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EBC Emerging Contaminants Program: PFAS Remediation and Disposal PFAS Detected, What’s Next?

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EBC Emerging Contaminants Program:

PFAS Remediation and Disposal – PFAS

Detected, What’s Next?

Welcome

Daniel Moon

President & Executive Director

Environmental Business Council

Environmental Business Council of New England

Energy Environment Economy

Welcome

Blake Martin

Vice President

Weston & Sampson

Environmental Business Council of New England

Energy Environment Economy

Thank you to our Host

EBC Committees & Chapters

Environmental Business Council of New England

Energy Environment Economy

Climate Change and Air Committee

Dam Management Committee

Energy Resources Committee

Infrastructure Committee

Ocean and Coastal Resources Committee

Site Remediation and Redevelopment Committee

PCB & Emerging Contaminants Subcommittee

Solid Waste Management Committee

Water Resources Committee

Ascending Professionals Committee

Connecticut Chapter

New Hampshire Chapter

Rhode Island Chapter

EBC PCB & Emerging Contaminants

Subcommittee

Environmental Business Council of New England

Energy Environment Economy

Committee Chair

Frank Ricciardi, Weston & Sampson

Leadership Team

Malcolm Beeler, Weston & Sampson

Elizabeth Denly, TRC

Steven LaRosa, Weston & Sampson

Jim Occhialini, Alpha Analytical

Timothy Snay, Ransom Consulting

Programs

Access

Networking

EBC Membership Benefits

Environmental Business Council of New England

Energy Environment Economy

Upcoming Programs

Environmental Business Council of New England

Energy Environment Economy

July 26: New England Climate Change Summit

July 31: Treatment & Disposal of PCBs in Building Materials

Aug 1: Connecticut Program: PFAS Overview

Aug 6: Rhode Island Chapter Summer Gathering

Aug 8: 25th Annual Summer Garden Party

Sept 12: Annual Portsmouth, NH Harbor Cruise

Sept 17: Briefing from MassDEP Solid Waste Section Chiefs

Sept 20: Climate Adaptation Forum – Public Health

Sept 26: Connecticut Climate Change Update

Sept 27: Ocean Resources, Coastal Contamination

1. Presentations will be posted to “ebcne.org”– Link to location of presentations in follow-up email

2. Get involved in EBC Chapters and Committees– Join Leadership Teams

– Join Google Group for each committee / chapter

• Email request to [email protected]

3. Ask questions during presentations– Don’t hesitate to interrupt the speaker

4. Audience Introduction

Final Notes

Environmental Business Council of New England

Energy Environment Economy

Program Purpose – What You Will Learn

AnnieLu Dewitt

Program Co-Chair

PFAS Water Treatment Lead

Clean Harbors

Environmental Business Council of New England

Energy Environment Economy

11

11 July 25, 2019 - Clean Harbors Company Confidential

Introduction to the EBC PFAS Treatment and Disposal Program

EBC Program July 24th, 2019

12

What Questions Are We Hoping To Answer Today About the Current State of the PFAS Treatment and Disposal Field

• How did we get here?

• Where are we now?

• Where do we think this field is heading?

• What technologies are widely accepted for water and soil treatment and disposal?

• What are the developing technologies out there for managing PFAS impacted material?

• Review Case Studies of Ongoing Treatment projects

• Review the Lifecycle of a PFAS Water Treatment Project

13

How Did We Get Here

• UCMR 3 2012-2015 Public water supplies identified communities impacted by PFOA and PFOS

• Advances in Laboratory Testing- at the time of the UCMR 3 testing rounds the reporting limit was 200 ppt for a number of laboratories. By 2016 the industry standard dropped to 2-5 ppt and additional compounds were added to PFAS testing methods

• Public Awareness- NY, NH,VT and NC followed by MI in 2017.

• Flint, MI- “Flintification” states decided to get out in front of potential drinking water contamination issues

14

Federal Regulatory Status - PFAS

• June 27, 2019, the US Senate passed legislation to regulate per- and polyfluoroalkyl chemicals (PFAS) as a rider to the 2020 defense spending bill (S1790)

• Passed the House on July 12th,

• There appears to be gaps between house and senate bills on funding. The expectation

is that the states will continue to drive this process for the next one to two years.

• Manufacturers must list air and water PFAS discharges on TRI

• PFOA & PFOS managed under TSCA• With in 1 year EPA propose interim standards on

destruction and disposal • Expected that PFAS will be regulated as a hazardous

substance under CERCLA• EPA has established the health advisory levels at 70 parts

per trillion

15

State Regulatory Status - PFAS

• Many states are regulating PFAS more stringently than EPA has proposed

• MI,VT, NH, NJ, WI, MN, RI, MA, NC,MN and CA are all states that are rapidly going farther than then the federal guidelines

• States are moving to ranges of 10-20 ppt vs.70 ppt federally proposed

• NY State: Governor Cuomo has announced $350M to be available for drinking water projects

16 New EPA Method 8327 Compound list

• The new EPA PFAS testing method is finishing up it’s comment period. It is a direct injection method to address other matrixes besides drinking water. This new method will standardize methodologies and allow for better comparison of data between laboratories. Same LC/MS/MS instrumentation.

• PFBS PFBA

• PFPeS PFPeA

• PFHxS PFHxA

• PFHpS PFHpA

• PFOS PFOA

• PFNS PFNA

• PFDS PFDA

• 4:2 FTS PFUdA

• 6:2 FTS PFDoA

• 8:2 FTS PFTrDA

17 Where is the PFAS Treatment Field Heading

• How low can standards go? Just because we can does not mean we should. Going below 2 ppt is achievable. However, going lower opens up the possibility of detecting ambient levels of PFAS in the environment and potential laboratory background contamination calling results into question

• New technologies are being developed and the ones that can be made economically feasible and scalable will gain momentum

PFAS Water Treatment Lifecycle

AnnieLu DeWitt

PFAS Water Treatment Lead

Clean Harbors

Environmental Business Council of New England

Energy Environment Economy

19

19 July 25, 2019 - Clean Harbors Company Confidential

The Lifecycle of a PFAS Project

20

Terminology

PFAS Is a broad term used to encompass per-fluoroalkylsubstances and poly-fluoroalkyl substances. Please note that there are many synonyms for the same compounds. Nomenclature of organic chemistry is similar to dialects of the same language. Therefore, if possible you use CAS numbers to simplify the possible confusion of having different methods of nomenclature to reference the same analyte.

• Per-fluoroalkyl substances- subset of PFAS that describes fully substituted alkyl chains where fluorine replaces the hydrogen.

• Poly-fluoro alkyl substances- subset of PFASs that describes compounds where not all of the hydrogens have been substituted with fluorine.

• There are over 2000 known PFAS compounds. PFOA and PFOS are just two of the PFAS. The others until identified can be considered as “dark matter” possibly present but not qualified or quantified. Not an issue to qualify and quantify as but it is a matter of identifying.

21

PFAS Definition

PFAS are per and poly-fluorinated chained carbon compounds

They are used to make fabrics water-proofNon-stick cookwareAFFF (Aqueous Film Forming Foams)Popcorn BagsPost-It NotesCountless Manufacturing Processes

22

History of PFAS Production

• In 1938 at Dupont in Deepwater, NJ Teflon was created by accident in a failed refrigerant experiment. The waxy material produced proved to be the most slippery material in existence.

• 1951 Dupont makes C8 to make Teflon and related polymers at the Washington Works plant near Parkersburg, W. VA and by Minnesota Mining (3M)

• 1956 3M begins selling Scotchgard protector

• 1962 FDA approval for Teflon cookware

• 1967 FDA approval of Zonyl for use in food packaging

23 Commercial and Consumer Products containing PFAS

• paper and packaging

• clothing and carpets

• outdoor textiles and sporting equipment

• ski and snowboard waxes

• non-stick cookware

• cleaning agents and fabric softeners

• polishes and waxes, and latex paints

• pesticides and herbicides

• windshield wipers

• paints, varnishes, dyes, and inks

• adhesives

• medical products

• personal care products (for example, shampoo)

24

Where Are They Found

• DoD will be testing every base in the U.S. estimated to be over 600 sites (article in NY Times claims number is at 2000 now)

• Municipalities Drinking Water and Wastewater

• Landfills

• Airports

• Superfund Sites

• End-user Industrial Clients

• Plating Facilities

• Biosolids

• Fire Department Training Centers

25

Project LifeCycle Stages

• Identify- Characterize water with applicable test methods

• Pilot Study

• Define Project Objectives

• Select Best Fit Approach

• Choose Equipment

• O&M /Service System

• Final Deposition (landfill, reactivation, incineration)

26 Identification

• Analytical Lab Choice- experience is important. For example, multiple runs may be required to meet low detection levels if there are high concentrations for other PFAS compounds. 6:2 FTS dwarfing PFOS

• Choosing Appropriate Compound List- EPA Method 8327, DoD list, not all labs have GenX standards

• Currently modified 537 is not standardized across laboratories. The new EPA 8327 will create standardization between laboratories. The question now is when do you make the switch to the new method and how, do you run both methods for a period of time and what will the added cost be. For low flow systems analytical becomes a huge additional cost per gallon treated

• Test for other analytes that might interfere with adsorption and ion exchange. TOC, Fe, PO4, TDS

• TOP Assay- Total Oxidisable Precursor Assay analytical method helps to identify “dark matter” Good for initial influent water characterization

27 Examples of C8

Generic PFC structures. The 8-carbon (8C) structures are shown. The 8C, or "long-chain" structures are generally the most persistent.

28

Unidentified PFAS Compounds

• Unidentified PFAS compounds can be considered “dark matter” they consume media and shorten life expectancy of media

• Double-edged sword low detection limits means very selective identification

• Top Assay offers ability to gently oxidize and break compound down to base structures that can be measured. Not qualitative but helps with quantitation

29 Pilot Study

Once analytical is evaluated a pilot study demonstrates a scaled down version of a proposed full scale system. It also allows for evaluation of systems that have variability in influent over time. Especially useful in production facilities where influent varies between batches and processes. Pilot studies also allow for competitive adsorption to be identified and more accurate exchange rate estimations for media.

30

Define Project Objectives

• Most important stage

• Requires communication of limits to be achieved 2ppt, 70ppt for PFOA, PFOS combined, GenX, PFNA, combined list of compounds to not exceed 70 ppt

• Media requirements, Is GAC the only acceptable technology for a municipality

• Discharge permits, pH spikes from treatment

• Space Constraints sizing for 10 minute EBCT means big vessels

31

Select Best Fit Approach

• Balancing cost and performance

• Depending upon concentration and flow there will be a best fit solution

• For example, very low flow and high concentration may be best for straight incineration

• Very high concentration and high flow may be best for a resin application. Smaller vessels and higher capacity for media.

• Moderate concentrations and medium flow is where other considerations will sway which approach makes the best sense for a project. For example, remote location may dictate remote monitoring and high capacity media in a conex box.

32

Current Options for Treatment• GAC- Widely accepted treatment option for PFOA

and PFOS shorter chained PFAS compounds dictate very short exchange cycles

• Resin- Different resins are good options for longer chained compounds, PFOA, PFOS and for shorter chained PFAS that are poorly adsorbed by GAC. Shorter EBCT

• Oxidation and other destructive technologies- have shown effectiveness of breaking down longer chained compounds. Our hesitation is that with the complex influent water we see and rapid deployment we may not have time to do full studies to calculate required energy in a timely manner. A static system would be an ideal situation for this type of application

• Incineration of water

• Additives - Effective for reducing PFAS in highly concentrated waste streams

• Reverse Osmosis- Very effective with PFAS compounds but the reject stream can be substantial and skilled RO operators are in very demand

Emerging Contaminant Support Services

33 Choose Equipment

When choosing equipment for a project it is important to make the most of the available resources. Weighing rental and purchase decisions. Many times we have customers choose to rent equipment in the beginning for PFAS projects. There is hesitation to invest in a solution that may evolve with changing regulations. Guidance from states is increasingly lower reporting levels. VT, MI, NJ, CT, MA,RI, NH,NC,NY

34

O&M/ Service

• With PFAS projects analytical is an important part of the operation and maintenance program. Proper sampling, monitoring for breakthrough and performance confirmation

• Vessel swapping or on-site service. Remote locations can benefit from a vessel exchange program for lower flow applications

• Documentation of variables in system, flow, pH, pressure drop assist with optimizing treatment

35

Final Deposition of Media

• There are currently three options for media at the end of it’s lifecycle

• Landfill- many landfills are not accepting PFAS material.

• Reactivation- Investigate to make sure temperature is adequate to destroy the C-F bond

• Incineration- Is the current BDAT (best demonstrated available technology) destruction of media has been increasingly the choice for customers

36

Current CH Projects

• We have full scale current projects across the country that are in the ppt to ppm range consistently achieving ND levels (2-5 ppt)

• Piloting systems that evaluate difficult to treat systems to identify best pre-treatment and associated PFAS treatment.

• Every application is different and many times the pre-treatment requires more attention than the actual PFAS removal

• GAC and GAC/Resin solutions with associated pre-treatment. Concentrate contaminants onto media by adsorption and or ion exchange and then dispose of media

• Direct incineration of water and soil

37

Industrial Wastewater High Concentration PFAS Treatment

PFHxA

4:2 FTS0

10

20

30

40

Co

nc.

In P

PT

Date

Final

PFHxA PFHpA PFHpS PFOS

4:2 FTS 6:2 FTS PFOA

PFHxA

4:2 FTS0

200000

400000

600000

800000

10/16/2018

Co

nc.

in P

PT

Date

Raw Water

PFHxA PFHpA PFHpS PFOS

4:2 FTS 6:2 FTS PFOA

Industrial wastewater system with PFAS Concentrations as high as 700,000 ppt total PFAS consistently brought down to ND. Clean Harbors has designed and installed a system to treat 120 gpm daily. This treatment system has allowed customer to meet discharge parameters since installation.

38 Case Study – Petroleum Processing Client, Upper Midwest

PFAS Capture – Post-fire Construction and Operation of Treatment System

• System Design – Clean Harbors recommended the proper combination of equipment, filters, activated carbon, and resin needed to process PFAS concentrations. System is capable of flow rates up to 400 gallons per minute (gpm).

➢ Prior to mobilization, the system design was approved by the Wisconsin Department of Natural Resources (WDNR) to levels suitable for discharge to the environment.

• System Construction – The entire system was transported, then constructed on-site in less than 3 days. After one day of performance testing, the system successfully reduced PFAS concentrations to non-detectable levels. System operates at 250 gpm.

➢ PFAS concentrations in the discharge water are well below permit limits. A second, similar system was installed on a similar schedule six weeks later.

• System Operation & Maintenance – Clean Harbors was contracted to operate the system to properly balance the treatment system alongside the on-site wastewater treatment plant operations. Clean Harbors then trained client personnel. Client staff assumed responsibility for system operation several weeks later.

➢ Clean Harbors continues media change-out and disposal services, including incineration and hazardous landfilling.

Subcontract Remediation Services

39

Case Study – Industrial Plater, Michigan

PFAS Control – Emergency; Full Scale Treatment Design and Implementation

Clean Harbors was contracted by a Michigan plating and surface finishing firm after discovery of multiple PFAS compounds in its discharge to the local publically owned treatment works. The POTW set strict PFAS limits, and demanded compliance within a limited time or cessation of all discharges. Clean Harbors provided services that met its client’s discharge permit limits, allowing continued operations.

• Operations analysis – Fluctuations in product demand triggered irregular treatment, discharge, and renewal of individual baths, which yielded a waste stream of constantly changing chemical composition.

• Media testing – Clean Harbors tested a number of adsorbent media, individually and in series. Each was intended to adsorb PFAS compounds or inorganic and organic waste components that interfered with PFAS capture.

• Full-scale system design – Testing data and the extensive experience and expertise of Clean Harbors staff were used to develop a treatment system.

• System installation and operation – Clean Harbors constructed and started the treatment system, which met POTW permit limits before the deadline. Clean Harbors commenced support of client staff through media exchange and disposal services, as well as performance testing.

Subcontract Remediation Services

PFAS Contaminated Soils Washing

Adrian Convery

Landfill Diversion Sector Manager

CDEnviro

Environmental Business Council of New England

Energy Environment Economy

CDEnviro – PFAS Contaminated Soils Washing

24th July 2019

Contents

- Background of CDEnviro- Installation Locations- PFAS Contaminated Soils Washing- Water Treatment- USA Project Examples

CDEnviro Background Info

- CDEnviro is a company within the CDE Group, formed in 1992 and employing over 400 people across 8 regions.

- We develop bespoke processing systems for a variety of wastes to recycle wastes to resources.

- USA offices are located in Cary, North Carolina and Cleburne, Texas.

- Waste Recycling- Contaminated Soils- Construction and Demolition- Dredged Sediment- Street Sweepings- MRF Glass Waste- Food Waste

- Waste Water Recycling- Sludge Screening- Anaerobic Digester Cleaning

Installations

Scrubbing and Attrition

Hydro:Grade

Attrition Cells

Density Separation

CFCU (Counter Flow Classification Unit)

Water Treatment

- Stage 1 – Advanced Filtration System to effectively reduce solids under 25 micron in wash water using filtration media.

- Stage 2 – Removing dissolved organic contaminants and hydrocarbons from water via adsorption.

- Stage 3 – Heavy metal reduction using Ion Resin Exchange.- Stage 4 – Disinfection to remove harmful bacteria using hypochlorite based

chemicals.

- Four Stage Solution for Advanced Water Treatment

USA Project Examples

Metroplex Sand & Gravel, Texas

The final products include Concrete Sand, Asphalt Sand, Masonry Sand, Cushion Sand, Concrete Rock and Pea Gravel.Client required Modularity – Plant was moved north to a new location after 1.5 years at the original site.

4 weeks for breakdown, 4 weeks to reinstall.

Matthews Sand & Gravel, North Carolina

This modular plant is offering feeding, screening, sand washing, stockpiling on a compact chassis which allowed the producer to nearly triple production levels. The final products include concrete sand and a residual fine sand.

USA Project Examples

Martin Marietta, Burlington Quarry, North Carolina

Fines recovery unit. This machine recovers virtually all sand larger than #325 sieve which overflows the sand screw.Currently this unit recovers 5-10 tph of sand which previously went to the settling ponds. Now, only the #325 sieve minus reports to the settling ponds, resulting in dramatically less pond maintenance and costs.

GS Materials, North Carolina

Specialist golf sands produced.

QUESTIONS AND DISCUSSION

PFAS Treatment in Soil and Water

Lauren Soós

Project Manager

Operations & Technical Sales

TRS Group, Inc.

Environmental Business Council of New England

Energy Environment Economy

July 24, 2019

PFAS Treatment in Soil and WaterIn Situ Thermal Remediation for Soils

PerfluorAd for Water

Lauren Soós

TRS Group

978-514-3133

[email protected]

Who are TRS and Cornelsen?

• 100% ESOP

• Health & Safety

• Best Practices

• Technologies

• Joint Ventures

• 220 ISTR Projects

• R&D

Why ISTR: The Results

99.995% removal

Guaranteed

Vadose zone

Saturated zone

Silty clay

Strip Mall in Alexandria, Virginia

ISTR Technology Comparison

Electrical Resistance Heating

Thermal Conduction Heating

Steam Enhanced Extraction

High Temperature TCH

ERH HEPA® Remediation

RDX/DPCA* TCE PCE Xylenes Napthalene PCB Dioxin PFAS

100 °C 200 °C 300+ °C Boiling Point

50 °C

*DPCA: Dissolved Phase Chlorinated Alkenes

FlexHeater® Remediation Service

• Patent awarded Feb. 2019

• Infra-red radiation

• Variable heating

• Small diameter casing

FlexHeater® Element

59

PFAS Remediation in Soil

FlexHeater® technology

• Vadose zone soils

• Ex situ cells

Proof of ConceptTreatment of PFAS in Soil

Ex Situ Cell Heat Up

PFAS Thermal Treatment System

PFAS Volatilization from SoilTime & Temperature

0

5,000

10,000

15,000

20,000

25,000

Unheated300 °C

350 °C400 °C

PFA

S So

il C

on

cen

trat

ion

g/kg

)

350°C: 99.91% reduction

400°C: 99.998% reduction

Contaminant Boiling Points

100 °C

200 °C

300 °C

400 °C

500 °C

TCE

PCE

Xylene

Naphthalene

PCB

Dioxin

Benz(a)pyrene

Sulfonate/Sulfonic Acid

PFTeDS – 14 carbon

PFOS – 8 carbon

PFHxS – 6 carbonPFBS – 4 carbon

PFBA – 4 carbonPFHxA – 6 carbon

PFOA – 8 carbon

PFDA – 10 carbon

PFDoDA – 12 carbon

Carboxylate/Carboxylic Acid

Perfluoroalkyl acids

Next Steps

✓ Substantial PFAS reductions in bench tests

✓ Temperatures achievable by FlexHeater® technology

• Field demonstration

Treating PFAS in Water with thePerfluorAd System

PFAS Water Treatment - PerfluorAd

• Treatment system – GAC or ion exchange polish

• Plant-based oleic acid

• Forms ionic bond w/PFAS

• Works with high DOC

• Rapid return on investment

© Cornelsen Umwelttechnologie GmbH

PerfluorAd Precipitation Process

Traditional Treatment PerfluorAd Treatment

© Cornelsen Umwelttechnologie GmbH

PerfluorAd Advantage

Courtesy of CDM Smith and Colorado School of Mines

Wurtsmith AFB Groundwater

© Cornelsen Umwelttechnologie GmbH

PFAS in Fire Water

Nuremberg Airport Fire Brigade Training Area

© Cornelsen Umwelttechnologie GmbH

© Cornelsen Umwelttechnologie GmbH

93.5 % Removal

100 % Removal

Nuremberg Airport Fire Brigade Training Area

ND

Conclusions

• ISTR

– VOCs, SVOCs, PCBs, 1,4-Dioxane

– PFAS in soil

• PerfluorAd system

– PFAS in water

– Fire water

– Landfill leachate

Contact Information

Lauren D. SoosTRS Group

(978) [email protected]

Networking Break

PFAS Treatment & Disposal

Solutions

Hugo DelRosso

Senior Account Executive

US Ecology

Environmental Business Council of New England

Energy Environment Economy

92

July 24, 2019

PFAS Treatment &

Disposal Solutions

9393

• TSCA PCB’s

• RCRA Metals

• RCRA Organics

• RCRA Listed Waste

• NORM/TNORM

Mixed Waste Treatment/Disposal

▪ Secure Subtitle C Landfill

▪ Treatment Facilities

▪ Treatment options for high/low

concentrations

▪ Isolation of treated residuals from leachate

▪ Rail and Truck Access

Waste Type Considerations

• AFFF Concentrate

• Impacted Soil

• Impacted WWT Media

• WWT Filtercake

• Impacted Debris

US Ecology PFAS Treatment & Disposal

9494

Beatty, Nevada

• Michigan (Belleville)

• Quebec (Blainville)

• Idaho (Grandview)

• Nevada (Beatty)

• Texas (Robstown)

Subtitle C Landfill

▪ Positioned throughout North America

▪ Treatment & Disposal Facilities

▪ Broad Range of Permits/Acceptance Criteria

▪ Infrastructure to Support Volume Transport

▪ Rail and Truck Access

▪ Non-Bulk T&D Services Available

Grand View, Idaho

US Ecology Disposal Options

Deep Well

• Winne, TX

Incineration

• Robstown, TX

• Saint Ambrose, QC

95

Batch Solidification

Leak-Proof Pactec Liner (high concentrations)

Placement in Subtitle C Landfill

Isolated from Leachate

US Ecology Michigan (WDI/MDI)

96

Native Clay

Peastone - minimum 24”

Hazardous Waste

5 ft. Re-compacted Clay

80 mil. HDPE Primary Liner

60 mil. HDPE Secondary Liner

Leachate

Detection

System

Leachate

Primary

Collection

System 6” Top Soil

Minimum 3 ft. Final Clay Cover

1 ft. Sand

30 mil. HDPE Cover Liner

1 ft. Clay

Intermediate Cover

Grass

Wayne Disposal, Inc.

Subtitle “C” Landfill

97

US Ecology Texas

Robstown, TX Thermal

Process & Recycle numerous waste streams

• “PFAS” Streams

• Organic-bearing waste from petroleum,

petrochemical, ethylene processing

and other manufacturing practices

• Organic liquids, sludges and solids

• Metal-bearing catalysts

• RCRA Listed (K171 and K172) catalyst

• RCRA exempted metal-bearing catalyst

Incineration

• F.K.A. Récupère Sol

• High Temp Soil Incineration

• 99.99999% Destruction of Organic Contaminants

• Controlled-emission soilcooling system

• Continuous monitoring of stack gas emissions

• Treatment of industrialwastewater

• Secure site

RSI

99

Landfills

Treatment

Treatment & Disposal Locations

Deep Well

Incineration

Thermal Desorption PFAS

Contaminated Soils

Scott Miller

Regional General Manager

Clean Earth

Environmental Business Council of New England

Energy Environment Economy

EBC MassachusettsThermal Desorption PFAS Contaminated Soils

Thermal Desorption PFAS SoilPresentation Summary1. Who is Clean Earth?

2. Thermal Desorption Overview

3. Fort Edward Initial RD&D

4. Fort Edward Proposed Second RD&D

Recently Acquired

by:

HARSCO Corporation

Our network of full-servicetreatment, disposal, andrecycling locations provides the bestsolutions for our customers.

27Facilities Nationwide

About Clean EarthTreatment & Recycling Facts

ENGINEERING NEWS-RECORD

TOP 200ENVIRONMNETAL FIRMS

2018

of the material

we process is

recycled

3.6

Million

8.8

Million

OV

ER

of the material we

process is recycled

4 Milliontons recycled

in 2018

8 Million

7 Millionyd3 dredged material

recycled since 1996

pounds of aerosol

products recycled in

2018

25reclaimed industrial

brownfields & former

landfills

OV

ER

OV

ER

OV

ER

ENGINEERING NEWS-RECORD

TOP 600SPECIALTY CONTRACTORS

2018

ENGINEERING NEWS-RECORD

NO. 9TOP 30 ENVIRONMNETAL FIRMS

2018

ENGINEERING NEWS-RECORD

NO.7TOP ENVIRONMNETAL MGMT FIRMS

2018

Thermal Treatment OptionsFacilities in New England

1. Clean Earth Loudon (ESMI NH)67 International Drive, Loudon, NH 03307

Main: 603-783-0228

2. Clean Earth Fort Edward (ESMI NY)304 Towpath Lane, Fort Edward, NY 12828

Main: 518-747-5500

3. Clean Earth Plainville (Phoenix Soil)58 North Washington Street, Plainville, CT 06062

Main: 860-747-8888

4. Clean Earth Mobile ServicesOn Site Low Temperature Thermal Desorption (LTTD) units

Thermal Treatment Operating Principles

What is Low Temperature Thermal Desorption (LTTD)?• < 1,000 oF (>1,000 oF = incineration)

Utilizes heat to physically separate contaminates from soil• Rotary Kiln (volatilization and steam stripping)• Volatilization (temperature ranges from 550-900 oF)

Contaminants in gas stream are thermally oxidized• Thermal oxidation (range from 1,500-2250 oF)• Immediate quench of gas stream (to 420oF)• Bag house (particulate removal)• Effluent stack (CECT equipped with wet scrubber)

*Effluent stack discharges less emissions than your car

Thermal Treatment Process Diagram

Clean Earth Fort Edward Initial RD&D

PFAS Thermal Treatment Demonstration• New York State Department of Environmental Conservation (NYSDEC)

Led PFAS Treatment Test• 22.6 Tons Treated in December 2018 & February 2019• High Soil Organic Matter (SOM) at over 7%• PTU Temperature 910-940 oF, STU Temperature 1800 oF• Treatment Goal of 72 ppb for total of PFOA and PFOS• No stack testing due to small sample size

Pre & Post Primary and Secondary Treatment for Total Mass (ug/kg)

Substance

Pre-Primary

Treatment (ppb)

Post-Primary

Treatment (ppb)

Post-Primary

Removal Efficiency

Post-Secondary

Treatment (ppb)

Post-Secondary

Removal Efficiency

Perfluorobutanoic acid (PFBA) 0.42 ND 100% ND 100%

Perfluoropentanoic acid (PFPeA) 0.63 ND 100% ND 100%

Perfluorohexanoic acid (PFHxA) 0.70 ND 100% ND 100%

Perfluoroheptanoic acid (PFHpA) 1.10 ND 100% ND 100%

Perfluorooctanoic acid (PFOA) 4.50 ND 100% ND 100%

Perfluorononanoic acid (PFNA) 2.90 ND 100% ND 100%

Perfluorodecanoic acid (PFDA) 5.70 ND 100% ND 100%

Perfluoroundecanoic acid (PFUnA) 3.00 ND 100% ND 100%

Perfluorododecanoic acid (PFDoA) 2.20 ND 100% ND 100%

Perfluorotridecanoic acid (PFTriA) 0.94 ND 100% ND 100%

Perfluorotetradecanoic acid (PFTeA) 0.88 ND 100% ND 100%

Perfluorobutanesulfonic acid (PFBS) 0.09 ND 100% ND 100%

Perfluorohexanesulfonic acid (PFHxS) 0.24 0.05 78.1% ND 100%

Perfluoroheptanesulfonic acid (PFHpS) 0.55 0.05 90.3% ND 100%

Perfluorooctanesulfonic acid (PFOS) 88.00 7.65 91.3% ND 100%

Perfluorononanesulfonic acid (PFNS) 0.04 ND 100% ND 100%

Perfluorodecanesulfonic acid (PFDS) 0.13 ND 100% ND 100%

Perfluorooctanesulfonamide (FOSA) 1.15 ND 100% ND 100%

(NMeFOSAA) 3.35 ND 100% ND 100%

(NEtFOSAA) 6.40 ND 100% ND 100%

Total PFAS 122.91 7.76 93.7% ND 100%

Pre & Post Primary and Secondary Treatment by SPLP (ng/kg)

Substance

Pre-Primary

Treatment

(ppt)

Post-Primary

Treatment (ppt)

Post-Primary Removal

Efficiency

Post-Secondary

Treatment (ppt)

Post-Secondary

Removal

Efficiency

Perfluorobutanoic acid (PFBA) 29.38 ND 100% ND 100%

Perfluoropentanoic acid (PFPeA) 15.30 ND 100% ND 100%

Perfluorohexanoic acid (PFHxA) 10.85 ND 100% ND 100%

Perfluoroheptanoic acid (PFHpA) 14.50 ND 100% ND 100%

Perfluorooctanoic acid (PFOA) 109.50 0.44 99.6% ND 100%

Perfluorononanoic acid (PFNA) 68.00 ND 100% ND 100%

Perfluorodecanoic acid (PFDA) 18.80 ND 100% ND 100%

Perfluoroundecanoic acid (PFUnA) 1.40 ND 100% ND 100%

Perfluorododecanoic acid (PFDoA) 0.65 ND 100% ND 100%

Perfluorotridecanoic acid (PFTriA) ND ND N/A ND N/A

Perfluorotetradecanoic acid (PFTeA) 0.57 ND 100% ND 100%

Perfluorobutanesulfonic acid (PFBS) ND 0.44 N/A ND N/A

Perfluorohexanesulfonic acid (PFHxS) 3.65 0.60 83.5% ND 100%

Perfluoroheptanesulfonic acid (PFHpS) 7.28 0.47 93.5% ND 100%

Perfluorooctanesulfonic acid (PFOS) 527.50 20.50 96.1% ND 100%

Perfluorononanesulfonic acid (PFNS) ND ND N/A ND N/A

Perfluorodecanesulfonic acid (PFDS) ND ND N/A ND N/A

Perfluorooctanesulfonamide (FOSA) ND ND N/A ND N/A

(NMeFOSAA) ND ND N/A ND N/A

(NEtFOSAA) ND ND N/A ND N/A

Total PFAS 807.37 22.45 97.2% ND 100%

Clean Earth Fort Edward Second RD&D

Second RD&D Objectives• Measure stack emissions (MM5) for the presence of PFAS compounds• Demonstrate compliance with soil clean-up objectives for reuse• Use performance data to determine LTTD removal/destruction

efficiency and effectiveness for processing PFAS contaminated soil

Second RD&D proposed for Q4 2019

Clean Earth Fort Edward Second RD&D

Proposed PFAS Thermal Treatment Demonstration• NYSDEC Led – Second RD&D Submitted and reviewed June/July• Three separate batches (control and 2 confirmed PFAS)• Varying STU temperatures per batch (1800 oF and 1500 oF)• Pre/post treatment sample collection & analysis (mass & SPLP)• Treatment Goal of 72 ug/kg for total of PFOA and PFOS, 10 ppt each by SPLP• Emission samples to be collected and analyzed per Modified Method 5

(MM5)• 21-Compound PFAS List soil and stack emissions

Modified Method 5 Testing Diagram

PFAS Contaminated SoilTreatment Options in Development

1. Additional Thermal Treatment Options• Similar demonstrations with stack emission testing for

facilities in Loudon, NH and Plainville, CT

• Mobile LTTD demonstration

2. Solidification/Stabilization• Encapsulating or binding PFAS compounds within the soil

matrix reducing mobility

• Treatability studies using proprietary blends of Portland cement, carbon and CKD for in-situ and ex-situ treatment alternatives

Contact Me with Questions

Scott A. Miller, P.E.

Regional General Manager, New England

Clean Earth

58 North Washington Street, Plainville, CT 06062

T 860.747.8888 x 2004 | C 860.670.7608

[email protected] | www.cleanearthinc.com

Questions?

PFAS/PFOS Waste Management

Options, Best Practices and

Challenges

Phillip Retallick

Senior Vice President

Compliance and Regulatory Affairs

Clean Harbors

Environmental Business Council of New England

Energy Environment Economy

“PFAS/PFOS Waste Management Options,

Best Practices and Challenges”

Presented Before

Environmental Business Council of New England

July 24, 2019

119July 25, 2019 - Clean Harbors Company Confidential

Introduction to Clean Harbors

• Founded in 1980

• Publicly Traded Corporation

(NYSE: CLH)

• Over $3.2 Billion USD in Revenue in

2015

• North America’s Largest Hazardous

Waste Disposal Company

• Leading Provider of Comprehensive

Environmental, Energy and Industrial

Services

• Largest used oil collector and re-

refiner in North America

120July 25, 2019 - Clean Harbors Company Confidential

Company Profile

• More than 260,000 customers

including a majority of the Fortune

500

• More than 13,000 employees

in over 350 service locations

in US, Canada, Mexico and

Puerto Rico

• Over 50 waste management

facilities

• Expanded North American

footprint with our Safety-Kleen

branch network

121July 25, 2019 - Clean Harbors Company Confidential

Risk & Security Management

• Health & Safety is Clean Harbors' #1 Priority– TRIR 1.33 in 2015 – DART .83 in 2015– EMR 0.67 in 2015– OSHA Voluntary Protection Program (VPP) at Clean Harbors

Facilities

• Regulatory Compliance– Encompasses All Clean Harbors Activities– Clean Compliance Program

• Liability Protection– Comprehensive General Liability– Umbrella Liability– Workers’ Compensation and Employers’ Liability– Contractors’ Pollution Liability– Environmental Impairment Liability

122July 25, 2019 - Clean Harbors Company Confidential

Complementary Networks

Clean Harbors Footprint Safety-Kleen Footprint

123July 25, 2019 - Clean Harbors Company Confidential

Asset Infrastructure

• 3 Solvent Recycling Facilities– Recycling, tolling and chemical sales

• 6 Incineration Facilities (9 Incinerators)– Greatest commercial hazardous waste incineration

capacity in North America

– Thermal treatment of liquid and solid hazardous wastes

• 9 Landfills– Hazardous and non-hazardous waste disposal capabilities

– More than 25 million cubic yards of remaining capacity

• 7 Wastewater Treatment Operations– Treatment of hazardous and non-hazardous wastes

received in liquid and sludge form

• 22 Treatment Storage & Disposal Facilities (TSDF)– Provides broad coverage across North America

• 6 PCB Management Facilities– Recycling and disposal

• 4 Oil & Used Oil Products Recycling Facilities

124July 25, 2019 - Clean Harbors Company Confidential

Management of PFAS As-Generated and

Site Remediation Waste

• Management of PFAS waste is a very challenging task

given the diverse isomeric chemistry of these substances

coupled with their tendency to be persistent in the

environment;

• There is little regulatory agency guidance available today to

help select the best demonstrated treatment waste

technology given the ubiquitous nature of PFAS

contamination in the environment;

• Selection of Waste Treatment Technologies must also

account for potential of cross-media transfer of treatment

residues into the ecosystem.

125July 25, 2019 - Clean Harbors Company Confidential

Management of As-Generated PFOS/PFAS

Wastes such as Firefighting Foam Products

• The Best Demonstrated Available Technology (BDAT) available today to destroy stockpiles of Firefighting Foam Products is High-Temperature Incineration with Acid Gas Scrubbing and Particulate Removal Technology;

• The US DOD mandates utilization of High Temperature Incineration Technology to destroy As-Generated and Remediation Wastes;

• The Interstate Technology Regulatory Council (ITRC) recommends Disposal of expired or unneeded Class B fluorinated foam concentrate at a Resource Conservation and Recovery Act (RCRA) permitted incinerator or another alternative incinerator that can ensure complete destruction of the PFAS; (note 1)

• Emerging technologies such as Supercritical Water Molecular Disassociation Chemistry, ReDOX Chemistry and Molecular Substitution Chemistry are not ready for commercialization, especially for destruction of Firefighting Foam stockpiles.

– Note 1: See Remediation Technologies and Methods for Per- and the Interstate Polyfluoroalkyl Substances (PFAS) fact sheet for details on

– thermal destruction of PFAS (ITRC 2018).

126July 25, 2019 - Clean Harbors Company Confidential

Management of PFAS Contaminated Media &

Remediation Wastes

• PFAS contamination in soil, river sediment, surface water and

groundwater creates unique challenges for the responsible party that

must select the appropriate technology to address contamination in a

cost-effective yet environmentally sound manner:

• Aside from High Temperature Incineration other commercially

demonstratable technologies include:

– GAC/PAC Carbon Sorption and Stabilization

– Isolation via containment capping of contaminated area requiring long term O&M

– Excavation and Disposal via Landfill or High Temperature Incineration

– Thermal Desorption provided the TDU is connected to an Incinerator that achieves at least 99.99 % Destruction and Removal Efficiency “DRE”, and the desorbed organics are incinerated in a RCRA High-Temperature Incinerator that achieves 99.99% - Plus DRE.

127July 25, 2019 - Clean Harbors Company Confidential

Interstate Technology Regulatory Council “ITRC” PFOs and

PFAs Waste Treatment Technology Analysis and

Recommendations

128July 25, 2019 - Clean Harbors Company Confidential

Landfill Network• Landfills

– Hazardous and non-hazardous waste disposal capabilities

– More than 25 million cubic yards of remaining capacity

– Leachate collected and treated to prevent subsequent discharges of PFAS - laden Leachate to Groundwater and Surface Water.

• Landfills Accepting PFAS Waste Streams

– Sarnia (CDN), Lone Mountain, Grassy Mountain, Deer Trail, Ryley (CDN)

– Rail served

129July 25, 2019 - Clean Harbors Company Confidential

Landfill Construction

Deer Trails Subtitle C Disposal Cells –

constructed and operated to meet or

exceed State and Federal Regulations.

-Naturally low-permeable sediments - clay soil & Pierre

weathered shale

-Primary & Secondary synthetic HDPE liner systems

-Dual leachate detection/collection system

130July 25, 2019 - Clean Harbors Company Confidential

Deer Trail - Geology

131July 25, 2019 - Clean Harbors Company Confidential

PFAS Soil

Transportation and

Disposal

• Manage transportation

and disposal from IDW

drums to unit trains of

soil

• Own our rail cars and

intermodal containers

132July 25, 2019 - Clean Harbors Company Confidential

High Temperature Incineration

Technology Overview

• High Temperature Incineration Technology (HTI) has been employed

since the 1960’s to effectively destroy simple and complex organic

waste streams, including the Halogen Series Compounds e.g. PCBs,

CFCs, Brominated Compounds;

• HTI Technology consists of the following elements:

– Primary Combustion Chamber (1500-1800o F)

– Secondary Combustion Chamber (1800-2050o F)

– Spray Dryer

– Acid Gas Scrubbing Technology to neutralize HCL, H2SO4 and HF Acid vapors

– Particulate Filtration ( primarily two-stage baghouse configuration)

– DE NOx Removal

– Polishing Carbon Filtration to remove Dioxins and Mercury

133July 25, 2019 - Clean Harbors Company Confidential

High Temperature Incineration Principles

• Optimized Incineration of Hazardous Waste is governed by the following parameters:

– Consistent High Temperature Regimes in primary and secondary combustion chambers;

– Sufficient Solids and Vapors Retention Time in the Combustion Zone (from Seconds for vapors to hours for solids);

– Flame Zone Turbulence (governed by Burner Design);

– We Refer to “The 3- T’s” when determining Optimization through USEPA and State Regulatory Agency mandated Compliance Performance Tests (CPTs) conducted during Real-Time Waste Destruction Activities;

– The CPT’s generate Destruction and Removal Efficiencies (DREs) which show the incineration train’s ability to destroy complex organic compounds, like PFAS, plus remove inorganic heavy metals regulated under the MACT Standards;

– DREs are expressed as 99.99 to 99.9999+ %

134July 25, 2019 - Clean Harbors Company Confidential

Clean Harbors Incineration Technology

Capabilities

• Clean Harbors Incinerator Locations:

– Deer Park, Texas

– El Dorado Arkansas

– Aragonite, Utah

– Kimball, Nebraska

– Sarnia, Ontario Province, Canada ( includes a TDU which is directly connected to the on-site commercial high temperature incinerator which destroys all exhaust vapor and condensate ).

Total Annualized Incineration Capacity = 800,000 metric tons/yr.

135July 25, 2019 - Clean Harbors Company Confidential

Highlighting Clean Harbors Newest High

Temperature Incineration Train in El Dorado,

Arkansas

• The El Dorado Incineration Complex added a new

incineration train meeting the latest USEPA MACT EEE

emissions standards in December, 2016;

• The new unit can manage bulk and containerized solid

and liquid waste streams and has the capability to

directly feed liquids and gases from shipping

containers into the primary and secondary combustion

chambers;

• The new incinerator train increased site capacity from

73,000 metric tons/yr. to 140,000 metric tons/yr.

136July 25, 2019 - Clean Harbors Company Confidential

Highlighting Clean Harbors Newest High

Temperature Incineration Train in Eldorado,

Arkansas

137July 25, 2019 - Clean Harbors Company Confidential

Highlighting Clean Harbors Newest High

Temperature Incineration Train in El Dorado,

Arkansas

138July 25, 2019 - Clean Harbors Company Confidential

1 - Rotary kiln and secondary combustion chamber.

139July 25, 2019 - Clean Harbors Company Confidential

2 - Spray dryer.

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3 - First baghouse and wet scrubbers.

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4 - Second baghouse and Carbon

Injection

142July 25, 2019 - Clean Harbors Company Confidential

5 – DE-NOx Unit and Stack.

143July 25, 2019 - Clean Harbors Company Confidential

Summary

• Best Demonstrated Available Technology for

Destroying PFAS is High Temperature Incineration

Technology;

• The Best Containment Technology for PFAS

contaminated soil and sediment is isolation in a RCRA

Subtitle C Triple –Lined Landfill with Leachate Capture

and Destruction;

• The Best Water Treatment Technology is Carbon

Adsorption combined with Ultra-filtration.

Please Fill out the Program Survey

Environmental Business Council of New England

Energy Environment Economy

Panel Discussion

Moderator: Scott Miller, Clean Earth Inc.

Panelists:

• Adrian Convery, CDEnviro

• Hugo DelRosso, US Ecology

• AnnieLu DeWitt, Clean Harbors

• Phillip Retallick, Clean Harbors

• Lauren Soós, TRS

Environmental Business Council of New England

Energy Environment Economy