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Decision Trees for in Situ Bioremediation of Nitrates, Carbon Tetrachloride, and Perchlorate

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Decision Trees for in Situ Bioremediation of Nitrates, Carbon Tetrachloride, and Perchlorate A SYSTEMATIC APPROACH TO IN SITU BIOREMEDIATON IN GROUNDWATER Including Decision Trees for In Situ Bioremediation of Nitrates, Carbon Tetrachloride, and Perchlorate ABOUT ITRC Established in 1995, the Interstate Technology and Regulatory Council (ITRC) is a state-led, national coalition of personnel from the regulatory and technology programs of some 40 states and the District of Columbia; three federal agencies; and tribal, public, and industry stakeholders. The organization is devoted to reducing barriers and speeding interstate deployment of better, more cost-effective, innovative environmental technologies. Various tools have been developed and services provided by ITRC to accomplish this goal. ITRC Technical/Regulatory Guidelines, each of which deals with a specific type of technology, enable faster, more thorough reviews by state agencies of permit applications and site investigation and remediation plans for full-scale deployment of such technologies. Use of these documents by states in their regulatory reviews also fosters greater consistency in technical requirements among states and results in reduced fragmentation of markets for technologies caused by differing state requirements. Those who conduct and oversee demonstrations and verifications of technologies covered by ITRC Technical/Regulatory Guidelines will also benefit from use of the documents. By looking ahead to the typical technical requirements for permitting/approving full-scale deployment of such technologies, they can collect and evaluate information to facilitate and smooth the permitting/regulatory approval process for deployment. ITRC also has developed products in the categories of Case Studies and Technology Overviews (including regulatory information reports, state surveys, closure criteria documents, and formats for collection of cost and performance data); provided state input into other complementary efforts; and worked on approaches to enable state regulatory agencies to accept performance data gathered in another state as if the testing had been done in their own state. More information about ITRC and its available products and services can be found on the Internet at www.itrcweb.org. DISCLAIMER ITRC does not endorse the use of, nor does it attempt to determine the merits of, any specific technology or technology provider through publication of any ITRC documents; nor does it assume any liabilities with respect to the use of, or for damages resulting from the use of, any information, apparatus, method, or process discussed in this document. Mention of trade names or commercial products does not constitute endorsement or recommendation of use. These documents are designed to help regulators and others develop a consistent approach to their evaluation, regulatory approval, and deployment of specific technologies at specific sites. The Internet Web sites referenced in this document may become outdated or be changed over time. A Systematic Approach to In Situ Bioremediation in Groundwater Including Decision Trees for In Situ Bioremediation of Nitrates, Carbon Tetrachloride, and Perchlorate August 2002 Prepared by Interstate Technology and Regulatory Council In Situ Bioremediation Team Copyright 2002 Interstate Technology and Regulatory Council This page intentionally left blank. ACKNOWLEDGMENTS The members of the Interstate Technology and Regulatory Council (ITRC) In Situ Bioremediation Team wish to acknowledge the individuals, organizations, and agencies that contributed to this guidance document. The In Situ Bioremediation Team effort, as part of the broader ITRC effort, is funded primarily by the U.S. Department of Energy (DOE). Additional funding and support has been provided by the U.S. Department of Defense (DoD) and the U.S. Environmental Protection Agency (EPA). Administrative support for grants is provided by the Environmental Research Institute of the States (ERIS), a nonprofit educational subsidiary of the Environmental Council of the States (ECOS). The Western Governors’ Association (WGA) and the Southern States Energy Board (SSEB), who previously held secretariat duties for ITRC, remain involved. The team recognizes the following states’ support of team leadership and guidance preparation: • New Mexico Environment Department, Bart Faris – Team leader • North Dakota Department of Health, Kris Roberts – Subteam leader • Missouri Department of Natural Resources – Candice McGhee • Oklahoma Department of Agriculture – Jim Shirazi • Colorado Department of Public Health and Environment – Clay Trumpolt • Kansas Department of Health and Environment – Donna Porter • Virginia Department of Environmental Quality – Hassan Vakili • New Hampshire Department of Environmental Services – Fred McGarry The team also recognizes the exemplary efforts of Dr. Eric Nuttall from the University of New Mexico and Dr. Roy Spalding from the University of Nebraska. We also wish to thank industry representatives, who bring the necessary pragmatism and guidance to the team, including Dupont, MSE, Envirogen, Burns and McDonnell, Geotec, Profind, EnviroMetal, Papadopoulos and Associates, Concurrent Technologies Corporation, Research Triangle Institute, and Aerojet and Bioprocess. Other unnamed members also contributed valuable perspectives with their advice throughout the project. The U.S. Department of Defense added several perspectives, including those of Goeff Cullison from the Navy, and few ITRC guidance documents have been without the tireless support of Linda Fiedler from the Technology Innovation Office of EPA. Los Alamos National Laboratory and Sandia National Laboratories contributed research and case study information. Thanks also to Steve Hill, ITRC program advisor and president of RegTech, Inc., for urging constant progress during development of the guidance and assisting wherever necessary. As she did with the Enhanced In Situ Biodenitrification Technology Overview, Anne Williams Callison added the perspective of the community stakeholder to the guidance. Lastly, without the leadership, common sense, and enthusiastic drive of Bart Faris (New Mexico) and his Perchlorate Subteam Leader Kris Roberts (North Dakota), this guidance would not have been prepared. They spent many hours of their own time researching the literature, writing sections of the report, reviewing drafts, and planning conference calls and meetings. They are the cohesive force of the team, and the substance of the guidance is much better due to their efforts. i This page intentionally left blank. ii EXECUTIVE SUMMARY Applications submitted to regulatory authorities containing in situ bioremediation have not been prepared nor evaluated using a consistent and accepted suite of parameters. The ITRC In Situ Bioremediation (ISB) Team prepared this document to provide guidance for the systematic characterization, evaluation, and appropriate design and testing of ISB for any biotreatable contaminant. It serves as guidance for regulators, consultants, responsible parties, and stakeholders when an ISB technology is considered. The ISB Team is composed of eight state environmental agencies (New Mexico, North Dakota, Missouri, Oklahoma, Colorado, New Hampshire, Kansas, and Virginia), three federal agencies (DOE, DoD, and EPA), 12 companies, two universities, and public stakeholders. ITRC has produced a number of products related to ISB, which are available at ITRC’s Web site (www.itrcweb.org). Bioremediation is the application of biological treatment to the cleanup of contaminants in groundwater. Bioremediation melds an understanding of microbiology, chemistry, hydrogeology, and engineering into a cohesive strategy for planned and controlled microbial degradation of specific classes of organic compounds and in certain instances, inorganic compounds. This assemblage of science and engineering requires a rigorous degree of data evaluation to determine the effect and efficiency of bioremediation. In situ bioremediation creates subsurface environmental conditions, typically through oxidation- reduction manipulation, which induce the degradation of chemicals (i.e., the target chemical) via microbial catalyzed biochemical reactions. In turn, the microbes produce enzymes that are utilized to derive energy and that are instrumental in the degradation of target chemicals. To accomplish this chain of events, the following aspects must be considered: • type of microorganisms, • type of contaminant, and • geological conditions at the site. Since in situ conditions are manipulated by engineered means, the most important consideration is the ability to transmit and mix liquids in the subsurface. In response to ITRC’s and California’s requests for clarification of RCRA, EPA’s director of the Office of Solid Waste clarified EPA’s policy on the injection of contaminated groundwater by explaining that reinjection of treated groundwater to promote in situ treatment is allowed under 3020(b) as long as…the groundwater is treated prior to reinjection; the treatment is intended to substantially reduce the hazardous constituents in the groundwater before or after reinjection; the cleanup must be protective; and the injection must be part of a response action under CERCLA or RCRA. In addition, if the injected fluid contains a hazardous waste, and the fluid is being injected into an aquifer, an exception to the usual prohibition of Class IV Underground Injection Control wells is available for CERCLA and RCRA cleanups. The ISB Team of ITRC concludes from the reviews conducted as part of this project, there are no regulatory
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