE Program at the NL Industries, Inc. Superfund groups in the polymer backbone and pendent carboxyl site in Pedricktown, NJ. The mobile pump and treat sys- groups) provide selective affinity for heavy metals in both tem treated groundwater contaminated with heavy met- cationic and anionic states, preferentially forming coordi- als. The demonstration focused on the system’s ability to nation complexes with transition-group heavy metals remove lead, cadmium, chromium, and copper from the (groups IB through VIIIB of the Periodic Table). The order contaminated groundwater over a continuous 72-hr test. of affinity of the polymer for metals is influenced by solu- The results from the demonstration indicated that cad- tion parameters such as pH, temperature, and total ionic mium was reduced by 90%, copper reduced by 97%, content. The following affinity sequence for several repre- lead reduced by 97%, and chromium reduced by 32%. sentative ions is generally expected by Dynaphore: The removal of heavy metals proceeded in the presence of significantly higher concentrations of innocuous cat- Cd++ > Cu++ > Fe+++ > Au+++ > Mn++ > Zn++> Ni++> Co++ > Pb++ - -2 -3 -2 -2 + ions such as calcium, magnesium, sodium, potasslum, > Au(CN)2 > SeO4 > AsO4 > Hg++> CrO4 > UO4 > Ag > and aluminum. Al+++ > K+ > Ca++ > Mg++ >> Na+

The ForagerTM Sponge technology was easy to oper- The high selectivity for heavy metals, and the low ate and exhibited no operational problems over the course selectivity for alkali and alkaline earth metals (Na+, K+, of the demonstration. The system is trailer-mounted, easily Mg++, and Ca++), is especially useful for the treatment of transportable, and can be operational within a day upon contaminated natural waters which may contain high arrival at a site. The spent Sponge can be compacted concentrations of these innocuous chemical species. These into a small volume for easy disposal. monovalent and divalent cations do not interfere with or compete with absorption of heavy metals, therefore al- The ForagerTM Sponge technology was evaluated lowing for maximum removal of heavy metals from con- based on the seven criteria used for decision making as taminated waters. part of the Superfund Feasibility Study (FS) process. Results of the evaluation are summarized in Table 1. The Sponge is highly porous which promotes high rates of absorption of ions. Absorbed ions can be eluted Technology Description from the Sponge by techniques typically employed for regeneration of ion exchange resins. Following elution. The ForagerTM Sponge is an open-celled cellulose the Sponge is ready for the next absorption cycle. The sponge which contains a water-insoluble polyamide useful life of the media depends on the operating envi- chelating polymer for the selective removal of heavy ronment and the elutlon techniques used. Where regen- metals. The polymer is intimately bonded to the cellulose eration is not desirable or economical, the Sponge can so as to minimize physical separation from the supporting be compacted to an extremely small volume to facilitate

Table 1. FS Criteria Evaluation for the Forager TM Sponge Technology

Overall Protection of Compliance with Long-Term Reduction of Toxicity Short-Term Implementability Cost Human Health and federal ARARs Effectiveness and Mobility. or Volume Effectiveness the Envkonment _ Permanence Through Treatment Protects human health Requires compliance Permanently removes Volume reduction Presents minimal Easily implement- $340/1,000 and the environment with RCRA treatment. contamination from technology which risk to workers able and trans- gal with by removing storage, and the affected transfers contam- and the portable. regenerate contaminants from disposal regulations matrix. inants from community ;on. groundwater or and pertinent aqueow media surface water. radioactive and to a smaller mixed waste volume. regulations.

Minimizes or Well construction Residuals from the Ability to compact Requires minimal $238/1,000 eliminates the activities may process must be Sponges to small site preparation gal with further spread of require permits. disposed of in an volumes may be and utilities Sponges contaminants within appropriate advantageous for (water & elec- regener- the aquifer. manner. radioactive or mixed tricity). ated waste. twice pro- vlding for 3 useful cycles.

Disposal of treated waters may requkw compliance with Clean Water Act and Safe Drinking Water Act.

*Actual cost of a remedial technology is site-specific and is dependent on factors such as the cleanup level, contaminant concentrations and types, waste characteristics, and volume necessary for treatment.

2 disposal. The metal-saturated Sponge can also be incin- 4.4 psig. Although not demonstrated, if sufficient head erated wlth careful attention given to the handllng of were provided, the system could have operated by grav- resultant vapors. ity flow. The Sponge can be used in columns, fishnet-type Technology Limitations enclosures, or rotating drums. For this demonstration, the Sponge was utilized in a series of four columns. Each 3 The technology is considered a volume reduction column was comprised of a 1.7 ft , pressurized acrylic technology since the contaminants are removed from tube containing about 24,000 half-in. Sponge cubes con- the waste stream and concentrated into a smaller vol- tained within a fishnet bag. The columns were mounted ume which can be more easily handled and disposed. on a moblle trailer unit. The reduced volume, either sponge or acid regenerant solution, must be immobilized by other means on-site or Technology Applicability off-site. According to the developer, the scope of contami- TM nants suitable for treatment using the Dynaphore Inc. The Forager Sponge is capable of removing dis- TM solved heavy metals from a wide variety of aqueous Forager Sponge Technology is limited to heavy metals. media Including groundwater, surface waters, landfill The technology’s affinity and absorption capacity for given leachate and industrial effluents. The chemistry employed metals can vary and is dependent on a number of waste for metal removal Is selective, allowing for the treatment characteristics including pH, concentration and types of of toxic heavy metals in the presence of high concentra- cations and anions present, and the presence of tions of innocuous cations, such as Ca++, Mg++, Na+, and complexing agents. K+. The selective afflnity of the polymer is similar to com- mercially available selective chelating resins. However, The technology usefulness may be limited by its over- the Sponge’s unique supporting cellulosic matrlx may pro- all absorption capacity for the heavy metals of concern. vide the technology with distinct advantages under cer- If frequent changeout or regeneration of the columns is tain processing conditions. required, it could make this technology cost prohibitive. In these applications. pretreatment may be necessary in The ForagerTM Sponge could be potentially Incorpo- order to reduce the concentration of specific contaml- rated into varled treatment configurations. The technol- nants to technically and/or economically optimal levels. ogy can be utilized in a conventional pump-and-treat remedial process, as was performed during the SlTE Dem- Process Residuals onstratton. The Sponge can be utilized as the primary or secondary removal mechanism, dependent on the type The residuals generated from the Sponge technology and concentration of contaminants, as well as the prop- consist of either solid sponge material or liquid (acid) erties of the influent wastestream. For example, the Sponge regenerant solution. These residuals will be concentrated may be used as a polishing step in conjunction with a with heavy metals, and depending on contaminant lev- technology that can remove high concentrations of met- els, may be subject to RCRA regulations as a hazardous als to moderate levels (e.g., chemical precipitation). Ac- waste. These waste materials can be easily stored In cording to the developer, the ForagerTM Sponge appropriate 55-gal drums for off-site transport and dis- technology can also be used in applications requiring in- posal. For the demonstration, four Sponges were hand situ treatment. In these applications, the Sponge can be compacted into one 55-gal drum. Further compaction is placed into tubular fishnet containers and emplaced within possible utilizing a waste compactor. Following comple- wells or trenches to intercept groundwater flow. The tion of the demonstration, the developer sent four flshnet Sponge can be used to treat surface waters by placing bags of virgin Sponges to a waste compacting firm to the Sponge in a fishnet configuration across channels or determine maxlmum compaction achievable. Tests per- within other surface water bodies. formed revealed compactlon ratios of 4: 1 and 10: 1 utiliz- lng compactlon forces of 20,000 lb and 85,000 lb, In addition, to potential different treatment applica- respectively. tions, the Sponge’s unique matrix provides advantages in terms of disposal and operating conditions. The metal- Treated wastewater can be discharged to a Publicly laden Sponge can also be compacted into small dis- Owned Treatment Work (POTW), into surface waters, or posal volumes, which could aid in lowering disposal costs, reinjected through underground injection wells, if appro- and is beneficial where a minimum volume of residual priate discharge limitations are met and the proper per- waste is needed due to the properties of the contami- mits are obtained, For this demonstration, the treated nants being absorbed. For example, this may be advan- effluent was suitable for off-site treatment at a local POTW. tageous in the treatment of radiologically contaminated waters, where the need to minimize residual waste is a Site Requirements critical disposal issue. The ForagerTM Sponge treatment unit Is mounted The high porosity of the Sponge enables a low pres- on a flat bed trailer and is easily transportable. The four- sure system to be used. For this demonstration, the four column trailer unit, measuring approximately 50 ft2, is column unit operated under an inlet pressure as low as equipped with a water heater, wastewater pump, flow

3 meter and totalizer. Once on site, the treatment system cern at the NL site, and are therefore the critical param- can be operational within a day, if all necessary facilities eters for this study. In addition, copper was also consid- utilities and supplies are available. On-site assembly and ered a critical parameter because of the high removal maintenance requirements are minimal. efficiency observed in predemonstratlon treatability tests.

Utilities required for the trailer unit are limited to water The developer claimed that the technology would and electricity. Electricity requirements are dependent achieve at least a 90% reduction of lead and copper, an upon the need to pump the wastewater, if gravity feed is 80% reduction in cadmium, and a 50% reduction of chro- not feasible, and the need to heat the wastewater to mium (as trivalent chrome) In the groundwater. improve absorption of metals. The water can be pumped with the 12-V pump equipped on the trailer. This pump In addition to the prlmary objective, other secondary can also run off a car battery, which was done for the (non-critical) objectives included: demonstration. The water heater requires a 220-V electri- cal outlet. Water will be required occasionally for regen- determine removal efficiencies for other heavy metals present eration of the Sponges, cleanup and decontamination. in the groundwater: determine removal efficiencies for critical parameters across Support facilities include an area for untreated and the four columns; treated groundwater storage tanks (if used), a chemical evaluate the absorptlon capacity and regenerative capabili- ties of the Sponge for the critical parameters; storage area for regenerant chemicals (i.e. acids) and gather information to estimate operating costs, (e.g.. utility any other process chemicals, and a waste drum storage and labor requirements, waste disposal costs, treatment ca- area for spent Sponges, regenerant solutions and other pacity, etc.). wastes requiring disposal. These areas must be constructed to control run-on and run-off. Addltlonally, an enclosed The technology was evaluated over a continuous 72- building or shed may be necessary to protect equipment hr operational perlod, resulting In a total treatment vol- and personnel from weather extremes. During the dem- ume of approxlmately 4,300 gal. Groundwater was onstration, the treatment unit was housed in a tent. Mo- pumped from the influent storage tank through the four- bile office trailer(s) may also be needed on site. column system at a treatment flow rate of 1 gpm or 0.08 bed volumes/min. The lnfluent temperature was raised Support equipment for the ForagerTM Sponge Tech- approximately 15o C to increase reaction rates nology may Include a drill rig for well Installation, contain- (i.e.,improve absorption of the critical metals). The treated ers for waste storage, a forklift for movlng waste drums, effluent was initially discharged to a 250 gal portable tank and a waste compactor for compaction of Sponges. In from which it was subsequently pumped to a 20,000 gal addition to an influent equalization tank, a treated stor- effluent storage tank. The stored effluent was transported age tank may be needed if the water can not be directly off-site for treatment at a local POTW. A flow schematic discharged to a POTW or stream, or reinjected into the of the system is shown In Figure 1. ground. According to the developer, replacement or regen- Performance Data eratlon of the columns was not necessary, since none of the columns were anticipated to become saturated (i.e., The ForagerTM Sponge Technology was evaluated for no further absorption capacity available for the critical its ability to remove heavy metals from groundwater. metals). Four columns were reportedly needed to provide Lead, cadmium, and chromium are contaminants of con- sufficient path length to meet the demonstration goals.

Figure 1. Process flow diagram for the Dynaphore, Inc., ForagerTM Sponge demonstration.

4 als during the demonstration. Specifically, the first column Although concentrations of some of the critical met- became saturated with both cadmium and lead, while als exceeded cleanup goals for the site, the groundwater the second column became saturated with only cad- was spiked with solutions of lead, copper, and cadmium mium. Saturation is deflned when the effluent concenlra- to as-sure effective evaluation (quantification) of the tion of a given metal is approximately equal to or greater developer’s claim. thanthe influent concentration The first column was saturated with both cadmium and lead at approximately Grab samples for analysis of critical parameters were the 49th hr. Approximately 10 hr later, cadmium satu- collected from the raw influent, final effluent, and inter- rated the second column. None of the columns were mediate column effluent points (see Figure 1). In addition, saturated with copper during the demonstration test. equal volume 24-hr composite samples were collected Based on a non-linear extrapolation of the data, the first for total metals, chemical oxygen demand, total sus- column would have become saturated with copper af- pended solids, total dissolved solids, sulfate, and gross ately 4 days of continuous operation. alpha and gross beta radioactivity. Process measurements for flow rate, total volume, pressure, pH, and temperature Based on data from the 72-hr demonstration, the were also monitored at these locations. Since the devel- actual absorption capacity for the critical metals was oper reported that replacement or regeneration of the significantly lower (approximately 10 to 100 times lower) columns was not necessary, side tests on laboratory scale than the developer’s predemonstration estimates. These columns treating standard metal salt solutions were per- estimates were based on absorption capacity tests on formed to aid in evaluating the absorption capacity and standard metal salt solutions rather than the groundwa- regenerative capabilities of the Sponge. ter. The developer theorizes that anion species such as sulfate and phosphate may have interfered with the Analytical results of critical parameters for the raw effective removal of these metals. These results show the influent and final effluent are presented in Table 2 and need to conduct treatability tests on each wastestream depicted in Figure 2. These data show that treatment proposed for treatment to determine the true absorption claims for cadmium, copper, and lead were achieved. capacity of the system prior to Implementing the tech- The developer, however did not achieve treatment claims nology. for chromium. The treatment claim was based on com- paring the mean concentration of the raw influent to the Effective removal of cadmium, copper, and lead mean concentration of the final effluent. was achieved in the presence of a groundwater pH ranging from 3.1-3.8, a sulfate concentration of approxi- As shown in Figure 2, effective removal of chromium mately 20,000 mg/L, a TDS concentration of approxi- (based on the 50% claim) was achieved within the first 10 mately 23,000 mg/L, and disproportionately higher hr of operation until performance markedly decreased. concentrations of other cations such as magnesium (72 The decrease in removal efficiency could be the result of mg/L), potassium (82 mg/L), aluminum (149 mg/L), cal- the Sponge’s higher affinity for the other critical metals. cium (224 mg/L), and sodium (6,000 mg/L).The Although the cadmium claim was met based on the technology’s low affinity for these cations was supported overall effluent average, final effluent cadmium concen- by the near zero removal rates of these ions. Table 3 trations were below desired performance levels (107 ug/ presents a summary of data for the non-critical heavy L) at approximately the 61st hr of operation. This is due to metals. the lower than anticipated absorption capacity for cad- mium which resulted in saturation of the first two columns In addition to the regeneration of the small test col- within the test period. umns, the developer conducted regeneration tests in his laboratory on Sponge cubes taken from the demonstra- The technology had the greatest efficiency for cop- tion columns. Both tests showed that regeneration is fea- per. One column was sufficient to meet the developer’s sible for lead, copper, and cadmium. Regeneration of 90% removal claim for approximately 53 hr of the 72-hr chromium was evaluated only for the small test columns test. Copper concentrations for columns 2.3, and 4. were and showed only partial regeneration. at or near detection limits throughout the demonstration test. With regard to lead, three columns were sufficient to The cost to treat heavy metal contaminated ground- meet the developer’s 90% claim for approximately 61 hr water over a one year period with the Dynaphore, Inc. of the demonstration test. ForagerTM Sponge Technology is estimated at $340/1,000 gal. assuming the Sponges are not regenerated and are Although claims for cadmium and leadwere met, replaced upon saturation and $238/1,000 gal, assuming some of the columns became saturated withthese met- the Sponges are regenerated twice providing for three

Table 2. Treatment Performance for Critical Metals

Parameter 90% Confidence 90% Confidence 90% Confidence Developer’s Interval for Interval for Interval for Treatment Claim Avg. Influent Avg. Effluent Percent Removal (%) Conc. (ug/L) Conc. (ug/L) (%) Cadmium ~537f77 56* 13 9 +2.7_ 80 Chromium 426231 290*30 32 i5.8 50 Copper 917f 14 25?0 97rt.04 90 Lead 578 f 12 1823 97 f .59 9090

5 Figure 2. Final effluent-critical metals.

Table 3. Data Summary for Non-Critical Heavy Metals

Parameter Avg. Influent Conc. (ug/L) Avg. Effluent Conc. (ug/L) Avg. Total % Removal

Aluminum 149,000 152,000 -2 Arsenic 47.7 44.4 7 Barium 50.2 46.3 8 Beryllium 15.9 13.9 13 Calcium 224,000 248,000 -11 Cobalt 176 146 17 Iron 199,000 199,000 0 Lithium 460 473 -3 Magnesium 71,700 72,300 -1 Manganese 5870 5880 -1 Mercury 0.39 0.21 46 Nickel 378 107 72 Phosphorus 1520 557 63 Potassium 82,300 83,700 -2 Sodium 6,030,000 6,130,000 -2 Strontium 557 562 -1 Vanadium 1310 53.2 96 Zinc 1300 1190 9

6 useful treatment cycles. This cost estimate assumes ground- Potential in-situ applications, as previously discussed, water characteristics are similar to the demonstration may be promising. However, insufficient data is currently groundwater and cadmium, lead, and copper are treated available which demonstrates the viability of this treat- to demonstration performance claims utilizing a four-col- ment option. The effectiveness and cost of in-situ applica- umn, pump-and-treat unit similar to the demonstration tions have not been evaluated in this study nor has the unit. The system would operate 24 hr a day, 7 days a developer commercially utilized the technology in these week at a flow rate of 1 gpm resulting in a total treatment applications. EPA is, however, planning to conduct a volume of approximatley 525,000 gal. second demonstration which will evaluate the technol- ogy in an in-situ scenario. A significant portion of the cost is attributable to the frequent replacement or regeneration of the Sponges Disclaimer due to the limited absorption capacity for cadmium in this groundwater. The developer believes that a modifi- While the technology conclusions presented in this cation of the polymer may improve its overall adsorption report may not change, the data has not been reviewed capacity for the critical metals which would greatly aid in by the Quality Assurance/Quality Control Office. lowering treatment costs. Additionally, further cost reduc- tion may be achieved through the use of larger scale units which could handle higher flow rates (see below) Source of Further Information and the use of an industrial compactor to compact Sponges to lower disposal costs. EPA Contact:

Technology Status U.S. EPA Project Manager Carolyn Esposlto To date, this SITE demonstration represents the first full- U.S. EPA, (MS-106) scale use of this technology. The trailer mounted-unit was 2890 Woodbrldge Avenue built exclusively for this SITE Demonstration. This unit can Edison, NJ 08837 be modified to include additional columns of the same (908)906-6895 size. Additionally, a larger scale unit can also be con- structed. This unit uses larger columns and would be just as effective as the smaller system, but could operate at Technology Developer: approximately double the flow rate. Norman Rainer Dynaphore, Inc. has formed a liaison with a known Dynaphore, Inc. environmental remediation firm, Adtechs Corporation of 2709 Willard Road Herndon, VA, to provide the necessary expertise In per- Richmond, VA 23294 forming full-scale remediations at contaminated waste (804)288-7109 sites.

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