Soil Corrective Action Completion at Former Instrument Manufacturing Plant
Low Temperature Evaporative Desorption Technology (EDT)
Formerly an instrument manufacturing facility, the 45-acre site in Fullerton, California was designated a “large quantity generator” of hazardous waste. In 2008, under oversight of the CA DTSC, a RCRA Facility Investigation identified VOCs including PCE, TCE and degradation compounds in soil, soil vapor, and groundwater. Reterro was contracted for a pilot test, then subsequent full-scale remediation of 100,000 tons of soil.
The project consultant identified Reterro EDT as the preferred remedial method due to the minimal environmental impact. EDT is a static, ex-situ process using electrically heated air to evaporate contaminants from soil with no PM10, NOx or SOx emissions. Evaporated contaminants for this project were captured with granular activated carbon.
The EDT pilot test was performed in accordance with a DTSC-approved work plan under Corrective Action Management Unit rules (CAMU) (40 CFR 264.550), and permits issued by the South Coast Air Quality Management District.
Client requested residential level clean-up standard
Proximity to schools and commercial properties created emission and sound limitations
Due to proximity to residential, commercial, and school developments, emissions levels were closely monitored and regulated. Additionally, conservative cleanup and emission goals were set by the DTSC and SCAQMD to prove the effectiveness of Reterro’s EDT technology. A major challenge was to meet residential level cleanup goals in a cost-effective timeframe.
Contaminants of concern: Chlorinated Volatile Organic Compounds
Clay and silt soil types
8-to-24-foot excavation depths
Project size: 100,000 tons
Soil remediated to levels surpassing residential and soil-to-groundwater targets
Operated 24-hours, 7 days/week
Electric, flameless unit both quiet and zero-emission
Permitted to strictest Air Quality Management District standards
Easily deployed to high density area
Zero reportable safety incidents
Deployed multiple EDT systems to accelerate treatment production rates
Initial EDT pilot testing successfully treated 1,100 tons of soil to five times below USEPA RSLs (4.4 milligrams per kilogram (mg/kg) PCE and 0.182 mg/kg TCE). Based on demonstrated EDT treatment effectiveness, DTSC approved an extended EDT pilot test to 8,800 tons using a risk-based soil matrix cleanup goal three orders of magnitude lower than the original RSLs (0.0023 mg/kg PCE and 0.0018 mg/kg TCE).
The extended EDT pilot test was successful and DTSC approved EDT as the remedial measure for the remaining 90,000 tons of VOC-impacted soil. Reterro process engineering, supported by instrumentation and pre- and post-soil monitoring, increased soil treatment throughput, provided cost effective operation, and allowed treatment to a very aggressive cleanup target.
Continuous data capture from the EDT process instrumentation, field pre-testing of every batch of soil, analysis of GAC loading, and periodic soil and soil vapor chemical analyses provided multiple lines of evidence to demonstrate the effectiveness of EDT on VOC-impacted soil, which facilitated expedited DTSC closure for site soil.
Within two years from the start of the EDT pilot test, the DTSC issued a Soil Corrective Action Completion for the 100,000-ton soil treatment phase of the RCRA site remediation process.
Alternative to transport and disposal of over 5,000 truckloads of soil and associated emissions and traffic risks
Eliminated landfill costs and liability
On-site EDT treatment was designated “CEQA-insignificant”
Reterro’s technology saved the client from many environmental cleanup liabilities. Because all remediation was done on-site, no transportation permitting, costs, or liability were factors. It is estimated that the on-site EDT treatment avoided transport of over 5,000 truckloads of soil. Traffic risks and associated fuel-burning truck operations are eliminated.
The SCAQMD designated Reterro’s EDT process as “CEQA-insignificant”, saving the densely populated Fullerton community from added health risks (smog and emissions) as well as traffic hazards.
In addition, the client avoided the high cost and long-term liability associated with disposal to a Class I Hazardous Waste Landfill.
Consultant: Hargis + Associates
Contractor: Reterro, Inc.
Subcontractor: RECON Services, LP
Regulatory Oversight: DTSC and SCAQMD