State Dry Cleaners Remediation Project Meeting
Holiday Inn Capitol
Washington, D.C.
April 13-14, 1999

WELCOME AND INTRODUCTIONS
Richard Steimle, Environmental Protection Agency (EPA), Technology Innovation Office (TIO)

Richard Steimle opened the meeting by welcoming participants (see Attachment A) to the first official State Dry Cleaners Remediation Project conference. He noted that representatives from eleven states were in attendance; all of these states have programs to fund dry-cleaner cleanup or have legislation for such programs pending. Steimle said that state representatives have communicated via conference calls during the last year (see http://drycleancoalition.org/) and that this meeting was being held so that representatives could communicate face-to-face about their future goals and group organizational structure.

OPENING REMARKS
Walter Kovalick, EPA, TIO

Walter Kovalick said that TIO is trying to promote the use of cost-effective innovative remediation technologies across a variety of programs. Using such technologies, he continued, is of particular benefit at small dry-cleaner sites where limited funding is often an issue. Kovalick said that many members of the State Dry Cleaners Remediation Project already recognize the merits of using innovative technologies--Kansas and Florida, for example, have already initiated demonstration projects. Kovalick said that TIO is eager to offer Project members further information and assistance to help promote their efforts. He provided a brief overview of some of TIO's services and partnerships.

Over the last 10 years, Kovalick said, TIO has identified barriers that prohibit more widespread use of innovative technologies. Poor communication between technology vendors, responsible parties, regulators, and consulting engineers, he said, is one major obstacle. In an attempt to rectify this problem, TIO acts as an information broker, collecting and distributing a wide variety of information:

• Potential markets for innovative technologies. In 1996, Kovalick said, TIO released a report to help technology vendors determine where they can sell their products. The report describes the future remediation market for sites associated with Superfund, RCRA, the Underground Storage Tank (UST) program, the Department of Defense (DOD), the Department of Energy (DOE), other federal agencies (e.g., the Bureau of Land Management), and state agencies. Although the report lists more than 200,000 sites, it is not comprehensive because it does not include brownfield sites, state voluntary program sites, or dry-cleaner sites.

• Soil treatment technologies that have been deployed at Superfund sites. Kovalick said that a wide variety of treatment technologies has been used at Superfund sites, ranging from established technologies (e.g., incineration and solidification-stabilization) to innovative technologies (e.g., bioremediation and flushing) and including technologies that are in a transitional phase between the two (e.g., soil vapor extraction [SVE] and thermal absorption technologies). TIO tracks trends in treatment technologies' application: over time, the use of incineration has decreased, but that of SVE and bioremediation has increased, with the latter leveling off in recent years. Interest in using in situ technologies has increased strongly since the 1980s because these technologies (1) do not require excavation, (2) do not cause worker or citizen exposures, and (3) are usually cheaper than ex situ technologies. (In 1982, 22 percent of remedial actions involved in situ technologies, but this number rose to 52 percent by 1997.)

• Ground-water treatment technologies that have been deployed at Superfund sites. Kovalick said that pump-and-treat has been chosen as the ground-water remedial option at 90 percent of Superfund sites. In situ technologies (e.g., permeable reactive barriers [PRBs] or solvent extraction) are rarely chosen, noting that such technologies were chosen as the sole treatment approach at only 5 percent of sites and as a supplement to pump-and-treat at an additional 5 percent of sites.

• Information on pilot and full-scale test projects. Kovalick said that TIO tracks information on innovative plume reduction/management technologies and source removal technologies. In the former category, much enthusiasm has been expressed for PRBs, phytoremediation, bioremediation, and natural attenuation. (Kovalick stressed that sites that use natural attenuation must be well-characterized and carefully monitored.) Less information has been collected on source removal technologies (e.g., oxidation, in situ flushing, and thermal heating), but a side-by-side demonstration project will be initiated at Cape Canaveral's Launch Pad 34 in the near future.

• Cost and performance data for site characterization and treatment technologies. Kovalick said that the Remediation and Characterization Innovative Technologies Web site (http://www.epareachit.org/) combines information from three databases: (1) TIO's Innovative Treatment Technologies (ITT), which summarizes project information for 900 projects; (2) Vendor Information System for Innovative Treatment Technologies (VISITT), which provides information on 371 technologies; and (3) Vendor Field Analytical and Characterization Technologies System (Vendor FACTS), which provides information on 160 technologies.

• Using innovative technologies as an option at brownfield sites. Kovalick said that TIO released the "Road Map to Understanding Innovative Technology Options for Brownfield Investigations and Cleanup."

• Case studies. Kovalick said that the Federal Remediation Technologies Roundtable (FRTR)'s Web site (see http://www.frtr.gov) has a database summarizing 140 case studies. Users can search the database by media, contaminant, or technology.

• Guidance on collecting cost and performance data. Kovalick said that FRTR has released a document to provide guidance on data collection. The document was written to standardize reporting efforts; Kovalick encouraged meeting participants to use it.

• Other organizations with useful information. Kovalick noted that there are several other organizations that offer useful information.

Kovalick strongly encouraged participants to visit http://clu-in.org. He said that much of the information that he discussed can be found on this site. In addition to acting as an information broker, Kovalick said, TIO has become directly involved with demonstration and deployment projects through its partnerships. He cited the Superfund Innovative Technology Evaluation (SITE) program and the Remediation Technology Development Forum (RTDF) as examples of partnerships. The latter was formed in 1992, he said, to identify what government and industry can do together to develop and improve environmental technologies that will address their mutual cleanup problems in the safest, most cost-effective manner. Kovalick said that seven RTDF Action Teams have been formed, each of which is autonomous. Activities undertaken by the RTDF Action Teams include sharing information during meetings and conference calls, pooling resources for demonstration projects, designing protocols, compiling bibliographies, generating technical reports, preparing peer-reviewed scientific journal articles, acting as "sounding boards," and licensing commercial products. (See http://www.rtdf.org.)

NATIONAL GROUND WATER ASSOCIATION (NGWA) OVERVIEW
Richard Steimle, EPA, TIO

Richard Steimle said that NGWA has agreed to provide training to Project participants and to reimburse them for their travel expenses at two meetings per year. He said that NGWA offers training in about 70 to 80 topics, and that they are willing to create customized courses. Robin Schmidt asked whether NGWA would be willing to provide regional training sessions targeted for state project managers, hydrogeologists, consultants, dry cleaners, and members of the fabric-care industry. Steimle said that the agreement established between TIO and NGWA only requires the latter to provide training to state-government representatives during their semi-annual meetings. He said that NGWA might be interested in holding training sessions for a wider audience, but that this effort would be conducted separately from the agreement that is currently established. Steimle agreed to talk to NGWA representatives to explore their interest level. Schmidt said that some members of the fabric-care industry might be interested in cosponsoring regional training sessions.

TECHNICAL PRESENTATIONS ON INNOVATIVE TECHNOLOGIES

Fracturing Enhancements
John Liskowitz, ARS Technologies

John Liskowitz stressed that in situ remediation technologies are often ineffective in low permeability areas simply because "tight" soil formations prevent the dispersion of treatment agents to contaminated areas. Liskowitz said that fracturing technologies can alleviate this problem by enhancing subsurface permeability and increasing a treatment agent's radius of influence. He said that the subsurface can be altered by injecting a compressed gas (nitrogen or air) into a bore hole (or well point) at pressures that break the cohesive stressors in a bedding plane. After the initial pressure is applied, he said, outward-spreading fractures can be generated by pushing a steady gas flow through the system for a short duration. Liskowitz stressed that fracturing technologies use low pressures that do not threaten the structural integrity of buried utilities. (He said that pressures of 150 psi are usually sufficient to initiate fracturing and that pressures usually drop to 10 psi 10 feet away from the bore hole.) Because the technology alters cohesive bonds, Liskowitz said, the channels created at most sites do not require sand props to prevent collapsing. (Liskowitz said that props are needed for only about 2 percent of sites--those with excessive swelling, where moisture content is not controlled.) Liskowitz briefly summarized costs associated with fracturing technologies, estimating that it costs about $5 to $7 to influence one cubic yard (yd³) of the subsurface.

Liskowitz said that fracturing technologies have been commercially available since 1991 and have been used at about 75 sites across the United States. They have successfully altered subsurface formations above and below the water table and along the capillary fringe in areas with fine sand, silts, clays, rocks, and fill material. Liskowitz said that fracturing can create radii of influence of about 20 to 40 feet in unconsolidated sediments and 30 to 60 feet in rocky areas. At one site, he said, the radius of influence tripled after fracturing was applied. Liskowitz said that fracturing has been used to increase subsurface permeability at the Tinker Air Force Base. He described the site briefly, noting that large quantities of No. 2 fuel oil were released to a subsurface consisting mostly of tight clays, sandstone, and siltstone. He said that the release caused a thick layer of product to form on top of the water table and that a skimming system was installed to remove it. The recovery system had limited effectiveness (with only 87 gallons removed over a 2-year period), so the subsurface was fractured to enhance recovery. Following this subsurface alteration, Liskowitz said, 1,450 gallons of product were extracted over a 1-month period and several thousand gallons have been removed in the months and years that have followed. (The system is still operational.) Liskowitz said that fracturing has also been used to alter the subsurface geology at a dry-cleaner site in Northern Virginia. At this site, he said, chlorinated solvents escaped via a floor drain to a fractured bedrock subsurface. The resulting contamination plume, he said, is about 150 feet by 300 feet in size and is migrating toward a nearby neighborhood. Liskowitz said that a pilot-scale fracturing study was performed at the site and the technology was shown to be useful. As a result, a full-scale demonstration project, coupling pneumatic fracturing with dual-phase vapor extraction, is planned for the near future.

As noted above, fracturing technologies involve applying pressure and injecting a steady gas flow. Building on these concepts, ARS Technologies has recently developed some new applications:

• PFE^® Enhanced Bioinjection System. Liskowitz said that biological inoculums (e.g., nutrient solutions or engineered microorganisms) can be used to remediate subsurface contaminants. The subsurface transport of these inoculums can be greatly enhanced by releasing them into gas streams and creating an atomized mist.

• FEROX_SMTechnology Iron Powder Injection. Liskowitz said that zero-valent iron can be used to dechlorinate contaminants. Several investigators have used zero-valent iron filings in PRBs, a technology where contaminated ground water passes through an iron-filled wall and then emerges clean on the other side. Although Liskowitz praised the success of PRBs, he pointed out that they are often limited to a depth of 20 feet and can be difficult to install near utilities and buildings. Additionally, he said, coatings of the iron filings often form because very large amounts of iron are needed to ensure that reactions take place as ground water passes through the narrow PRB walls (which are usually 6 inches to 1 foot thick). Liskowitz said that ARS Technologies has developed a technology that injects zero-valent iron powder directly into the ground. Using such an approach, he said, offers the following advantages over PRBs: (1) powder can be dispersed more widely and deeply, (2) a coating of iron particles does not occur due to the use of excessive iron, and (3) vadose source zones can be treated in the presence of moisture. (Liskowitz said that studies show that dehalogenation can occur when contaminants are in the vicinity of zero-valent iron and that direct contact between the contaminant and the iron is not required.) Liskowitz said that his company has generated data on the FEROX_SMtechnology for 2 years; information should be available by May 1, 1999, at http://www.arstechnologies.com.

In Situ Oxidation
Richard A. Brown, IT Corporation

Richard Brown said that dry-cleaner sites can be remediated by injecting oxidants into the subsurface. He said that in situ oxidation cleans sites to regulatory standards quickly (within days to weeks), efficiently (requiring one or two treatments only), and inexpensively (ranging from $150,000 to $300,000). Brown said that in situ oxidation can be used to treat a variety of contaminants, including phenols, aromatics (e.g., benzene, ethylbenzene, toluene, xylene, and polycyclic aromatic hydrocarbons [PAHs]), chlorinated solvents (e.g., trichloroethylene [TCE], tetrachloroethylene [PCE], dichloroethene [DCE], trichloroethane [TCA], and vinyl chloride), ethers, ketones, pesticides, polychlorinated biphenyls, and inorganics. Oxidation rates can be controlled by controlling the amount of oxidant added.. Several factors must be considered, Brown said, when determining how much oxidant is needed for remediation at a given site. There must be enough to account for the amounts used during the following reactions:

• Oxidation of contaminant. Brown said that the equivalent weight of contaminants and oxidants can be calculated by balancing chemical equations. After this is completed, the stoichiometric oxidant demand can be calculated by dividing the equivalent weight (EW) of the oxidant by the EW of the contaminant. The lower the latter is, Brown explained, the more oxidant will be required. Brown provided the EW for several chlorinated solvents, fuel components, and PAHs.

• Oxidation of native metals and organic compounds. Brown noted that iron, manganese, arsenic, carbon monoxide, methane, acetate, and nonidentified biological byproducts are commonly present in soil materials. All of these elements/compounds, he said, consume oxidants.

• Decomposition. Brown said that some oxidants decompose readily. For example, hydrogen peroxide, ozone, and permanganate decompose at fast, moderate, and slow rates, respectively.

Several oxidants exist, Brown noted, and contaminants react to each differently. Brown presented tables summarizing the reactivity of different oxidants for particular contaminants and described the three oxidants that are commercially available:

• Hydrogen peroxide. Brown said that hydrogen peroxide has a molecular weight (MW) of 34 grams, an EW of 17 grams, and is commercially available in 30-percent and 50-percent solutions. The oxidant is clear, miscible in water, and can be applied via wells and geoprobes. The oxidant is highly corrosive, Brown warned, and great care should be employed when using it. Hydrogen peroxide can generate tremendous amounts of heat. Subsurface steam stripping can be induced when it is used at high concentrations in conjunction with iron and a catalyst. Brown said that the amount of hot gas produced during these reactions can be dangerous--at one site, the ground caught on fire. Brown said that some investigators are experimenting with lower concentrations (5 to 8 percent) of hydrogen peroxide.

• Ozone. Brown said that ozone has a MW of 48 grams, an EW of 24 grams, and can be generated from air or oxygen sources. (He said that it is often more cost-effective to generate ozone on site at large sites where large oxidant quantities are required.) The oxidant is a colorless gas with a solubility of 600 mg/L at 20 degrees Celsius (ºC). To date, Brown said, ozone has been used mostly as a polishing tool. (At three sites, air sparging was used until contaminants reached a plateau. Then ozone was injected to further decrease contaminant levels to concentrations below drinking-water standards.)

• Permanganate. Brown said that permanganate is commercially available in two forms, potassium manganate (with a MW of 158 grams and an EW of 52.6 grams) and sodium manganate (with a MW of 141.9 grams and an EW of 47.3 grams), both of which can be injected through wells and geoprobes. Permanganate is purple and leaves a pink color in water when present at concentrations of about 0.5 parts per million (ppm). (Brown said that some regulators are concerned about creating discolored water, but that permanganate can be easily reduced.) In laboratory experiments, potassium manganate has been shown to destroy nonaqueous phase liquids (NAPLs). In field studies, it has been shown to reduce contaminant concentrations. Strong evidence indicates that the potassium ion helps desorb contaminants from clay materials.

Brown provided some cleanup cost estimates for a hypothetical 1-acre site, with 20 feet of thickness, and 1 ppm of TCE. He said that costs associated with each oxidants would be: ozone ($269,000), potassium manganate ($136,000), sodium manganate ($187,000), and hydrogen peroxide ($201,000). Brown closed his discussion by bringing up some of the issues that must be addressed or considered before in situ oxidation is more widely accepted. First, he said, several safety considerations must be taken into account when using oxidants because they are corrosive materials that often decrease the lower exposure limit of combustible material. Also, he said, some regulators are concerned that using large quantities of oxidants will plug up subsurface formations. Lastly, he said, more research is required to determine how microbial activity is effected by oxidants. Brown said that permanganate kills microbes, but that it is unclear how far-reaching the effects are.

Surfactant and Cosolvent Flushing
Michael Annable, University of Florida

Michael Annable said that subsurface NAPLs can be solubilized and/or mobilized by flushing surfactants or cosolvents into the ground. This form of in situ flushing, he said, effectively removes contaminant masses from source zones. He said that the technology is unlikely to eradicate source areas completely and that it cannot be used to remediate migrating plumes. He recommended using it at the front end of a treatment train and following up with a polishing technology or a plume-targeting technology. (At all sites, Annable said, investigators must determine whether complex remediation or simple monitoring is required. At sites that pose high risks, remediation is often chosen. By removing the bulk of a contaminant source, however, flushing technologies may be able to transform high-risk sites to low-risk sites. Once the risk falls, regulators may be more willing to allow site owners to use monitored natural attenuation as a follow-up.) Annable said that in situ technologies work best in homogeneous environments, but that they can also be used in heterogeneous environments. At the latter, he said, fracturing technologies or a flow-interruption-type system can be used to enhance subsurface transport.

Annable said that several researchers are using surfactants and cosolvents in flushing demonstration projects. He recently participated in a cosolvent flushing pilot study at Sage's Dry Cleaners, an abandoned site located in Jacksonville, Florida, that is underlain by fine sands and a 3-meter-deep water table. Annable said that extensive characterization tests (including soil core analysis and partitioning tracer tests) were conducted to determine the extent and spatial distribution of contaminants. The results indicated that a PCE source zone, with dense nonaqueous phase liquids (DNAPL), was present at depths of 8 to 9½ meters. Annable said that the contaminant distribution was uneven, with DNAPL pools forming in the areas with the finest sand. Once the source zone was delineated, 9,000 gallons of ethanol were mixed with water, injected into three injection wells, flushed through the subsurface, and extracted through six recovery wells. (The recovery wells were installed in a circle around the injection wells to optimize alcohol recovery; investigators were confident that this setup would work because it was tested prior to the flush with a partitioning tracer test.) Annable noted that large quantities of flushing agents were required because of the uneven spatial distribution of the contaminants. He said that many clean areas were flushed in an effort to target narrow contamination zones. The flush was performed over a 3½-day period and succeeded in extracting about 80 percent (or 45 liters) of DNAPL. Once above ground, Annable said, the recovered fluids were passed through a macroporous polymer system to separate the PCE from the alcohol and water. All materials were then disposed of off-site. A full-scale flushing demonstration project will be installed in the near future to remove the remaining 20 percent of the contaminant source.. In the interim, Annable said, researchers will determine how beneficial the pilot study was by evaluating whether PCE concentrations decreased in downgradient wells once the bulk of the source was removed. Researchers will also evaluate whether residual ethanol (a carbon source) will enhance microbial degradation processes. Since performing the flush, Annable said, biodegradation byproducts have started to appear.

Annable said that it cost about $400,000 to conduct the pilot study at Sage's Dry Cleaner. About $150,000 of this total, he said, was used to conduct pre- and post-flush partitioning tracer tests, $100,000 to $150,000 was used for above-ground waste disposal, and $25,000 was used to purchase the cosolvent. Annable said that the above-ground disposal costs and the cosolvent costs could be reduced substantially by recycling and reinjecting the cosolvent. This approach was used at the Dover Air Force Base: cosolvents were reinjected to the subsurface after being treated with a technology that used air stripping and activated carbon. Annable said that recycling and reinjecting cosolvents has a dramatic impact on economics, but that regulators are often reluctant to allow reinjection if materials contain residual PCE concentrations above maximum concentration levels (MCLs).

Thermal Treatment
Greg Beyke, Current Environmental Solutions

Greg Beyke said that thermal treatment technologies reduce subsurface NAPL concentrations by transforming the NAPL into a steam that can be easily extracted. He said that a variety of methods (e.g., injecting hot air or steam) can be used to heat subsurface soils, but that his company advocates using the six-phase heating approach. With this approach, he said, several electrodes are installed and used to transfer electric current to surrounding subsurface areas. He said that multiple current pathways are established between the electrodes, creating a situation where the subsurface is heated uniformly, steam is generated in situ, and microfractures are created in surrounding soils. Unlike other technologies, he said, the six-phase technology performs effectively in heterogeneous areas because it does not rely on advective transport. Beyke noted that much of the steam created in situ is created by volatilizing contaminants. (Raising the subsurface to 89ºC can cause PCE to volatilize.) He said that contaminant-laden steam is removed from the subsurface via extraction wells and captured in off-gas treatment systems. In some cases, Beyke noted, the electrodes, which are often made out of hollow graphite or steel-shot pipes, serve as the extraction wells.

Beyke said that each six-phase electrode formation consists of a circle of six electrodes that surround one central electrode. He said that each array usually spans a 30-foot diameter, but that his company hopes to expand the diameter to 40 to 60 feet in the near future. Conventional utility power is used to stimulate the electrodes; the frequency required [60 Hertz] does not interfere with radar systems. Each electrode, Beyke said, is surrounded by an electrical insulator. (In arid environments, some moisture must be added at the soil-electrode interface.) Beyke said that the electrodes operate efficiently over a wide range of climates. In fact, his company has used the technology in Fairbanks, Alaska, at a site with an 8-foot-deep permafrost layer. Beyke said that electrodes are typically installed to the depth at which contaminants are present. In some cases, however, researchers choose to heat areas below the contaminants to create a thermal barrier that prevents downward contaminant migration. Even when this precaution is not taken, Beyke noted, the six-phase heating approach poses less risk of inadvertent contaminant migration than technologies that use gas or fluid injections. Beyke said that the six-phase heating approach does not pose harm to the public; his company does not use voltages higher than 15 in areas with public access. Subsurface heating can cause some structural damage to plastic utility lines, he noted, but has little impact on those made of steel or other metal.

Beyke said that Current Environmental Solutions recently initiated a demonstration project, using 28 electrodes, four horizontal extraction wells, and a vapor collection/treatment chamber, at a brownfield dry-cleaner site in Seattle, Washington. He said that the system has been operating for about 1½ months, and that data will be available in the near future to show how effectively the technology is performing. (At most dry-cleaner sites, Beyke said, remedial objectives will likely be met over a 1- to 2-month period.) Beyke said that this particular dry cleaner site is larger than most and will cost about $200,000 to remediate. (This estimate includes costs associated with permitting, work plan development, electrical power, and installation, but does not include site characterization costs.) In general, Beyke said, achieving a 99-percent contaminant reduction using six-phase heating technology costs about $100,000 plus $30/yd³. Using this rough estimate, he generalized, six-phase heating is more cost-effective than excavation at sites that are more than 1,500 yd³ in size. (The cost of electricity constitutes about 25 percent of the total cost. On average, heating the vadose zone requires $7.5/yd³ and heating an aquifer requires $8.4/yd³.)

Beyke said that the six-phase heating technology was recently used at a site in Illinois, where the subsurface geology consists of saturated silts and clay zones and the water table is located about 7 feet below ground. In 1991, he said, a DNAPL pool, consisting of TCA, TCE, PCE, and cis-DCE, formed about 18 feet below the site. In an attempt to remediate contamination, he said, a SVE was installed and low-input steam injections were used. These approaches only had limited success, however. In 1998, Current Environmental Solutions initiated a full-scale six-phase heating project at this site, using a total of 107 electrodes over two-thirds of an acre. After operating the system for 18 weeks and 5 days, contaminant concentrations fell below risk-based cleanup levels. Concentration averages from seven of the most contaminated wells, Beyke said, indicated that TCA concentrations fell by 99..9 percent and TCE concentrations fell by 99.1 percent. Reductions in cis-DCE concentrations (97.9 percent) were slightly less dramatic, he noted, because much of the TCA was biodegraded to cis-DCE. Beyke said that thermal heating stimulates biodegradation processes.

Hydrogen Release Compounds (HRC) and Oxygen Release Compounds (ORC) for Chlorinated Solvent Degradation
Donald Ochs, Regenesis

Donald Ochs said that microorganisms effectively degrade chlorinated solvents through anaerobic reductive dechlorination. During this process, he said, PCE is converted to TCE, then to cis-DCE, then to vinyl chloride, then to ethene. The last of these is fairly non-toxic. Each conversion, he said, involves substituting a hydrogen for a chloride; the availability of hydrogen often limits conversion rates. To enhance reductive dechlorination processes, therefore, Regenesis has created a long-lasting, time-release hydrogen source that can be injected into the ground. Their product, HRC™, is a polylactated ester, consisting of sugar molecules with several attached lactic acids. When HRC™ contacts water, lactic acids are released over a 6-month to 2-year period. Ochs said that the lactic acids promote anaerobic conditions, and that hydrogen is released as fermentation processes degrade lactic acid to acetic acid. Ochs said that HRC™ addresses ground-water plumes rather than source areas and is useful at sites that already show evidence of reductive dehalogenation processes. Sites that fit this description, he said, are those that have (1) low oxygen and nitrate concentrations, and (2) measurable concentrations of hydrogen sulfide, methane, and daughter products (e.g., cis-DCE, vinyl chloride, and ethene). He said that HRC™ can be injected via geoprobes and pushed into contaminated zones using pressures up to 15,000 psi. The slurry that emerges into the subsurface, he said, typically extends over 3 to 10 feet and then travels further via advective processes.

Anaerobic degradation of PCE, TCE, and cis-DCE causes the accumulation of vinyl chloride, a highly toxic compound. Ochs said that vinyl chloride can be degraded aerobically via metabolic and cometabolic processes. If vinyl chloride accumulates at a site, ORC^®, an oxygen-releasing product, can be injected to promote aerobic conditions. Ochs said that Regenesis' ORC^® consists of a magnesium peroxide that is in a powdered form. The product can be mixed with water, he said, and injected into the subsurface via geoprobes.

Ochs said that Regenesis has tested their HRC™ and ORC^® products extensively in laboratory bench-scale projects and aquifer simulation vessels. Additionally, several pilot and full-scale projects have been initiated in the field. (The full-scale projects are located at DOD facilities, dry-cleaning facilities in Florida and Washington, and manufacturing sites.) Ochs spoke briefly about Regenesis' work at a dry-cleaner site in Wisconsin. At this site, he said, HRC™ has reduced PCE concentrations by 80 percent over a 10-month period. Over this same time period, Ochs said, temporary increases of TCE and cis-DCE were observed as different compounds degraded into different forms. He said that concentrations of vinyl chloride and ethene have increased at this site and that ORC^® will be used to reduce the vinyl chloride rapidly. Ochs said that dramatic success was demonstrated using HRC™ at a site in Watertown, Massachusetts. At this site, he reported, TCE concentrations were reduced from 13,000 ppm to less than 100 ppm over a 180-day period. Ochs said that similar success stories are documented in research papers, several of which will be presented at the April 1999 Battelle conference in San Diego, California. Ochs said that additional information on Regenesis' products can be obtained at http://www.regenesis.com. He encouraged participants to visit this Web site, noting that it includes a 3-page form that site owners can fill out to determine whether Regenesis' technologies could be useful at their site.

Ochs said that very little work has been performed to estimate the costs associated with using HRC™. He estimated that it would cost about $50,000 to remediate a half drum of spilled PCE, assuming that the spill created a 180-foot by 20-foot zone of a TCE/PCE mixture at 8,000 parts per billion (ppb). (He said that two injections would be needed to remediate a half drum of PCE and estimated that each injection would cost $10,000 and the amount of product required for each injection would cost $15,000.) Ochs said that he has made some preliminary comparisons between Regenesis' HRC™ technology and other innovative technologies; the costs appear to be in the same ballpark.

Ochs concluded his talk by stressing that Regenesis' products may be very useful at dry-cleaner sites because the technologies are passive, do not interfere with daily business operations, require minimal space (about 2 parking spaces), and are easy to use in residential areas without causing panic. He said that all of the equipment used is located underground, leaving little concern that equipment can be stolen or tampered with. He said that several programs have been established to promote the types of technologies that Regenesis offers, including:

• Incentives under New Jersey's brownfield program. Ochs said that site owners can submit "Applications of Destructive Technologies" and "Applications of Certified Innovative Technologies." Under each of these grants, Ochs said, site owners can obtain reimbursement for 25 percent of remedial costs. (He said that each grant has a ceiling of $100,000 per site.)

• Air emissions credits. Ochs noted that Regenesis' technologies do not consume energy. He said that the New Jersey Air Quality Act allows site owners to claim credits when they use remediation technologies that do not produce sulfur dioxide, nitrogen oxides, or volatile organic compounds.

COST ESTIMATING/CONTRACTING ROUNDTABLE
Robert Jurgens, Kansas Department of Health and Environment (KDHE)
Dick DeZeeuw, Oregon Department of Environmental Quality

Robert Jurgens provided a brief summary of some of the cost estimating and contracting approaches that are used in Kansas. He distributed a packet that included (1) information on Kansas' priority ranking system, (2) KDHE's work orders, and (3) KDHE's cost estimate sheets for labor, equipment, and laboratory analysis. The packet also provided information on how KDHE establishes agreements with their contractors. Jurgens said that contracts are competitively bid before KDHE chooses a primary and secondary contractor. (The secondary contractor receives work assignments only if the primary contractor fails to perform adequately.) Contracts established between KDHE and their contractors cannot exceed a 3-year period and all of the contractor's overhead costs must be built into their task cost. (No consultant project management fees are allowed.) Jurgens talked briefly about site assessments, noting that KDHE has been involved in 13 Expanded Site Assessments for dry-cleaner sites. At most of these sites, he said, some site investigatory work had been performed previously. The number of new probes or samples that had to be collected at each varied significantly. On average, he said, site characterization costs about $32,000 per site. Before closing, Jurgens talked about some of the remedial approaches that have been used at dry-cleaner sites in Kansas. He said that eight SVE systems have been installed, three KV Associated C-Sparger^® (an ozone treatment) systems have been installed, and an AAS/SVE system is under construction. He said that municipal packed tower systems have also been utilized in Kansas.

Dick DeZeeuw provided a brief summary of some of the cost estimating and contracting approaches that are used in Oregon. He distributed a packet that included information on (1) the first four site assessments conducted under Oregon's funding program and the budget associated with each (costs ranged from $31,000 to $56,000), (2) site-specific budgets and work proposals for a specific dry-cleaner remediation effort, and (3) cost projections for additional dry-cleaner sites. DeZeeuw said that Oregon and Kansas use similar approaches to track costs and establish contracts. He did point out, however, that Oregon typically uses three contractors at a time rather than just one. DeZeeuw said that his department just tracks contractor costs, but that he is very interested in instituting a tracking system that captures his department's internal costs. He asked meeting participants to forward suggestions to him.

CLEANUP ASSESSMENTS--FLORIDA'S EXPERIENCE
William Linn, Florida Department of Environmental Protection (DEP)

William Linn noted that there are 1,600 registered dry cleaners in the state of Florida and that 1,564 have applied to participate in the state's dry-cleaner cleanup fund. Linn said that site assessments have been performed at about 100 sites, 30 of which are currently being evaluated. When performing site assessments, Linn said, Florida's DEP has (1) utilized existing data and monitoring wells when possible, (2) minimized the number of site mobilizations, (3) minimized waste generation, (4) streamlined data management and reporting, and (5) developed and maintained good communications between contractors, and property owners. Linn strongly encouraged participants to draw facility maps showing where machines are (or were) located at a site. Sampling points should be collected directly under these machines, he advised. He told participants that their dollars will be most wisely spent if they concentrate on delineating source zones more thoroughly than plume areas. Linn dedicated the bulk of his talk to discussing sampling approaches and site-specific contamination issues. He noted that Florida has benefited greatly by using mobile laboratories.

WORKING WITH THE INTERSTATE TECHNOLOGY REGULATORY COOPERATION (ITRC)
Brent Hartsfield, Florida Department of Environmental Protection

Brent Hartsfield said that it may be useful to collaborate efforts with ITRC, an organization that creates tools and strategies to reduce interstate barriers to the development of new, useful, environmental technologies. Hartsfield noted that there are several working groups within ITRC, each of which focus on a different technology. As a member of the DNAPL Remediation working group, Hartsfield said, he has been reviewing available documents on technologies that remediate DNAPL. (He advised Project participants to obtain a copy of John Fountain's paper on this topic.) Hartsfield strongly encouraged other participants to become involved with ITRC, noting that the organization helps defray travel expenditures when representatives from new states agree to join.

MISCELLANEOUS TOPICS

Dick DeZeeuw distributed the 1998 Dry Cleaner Annual Hazardous Waste and Air Compliance Report Booklet. Over the next month, he said, his agency plans to visit all of the dry-cleaner sites in Oregon to see how well they comply with regulations and best management practices.

Dale Trippler distributed a copy of Minnesota's Dry Cleaner Fund questionnaire, a form that was sent to about 400 dry cleaners in Minnesota to seek their input on ways to improve the administration of the state's cleanup funding program. Trippler said that he received 75 responses and learned the following: (1) the majority of respondents want to move the due date for annual fees to October, (2) owners who operate large businesses are content basing fees on Full Time Equivalent (FTE) employees, but owners of small businesses want to explore other fee structures, and (3) the majority of respondents do not want to move toward a gross receipt fee system.

ORGANIZATIONAL ISSUES
Carolyn Perroni, Environmental Management System, Inc. (EMS) (facilitator)

Carolyn Perroni asked participants to decide what they want to accomplish as a group, how they want to organize themselves, who should lead their efforts, and when they want to meet their goals. Project members decided to separate into Subgroups after they identified topics that need to be addressed. Each Subgroup will discuss a subset of issues during Subgroup conference calls, and will report on their progress during Project conference calls and meetings. Three Subgroups were formed:

Program Development/Administration Subgroup
Subgroup leader: Dick DeZeeuw (Oregon)
Other Subgroup members: Tim Steele (Arizona), Leo Henning (Kansas), Dale Trippler (Minnesota), Tim Eiken (Missouri), Bruce Nicholson and Lisa Taber (North Carolina), Robin Schmidt and Leslie Gauberti (Wisconsin)

The Program Development/Administration Subgroup said that they plan to examine each state's dry-cleaner cleanup fund program, monitor and share information on "Pilgrim-like" lawsuits, and define "technical impracticability" standards. The Subgroup identified four action items:

• Assess fees and revenues. As part of this task, the Subgroup will compare fee structures across states and evaluate whether revenue expectations are being met. (Dick DeZeeuw said that most states are only meeting about 60 percent of their expectations.) Also, this Subgroup will evaluate whether dry cleaners are able to pay their fees without jeopardizing their businesses.

• Compare the elements of each state's program. Subgroup members said that this comparison will focus primarily on administrative budgets.

• Track project cost control. The Subgroup will track project-related costs and evaluate incentives for cost effectiveness (e.g., paying for performance).

• Track legislative regulations/issues. The Subgroup will list Fund-related issues that are arising in each state and discuss how each is being handled. By creating such a resource, DeZeeuw explained, the Subgroup will serve as a "sounding board" for new states that are developing legislation.

DeZeeuw said that the Subgroup will choose a schedule for implementing their action items during future conference calls. He said that the Subgroup does not plan to use contractors during information-gathering stages, but that it will ask for help formatting the information and posting it on the Project's Web site. Subgroup members noted that some of the cost information might need to be restricted to a password-protected area of the Web site. (Richard Steimle agreed to talk to EMS about establishing a password-protected area.)

Project Management/Technical Issues Subgroup
Subgroup leader: William Linn (Florida)
Other Subgroup members: Brent Hartsfield (Florida), Bob Jurgens (Kansas), Dave Anderson (Oregon), Bruce Nicholson (North Carolina), Craig Dukes and Mark Whittle (South Carolina)

The Project Management/Technical Issues Subgroup said that they will focus their efforts on learning more about which remediation technologies have been used at dry-cleaner sites. The Subgroup also plans to discuss presumptive remedies, the pros and cons associated with establishing a national cleanup standard, and ways to optimize assessment. The Subgroup identified three action items:

• Develop and distribute a project management/technology questionnaire. The Subgroup will distribute an internal questionnaire to the states that are currently participating in the Project. The survey will ask state representatives to provide information on innovative technologies that are being used at dry-cleaner sites. William Linn said that the questionnaire will be developed and distributed within 3 months and that results should be available by the end of August 1999. He said that he will talk to Steimle about how to include contractors in this effort.. At a minimum, he said, the Subgroup will ask for assistance tabulating and formatting the survey's responses.

• Gather information from states. The Subgroup will gather information from participating states on how their programs are run, what cleanup criteria are used, and whether guidance documents are available. Linn said that the Subgroup has not yet decided how they will collect this information. One Subgroup member recommended distributing a survey, but another thought a simpler polling method might be adequate.

• Develop 1-page summaries describing remedial technologies at each dry-cleaner site. This Subgroup will provide information on the remedial technologies that are being used at dry cleaners. Linn said that the Subgroup will need support from contractors to compile 1-page summaries for distribution on the Project's Web site.

Steimle asked the Subgroup to write a 1-paragraph summary explaining how they would like contractors to assist in their action items.

Outreach Subgroup
Subgroup leader: Robin Schmidt (Wisconsin)
Other Subgroup members: Julie Kelsey (Missouri), Scott Stupak (North Carolina), Clarence Cothran and James Gilbert (Tennessee)

The Outreach Subgroup said that they will develop communication tools and distribute information on PCE and stoddard health effects. Also, they will discuss how to (1) encourage other states to join the Project, (2) communicate with industry organizations, (3) expand the Project's Web site, and (4) set states up as a liaison for disseminating information on federal grants and other funding assistance. At this point, the Subgroup identified three action items:

• Set up a conference call with EMS to discuss the Project's Web site. This Subgroup will talk to EMS about expanding and updating the Web site. The Subgroup may ask EMS to provide links to each state's Web site and to establish a password-protected chat room.

• Describe ways to disseminate information. The Subgroup will make recommendations on ways to facilitate communication between state-government representatives and affected communities (e.g., dry cleaners). As part of this effort, the Subgroup will identify links with fabric-care associations and will initiate communication between Project participants and the associations. The Subgroup will also instruct state-government representatives on how to use the Project's Web site to disseminate information.

• Compile information on health effects. Clarence Cothran said that he plans to compile a bibliography on health effects that result from PCE and stoddard exposures. He said that he has a useful source that will allow him to initiate this effort. Meeting participants recommended that he visit ATSDR's Web site and different state Web sites for additional references.

This Subgroup said that it could make significant headway on all three of their action items within the next 3 months.

CLOSING REMARKS
Richard Steimle, EPA, TIO

Richard Steimle thanked participants for attending the meeting and asked them to start thinking about when and where the next meeting should be. He said that participants may want to consider having it in conjunction with another conference, such as the ITRC, NGWA, or Association of State and Territorial Solid Waste Management Officials (ASTSWMO) conference. (Steimle said that participants can find information on other national conferences by visiting the CLU-IN and TechDirect Web sites.) Steimle said that the next Project conference call will be held on June 2. Conference call participants should be prepared to choose a location for the next meeting at that time. Also, Steimle said, Subgroup leaders will be asked to report their progress on action items.

Attachment A: Final Attendee List

State Dry Cleaner Remediation Project Meeting
Holiday Inn Capitol
Washington, DC
April 13-14, 1999>