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Page 1: TECO Networking Conference 16-17 November 2016...16-17 November 2016 ERM The business of sustainability Graphics What’s this layout for? Plain slide without a text box – used for

The business of sustainability

TECO Project Technological Eco-Innovations for the Quality

Control

and the Decontamination of Polluted Waters and

Soils

Hexavalent Chromium

Assessment & Remediation Design

Case Study

Jaydeep Sathaye

Tel: +39 06 9067 2540

E-mail: [email protected]

Website: www.tecoproject.eu

TECO Networking Conference

16-17 November 2016

ERM

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The business of sustainability

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We have worked in

over

countries in the past

3 years

We work for

60% of

the global Fortune

500 companies in the

past 3 years

5,000+

people

and offices in

countries and

territories 40

160

The world’s leading provider of environmental, health, safety, risk, social consulting and

sustainability related services

About ERM (global)

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The business of sustainability

ERM in India

3

- Leading Provider of Environmental, Social,

Safety, Risk and Sustainability Solutions

- Successfully completed over 5,000

projects in India

- 5 offices; 170+ professional staff

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Contaminated Site Management Services

4

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Project Background

5

• Capacity Building for Industrial Pollution Management

Project (CBIPMP), aided by the World Bank

• Orphan site (public & private land) north of Kolkata:

Investigations, Remediation Design and Monitoring and

Validation of Remediation

• Chromium bearing sludge dumped (over ~30 years) in

low-lying areas along a highway by some industries (most

no longer in operation)

• Significant redevelopment using waste: filling for

construction; access roads to industrial/commercial

establishments, residences

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Site Location

6

• Flat topography; floodplain deposits

• Mix of silts, clays, and sand

Hooghly

River

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Site Settings

7

• Semi-rural locale

• Mix of industrial, commercial, agricultural, residential land use

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Impacted Sites

8

Hexavalent Chromium

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Impacted Sites

9

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Preliminary Environmental Site Assessment

10

Original number of sites was 7;

ERM conducted a Comprehensive Environmental

and Social preliminary assessment

• 395 XRF screenings along SH13 & 500m E/W

• As a result, 20 new sites identified

• Study area increased from 15 km to 18 km

Visual Screening, XRF Study, Receptor Survey, SPR Linkages

• 7 sites High Impact ( = 0 - 1.5 ohm-m)

• 15 sites Moderate Impact ( =1.5 - 3.0 ohm-m)

• 4 sites Low Impact ( > 3.0 ohm-m)

Geophysical Site Screening

• WB recommended TCLP evaluation at each site

• Total Cr in soil varied ~8 mg/Kg to ~19,700 mg/Kg.

• CPCB guideline for Cr VI in (water leachate) is <0.5mg/L; most sites failed this value in leachate

Soil and TCLP Chromium Evaluation

• Out of 27 identified sites, 14 represented ‘High’ environmental risk, 6 represented ‘Medium’ risk, and 7 represented ‘Low’ risks.

Risk Ranking

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Preliminary Environmental Site Assessment

11

Factors contributing to qualitative environmental RA

XRF Screening Rating

• <5,000ppm Cr- 1 point

• 5,000-19,999ppm Cr- 3 points

• >20,000ppm Cr- 5 points

Total Cr and Cr VI in soil and TCLP

(leachate)

• Average multiplier range 0.00-1.00 = 1 point

• Average multiplier range1.01-10.00 = 3 points

• Average multiplier >10.00 = 5 points

Potential area of impact

• <1 acre- 1 point

• 1-2 acres- 3 points

• >2 acres- 5 points

Source-Pathway-Receptor (SPR) linkages

• 1 potentially complete SPR linkage-1 point

• 2 potentially complete SPR linkages-3 points

• >3 potentially complete SPR linkages-5 points

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Site Risk Ranking

12

So

cio

-Eco

no

mic

Ris

k

Hig

h

4. Drum Cleaning Unit

6. Om Forging

26. Ashalata Brickfield

5. Shentracon Chemicals

25. Appayan Hotel Dump

27. Indotan Chemicals M

ed

ium

22. Bhola Baba

Corrugated Box

23. Steel Cracker Unit II

8. Hooghly Alloy and

Steel

9. Ganesh Steel and

Alloy

24. Sonar Bangla Hindu

Hotel

11. Shree Krishna Timber

12. Fortune Furnitech

16. Padmabati Dump 1

17. Padmabati Dump 2

Lo

w

1. Private Road near

Nezone Tubes

2. Balaji Technomech

3. Vacant Land, Chakundi

10. Misrilall Mines

20. Sada Shiv Sakti

Exim

7. Sarkar Weighbridge

13. Sheela Foam

14. Sasmalpara Dump

15. Dipendra Sasmal’s House

18. Minu Computer Weighbridge

19. Zenith Timber Products

21. Pashupati Seohung

Low Medium High

Environmental Risk

• Subsequently: detailed investigations

• Risk assessment to derive site-specific target levels (SSTL)

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Findings of Investigations

13

Results were used to evaluate potentially complete SPR

linkages identified during the PA.

Data exceeded applicable Dutch Intervention Values

(DIVs) in all media analyzed.

Study eliminated Volatile Organic Compounds (VOCs),

Semi-Volatile Organic Compounds (SVOCs), Total

Petroleum Hydrocarbons (TPH), and pesticides as

contaminants of concern.

Study confirmed Cr as the key CoC.

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Findings of Investigations

Geology/Hydrogeology - the generalized lithology of the study area is

clay (4-6m thick) and clayey silt (8-17m thick. Shallow saturated zone

occurs from 4-7m bgl.

15

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Tier I Risk Assessment

■ Objective: preliminary determination of potential risks

■ The Tier 1 screening assessment process forms the

‘Source’ identification component of the ‘Source-Pathway-

Receptor’ relationship.

■ Aim of Tier 1 screening: rule out contaminants that are

unlikely to cause a significant risk to human health.

Contaminants with concentrations above the Tier 1

screening criteria are assessed further as part of the Tier 2

risk assessment.

16

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Applicable Tier I Screening Levels

Screening Levels are conservative, generic

17

Source Primary Screening Option Secondary Screening Option

Hand Pumps BIS Specification (IS-10500:2012)* -

Monitoring

Wells

Dutch Serious Risk Concentrations

(SRChuman)

BIS Specifications (IS-10500:2012)*

Surface

Water

BIS Specification (IS-10500:2012) -

Soil Dutch Serious Risk Concentrations

(SRChuman)

USEPA MCL based SSLs***

Sediment Dutch Serious Risk Concentrations

(SRChuman)

-

* IS 10500 (2012): Drinking Water--Specification (Second Revision).

** RIVM (NATIONAL INSTITUTE OF PUBLIC HEALTH AND THE ENVIRONMENT) and The Dutch Ministry of Housing

Spatial Planning and the Environment, Directorate General for the Environment (DGM), Directorate of Soil, Water and Rural

Areas, Technical Evaluation of the Intervention Values for Soil/sediment and Groundwater. Human and Ecotoxicological

Risk Assessment and Derivation of Risk Limits for Soil, Aquatic Sediment and Groundwater, February 2001

***United States Environmental Protection Agency (USEPA), “Regional Screening Levels, Chemical Specific Parameters

Table,” November 2012, http://www.epa.gov/region9/superfund/prg/.

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Tier II Risk Assessment (HHRA)

Objective: to assess whether impacts resulting from the dumping of

chromium-containing wastes at the sites has potential to represent a

risk to human health under the current and intended future land-use.

HHRA provides details on:

■ Issues Identification (includes conceptual site model);

■ Exposure Assessment;

■ Hazard Assessment;

■ Risk Characterisation; and

■ Uncertainty and Sensitivity Analysis.

Potential risks were assessed using exposure values derived in the

guidance documents (e.g., enHealth, 2004; USEPA, 2004; USEPA,

1997; ASTM, 2002) and best professional judgement regarding realistic

use of the study area resources.

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Tier II Risk Assessment (HHRA)

Exposure scenarios

■ Scenarios represent reasonable worst-case circumstances.

■ Scenarios include On-site Residents, On-site Employees,

Agricultural Worker and On-Site Workers within Excavations.

Modelling Methodology

■ Exposure scenarios are combined with the observed

contamination concentrations at each site using mathematical

algorithms.

■ Exposure point concentrations were based on site specific

analytical data.

■ Exposure was estimated for each chemical and pathway in the

form of a maximum daily intake (MDI) and a chronic daily intake

(CDI).

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Target Areas and Contaminants

20

Soil – chromium VI contamination

Shallow groundwater – quality will improve once the

source in the soil (soil impacts) are treated; deeper

groundwater not affected by chromium contamination in

soils

Surface water – quality will improve once the source in the

soil (soil impacts) are treated

Sediments – not impacted

Therefore, treat soil at all 16 identified sites

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Tier II Risk Assessment & Remedial Goal

■ Soil Human Health SSTLs (mg/Kg)

■ Incorporated standard methodology for calculating risk-based Tier 2

values:

■ Issues Identification (conceptual site model);

■ Exposure Assessment;

■ Hazard Assessment;

■ Risk Characterisation; and

■ Uncertainty and Sensitivity Analysis

■ Regulators selected the residential Tier 2 SSTL (104 mg/Kg) as the

remedial goal, regardless of land use/exposure scenario

21

Soil (mg/kg) Resident with

Garden

On-site Employee Intrusive Worker

(within Excavation)

Chromium VI 104 3,267 3,020

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Remediation Alternatives Analysis

No Action

Physical

Physico-chemical

Biological

22

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Preliminary Remedial Technology Screening # Option Assumptions/Limitations Time

frame

(yrs)

Expected outcome Technology screening/ Tier I

Sustainable Remediation

Screening

Comments Consider

further?

1 Paving over surface Paving over soil surface either

using PCC and/ or asphalt.

This does not account for part

of some sites which will come

under the proposed highway

expansion project. Soil at these

locations will need to be

excavated, and either treated

or disposed at landfill, as it may

not meet the physical

properties for construction of a

road.

< 2 Exposure to Cr VI will be

eliminated as long as the

engineered cover (ie PCC

or other) will be in place

and is not structurally

damaged. However, Cr VI

will continue to remain a

source and potentially

continue to leach out into

the underlying vadose

zone water

This control mechanism would reduce

exposure to Cr VI, however would not

remove the source. This option may

be retained only if prior treatment of Cr

VI contaminated soils are undertaken

with a reducing agent. The engineered

surface would then limit the exposure

to Cr III, which is acceptable as Cr III

is not a carcinogen and is not easily

convert to Cr VI.

Relatively simple and

established technology, no

requirement for technology

transfer; relatively high

H&S concerns; local skills

available. Short term

implementation.

Cost: High

Yes in

conjunction

with a in-situ

or ex-situ

chemical

reduction

technology

2 Native revegetation/

Phytoremediation

Native re-vegetation to be

considered at sites where no

human activity is anticipated to

take place (eg maybe at a

dump site). Re-vegetation

would be done with Cr VI

hyper-accumulators. Locations

would need to be free of any

human or vehicular traffic so

that the plants would proliferate

adequately

> 10 Exposure of Cr VI would

be reduced by way of re-

vegetation. Cr VI would be

accumulated within the

plants. Time between

planting trees and

completion of

phytoremediation would be

long and a potential

exposure would still remain

in the interim.

The time duration, stringent

requirement that the vegetation be left

undisturbed, the fact that Cr VI would

accumulate within the plan tissue and

therefore the plants themselves would

need to be harvested and disposed off

at a TSDF make this a non viable

solution. However, it is probably the

least expensive option that can be

considered under the Tier I screening

of treatment technologies.

Relatively simple; no

requirement for technology

transfer; needs

administrative or physical

access control; relatively

low H&S concerns; local

skills available. Short term

implementation.

Cost: Low

No

3 Reducing agent

spray over

Spraying of a reducing agent

over the impacted soils.

<2 Cr VI would be converted

to Cr III. However, only

spraying would lead to

dead spots that would not

allow for direct contact

between the reducing

agent and Cr VI.

This technology will be retained but

will require a thorough mixing

mechanism to enable adequate

contact period between the reducing

agent and Cr VI.

Relatively more complex;

no requirement for

technology transfer; needs

administrative or physical

access control; relatively

low H&S concerns; local

skills available for

implementation. Short-

medium term

implementation.

Cost: Medium

Yes

23

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Preliminary Remedial Technology Screening #. Option Assumptions/Limitations Time

frame

(yrs.)

Expected outcome Technology screening/ Tier

I Sustainable Remediation

Screening

Comments Consider

further?

4 Excavate & Haul

to TSDF, backfill

with virgin soil

All the impacted soils would be

excavated and moved to a TSDF

where the appropriate remediation

technology would be applied

(reducing, stabilization/ solidification).

Fresh uncontaminated backfill soil

would need to be sourced from nearby

areas.

<2 Cr VI source would be

physically removed to a

TSDF that would

accept and isolate such

type of wastes.

The environmental (emissions),

social (high traffic movement,

dust, noise) and economic (costs

of excavation, transportation and

disposal at TSDF) impacts of this

option make it a non starter.

Fresh backfill soil would need to

be bought to the site.

Relatively simple; no

requirement for technology

transfer; relatively high

H&S concerns; local skills

available for

implementation. Short-

medium term

implementation.

Cost: High

No

5 Excavate, mix with

reducing agent

and backfill

This can be a combination option.

Spraying a reducing agent over the

dump site, along with thorough mixing

and reapplication of the reducing

agent, such that an excess dosage is

applied allowing for excess chemical

to infiltrate the shallow vadose zone

layer. Various options for reducing

agents can be chosen from. (a)

calcium Polysulfide; (b) Zero-valent

iron; (c) molasses; (d) commercially

available remediation mixtures such

as those from Ecocycle; (e) sodium

dithionate.

(f) Molasses/manure/fructose syrup

< 2 Cr VI would be

reduced to non toxic Cr

III. This option could be

finished off with native

revegetation and/ or

paving over surfaces to

seal and reduce the

exposure of Cr III to

receptors, although

this is not essential as

Cr III is known to be

non carcinogenic.

This is the preferred option from

an environmental (reduced

emissions), social (reduced dust/

noise, traffic) and economic

standpoint.

Relatively more complex;

no requirement for

technology transfer; needs

administrative or physical

access control; relatively

low H&S concerns; local

skills available for

implementation. Short-

medium term

implementation.

Cost: Medium

Yes

6 Bioremediation/

Natural

Attenuation

Use of naturally occurring bacteria to

reduce Cr VI.

> 5 Cr VI may be

converted to non toxic

Cr III. However,

specific control and

monitoring of various

parameters will be

required as biological

processes can only

take place if the

various right conditions

are present in the right

ratio

This option is very sensitive to

various critical geochemical

conditions such as redox, pH,

aerobic/ anaerobic, organic

matter conditions. In addition Cr

VI can also be toxic to

microorganisms. Therefore given

the uncertainty around this

option and it's sensitivity and

reliance on geochemical

conditions, it is not retained for

further assessment.

Relatively simple; no

requirement for technology

transfer; needs

administrative or physical

access control; relatively

low H&S concerns; local

skills available for

implementation. Short

term implementation.

Cost: Low

No

24

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Preliminary Remedial Technology Screening # Option Assumptions/Limitations Time

frame

(yrs.)

Expected outcome Technology screening/ Tier I

Sustainable Remediation

Screening

Comments Consider

further?

7 In-situ

encapsulati

on

Grouting around the perimeter of the

impacted locations with pozzolanic and

Portland cement. Surface sealing on the

top.

< 2 Exposure to Cr VI will be

eliminated as long as the

engineered cover (i.e., PCC

or other) will be in place and

is not structurally damaged.

However, Cr VI will continue

to remain a source and

potentially continue to leach

out into the underlying

vadose zone groundwater.

This control mechanism would

reduce exposure to Cr VI, however

would not remove the source.

Lateral migration of CrVI impact

will be halted via use of pozzolanic

material and ordinary Portland

cement. Engineered cap or grout

within the contaminated soil mass

would immobilize the contaminant.

Relatively complex

method; no tech transfer

required; high H&S

concerns; requires

specialized skills. Short-

medium term

implementation.

Cost: High

No

8 Electro

kinetic

Remediatio

n

Process is limited by the solubility of the

contaminant and the desorption of

contaminants from the soil matrix.

Incomplete remediation could result if

there are areas of poor electrical

conductivity between wells or the

contaminant migration path is long.

2-3 Cr VI would migrate towards

the Iron Anode which is

placed in an alkaline media,

causing the Cr VI to

precipitate out.

This option would force the

migration of Cr VI and allow for

targeted excavation at the iron

anode, circumventing the

requirement for large scale

excavation. Not considered as this

technology would need to be

imported, is energy intensive and

has associated H&S risks around

electric/ high voltage hazards

Complex method; may

require technology

transfer elements; high

H&S concerns; requires

specialized skills. Long

term option.

Cost: High

No

9 Soil

flushing/

enhanced

extraction

In situ soil flushing is used to mobilize

metals by leaching contaminants from

soils so that they can be extracted without

excavating the contaminated material.

Water or an aqueous solution is injected

into or applied onto the area or

contamination to mobilize the

contaminants. Flushing solution can be

applied by surface flooding, sprinklers,

leach fields, vertical or horizontal injection

wells, basin infiltration systems, or trench

infiltration systems. After contact with the

contaminated material, the flushing

solution is collected using pump-and-treat

methods for disposal or treatment and

reuse.

2-3 Cr VI and potentially Cr III

would be flushed out of the

impacted soils, thereby

removing the source

component.

Although the source would be

removed from the soils, the

leachate would need to be

collected from each site and

treated either individually at each

site or at a central processing

station so that Cr VI would be

converted to Cr III. In addition, the

residual treated Cr III wastes would

need to be disposed of as per

regulations. This would involve

additional transportation and other

logistics which make this option

both un-economical and untenable

from a logistics standpoint.

Complex method; may

require technology

transfer elements; high

H&S concerns; requires

specialized skills. Long

term implementation.

Cost: High

No

25

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Remedy Selection

26

• Multi-Criteria Analysis (MCA) tool based on SuRF-UK

framework under Contaminated Land: Applications in Real

Environments (CL:AIRE)

• Remedy: Reduction by Glucose followed by CPS

Environmental

Air

Soil & Ground Conditions

Groundwater & Surface water

Ecology

Natural Resources & Waste

Social

Human Health & Safety

Ethics and Equality

Locality

Community Involvement

Uncertainty and Evidence

Economic

Direct Economic Cost & Benefits

Indirect Economic Costs & Benefits

Employment & Employment Capital

Induced Economic Costs & Benefits

Project Lifespan & Flexibility

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Chromium Reduction

27

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Proposed Remedial Approach

• Soil up to ~3.5m

• Soil up to ~3.5m

Excavation

• Onsite treatment (SSTL 104 mg/kg)

• Onsite treatment (SSTL 104 mg/kg)

Remediation • Confirmation sampling

• Confirmation sampling

Validation

• Backfill treated material

• Backfill treated material

Backfill • Compaction

• Paving/ grass seeding

• Compaction

• Paving/ grass seeding

Restoration

28

Disposal to TSDF

if necessary

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Evaluation/Selection of CrVI Reducing Agents

■ Based on considerations such as local availability, cost,

safety hazards, decomposition products, case studies of

past use.

■ Based on the evaluation criteria, Calcium Poly Sulfide

(CPS) and Glucose were selected as reducing agents for

Cr VI.

■ Glucose: Carbon-based reductant. Lowered cost of

remediation by a minimum of 60% compared to sole use of

CPS.

■ CPS: Sulfur-based reductant. A ‘polishing’ step that

provides quick reduction of residual CrVI not reduced by

glucose.

29

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Dose, Stabilization and Applicability in Field

30

Completed extensive laboratory and field pilot treatability studies

Laboratory treatability studies (27 samples from various sites and 171 reactors):

Six (6) test conditions for each sample:

Mass-based glucose dosed at 8x, 12x, and 16x of baseline Cr(VI); followed by,

Stoichiometry-based CPS dosed at 0.05x and 0.15x of baseline Cr(VI)

3 days of contact time for glucose prior to CPS addition; and 1 day of contact time for CPS prior to final sampling

Test condition of 16x glucose followed by 0.15x CPS treated Cr(VI) of all 27 samples to <104 mg/kg (dry basis)

Therefore, 16x glucose followed by 0.15x CPS was selected as the dose for the field pilot study

Chemically treated material appeared to be an over wetted slurry with high water content that could be unfit for backfilling and compaction

Stabilization of the over wetted slurry was performed using cement; compaction criteria were established through Proctor Tests

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Steps (Page 1 of 2)

33

Sample collection

• Collected by hand auger

• Mixed, and stored in plastic ‘zip-lock’ bags

Baseline timepoint

• 27 samples sent for baseline Cr(VI) analysis

• Test reactors consisted of 300 gram (g) of homogenized soil

Sugar dosing, t = 0 day

• Three glucose doses

• Freshly prepared 500 gram per liter (g/L) stock of glucose

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Steps (Page 2 of 2)

34

Post-glucose timepoint,

t = 3 day

• 81 samples sent for Cr(VI) analysis (27 soil samples * 3 glucose doses)

CPS dosing,

t = 3 day

• Two CPS stoichiometric doses

• CPS dosing from 290 g/L stock solution

Post CPS timepoint,

t = 4 day

• Samples from 162 reactors sent for Cr(VI) analysis (27 soil samples * 3 glucose doses * 2 CPS doses)

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Chemical Reduction: Bench Testing Results

35

3916

219 68.7 43.5 11.4 11.6 1.4 0%

87% 93%

96% 98.79% 98.90% 99.83%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0

500

1000

1500

2000

2500

3000

3500

4000

4500

Baseline 8xglucose& 0.05Xx

CPS

8xglucose& 0.15x

CPS

12xglucose& 0.05x

CPS

12xglucose& 0.15x

CPS

16xglucose& 0.05x

CPS

16xglucose& 0.15x

CPS

Cr

(VI)

Co

ncen

trati

on

(m

g/k

g)

Cr (VI) Reduction after Glucose and CPS treatment

Average Cumulative Cr(VI) Concentration Average Final Cumulative % Reduction

% R

ed

ucti

on

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Field Demonstration: Ex-Situ Mixing

36

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Results (Ex-situ Mixing)

37

5920

67.3 16.7 0

98.86% 99.72%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0

1000

2000

3000

4000

5000

6000

7000

Average baseline Cr(VI) conc.

Average Cr(VI) conc.after 16x glucose

treatment

Average Cr(VI) conc.after 0.15x CPS

treatment

Avera

ge C

r (V

I) C

on

cen

trati

on

(m

g/k

g)

Ex-situ Mixing

Ex-situ Mixing Cr(VI) Ex-situ % reduction

Avera

ge %

Red

ucti

on

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Field Demonstration: In-Situ Mixing

38

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Results (In-situ Mixing)

39

4980

274.3 82.1 0

94.49% 98.35%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

0

1000

2000

3000

4000

5000

6000

7000

Average baseline Cr(VI) conc.

Average Cr(VI) conc.after 16x glucose

treatment

Average Cr(VI) conc.after 0.15x CPS

treatment

Avera

ge C

r (V

I) C

on

cen

trati

on

(m

g/k

g)

In-situ Mixing

In-situ Mixing Cr(VI) In-situ % reduction

Avera

ge %

Red

ucti

on

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Full-Scale Design: Ex-Situ Mixing

40

Central Treatment Area

Receiving

area (debris

crushing)

Glucose

reaction pits

Mixing

plant 1

(glucose

addition)

Mixing

plant 2

(CPS

addition)

CPS reaction

pits + validation

sampling

Contaminated

Site

Mixing plant

3

(restoration

amendment)

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Integrating Social/Environmental Aspects

44

Site-specific impacts of RAP activities

Expectations and concerns of potentially impacted entities

Public Consultation

Transition Support Options

Site-specific ESIA and

Consultation

Potentially impacted entities

Livelihood disruption

Environmental impacts

Early mitigation

Framework for Social Management

Impact Assessment

Rapid Social & Environmental Assessment;

Risk Rating;

Scope of Work

Scoping

• World Bank Consultation

requirements

• Broad consent from land

owners and occupiers;

• Basis for a detailed

Management Plan and

Stakeholder

Engagement Plan to

accompany RAP

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SIA in Action

47

Residential access

impact

Evaluations for alternate

access

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SIA in Action

48

Roadside eatery workers

Phasing of remediation

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49

SIA in Action Commercial establishment on contaminated land and consultations in progress

Adjacent grocery store impacted by

remedial activities

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Social Consultations

50

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Summary

52

Demonstrated success of real-time screening techniques

to aid in delineation of impacts;

Implementation of risk based remedial design a must for

populated, mixed land-use areas;

Incorporate socio-economic concerns early in the remedy

selection and remedial design process;

Engage often with stakeholders and build trust on

intentions, provide relevant information on positive impact

of project.

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THANK YOU

53

Jaydeep Sathaye

[email protected]

www.erm.com