Surfactant Injection for Ground
Water Remediation:
State Regulators' Perspectives
and Experiences
U.S. Environmental Protection Agency
Technology Innovation Office (5102W)
EPA 542-R-95-011
December 1995
Preface
This report is based on a series of interviews with State regulators involved in the review and
approval of applications for demonstrations or applications of surfactant technologies for the
remediation of contaminated ground water. Treatment of aquifers contaminated by non-aqueous
phase liquids (NAPLs) by traditional pump-and-treat systems has proven impracticable in many
instances. State regulators, researchers, and engineers are working on innovative solutions to this
problem. This report focuses on identifying specific technical issues, non-technical problems,
training, and technical or policy needs that would contribute to improving the use of in situ
surfactant enhancements. The goal of the study was to identify barriers and describe successes in
gaining State regulatory approval, in order to promote understanding among the various
stakeholders vital to developing this important technology.
The Technology Innovation Office gratefully acknowledges the assistance of the following
individuals who gave their time and consideration to this project: Gary Beyer, Texas Natural
Resources Conservation Commission; Duane Mortensen, Utah Department of Environmental
Quality; George Nicholas and Greg Zalaskus, New Jersey Department of Environmental
Protection; Jim Shaw, Pennsylvania Department of Environmental Protection; Randall Thomas,
Kentucky Department for Environmental Protection, Federal Facility Oversight Unit; Susan
Timm, Central Valley Regional Water Quality Control Board, California Environmental
Protection Agency; Mark Walker, Colorado Department of Health and Environment; and
Jonathan Williams, U.S. EPA, Region 10. Dr. Candida West of the Subsurface Protection and
Remediation Division of the National Risk Management Research Laboratory was essential to
the project, as well as the various investigators and researchers in the area of surfactant
technologies who dedicate their considerable resources to the search for innovative solutions to
the nation's hazardous waste remediation problems.
Walter W. Kovalick, Jr., Ph.D.
Director
U.S. EPA Technology Innovation Office
The information in this document has been funded by the United States Environmental
Protection Agency under contract number 68-W2-0004 to Environmental Management Support,
Incorporated. It has been reviewed by the Agency and has been approved as an EPA document.
The opinions expressed herein are those of the authors and do not necessarily represent those of
the U.S. Environmental Protection Agency. Any mistakes are attributable to the authors and not
those interviewed. Mention of trade names does not constitute endorsement nor recommendation
for use.
Comments or questions regarding this report should be directed to:
Rich Steimle
Technology Innovation Office (5102W)
U.S. Environmental Protection Agency
401 M Street SW
Washington, DC 20460
703-308-8800
Surfactant Injection for Ground Water Remediation:
State Regulators' Perspectives and Experiences
This is a report on a series of interviews remove contaminants from soils and ground
water at hazardous waste sites. 2 Information
conducted with eight State regulatory
representatives regarding the use of was collected from computerized databases,
surfactants for in situ ground water such as Dialog Information Services, EPA
remediation. The interviews were a follow-up technology databases (VISITT, ATTIC),
to a analysis conducted last year by the
Environmental Protection Agency's
Technology Innovation Office (TIO). In the Technology Needs
previous study, TIO identified State
regulations and policies concerning the Traditional pump-and-treat systems
injection of surfactants, co-solvents, or have proven impracticable in many
nutrients into contaminated ground water for instances for treating non-aqueous
remediation. The present study examined phase liquids (NAPLs) in aquifers.
procedures used in States that have reviewed NAPLs have very low solubility in
proposals for surfactant demonstrations to water, leading to very slow rates of
identify specific technical issues, non- removal by pumping. NAPLs tend
technical problems, training, and technical or to exist in pockets at the subsurface
policy needs that would contribute to location to which they have
improving the use of in situ surfactant migrated. New technologies are
enhancements. The goals of the study are to being developed to improve
identify barriers and describe successes in removal efficiency through
gaining State regulatory approval, and make mobilization or solubilization of
recommendations to future applicants that these pockets.
may improve their chances for approval. TIO
sponsored a meeting of several principals
involved in ongoing surfactant demonstra-
tions on September 20, 1995, in Kansas City, Superfund Innovative Technology Evaluation
Missouri.1 Participants in the meeting Profiles, and the Department of Energy's
addressed issues of regulatory barriers and Office of Technology Development Program
other problems. This information is included Reports. This information was supplemented
in this report where appropriate. with telephone interviews with selected
representatives of federal agencies, academic
research centers, and hazardous waste
Surfactant Demonstration Report and
remediation consulting firms to identify
State Regulation Study
ongoing or planned demonstrations and
In April of 1995, TIO conducted an in- commercial applications of surfactant
vestigation to identify research, demonstra- technologies. A separate investigation of
tions, and field applications of in situ applicable State regulations identified a
surfactant enhancement technologies to number of additional sites where surfactant
1
use has been reviewed, approved, or remediation system at an oil refinery in Kenai,
implemented.3 Alaska. The Region was asked for their
approval after the Alaska Division of
Environmental Conservation had already
Method
reached a decision to approve the project. The
State ground water contacts in each of the process was fairly informal, and was not very
States where surfactant demonstrations or lengthy. The State reviewed the work plan and
applications had been identified were sent a surfactant chemistry. They were convinced
letter inviting them to participate in the study. that the system was well contained and that
A questionnaire directed toward gathering the surfactant being used was harmless. The
information on the process used to review State informed the company that an
surfactant applications was included (see Underground Injection Control (UIC) program
appendix). The letter explained the purpose of review and approval also would be needed.
the study and asked for their participation in a The Regional UIC staff did not see the need to
half-hour interview. The questionnaire issue a permit in this situation.The surfactant
included questions regarding the site, the was being used only in the area of the
length of application review, the most pumping wells to increase the effectiveness of
important technical information contained in recovery of spilled petroleum.
the proposal, technical deficiencies (if any),
non-technical problems that caused delays, Mr. Williams was unsure of the efficacy of the
suggestions for improving the review and surfactant in solving the problem. He also felt
approval process, and the potential benefit of that technical guidance would be valuable.
training or guidance on surfactant chemistry Guidance should describe the different
and processes. Following the letter, each state sequestering agents available, their strengths
contact was called and a telephone interview and weaknesses, and what could happen if
scheduled at their convenience. Interviews they could not be recovered.
were completed with State representatives in
Alaska, California, Colorado, Kentucky, New California
Jersey, Pennsylvania, Texas, and Utah.
In California, ground-water remediation is
regulated by a number of Regional Water
Interview Summaries
Quality Control Boards and the Department of
Toxic Substances Control, part of the
Each of the eight interviews conducted by
California Environmental Protection Agency.
EPA are summarized below. In some cases,
The contact we interviewed in the Central
specific information about the site where
Valley Regional Water Quality Control Board
surfactant use has been approved or is under
has been involved in planning for an in situ
consideration is included, as well, to provide
surfactant remediation at the Department of
a context for understanding the State
Energy's Lawrence Livermore National
regulator's perspective. In addition, each of the
Laboratory. The proposed project will be
items in the questionnaire is addressed to the
conducted at the Livermore Site 300
extent possible for each State respondent.
Superfund site, about 50 miles east of San
Alaska
Francisco.
Jonathan Williams of EPA Region 10
The site is characterized by channel deposits
provided information regarding the use of a
underlain by thick sandstone and claystone
surfactant as a sequestering agent for iron-
deposits. There are four primary
fouling problems with a ground-water
2
hydrogeologic units: a shallow isolated, demonstration of surfactant technology.
perched water bearing zone; an unsaturated According to the State of California, the most
perching horizon; a claystone aquitard; and a important technical information they need
deep uncontaminated regional aquifer. The from the other parties includes certainty of
site is contaminated with high levels of hydrogeologic control (both surfactant and
volatile organic compounds (VOCs), tracers), and the understanding the interaction
specifically trichlorethene (TCE). TCE, mixed of the surfactant with the contaminant and the
with a silicone-based lubricant (TBO), was media. The State also must be convinced that
used as a heat exchange media in military the monitoring system is adequate to answer
production. The plume is relatively these questions.
concentrated near the source area. Researchers
believe that the perched zone represents a In California, surfactant proposals would be
good opportunity to test innovative reviewed using procedures established for
technologies. other types of remedies, which are based on
modeling, empirical data, and technical
The proposed surfactant injection will be used knowledge. The Department of Toxic
to initially solubilize the contaminants, Substances Control also has regulations for
followed by phase focusing on mobilization. underground injection of hazardous waste that
The project should provide proof of the may result in a need for a permit (This has not
concept, as well as the opportunity to been at issue for the present project, as it is a
demonstrate a separation technology. Superfund site). Also, for the LLNL project, a
Preliminary partition tracer tests were public meeting was held as part of the
conducted in November 1995; the appropriate CERCLA process, but citizen concerns
surfactant will be selected in January 1996, focused on the overall cleanup rather than on
and the surfactant test is planned for March the small section where surfactants are
1996. Participants include the Department of proposed.
Energy, Lawrence Livermore National
Laboratory, California's Department of Toxic State regulators in California are aware of the
Substances Control, the Central Valley potential benefits of surfactants, but concerned
Regional Water Quality Control Board, U.S. about hydrologic control and possible
EPA Region 9's Hazardous Waste reactions with other contaminants. Although
Management Division, the EPA Subsurface this project has not yet been conducted, she
Protection and Remediation Division of the said that the State would probably require
National Risk Management Research further action (probably pump-and-treat) if no
Laboratory (formerly R.S. Kerr results are gained from the surfactant project.
Environmental Research Laboratory), and
researchers from the University of Oklahoma. Ms. Timm thought that both training and
guidance from EPA would be of benefit. A
In our interview with Susan Timm of the number of people in the State office who
Central Valley Regional Water Quality haven't been involved in following surfactant
Control Board, we learned that LLNL had not research would be very interested to learn
made a formal application to the State, but had more. She recommended that training also
contacted RPMs involved at the site more than focus on the private sector. This is especially
six months ago to begin discussions of the important because private parties are the
project. The State has been pleased with the source of technology decisions, state
level of interaction and is quite interested in regulators do not generally propose specific
the possibility of using a perched area for a
3
solutions due to liability concerns, but do give
Technology Description (1)
final approval.
The application of surfactants can
Colorado
enhance remediation by increasing
contaminant mobility and solubility
The Colorado Department of Health and
to improve pump-and-treat
Environment has reviewed one proposal for a
performance; by decreasing the
surfactant remedy at a petroleum facility in
mobility of contaminants to prevent
Loveland, Colorado. This was a corrective
their migration; and by speeding
action for a leaking underground storage tank
the rate of biodegradation of
site, and the remedy was rejected. However,
contaminants in soil.
Mark Walker, whom we talked to, explained
that in Colorado, the facility can be
Surfactants increase contaminant
reimbursed for any technology that is
removal by increasing the apparent
demonstrated as technically and economically
solubility of the contaminant in
feasible. In this case, the State not only had to
water which improves the mass
approve the project, but literally to pay for it.
removal per pore volume. They
may also be used to reduce
The proposal review process took from four to
interfacial tension between the
six months, and consisted of review of the site
water and the contaminant. This
assessment documents and corrective action
requires greater surfactant
plan to remediate a gasoline leak from the
concentrations than those needed
leaking underground storage tank. The State's
for increasing solubility, but results
concerns in this case focused on the chemical
in direct mobilization of NAPLs,
makeup of the surfactant, which was a
which may allow them to be
proprietary product. The State requested a
extracted more efficiently.
sample of the surfactant that was analyzed by
However, if uncontrolled,
a State laboratory. They found two problems:
increasing the mobility of the
the surfactant itself contained hazardous
NAPLs also increases the risk of
components (e.g., benzene, toluene) and the
increasing the contaminant plume.
laboratory had a problem in quantifying the
surrogates. This was considered problematic
in that it would mask detection of the
contaminant at the point of compliance.
considered.
The State encouraged the applicant to conduct
a pilot scale test that compared the surfactant Other technical issues of concern include the
to a clean sample, a sample contaminated with need for very good hydrologic control as
diesel fuel, and a fourth sample with both demonstrated by monitoring wells, slug tests,
diesel fuel and the surfactant, and analyze for and flow direction, as well as adequate
total petrol HCs. Finally, the contaminant confidence in the ability to detect problems at
source was largely in the soil rather than the the point of compliance. It would be
ground water, and the State was concerned preferable that there be no immediate
with the idea of cleaning the soil by moving downgradient receptors.
the contaminant into ground water.
Alternatives that addressed removing the
contaminant directly from the soil were not
4
Mr. Walker was quite interested in the Pennsylvania has recently enacted new
possibility of training or guidance on a cleanup legislation that should make the
national level. He suggested that EPA should remediation process easier at a number of
be involved in conducting research to sites. The law incorporates generic remedies,
determine which surfactants are best in background levels, and the development of
particular situations. Guidance should focus site-specific standards as options. Each region
on an impartial test of surfactant reliability in the State will have responsibility for sites in
and performance. The State would also be that area. Review of proposals will be
interested in EPA guidance on 鈥渉ow clean is contingent on the availability of technical
clean.鈥? Training should be modeled on a resources and management priorities, but there
recent workshop called the Strategic Technical is a requirement for a 60-90 day turnaround on
Exchange Workshop. In this training, remedial projects. Mr. Shaw thought the effect
instructors, regulators, and the regulated of the new legislation would be to make it
community met together and in break out easier to implement innovative technologies.
sessions to discuss specific techniques.
State staff in Pennsylvania would benefit from
Pennsylvania a conference or training course on surfactants.
Mr. Shaw noted that it was difficult to locate
Jim Shaw discussed the State of staff with familiarity with the topic. The best
Pennsylvania's experience in reviewing and approach would be a series of regional
approving a pilot study to evaluate the use of conferences provided by EPA. Guidance on
surfactants for remediating PCBs at the how to implement surfactant demonstrations,
Delmont Site in Westmoreland County. The focusing on the process and options, also
State received a work plan and MSDS would be helpful.
(Material Safety Data Sheets) sheets from the
company with toxicity information on the Kentucky
proposed surfactant. The information
submitted was adequate, but delays were The Department of Energy's Paducah Gaseous
caused since this was the first such proposal Diffusion Plant has numerous contaminated
and the State did not have procedures in place areas (200 potential release sites or solid
to review it. Eventually, the information was waste management units). TCE used for
reviewed by a hydrologist, an aquatic cleaning metal and machinery parts has been
biologist, and a toxicologist. Mr. Shaw said identified in ground water plumes both to the
that he coordinated with the Bureau of Water northwest and northeast of the site. (Other
Quality to find the proper staff. Another contaminants include the radionuclide
problem involved proprietary information technetium-99, uranium, PCBs, chromium,
regarding the surfactant itself; however, this and other substances in both soil and ground
was overcome by the MSDS information. water.)
According to State staff, there are no The Commonwealth of Kentucky approved a
legislative or public barriers to the use of proposal for a surfactant demonstration to
surfactants in Pennsylvania. Proposals are facilitate removal of TCE in a small area
reviewed on a case-by-case basis; and (about 200 square yards). Although there were
approval is determined on the basis of no specific permit requirements or regulations
technical merit. It is possible that future that were applicable to the site, DOE
proposals would also be reviewed by State submitted a work plan to EPA for review
UIC staff as well. under UIC regulations. Kentucky's Division of
5
Waste Management has an arrangement for surfactants to enhance pump-and-treat
technical support from the University of remedies. The Commonwealth would like
Kentucky, where their Federal Facility DOE to try again, and DOE has not ruled out
Oversight Unit is located. Therefore, even this possibility.
though this was the first such request,
technical staff were available to review the Mr. Thomas also noted that training for both
proposal within three to four weeks. the regulators and the regulated community is
essential. People need knowledge about the
One problem identified by Randall Thomas of process and how to use it; however, he
the Federal Facility Oversight Unit was that thought it may be too early in the
DOE was not convinced that the State was development of the technology for EPA to
supposed to review and approve the proposal. provide guidance.
If DOE had involved the State earlier in the
process, a better working relationship most Utah
likely could have been established. Also, by
the time the Federal Facility Oversight Unit A number of remedial projects are ongoing at
became involved, DOE had strict time Hill Air Force Base in Utah. Surfactant-based
schedules to initiate the demonstration. The technologies will be included as three of eight
contractor doing the work was willing to work field demonstrations in one project led by
for free in order to show DOE their researchers from the University of Oklahoma
capabilities, but delays would have made this at Operable Unit 1 (OU1). A project at OU2 is
impossible. being conducted by researchers from the
University of Florida and the U.S. EPA
The proposal contained no major technical Subsurface Protection and Remediation
difficulties and approval was granted initially Division of the National Risk Management
based on technical merit. However, the Research Laboratory in Ada, Oklahoma. Both
contractor did not want to disclose much projects were discussed in the State regulator's
information about the surfactant. The interview.
compound initially proposed contained a
hazardous waste component and later a Hill AFB is designated as a Superfund site.
different surfactant was substituted. The Other partners in the projects include U.S.
Commonwealth also was concerned with EPA, Region 8; the Utah Department of
mobilizing the DNAPL (dense, non-aqueous Environmental Quality; and Hill AFB. The
phase liquid), since this may result in DNAPL purposes of the studies are to evaluate
moving deeper into the aquifer. innovative remediation technologies for the
removal of NAPL or constituents in NAPL
Unfortunately, the demonstration did not turn from saturated and unsaturated soil; and to
out as planned. The contractor was unable to conduct treatability studies of these
recover all of the surfactant, some of which technologies for remediating LNAPL
either moved downgradient or was bound up contamination. For the OU1 project, field
in the matrix. Mr. Thomas identified a number demonstrations will be executed inside a test
of possible reasons: they did not pump cell constructed to hydraulically isolate the
aggressively enough; there was not enough investigation area and minimize migration of
geologic testing in advance of the fluids from the cell. Participants hope to make
demonstration; and possibly they used the preliminary assessments of the long term
wrong surfactant. In spite of these problems, effectiveness of the technology and to develop
Mr. Thomas remains enthusiastic about using
6
basic cost factors that can be used for cost at a RCRA site. Approval of projects are
estimates for full scale application. based on technical merit, and state regulators
suggested there were no institutional barriers,
at least for Superfund sites. They did note that
Technology Description (2) it would be more complicated for a RCRA
site. Also, so far, no one has proposed using a
Cationic (positively charged) proprietary product for use as the surfactant.
surfactants have been shown to The State noted that they would need enough
improve the capacity of soil to sorb informa-tion on the chemical properties of the
hydrophobic organic contaminants, proposed surfactant to ensure public safety.
such as polyaromatic hydrocarbons
(PAHs). Other research suggests Since this is a CERCLA site, a certain level of
that low concentrations of public involvement is required. The local
surfactants may be useful for Community Working Group and South Weber
enhancing in situ biodegradation of Landfill Coalition have been very active and
hydrophobic pollutants. involved in the overall project. So far, local
citizens have not been overly concerned with
treatability studies, but they would be very
concerned if the Record of Decision (ROD)
Our interview was with Duane Mortensen of called for injecting some-thing with hazardous
the Utah Department of Environmental constituents. They also have concerns
Quality, and with one of his staff members regarding the overall cleanup strategy at the
who is a State Project Manager at Hill AFB. site.
The application was reviewed in six months.
The most important technical information Finally, State regulators noted the impor-tance
included in the proposal from the State of having very good communication and
perspective was information regarding the coordination with all the parties involved.
expected effectiveness of the technology (e.g., They have had several meetings with the
as demonstrated through treatability studies), Universities, EPA, and the Air Force that have
how well the containment system was helped keep the projects moving by keeping
designed, and the type of chemical to be used. everyone informed. They suggested that
The State Ground Water Quality Protection others become more familiar with the State's
Rule specifies levels equal to Maximum administrative process to facilitate approval of
Contaminant Levels (or, in some cases where demonstration proposals. Researchers
ground water has not been impacted by involved in the projects agreed with these
contamination, specified percentages of conclusions. In particular, they recommended
MCLs) as a standard for the concentrations of that keeping the regulators involved
injectant. A State applicable or relevant and throughout the process, developing work
appropriate requirements (ARAR) waiver plans, and familiarizing researchers with the
would be necessary for full remediation. regulatory process are all essential steps.
While there were no technical deficiencies in New Jersey
the application, appropriate regulatory
requirements of EPA's Treatability Study At Picatinny Arsenal, TCE was used for years
Guidance had to be addressed in the work as a degreasing solvent and has contaminated
plan. No UIC permit was required as this is a a sand and gravel aquifer. The site was
CERCLA site; however, one would be needed recently listed as a Superfund site and a pump-
7
and-treat system was installed as an interim The New Jersey Pollutant Discharge
remedy. The water table is 10 feet below the Elimination System (NJPDES) regulations
surface, and a lower confining unit 10 to 15 focus on the operational aspects of a discharge
feet thick is another 40 feet from the water to ground water. They outline requirements
table, making the site ideal for a small scale for obtaining and maintaining permits for
field test. discharge to ground waters or surface waters
of the State. These regulations also specify
Laboratory research indicated that a nonionic procedures for public comment/public notice,
surfactant, Triton X-100, may increase the and requirements for constructing and
desorption rate of TCE from soil and organic operating treatment works. The New Jersey
materials to ground water. This theory was Ground Water Quality Standards (NJGWQS)
field tested by researchers from the U.S. focus on the classification and quality of
Geological Survey (USGS), the University of ground water. These regulations deal with
Virginia, and the Army. The preliminary aquifer classifications, exceptions to aquifer
results from the field test completed in March classifications, ground water quality criteria,
1995 support the laboratory research. The calculation of ground water criteria,
work will be incorporated into the site identification of practical quantitation levels,
Remedial Investigation/Feasibility Study (RI/ and anti-degradation policies. Discharge limits
FS) and used in selection of final remedies. contained in a NJPDES discharge to ground
water (DGW) permit would be obtained from
The USGS designated the site as a research specified ground water quality criteria (or
site, and the University of Virginia has a grant guidance provided to calculate criteria)
from EPA to conduct research on the site. The contained in the New Jersey Ground Water
State of New Jersey has granted the Army a Quality Standards.
permit to discharge to ground water. State
regulators were brought into the process up to Under CERCLA Section 121 鈥淐leanup
a year prior to beginning the field test. Standards鈥?; federal, state, and local permits
According to the researchers, the State was are not required for the portion of any removal
willing to let the project go forward because or remedial action conducted entirely on-site.
the field test was being conducted within the However, also under Section 121 is the
capture zone of the existing pump-and-treat requirement for remedial actions to at least
systems. Modeling studies showed that all but attain legally applicable or relevant and
5% of the ground water is being captured by appropriate federal and state standards,
the existing system. requirements, criteria, or limitations (i.e.,
ARARs), unless such requirements are
Any discharge to ground water in New Jersey, waived.
whether it is clean water discharged from a
treatment system or chemical surfactants The State of New Jersey does not waive
injected/infiltrated into an aquifer, would be requirements, and ARARs must be met at
regulated by the New Jersey Water Pollution publicly-funded and Federal CERCLA sites.
Control Act (N.J.S.A. 58:10A). Two sets of ARARs include the Technical Requirements
regulations from this Act directly apply to for Site Remediation, N.J.A.C. 7:26E-6.1(b)3,
discharges to ground water. They are: 1) the which require a responsible party to meet the
New Jersey Pollutant Discharge Elimination equivalent of a permit's conditions; however,
System (N.J.A.C. 7:14A) and, 2) the New a permit number is not issued nor is a permit
Jersey Ground Water Quality Standards fee required. The surfactant injection project
(N.J.A.C. 7:9-6). at Picatinny must meet the equivalent
8
requirements that the Department would set expected concentrations, flow rates, duration
for any request for a permit to inject to ground of the discharge, static ground water flow
waters of the State. The NJDEP utilized a velocities and directions, health and safety
鈥淧ermit by Rule鈥? approach to facilitate the provisions, sampling/monitoring plans).
surfactant injection project while meeting
regulatory requirements. As discussed above, for pilot studies or
aquifer tests, NJPDES regulations now
At the NJDEP, contaminated sites are authorize using a 鈥減ermit by rule鈥? for a
identified, assessed, scored, and ranked. discharge to the ground. The permit by rule is
Depending on the ranking and the regulatory simply a letter and no public noticing
program, the site is assigned to a Bureau procedures are required. Adequate monitoring
which appoints a case or site manager to of the discharge, ground water quality, and
handle the case. For sites with substantial hydraulic conditions would be required
ground water and soil contamination, a full through whatever regulating mechanism or
case team is usually assigned. A full case team oversight document is driving the remedial
consists of the case manager, a technical work, not as part of the permit by rule. The
coordinator (responsible for evaluating soil permit by rule would include effluent limits
data, QA/QC, and related technical issues), based on specific criteria found in the Ground
and a geologist. The case team operates as a Water Quality Standards for the aquifer
unit under the direction of the case manager. classifications receiving the discharge.
For discharges to ground water, the purpose of Discharges occurring outside the limits of a
a NJPDES permit is to ensure the protection capture zone must meet 鈥渁nti-degradation
of human health and ecological receptors. limits鈥? (as discussed in Section 7:9-6.8 of the
However, NJDEP modified its NJPDES NJGWQS). These limits are designed to
regulations in September 1994 to ease the prevent any further degradation of ground
administrative permitting requirements for water quality from a regulated discharge.
certain discharges to ground water. These Higher discharge limits may be allowed, on a
include discharges related to pilot studies, case by case basis, if the discharge is
aquifer testing, or other discharges to the occurring within the limits of hydraulic
ground related to monitoring, engineering, or capture, or if the Department determines it is
design needs. appropriate to issue a Classification Exception
Area (CEA). For a full scale system, a formal
The following approach would likely be NJPDES-DGW permit would be issued,
followed at the NJDEP to allow surfactant except for on-site discharges at CERCLA
injection to be considered and implemented. sites, in which case a 鈥淧ermit Equivalent鈥?
As with any proposal to test a specified would be issued. Currently, submittal of
remedial approach, a responsible party or their formal application forms is not necessarily
consultant should inform the NJDEP case required for Permit Equivalents for a
manager that they would like to evaluate the discharge to ground water.
feasibility of surfactant injection. The case
manager would require submittal of a proposal Training on surfactant chemistry and
outlining the details and nature of a requested processes would be beneficial for future
discharge. This proposal should provide all decision making; however, New Jersey has
technical data to allow the Department to fully drastically cut back on training due to
review it, including where will the discharge resource limitations, and staff would be able
occur, what is the nature of the discharge, to attend only if training is offered free of
9
charge. Guidance would also be helpful in hydrogeologists and toxicologists. The
integrating information on surfactants, and requirement for an injection permit would be
should focus on State concerns and how these the main regulatory issue.
can be mitigated.
There would be a good deal of interest in
Texas training on surfactant use, especially for
remediation of TCE. The State's Innovative
EPA has identified one completed Technology Program has offered vendor
demonstration of surfactant technology for presentation days that have regulators become
hazardous waste remediation in Texas. 鈥淚n familiar with the technology. Because of
Situ Remediation Technology Status Report: travel restrictions, training or a workshop in
Surfactant Enhancements鈥? describes a pilot Austin would be the best venue. Written
test of use of a surfactant to facilitate removal guidance would also be welcome.
of carbon tetrachloride at the Corpus Christi
Dupont site in 1993. The demonstration Conclusions and Recommendations
showed positive results. No current projects in
Texas have been identified; however a number The survey of state regulators indicated that
of companies are looking into the technology, there is a great deal of variety in approaches
and a pilot project is being considered at and procedures relevant to gaining approval
Kelley Air Force Base. for demonstrations of surfactant technology.
For this reason, it is difficult to make
Gary Beyer of the Texas Natural Resources generalizations about how states can best be
Conservation Commission's Federal Facilities approached. As demonstrated by the projects
Team, discussed some of the technical discussed in the report, it is clear that
information requirements and regulatory opportunities do exist. Typically, proposals
requirements for conducting a demonstration. have been reviewed on a case by case basis
His office deals with corrective actions under and rejected or approved on the basis of
the RCRA program. The time to review a technical merit. However, the states are not
proposal for a Corrective Measures Study monolithic. Different agencies within the
would likely be about one month. A Class 5 states may be responsible or involved in
UIC well permit would be required, but could reviewing a surfactant application, and some
be obtained from within their office. The most effort may be involved in determining which
important technical data for the proposal State office has regulatory jurisdiction.
would be hydrogeological data explaining Moreover, the technology is still in a
recovery and chemical solubility data on the relatively early stage of development for use
surfactant. A surfactant containing hazardous in remediating hazardous waste, and states are
constituents would not be likely to be doing their best to keep up. Many questions
approved. remain about the technology itself, such as:
Which surfactants should be considered
Pilot studies can be approved under the State
Risk Reduction rules through a letter permit as for particular contaminants?
Will geochemical interactions with other
part of the normal corrective action process.
No public hearing would be required for a contaminants be a factor?
How can you ensure the surfactant will
pilot study. However, a full Corrective
Measures Investigation under RCRA does not remain in the matrix? and
How do you know when you've been
include a public participation requirement.
The proposal would be reviewed by staff successful?
10
Given these caveats, it is possible to draw mobilized without being recovered, and that
some conclusions based on experiences. the surfactant itself can be recovered or
remediated.
Time Required to Review Proposal
Information that should be included in the
None of the states included in the survey had proposal includes:
a specific procedure in place for reviewing
A detailed work plan for conducting the
proposals for surfactant projects. Most states
have more general procedures for review and project including objectives,
Comprehensive site characterization
approval of pilot projects or demonstrations of
innovative technologies, and these may information (including water levels and
require a broad range of time. In general, monitoring well data),
Background information on laboratory
researchers or others proposing a
demonstration should plan from one to six studies or other field demonstrations
months for state review of surfactant showing the efficacy of the proposed
proposals. States where pilot studies can be approach,
Demonstration of hydrologic control over
approved and permits issued by rule or letter
are likely to take less time. the test site to ensure that surfactant will
not be lost, nor NAPLs simply moved
In some cases review of proposals was further into the matrix,
Surfactant chemistry and contaminant
delayed because of the need to locate
appropriate experts for the review within the geochemical interactions, and
Demonstrated monitoring capabilities.
state office and because of the need to
coordinate among state offices. Types of
experts who are likely to be involved in the Barriers to Approval
state review include: hydrogeologists,
toxicologists, and possibly others. Suggestions Underground Injection Control (UIC)
for reducing the amount of time required for regulations are not applicable at Superfund
state review included knowledge of the sites and appeared generally not to be
regulatory process by those preparing considered a serious problem in States that
proposals and adequate technical information have approved surfactant demonstrations.
included in the submission (see below). Permits were not typically required for pilot
Training, technical support, or a national tests, and the UIC staff were simply kept
directory of experts might also be useful. informed of the surfactant activities. However,
UIC permits may well be required for full
Format and Technical Information remediation or even for pilot studies at RCRA
Requirements or private sites. There are also differences in
regulatory requirements based on whether the
The survey identified state concerns about the site is regulated under RCRA or CERCLA,
toxicity of the surfactant, masking effects, and whether it is a Federal Facility, a
transfer of contaminants from soil to ground Superfund, State, or private party lead. There
water, satisfactory hydrologic control, and appear to be fewer restrictions at a Superfund
adequate monitoring to ensure that processes site.
taking place in the subsurface are understood.
In particular, state regulators need to be In some states, water quality standards would
convinced that use of surfactants will not prohibit use of surfactants that contain Safe
make the situation worse, that NAPLs are not Drinking Water Act-listed constituents at
11
concentrations above the MCL. Waiver of specific permits are needed, and the
state ARARs may be needed for large scale specific format the proposal should take to
implementation at a Superfund site. Public facilitate approval.
disapproval has not generally been a problem
Surfactants about which considerable
for small scale demonstrations, but it could
become a concern for larger remedial efforts. chemical data is known and those that do
not contain hazardous constituents are the
Training and Guidance Needs most likely to be approved. The use of
proprietary products will make approval
Seven of the eight individuals interviewed more difficult in most cases.
recommended training in surfactant use and
EPA should consider developing training
processes for state staff. Most also mentioned
that the public needs training as well. The or technology transfer workshops for state
preferred format was a series of regional staff and the public sector.
workshops that would be close enough to state
capitals to minimize travel costs, and that As the technology for surfactant
would include researchers, regulators, and the enhancements develops, more is learned about
regulated community. which surfactants are least harmful and most
efficient, and cost and performance data
Guidance on surfactant use would also be become available, the approval process in the
welcome, especially as a substitute or addition states can be expected to improve.
to training, but some of those interviewed
admitted that it may be too early in the Notes
development of the technology for EPA to be
1.
able to write useful guidance. 鈥淲orkshop on In Situ Surfactant Use鈥?,
sponsored by U.S. Environmental Protection
Agency, Technology Innovation Office,
Recommendations
Kansas City, Missouri, September 1995.
Researchers or others interested in gaining
2.
state approval for a surfactant pilot test or 鈥淚n Situ Remediation Technology Status
demonstration project should consider the Report: Surfactant Enhancements鈥?, U.S.
following recommendations based on lessons Environmental Protection Agency,
learned by previous proposals: Technology Innovation Office, Washington,
DC, EPA542-K-94-003.
All relevant parties should be brought into
3.
the process early and kept informed of EPA's Technology Innovation Office will
project progress. Communications with all publish the results of this study in early 1996.
partners, and especially state regulators, is
critical to the process.
Researchers and others proposing
surfactant demonstration or remediation
projects need to be well versed in the
regulatory process, and should become
familiar with the state's regulatory and
administrative procedures. This will
frequently determine whether or not
12
13
Appendices
State Regulators' Interviews
Surfactant Injection for Ground Water Remediation
List of Participants:
STATE NAME SITE PHONE INTERVIEW
AK Jonathan Williams Refinery on Kenai 206-553-1369 Aug. 31
U.S. EPA, Region 10 Penninsula (UST Site) Fax 553-1280
1200 Sixth Street (WD132)
Seattle, WA 98101
CA Susan Timm Lawrence Livermore 916-255-3057 Aug. 31
Central Valley Regional Water Quality National Laboratory Fax 255-3015
Control Board
3443 Routier Road, Suite A
Sacramento, CA 95827
CO Mark Walker 1 site where surfactants 303-692-3449 Aug. 29
Colorado Department of Health and being used at an UST Fax 759-5355
Environment (HMWMD-RP-B2) site
4300 Cherry Creek Drive, So.
Denver, CO 80222-1530
KY Randall Thomas DOE Paduaka 502-564-4797 Sept. 6
Federal Facility Oversight Unit Gaseous Diffusion Fax 564-5096
14 Reilly Road Plant
Frankford, KY 40601
NJ George Nicholas Picatinny Arsenal 609-292-8427 Sept. 6
NJ Dept. of Environmental Protection Fax 292-0848
Division of Publicly Funded Site
Remediation (CN 413)
Trenton, NJ 08625
PA Jim Shaw 717-783-9475 Aug. 28
Dept. of Environmental Protection Fax 787-0884
Bureau of Land Recyclying & Waste
Management
400 Market Street (14th Floor)
P.O. Box 8471
Harrisburg, PA 17105
TX Gary Beyer 512-239-2361 Sept. 6
Texas Natural Resources Fax 239-2346
Conservation Commission
P.O. Box 13087, Capital Station
Austin, TX 78711-3087
UT Duane Mortensen Hill AFB 801-536-4172 Sept. 12
UT Dept of Environmental Quality Fax 359-8853
168 N. 1950 W., 1st Floor
Salt Lake City UT 84114
State Regulator's Interview Guide
Barriers and Successes in Demonstrating Surfactant Injection
for Ground Water Remediation
Introduction
This is a follow-up to a survey EPA conducted last year aimed at determining what State regulations and policies are
concerning the injection of surfactants, co-solvents or nutrients into contaminated ground water for remediation. At this
time, we are interested specifically in procedures used in your state for reviewing proposals for surfactant injection
demonstrations. EPA is aware of about half a dozen current surfactant demonstrations. EMS has been employed to
assist them in conducting interviews with key state regulators who may have been involved in reviewing and approving
such proposals. The goal of these interviews is to identify recommendations for future applicants that may improve the
efficacy of approval.
1. Are you the appropriate persons to discuss the details of the proposal for surfactant use within your state?
a. If not, whom should we contact?
Name ________________________________ Phone No.
Fax No.
[Thank you for your assistance]
2. What is the name and location of the site?
3. Can you give me the time frame during which the application was reviewed by the State?
From: ______________________ To: _____________________________
4. What would you consider the most important technical information in the proposal?
5. Were there major technical deficiencies in the application? Yes: ______ No: ______
a. Could you describe these briefly?
b. Did you request additional information from the applicant? Was this adequate?
6. Were there other, non-technical problems that caused delays?
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a. If so, how do you think these problems can best be addressed?
b. Who would be in the best position to change things?
7. Do you have any suggestions about how the application approval process can be speeded up?
8. Do you believe that training on surfactant chemistry and processes would be beneficial for future decision-making
related to permitting decisions?
If yes, what recommendations do you have?
9. Do you think guidance for specific surfactant applications is needed?
10. Are there other technical or policy options that could be addressed nationally that you feel would contribute to
improving the use of in situ surfactant enhancements in your State?
Thank you for your time. You will be given the opportunity to review our report and recommendations before they are finalized.
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