PIMS Field Demonstration Work Plan Section 4

Performance criteria that will be used to evaluate performance of the PIMS remedial technology are presented in Table 4-1. The general performance criteria used to evaluate performance of the innovative technology include reduction in contaminant mobility, ease of use, etc., and are shown in Table 4.2.

Performance Criteria	Description	Primary or Secondary
Contaminant Mobility	Pb mobility will be decreased as a result of this technology	Primary
Process Waste	There is no process waste. There will be natural infiltration that will be clean, but still needs to be permitted to be discharged or recycled	Secondary
Factors Affecting Technology Performance	Technology performance is unaffected by almost any operating condition including flow rate, feed rate, through-put, temperature, etc. Soil type, particle size distribution, GW pH, dissolved oxygen, and other contaminants also have little or no affect on the technology performance., even under unusual conditions.	Primary
Reliability	This technology has no reliability problems. Potential breakdown of the emplacement equipment may cause delays, but the performance will not be affected. Also there is no sensitivity to environmental conditions, the emplacement can be done at any time and conditions will only affect the comfort of the field personnel.	Secondary
Ease of Use	The actual number of personnel in the field will be five. This technology involves ordinary use of earth-moving equipment such as backhoe and shovel, and mixer. No special training is required. OSHA health and safety training is required as for any hazardous waste site, i.e., 40-hour HAZWPR.	Primary
Versatility	This technology can be used for other applications, e.g., permeable reactive barrier walls or treatment tanks, and it can be used at almost any other location. The technology can be adapted easily to other conditions and sites.	Secondary
Maintenance	No maintenance is anticipated for use of this technology. Only monitoring may be required.	Primary
Scale-Up Constraints	There are no issues of concern with scaling up the technology for full implementation, only using more Apatite II over a larger area.	Secondary

Performance Criteria		Expected Performance Metric (pre demo)		Performance Confirmation Method*	Actual (post demo)
Primary Criteria (Performance Objectives) (Qualitative)
Contaminant mobility
		The contaminant mobility is expected to be reduced such that the leachable lead available from the treated soils meet the groundwater MCL		Analysis of generated leachate by USEPA SW-846 method 7421 or 6010B.
Ease of Use
		This technology only utilizes typical construction type equipment for mixing and emplacement of the treated soils.		Experience from demonstration operations
Primary Criteria (Performance Objectives) (Quantitative)
Feed Stream
Contaminant concentration	10 cubic yard batch process with expected lead levels greater than 2,000 ppm.		USEPA SW-846 method 6010B.
Target Contaminant
Regulatory standard	Reduce leachable lead from soil to less that 15 ppb. Secondary goal to reduce leachable lead to below state of Texas Class 1 non-hazardous waste criteria of 1.5 ppm		USEPA SW-846 method 7421. USEPA SW-846 method 1311/6010B.
Hazardous Materials
Eliminated	None		Not Applicable
Generated	None		Not Applicable
Reliability
	None		Not Applicable
Process Waste
Generated	None		Observation
Factors Affecting Performance
throughput	- no limit		Analysis at high flow rate
media size	- large rocks may slow throughput		Soil sifting may be applicable
Secondary Performance Criteria (Qualitative)
Reliability
	No breakdowns		Record keeping
Safety
hazards	Dust		Experience from demonstration operation
protective clothing	Modified Level D PPE		Personnel monitoring
Versatility
intermittent operation	Yes		Experience from demonstration operation
other applications	Yes, may be applicable for other contaminant (e.g., chromium, cadmium, etc.)		USEPA SW-846 method 6010B.
Maintenance
required	None		Experience from demonstration operation
Scale-Up Constraints
flow rate	Largest batch unit available		Monitor during demonstration operation
contaminant concentration	Toxicity levels to classify waste.		USEPA SW-846 method 1311/6010B.
* Refer to Appendix B or Appendix D for further details

Effectiveness of the demonstration will be evaluated by monitoring lead concentration in the leachate collection system. A successful demonstration is represented by the lead concentration within the leachate being below the MCL and the groundwater protection criteria for Risk Reduction Standard 2 (30 TAC Chapter 335 Subchapter S). A secondary criterion exists for waste treatment efforts. This criterion is established by the regulators for disposal of the contaminated media within a landfill. These criteria (treatment) are specified in 40 CFR 268 land disposal restrictions for hazardous waste as well as 30 TAC Chapter 335 Subchapter R (waste classification) for non-hazardous waste. Additionally, in order to address potentially available lead not treated via mixing, initial samples will be collected of the soil and leachate and analyzed for phosphate and total lead, respectively. This will allow for an evaluation of the mixing technique used in this demonstration.

The conceptual design for the PIMS remedial technology is shown in Figure 4.1. The conceptual design includes a liner with leachate collection system to collect and recycle waters from the treatment unit. Leachate from the unit will be monitored by collecting samples from the discharge of the pump. It is currently planned to collect quarterly monitoring samples to measure the efficiency of the PIMS remedial technology.

Data analysis and evaluation will be conducted to determine efficacy of the PIMS remedial technology. Data analysis will include evaluation of chemical test results, risk evaluations from test results, and evaluations of field emplacement activities. It is expected this field demonstration will provide data regarding optimum field mixing and potentially monitoring requirements for a full scale remedial demonstration.

Technology for which this innovative technology is to be compared against is solidification technology with the use of Portland^�cement. The cement based systems have been the most frequently selected technology for treating metal contaminated soils. In treatment of industrial hazardous wastes, the USEPA has identified solidification/stabilization as Best Demonstrated Available Technology for 57 RCRA-listed wastes (USEPA, 1993). Problems encountered in cement based treatment can be broadly classified into solidification problems, i.e., obtaining the required physical properties in the resultant waste form. Use of cement in solidification efforts has requirements in compressive strength and physical/chemical properties in the immobilization of hazardous constituents. Additionally, the PIMS technology will be compared to other treatment technologies such as, but not limited to, phytoextraction, soil washing, and asphaltic stabilization

The primary concern emphasis for the planned risk assessment is to demonstrate that all exposure pathways for the residual contaminants have been removed as a result of the treatment of the contaminated soil. Data will be evaluated to determine the extent of liability remaining from the treatment effort.