Executive Summary

U.S. taxpayers and corporations are spending large sums of money for the cleanup of contaminated ground water and soil at hundreds of thousands of waste sites across the country. Business analysts estimate that spending on waste site cleanup totaled $9 billion in 1996 alone. Federal accountants estimate that taxpayers will spend between $234 and $389 billion over the next 75 years for the cleanup of contaminated sites on land owned by the Departments of Defense, Energy, Interior, and Agriculture and the National Aeronautics and Space Administration. Estimates have placed the total cost of cleaning up all contaminated sites, privately owned and publicly owned, as high as $500 billion to $1 trillion.

Despite the large sums invested, the problems associated with waste site cleanup are far from solved. Conventional technologies, especially those for cleaning up contaminated ground water, have been unable to restore many types of sites to the standards set by environmental regulations for protection of public health and the environment. For example, the 1994 National Research Council (NRC) report Alternatives for Ground Water Cleanup evaluated the performance of conventional pump-and-treat systems for ground water cleanup at 77 sites and found that regulatory standards had been achieved at only about 10 percent of the sites. The limitations of conventional ground water cleanup technologies are now widely recognized by environmental engineers, scientists, regulators, and others involved in waste site remediation.

The inadequacy of conventional remediation technologies, along with the high costs of remediation, is in part responsible for increasing pressure on policymakers to limit the number of contaminated sites that are actively cleaned up. Yet, leaving contaminants in place rather than cleaning up sites involves costs and uncertainties that are not always recognized. Those responsible for the



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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization Executive Summary U.S. taxpayers and corporations are spending large sums of money for the cleanup of contaminated ground water and soil at hundreds of thousands of waste sites across the country. Business analysts estimate that spending on waste site cleanup totaled $9 billion in 1996 alone. Federal accountants estimate that taxpayers will spend between $234 and $389 billion over the next 75 years for the cleanup of contaminated sites on land owned by the Departments of Defense, Energy, Interior, and Agriculture and the National Aeronautics and Space Administration. Estimates have placed the total cost of cleaning up all contaminated sites, privately owned and publicly owned, as high as $500 billion to $1 trillion. Despite the large sums invested, the problems associated with waste site cleanup are far from solved. Conventional technologies, especially those for cleaning up contaminated ground water, have been unable to restore many types of sites to the standards set by environmental regulations for protection of public health and the environment. For example, the 1994 National Research Council (NRC) report Alternatives for Ground Water Cleanup evaluated the performance of conventional pump-and-treat systems for ground water cleanup at 77 sites and found that regulatory standards had been achieved at only about 10 percent of the sites. The limitations of conventional ground water cleanup technologies are now widely recognized by environmental engineers, scientists, regulators, and others involved in waste site remediation. The inadequacy of conventional remediation technologies, along with the high costs of remediation, is in part responsible for increasing pressure on policymakers to limit the number of contaminated sites that are actively cleaned up. Yet, leaving contaminants in place rather than cleaning up sites involves costs and uncertainties that are not always recognized. Those responsible for the

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization contaminated site must bear the cost of continued liability should contamination escape from the site into surrounding communities. Predicting the potential for such contaminant migration off site is subject to significant uncertainties, so that the full costs of this long-term liability are difficult to calculate. Further, maintaining the site to prevent exposure to the contamination may involve long-term costs. Costs are also associated with decreased property values and difficulty in selling property when significant contamination remains in place. Finally, leaving contamination in place is unacceptable to members of some communities near contaminated sites. Affordable remediation technologies that can remove the bulk of contaminant mass from the subsurface at contaminated sites are needed to reduce the long-term risks, liabilities, and costs associated with these sites. While technologies for waste site cleanup have advanced in recent years, the menu of cost-effective options and use of existing innovative technologies are still limited, especially for contaminated ground water at large, complex sites. Innovative technologies have been selected for ground water restoration at just 6 percent of sites regulated under the Superfund program for contaminated site cleanup, according to recent Environmental Protection Agency (EPA) data. A noncomprehensive review of contaminated sites regulated under the Resource Conservation and Recovery Act (RCRA) found that innovative technologies were being used for ground water cleanup at 13 percent of the sites. A recent General Accounting Office audit of contaminated federal facilities found that "few new technologies have found their way into cleanups." This report analyzes options for stimulating development and commercialization of technologies for reducing the costs and improving the effectiveness of ground water and soil cleanup at contaminated sites. It focuses on technologies that treat contaminated ground water in place in the subsurface and technologies that treat contaminated soil directly at the site, either in place or in a treatment unit. The report suggests ways to strengthen market forces to create demand for innovations in these types of technologies; reviews the status of remediation technology development, identifying where technology needs are greatest; outlines criteria that should be used to assess remediation technology performance; describes strategies for testing remediation technologies to measure their performance against these criteria; and recommends methods for comparing the costs of alternative remediation technologies. The report was written by the NRC's Committee on Innovative Remediation Technologies, appointed in 1994 to develop testing and performance standards for subsurface cleanup technologies and to examine other issues related to commercialization of these technologies. The committee consisted of experts in hydrogeology, soil science, environmental engineering, environmental policy, patent law, finance, and public opinion. The committee's findings, as reported in this study, are based on reviews of technical literature and government reports; consultations with a range of stakeholders involved in waste site remediation, including federal and state regulators, industry groups, heads of start-up,

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization remediation technology companies, and venture capitalists; and the expertise of the committee members. STIMULATING THE MARKET FOR INNOVATIVE REMEDIATION TECHNOLOGIES Despite the billions of dollars being spent on environmental cleanup each year, companies founded on marketing new environmental remediation technologies have fared poorly in almost all cases. Of seven companies that have gone public based on marketing a technology for waste site cleanup, the stock value of six of the companies has dropped since the initial public offering. Although there has been a healthy level of scientific research aimed at developing new environmental remediation technologies, with patent applications in this area increasing from nearly zero in 1980 to more than 430 in 1993– 1994, few of these new scientific ideas have been successfully commercialized. Venture capitalists who could provide the critical funding for moving discoveries from the laboratory to commercial application have generally shied away from the waste site cleanup industry. For example, while total venture capital disbursements to all industries have more than doubled since 1991, venture capital disbursements to environmental technology companies have decreased by more than half during this period. A major failing of national policy in creating a healthy market for environmental remediation technologies is the lack of sufficient mechanisms linking the prompt cleanup of contaminated sites with the financial self interest of the organization responsible for the contamination. Several large corporations evaluated in this study spend an average of about 5 percent of their earnings on waste site remediation, yet corporate managers rarely look to innovative remediation technologies as a means of reducing costs. Under the current system, especially at sites regulated under the Superfund and RCRA programs, it is frequently perceived as more cost-effective for responsible parties to delay cleanup than to install an innovative cleanup system. Even when regulations require site cleanup, the implementation process is long and is easily extended by review and appeals. For example, from a financial perspective, incurring annual costs of $1 million for litigation to delay cleanup at a contaminated site is more cost effective for many companies than initiating a cleanup that might require a $25 million cash outlay. Enforcement of waste site cleanup regulations is inconsistent, so the risk of a major penalty for delaying cleanup is low. Adding to the incentive to delay is the possibility that legislative reforms will relax the requirements for site cleanup at some future date, making it financially unwise to invest in technologies to reach today's more stringent cleanup goals. Companies that make an effort to initiate waste site cleanups promptly may be placed at a competitive disadvantage when compared to competing companies that delay cleanup. The result of the failure to link prompt cleanup of contaminated sites to corporate financial self interest is low demand in the private-sector market for environmental

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization remediation technologies that can achieve improved performance at lower costs. Environmental remediation technologies are more of a legal product than a technological one, and there is little or no premium for improved solutions to subsurface contamination problems. In the public-sector environmental remediation market, inadequate cost containment has contributed to delays in remediation and has decreased incentives for selecting innovative remediation technologies. According to the General Accounting Office, federal remediation contractors are often placed on ''auto pilot" after being awarded a cleanup contract on a cost-reimbursable basis. With no incentive to contain costs, and in fact an incentive not to do so, quick action and cost effectiveness in remediation technology selection go unrewarded. Delays in waste site remediation occur not just because of lack of financial incentives for prompt action but also because of the long time period that can be required to obtain regulatory approval of a cleanup plan and because of technical uncertainties. According to a Congressional Budget Office review, the average time between the proposal for listing a site on the Superfund National Priorities List and construction of the cleanup remedy is 12 years. While delays due to technical uncertainties are unavoidable, delays due to slow action by site owners and slow approvals by regulators need to be controlled in order to revitalize the market for innovative remediation technologies. Start-up remediation technology development companies have gone out of business while awaiting all of the final approvals necessary to use their technology at a large enough number of sites to stay solvent. Delays in environmental remediation discourage investment in these start-up companies due to the inability to predict the timing of investment returns. Other factors also contribute to the weakness of the remediation technologies market and the poor success record of new remediation technology ventures. These include unpredictable time lines for remediation technology selection, which prevents technology developers and investors from accurately projecting investment returns; lack of consistent regulatory standards among various regulatory programs (Superfund, RCRA, underground storage tank, and state) and even within programs, making it difficult for technology developers to assure potential customers that their technology will meet regulatory approval; and lack of market data due to reluctance to disclose information about the magnitude and nature of site contamination problems, precluding the development of accurate market assessments for new technologies. Recommendations: Stimulating Markets To stimulate the market for innovative ground water and soil cleanup technologies, the committee recommends a variety of initiatives. Some of these are targeted at creating strong links between the financial self interest of those responsible for site contamination and the rapid initiation of site cleanup activities.

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization Others are intended to increase the certainty of the regulatory process so that technology developers and investors can more accurately predict their potential investment returns. (See Chapter 2 for a detailed description of these strategies.) The U.S. Securities and Exchange Commission (SEC) should clarify and strictly enforce requirements for disclosure of environmental remediation liabilities by all publicly traded U.S. corporations. Clarifying the existing requirements for reporting of environmental liabilities and strictly enforcing these requirements would provide an incentive for companies to initiate remediation, rather than delaying it, in order to clear their balance sheets of this liability. Detailed accounting procedures for complying with this requirement, along with a mechanism for certifying environmental accountants, need to be established by the U.S. accounting profession, possibly using the model of the International Standards Organization's series of standards for environmental management systems. Although technical uncertainties will preclude exact computations of remediation liabilities, companies should nonetheless be required to report their best estimates of these liabilities using reasonable estimate of probable remediation scenarios. The SEC should enforce environmental liability reporting requirements through a program of third-party environmental auditing. The possibility of an environmental audit, along with strong penalties for failing the audit, would help ensure that companies would comply with SEC requirements to report environmental liabilities. Certified public accountants, ground water professionals, or all of these could conduct the audits after receiving appropriate training. Congress should establish a program that would allow companies to amortize the remediation liabilities they report over a 20- to 50-year period. Such a program would ensure that by fully evaluating and disclosing their remediation liabilities with the best available current information, companies would not risk losing a major portion of their asset value. It would also provide a measurable cost target for remediation technologies to beat (the total cost of the declared liabilities). The EPA should work to improve enforcement of Superfund and RCRA requirements. Consistent, even-handed enforcement is essential for ensuring that U.S. companies are not placed at a competitive disadvantage compared to their domestic competitors by spending money on environmental remediation. Managers of federally owned contaminated sites should hire remediation contractors on a fixed-price basis and should establish independent peer review panels to check progress toward specified remediation milestones. Such steps are necessary to provide stronger incentives for federal remediation contractors to implement efficient, innovative solutions to contamination problems. When site complexities result in remediation costs that exceed

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization the initial estimates, the peer review panel could verify that the cost increase is technically justified. The EPA should review procedures for approving remediation technologies in its 10 regions and should develop guidelines for increasing the consistency and predictability of these procedures among regions and across programs; to the extent possible, state programs for contaminated site cleanup should follow these guidelines. A consistent regulatory process that responds rapidly to approval requests is essential so that remediation technology developers can predict with reasonable certainty the steps that will be required for regulatory approval of their technology and how long they may have to wait before receiving their first job contract. While the process for remedy selection should be the same at each site, site managers must have the flexibility to consider any remediation technology that they believe will meet regulations at the lowest possible cost, provided the public has sufficient opportunity to voice concerns during the remedy selection process and to challenge the selected remedy. Congress and the EPA should assess the arguments for and against establishing national standards for ground water and soil cleanup. While some states are adopting state-wide cleanup standards, no national standards exist. Such standards might increase the predictability of the remediation process and consistency in the approaches used in the many remediation programs; predictability and consistency would benefit technology developers by providing them with a more certain end point for remediation. On the other hand, such standards might have the detrimental effect of decreasing flexibility in site remediation. The issue of whether national cleanup standards are advisable should be carefully considered. The U.S. General Accounting Office should investigate the Massachusetts program for licensing site professionals to select remediation technologies on behalf of environmental regulators and should recommend whether such a program should be implemented nationally. Such a program might help eliminate delays associated with regulatory approval steps. The EPA should establish a national registry of contaminated sites similar to the Toxics Release Inventory and should make it publicly available on the Internet. Such a registry would allow technology developers to assess the size and characteristics of different segments of the remediation market. It would also provide an incentive for companies to clean up sites quickly in order to remove them from the registry. Although there is political pressure to avoid including contaminated sites on registries because of the perceived stigma associated with owning a site on such a list, public disclosure of contaminated site information is essential for ensuring that accurate and complete information about the remediation market is widely available. Federal agencies should continue to support and expand programs for testing innovative remediation technologies at federal facilities . Providing opportunities for testing full-scale technology applications is essential for new

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization technology ventures that need cost and performance data to provide to potential clients. ADVANCING THE STATE OF THE PRACTICE OF GROUND WATER AND SOIL CLEANUP Although considerable effort has been invested in ground water and soil cleanup, the technologies available for these cleanups are relatively rudimentary. Relatively effective and well-understood technologies are available for easily solved contamination problems—mobile and reactive contaminants in permeable and homogeneous geologic settings—but few technologies are available for treating recalcitrant contaminants in complex geologic formations. The greatest successes in remediation to date have been in the treatment of petroleum hydrocarbon fuels (gasoline, diesel, and jet fuel) because these are generally mobile and biologically reactive, but technologies for addressing other types of subsurface contamination problems are in short supply. Comparatively more technologies are available for treating contaminated soil than for treating contaminated ground water. While government agencies and others are investing considerable effort in remediation technology research, much more work in research, development, and field-scale application of remediation technologies is needed before ground water and soil contamination problems can be adequately solved. The greatest challenge in remediation is in the location and cleanup of contaminant mass in the subsurface that can serve as a long-term source of ground water pollution and lead to the formation of extensive plumes of contamination. Plumes of ground water contamination generally originate from material existing in a nonaqueous phase (in other words, from masses of contaminants that initially are not dissolved in the water but that slowly dissolve when in contact with water). Sources of contamination may include organic solids, liquids, or vapors; inorganic sludges; compounds adsorbed on mineral surfaces; and compounds adsorbed in natural organic matter such as humus. Often, contaminant sources are difficult to locate and delineate. Once found, source material may be inaccessible, lying under structures, or at great depth, or in fractured rock. Because of the possibility of continual release of contaminants to ground water, partial source removal may not result in a proportional increase in ground water quality. The source may remain in place for a very long time because dissolution, while fast enough to create a potential hazard, may be too slow to result in rapid elimination of the source. Pumping treatment fluids to the region where sources are located may be very difficult due to hydrogeologic complexities. Added complexities arise during treatment of sources containing mixtures of contaminants because of the variable effects of treatment processes on different types of contaminants. Chapter 3 provides a detailed listing of specific research needed for improving the ability to clean up contaminant mass in ground water and soil. Lack of information has contributed to the slow transfer of new ideas for

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization remediation technologies from the laboratory to the field and from one site to another. Technology reports are often incomplete and lacking in critical scientific evaluation and peer review. Reliable cost data are also lacking. Moreover, much information on prior experiences with remediation technologies is proprietary. While several data bases on innovative technologies exist, none of these provides complete coverage of every application or test of every available remediation technology used in every remediation program. This lack of coordinated, high-quality information make it difficult to compare technologies based on rational scientific evaluation. Recommendations: Technology Information Three types of activities are needed to improve the quality and availability of data on remediation technology performance. In addition to these activities, detailed research at the laboratory and field scales (see Chapter 3 for recommendations) is needed to increase the number of available remediation technologies and the efficiency of existing technologies. The EPA, in collaboration with other stakeholders, should increase the scope and compatibility of data bases containing remediation technology performance information and should make these data bases available on the Internet, with a single World wide Web page including links to all of the data bases. Improvements in information collection, assessment, and dissemination are needed to speed development and commercialization of remediation technologies. While a single, centralized data base will likely be unwieldy and may not satisfy the diverse interests of various users, a goal for the EPA should be to develop comprehensive and electronically accessible data bases that can be readily distributed and manipulated by different contributors and users. A consistent framework for data entry and retrieval should be developed and used in all the data bases. Government agencies, remediation consultants, and hazardous waste site owners should work to increase the sharing of information on remediation technology performance and costs. Incentives should be developed to encourage submission of technology performance and cost data to the national data bases. Government agencies, regulatory authorities, and professional organizations should undertake periodic, comprehensive peer review of innovative remediation technologies. This type of activity will help define the state of the art, build consensus, and provide a standard for design and implementation of functional and cost-effective remediation technologies.

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization ESTABLISHING MEASURES OF SUCCESS FOR INNOVATIVE REMEDIATION TECHNOLOGIES While many industries, such as the automotive and aerospace industries, have developed uniform standards for evaluating product performance, no such standards exist for ground water and soil cleanup technologies. Property owners responsible for site cleanup, citizen groups, state and federal regulators, and technology developers all may have different perspectives on how technologies should be evaluated and selected. There is currently no standardized mechanism for reconciling these differing expectations. Yet, to be widely applied, a technology must not only be a success in that it meets technical performance criteria, but it also must be accepted by these numerous stakeholders in site remediation. Any protocol used to test innovative remediation technologies must address common stakeholder expectations in some fashion if successful application is to follow. Disagreements among stakeholders may arise due to many issues, but the critical disputes often center on the effectiveness of the technology in reducing health and environmental risks and the cost of the technology. Disputes over the level of risk reduction the technology must achieve arise because assessing the health and environmental risks of ground water and soil contamination is an uncertain process, and there is controversy over how to interpret results of risk assessments. Major uncertainty exists in determining accurate levels of exposure to contamination and the level of health or environmental damage caused by the contaminants. In evaluating remediation technologies, indirect quantitative criteria must substitute for a direct measure of the level of risk reduction the technology can achieve. The best measures for comparing the ability of different technologies to reduce health and environmental risks are the technology's ability to reduce contaminant mass, concentration, toxicity, and mobility because these criteria indicate the degree to which the technology can reduce the magnitude and duration of exposure to the contamination. Disputes over costs of hazardous waste cleanup may arise because the affected public may want to "fix the contamination problem irrespective of costs" whereas site owners may wish to "manage the problem at the lowest possible cost." While there is no easy to resolve this conflict, involving the public early in evaluating possible remedies for the site can minimize the acrimony. Anecdotal evidence from case studies examined in this report suggests that if the public were involved earlier in the decision-making process as a matter of routine, the universe of technologies taken under consideration might more routinely include innovative technologies. Recommendations: Establishing Success Criteria Increased attention to the concerns of all the groups affected by hazardous waste sites is needed to streamline the process of remediation technology selec-

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization tion and to remove some of the obstacles to acceptance of innovative technologies. (See Chapter 4 for a detailed review of the factors of concern to stakeholders involved in site remediation.) The EPA and state environmental regulators should amend their public participation programs and require that public involvement in contaminated site cleanup begin at the point of site discovery and investigation . An informed public is better prepared to participate in the review of technology selection options and to consider innovative remediation technologies. Once site data are collected, the data should be made available at a convenient, accessible location of the public's choosing. While some members of the public desire short, factual data summaries, others may have expertise that equips them to review and evaluate the full studies, including laboratory analytical data and study protocol. To further assist the community, sources of toxicological and health information on contaminants of concern, as well as technical data collected from other sites where different technologies have been implemented and assessed, should also be provided. Technology developers should consider the potential concerns of all stakeholders in remediation, including members of the public, when testing the performance of remediation technologies. Even if a technology meets technical and commercial measures of success, strong opposition from the public or other stakeholders may make it undesirable. Technology developers should report the effectiveness of their systems in reducing public health and environmental risks based on the technology's ability to reduce contaminant mass, concentration, mobility, and toxicity. These measurable, technology-specific criteria are surrogates for environmental and health effects because they quantify the degree to which the technology can reduce exposure to the contamination. Technology developers should report the range of uncertainty in these measured values to allow for meaningful comparisons of risk reduction potential offered by different technologies. Technology developers should specify the performance of their technology at the point maximum effect and should indicate the distance of that point from the location where the technology is applied under some known or standardized flow or residence time conditions. Depending on the technology and how it behaves in the field, the full effect of a technology in reducing risk may occur at some distance from the actual point of application. Specifying the point of maximum effect and its distance from the technology installation will improve technology comparisons. TESTING INNOVATIVE TECHNOLOGIES Just as there are no standard criteria for evaluating the success of innovative ground water and soil cleanup technologies, there are also no standard protocols

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization for testing new product performance. This lack of protocols contributes to the difficulties that remediation technology developers face in trying to persuade potential clients that an innovative technology will work. The types of data collected for evaluating remediation technology performance vary widely and are typically determined by the preferences of the consultant responsible for selecting the technology, the client, and the regulators overseeing remediation at the contaminated site. Performance and cost data collected at one site are thus often insufficient for predicting how the technology will perform at another site. The Federal Remediation Technologies Roundtable has issued guidelines for collection and reporting of remediation technology performance data at federal sites, but no standard process exists for data collection and reporting at privately owned sites, and the degree to which the roundtable's guidelines are applied at federal facilities is unclear. A variety of federal and state programs exists for evaluating remediation technology performance data, but these programs are not coordinated. For example, the state of California has different requirements for documenting technology performance than the Federal Remediation Technologies Roundtable, the Southern States Energy Board, and the Western Governors Association. The EPA has a national program, the Superfund Innovative Technologies Evaluation (SITE) program, for evaluating remediation technology performance data, but its scope and funding are limited. A technology developer may spend large sums testing a technology under one of the existing evaluation programs or according to one agency's procedures, only to learn that the data are not acceptable to potential clients or environmental regulators who are not specifically involved in the program under which the technology was evaluated. As a result of the lack of standard procedures for collecting, reporting and evaluating data on remediation technology performance, a great deal of money is spent on site-specific tests. Testing costs could be minimized if standard remediation technology performance data and a widely recognized national evaluation program were available. Some site-specific testing of remediation technologies will always be required prior to technology installation in most situations, but the requirements for site-specific testing would decrease if standard, verified data were easily available. Increasing standardization of data collection, reporting, and evaluation would also enable more accurate predictions of remediation technology performance at a new site. While the specific protocols used to test and evaluate a remediation technology will vary with the technology, common principles apply to all technologies, and standard types of performance data can be reported in a standard format for all types of technologies. Recommendations: Technology Testing Remediation technology developers, owners of contaminated sites, and environmental regulators all can take steps to increase the consistency in testing, re-

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization porting, and evaluation protocols for assessing remediation technology performance. (Chapter 5 provides a detailed description of general principles that should be followed in testing innovative remediation technologies and a set of guidelines for determining the amount of additional testing required to assess the performance of a remediation technology that has been used elsewhere.) In proving performance of an innovative remediation technology, technology developers should provide data from field tests to answer the following two questions: Does the technology reduce risks posed by the soil or ground water contamination? How does the technology work in reducing these risks? That is, what is the evidence proving that the technology was the cause of the observed risk reduction? To answer the first question, the developer should provide two or more types of data, both leading to the conclusion that contaminant mass and concentration, and/or contaminant toxicity, and/or contaminant mobility decrease following application of the technology. To answer the second question, the developer should provide two or more types of evidence showing that the physical, chemical, and/or biological characteristics of the contaminated site change in ways that are consistent with the processes initiated by the technology. In deciding how much site-specific testing to require before approving an innovative remediation technology, clients and environmental regulators should divide sites into the four categories shown in Figure ES-1: (I) highly treatable, (II) moderately difficult to treat, (III) difficult to treat, and (IV) extremely difficult to treat. For category I sites, site-specific testing of innovative remediation technologies should be required only to develop design specifications; efficacy can be determined without testing, based on a review of fundamental principles of the remediation process, properties of the contaminated site, and prior experience with the technology. For category II sites, field pilot testing should be required to identify conditions that may limit the applicability of the technology to the site; testing requirements can be decreased as the data base of prior applications of the technology increases. For category III sites, laboratory and pilot tests will be necessary to prove efficacy and applicability of the technology at a specific site. For category IV sites, laboratory and pilot tests will be needed, and multiple pilot tests may be necessary to prove that the technology can perform under the full range of site conditions. All test of innovative remediation technology performance should include one or more experimental controls. Controls (summarized in Chapter 5) are essential for establishing that observed changes in the zone targeted for remediation are due to the implemented technology. Failure to include appropri-

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization FIGURE ES-1 Treatability of contaminated sites and level of site-specific testing of remediation technologies required as a function of contaminant and geologic properties. Note that "H" indicates high and "L" indicates low volatility, reactivity, or solubility. (See Table ES-1 for a listing of the contaminant compounds.)

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization TABLE ES-1 Classes of Compounds Shown in Figure ES-1 Contaminant Class (as shown in Figure ES-1) Volatility, Reactivity, and Solubility Example Contaminants A HHL Hydrocarbon fuels; benzene, toluene, ethylbenzene, and xylene B HLL Trichloroethane, trichloroethylene, tetrachloroethylene C HHH Acetone D LHH Phenols, glycols E HLH Methyl tertiary-butyl ether, tertiary butyl alcohol, methylene chloride F LHL Naphthalene, small polycyclic aromatic hydrocarbons (PAHs), phthalates G LLH Inorganic mixtures, metals of different chemistries H LLL Polychlorinated biphenyls, pesticides, large PAHs NOTES: Volatility: High (H) > approximately 10 mm Hg; Low (L) < approximately 1 mm Hg Reactivity: High indicates biodegradable, oxidizable compound; Low indicates recalcitrant compound Solubility: High > approximately 10,000 mg/liter; Low < approximately 1,000 mg/liter ate controls in the remediation technology performance testing protocol can lead to failure of the test to prove performance. The EPA should establish a coordinated national program for testing and verifying the performance of new remediation technologies. The program should be administered by the EPA and implemented either by EPA laboratories, a private testing organization, a professional association, or a nonprofit research institute. It should receive adequate funding to include the full range of ground water and soil remediation technologies and to test a wide variety of technologies each year. A successful test under the program should result in a guaranteed contract to use the technology at a federally owned contaminated site if the technology is cost competitive. The program should be coordinated with state agencies so that a technology verified under the program does not require additional state approvals. Applications for remediation technology verification under the new verification program should include a summary sheet in standard format. The summary sheet should include a description of the site at which the technology was tested, the evaluation methods used to prove technology performance, and the results of these tests. It should also include a table showing the types of

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization data used to answer each of the two questions needed to prove technology performance. Applications for remediation technology verification should specify the range of contaminant types and hydrogeologic conditions for which the technology is appropriate. Separate performance data should be provided for each different major class of contaminant and hydrogeologic setting for which performance verification is being sought. Data gathered from technology performance tests under the verification program should be entered in the coordinated national remediation technologies data bases recommended above. Data should be included for technologies that were successfully verified and for those that failed the verification process. Technology development partnerships involving government, industry, academia, and other interested stakeholders should be encouraged. Such partnerships can leverage resources to speed innovative technologies through the pilot testing phase to commercial application. COMPARING COSTS OF INNOVATIVE TECHNOLOGIES One of the greatest challenges in selecting systems for ground water and soil cleanup is the development of reliable cost data. Comparing costs of different remediation technologies can be difficult in some situations and impossible in others, for several reasons. First, costs reported under a set of conditions at one site are difficult to extrapolate to other sites with different hydrogeologic and contaminant characteristics. Second, technology vendors may report costs using a variety of different metrics (such as dollars per volume treated, reduction in contaminants achieved, mobility reduction achieved, weight of contaminant removed, or surface area treated); these different metrics may not be comparable. Third, assumptions about what cost elements should be included in the cost estimates and what interest rates should be used to project long-term costs vary considerably. For example, cost estimating systems used by the federal government, such as the federal work breakdown structure, vary from those used by the private-sector. Fourth, private-sector companies rarely compile cost information and release it for public use, so that it is often impossible to obtain actual cost data from completed projects. Cost uncertainties are especially a problem when evaluating whether to use an innovative remediation technology. While remediation consultants can gauge the costs of conventional technologies based on their experience with prior applications of the technology, no historical record or only a very limited record exists for estimating costs of innovative remediation technologies. Uncertainties about costs add to the disincentives to select innovative remediation systems. The uncertainties about what the new technology will cost, combined with the technical

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization uncertainty over whether it will perform as expected, may, in the client's view, outweigh the potential benefits of using the technology. Recommendations: Comparing Costs To improve the ability to compare costs of different remediation technologies and to extrapolate cost data from one site to another, a variety of strategies are needed to standardize current cost estimating and reporting procedures. (See Chapter 6 for a detailed critique of existing cost reporting procedures and a description of mechanisms for standardizing cost reporting.) The EPA should convene a working group composed of representative problem owners (corporations and government agencies) and technology developers to develop and refine a standardized system of ''template sites" for comparing the costs of ground water and soil remediation technologies. The template sites should provide realistic models of contamination scenarios for use in developing cost comparisons. The EPA might convene the working group under the auspices of an established organization such as the Remediation Technologies Development Forum or the American Academy of Environmental Engineers. The working group should develop several templates to represent the range of conditions of contaminant depth, aquifer thickness, and aquifer permeability. Once the templates are developed and refined, federal agencies and private corporations should request that remediation technology vendors present cost data in the template format if the technology is to be evaluated for purchase. The templates can then be used to provide screening-level comparisons of remediation technologies designed to achieve the same level of public health and environmental protection. More detailed cost data, based on actual site conditions, would then need to be developed for the technologies that pass this first level of screening. The Federal Remediation Technologies Roundtable should reevaluate the role of the work breakdown structure in standardizing federal remediation cost reporting and should document the system in a way that facilitates understanding by the private-sector. The federal work breakdown structure, a mechanism for tabulating costs of federal projects, may be too rigid in format to be appropriate for standardizing costs for the wide range of remediation needs and may not be an efficient tool for the private-sector to use in developing cost estimates for new technologies. The role of the work breakdown structure should be reevaluated and a guidance manual prepared to help the private-sector use this tool. The instruction manual should be advertised to remediation technology providers and users and should be available in an on-line version. Costs of remediation technologies should be included in the coordinated national remediation technologies data bases recommended above and should always be reported as cost per unit volume of the contaminated ma-

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Innovations in Ground Water and Soil Cleanup: From Concept to Commercialization trix treated and as cost per weight of contaminant removed, treated, or contained. The starting concentration of the contaminant, amount of material cleaned up, and process rate should be provided along with these cost data because unit costs may change with the amount of contamination or contaminated material treated Cost estimates should include one-time start-up costs as well as up-and-running costs. Start-up costs include the costs of site preparation, equipment mobilization, pilot testing, permitting, and system design, yet frequently these are not included in cost estimates. Assumptions about discount rates and tax benefits should be clearly stated in estimates of present costs of a technology that operates over an extended time period. In developing cost estimates for technology users, technology providers should tailor their assumptions about discount rates and taxes to the needs of the user, which vary widely. In summary, a combination of market incentives, research, and improved technology testing and evaluation strategies is needed to advance the capability to clean up ground water and soil at contaminated sites. Existing technologies have high costs and are inadequate for solving many types of contamination problems. If the United States is to protect the public health from risks associated with ground water and soil contamination, while avoiding needlessly exorbitant spending of taxpayer and corporate resources, then the federal government and others responsible for overseeing contaminated sites need to give high priority to the development of creative new solutions to site cleanup problems.