NCD980602163_19840809_Warren County PCB Landfill_SERB C_Draft Report of Intergovernmental Work Group on PCB Detoxification-OCR

DRAFT, August 9, 1984 1
REPORT OF INTERGOVERNMENTAL WORK GROUP ON PCB DETOXIFICATION
In the summer of 1978 the first reports of PCB spills
along North Carolina highways were received by the State,
initially on highway 58 in warren county. subsequently,
evidence of such spills was found on shoulders of fourteen
counties in North Carolina involving more than 210 miles of
secondary roads.
Almost immediately, after discussions with various state
and federal agencies, the NC Department of Transportation
(DOT) applied a mixture of activated carbon and liquid
asphalt to contaminated areas as a temporary measure to
prevent migration of the PCB and to reduce hazards to the
public. State officials and the us Environmental Protection
Agency (EPA) determined that the best solution available at
that time, follo~ing examination of the contaminated
samples, was the removal of the material and its storage.
In June 1979 EPA approved a tract of land in warren County
as the disposal site for the PCB-contaminated soil.
Several court actions were filed by local officials and
private citizens to review these decisions. The US District
Court enjoined the state from further action pending a full
hearing. In November 1981 the cases were dismissed by the
Court and in January 1982 the appeals were dismissed. In
the meanwhile, the State attempted on two occasions to have
federal laws amended to allow for treatment of the
contaminated material in place. These efforts were not
' DRAFT, August 9, 1984 2
successful and the only disposal of the waste authorized by
EPA was by incineration or storage. In May 1982, state and
federal officials signed a cooperative agreement for the
removal of the PCB contaminated soil and a storage landfill,
using 0 superfund0 money. T~is removal was completed in
September 1982 and the landfill was closed.
In October 1982 Governor James B. Hunt met with
residents of warren County who had concerns about the
project. In an open letter issued two weeks later, he made
a series of commitments, among which were: that no other
wastes would be stored at the site; that no other landfill
would be built in the count'lf that certain monitoring would
be conducted and the results made public. One of the
commitments was:
0 The State will push as hard as it can for
detoxification of the landfill when and if the
appropriate and feasible technology is developed.
We will seek to establish a joint
local-state-federal working group to pursue this
end.0
In fulfillment of this commitment the Intergovernmental
Work Group on PCB Detoxification was organized.
Nominations to the working group were made by local,
state and federal officials, and representation from among
these constitute the group membership.
The group met nine times beginning in June 1983 and
ending with this final meeting adopting this report in
November 1984.
DRAFT, August 9, 1984 3 .
Members of the working Group and their affiliations are
listed at the conclusion of the report.
Meetings were generally held in state offices in
Raleigh, although one meeting was held in Warrenton which
included a visit to the site, and anot~er was held in the
conference room of the EPA in Research Triangle Park. A
listing of dates and locations of meetings is appended to
the report. The meetings were public although in general no
more than one member of the press was present. The
proceedings of each of the meetings were summarized and are
on file in the Governor's Office.
The Group Process
The first meeting served as orientation with
presentations by Dr. Linda Little, Executive Director of the
Governor's waste Management Board, a member of the working
Group who presented a report on the nature of PCBs,
polychlorinated biphenyls, what they are, where they
originate, and their properties, including particularly the
health and environmental significance of this contaminant.
Mr. W.W. Phillips, project director for the PCB cleanup
operation, described the facility, the nature of the
construction, and the procedures for monitoring the
landfill. Final inspection was to be conducted within a few
weeks of that meeting.
A special presentation was made by Dr. Gary Saylor of
the University of Tennessee, a director of a study on
DRAFT, August 9, 1984 4
microbial detoxification of PCBs, sponsored by EPA. He
described research into microbiological techniques for
decomposition of PCBs and provided a basis on which the
group could evaluate presentations that were to be made
thereafter.
The working group agreed to invite all individuals and
organizations, both public and private, who had indicated
that they had information of significance to provide to the
group. In particular, invitations were extended to
organizations which have experience in developing and
applying PCB detoxification technology; also to engineers
responsible for selecting and employing such practices in
real situations; and also others identified by group members
who would have something to contribute. A list of all of
those who made formal presentations and their affiliations
is appended to this report. The Governor's Office met the
expenses of all individuals who expressed an interest in
making a presentation, whether that interest was elicited by
the Governor's Office or the group, or was initiated by the
-,,,t:...._____ individual or his organization. )
The group was repeatedly commended by those who
participated during the later meetings for having conducted
possibly the most exhaustive review of the status of PCB
detoxification technology currently available.
Unfortunately, as is described later in the report, most of
the technology has been developed for detoxification of PCBs
in a relatively "pure" state, such as in oils, where
DRAFT, August 9, 1984 5
experiments can be designed to yield results that are
reasonably likely to be reproducible. The PCBs in the
Warren County landfill are heterogeneously mixed with soils
of various types and fixed in varying degrees to the
activated carbon and asphalt that had been applied to the
shoulders before the material had been removed. A second
important complicating factor in evaluating technologies
offered to the group is that most investigations are being
directed to materials that are currently presenting a
significant environmental and health hazard by being open to
the environment. In the case of the warren County landfill,
the material is not exposed and most of the technologies
offered would require exposing it for the purpose of
detoxification.
The warren county Landfill
The warren County landfill, a cross-section of which is
attached to this report, contains about 40,000 cubic yards
of soil contaminated by PCBs associated with activated
carbon, asphalt, and myriad other impurities that are
inevitably found on the shoulders of roadways.
Analyses made by the State of six core samples taken
from the fill prior to capping showed the concentration of
PCBs to range from 46 to 200 ppm, averaging about 135 ppm.
The PCBs in the landfill consist of about 80% Aroclor 1260
and 20% Aroclor 1242. The average chlorine contents of
these PCBs are 6.3 and 3.1 chlorine atoms per molecule
DRAFT, August 9, 1984 6
respectively. (The difficulty in degrading Aroclor is a
function of its chlorine content, with those containing
higher chlorine content being more difficult to decompose
microbiologically.) The PCBs in the landfill are in an
anaerobic state because the process of sealing the landfill
prevents replenishment of the oxygen used by microorganisms
in the landfill. (Unfortunately, far less knowledge is
available concerning PCB degradation by anaerobic bacteria.
Knowledge concerning the precise state of the PCBs and
associated soil materials is impossible to determine without
violating the integrity of the landfill. However, it can be
assumed that, although all drainable water has been removed
from the landfill, the nheldn water that is contained on
soil particles is relatively high because evaporation cannot
take place.
Detoxification Technologies
Incineration is the only method currently approved by
EPA for materials containing more than soj ppm of PCBs.
Incineration of the 40,000 cubic yards of contaminated soil
in the landfill, given that most of the material in the fill
is not combustible, would involve a mammoth earth moving
project that would be highly impractical in this particular
application.
Aerobic microbial methods have seemed to offer the most
promise for PCBs in soils.
DRAFT, August 9, 1984 7
Several chemical methods have been approved by one or
more of the regional offices of EPA for PCBs in oil and
other non-aqueous liquids. These generally involve
dechlorination which requires that the moisture content be
low. Incidentally, all EPA approved processes are for
closed systems where batches of the contaminated material
are treated. No definitive laboratory or field work
supporting any treatment in the open have been presented to
EPA.
PCBs may also be destroyed by ultraviolet radiation, but
this requires that the PCBs be dissolved in liquids that
permit penetration of the ultraviolet light and so this
would not be feasible for contaminated soils.
As listed in the annex to this report, the following
organizations made presentations regarding their proposed
technology for destroying PCBs: PPM, Inc.; Bioteknika
International, Inc.; Genex Corporation; Atlantic Research
Corporation; Sybron; and Polybac Corp and Galson Research
Corporation, jointly. Of these, only the Polybac/Galson
proposal was supported by actual field data on treatment of
PCB contaminated soil. Their approach involves both an
initial chemical dechlorination procedure using a
proprietary sodium based reagent system followed by aerobic
microbial treatment for final cleanup.
EPA is currently evaluating the Galson/Polybac process.
Inasmuch as the Galson/Polybac is, if it should prove
successful, one of the most likely to be appropriate, some
DRAFT, August 9, 1984 8
description of the process is warranted here. For the
Warren County Landfill, the entire landfill would need to be
excavated at a rate so as to be treated in three reactors of
18 cubic yard capacity, each operating on a 24-hour basis
for about 14 months. The reactors, built on the order of
cement mixers, bring the solvent, the composition of which
is known only to members of the group, Ors. Lewis and Neal,
under a confidentiality agreement with the proprietary
owners of the solvent. The solvent itself, after agitation
with the soil, is to be reclaimed by distillation, with the
wastewater to be decontaminated by centrifugation followed
by biological treatment or distillation. The chemically
treated soil would be returned to the landfill after further
biological treatment. Many questions remain unanswered
regarding the exact procedures so that even an approximate
estimate of the cost could not be made. The Galson/Polybac
representative suggested a range from as little as $2
million up to $12 million. In any event, before such a
commitment could be made, laboratory and pilot scale tests
would be required. In order for such tests to be undertaken
at the warren County landfill, the landfill would need to be
opened to extract a reasonably representative and adequate
sample of the soil contained therein for study.
The promise of this process is further placed into
question by the field trials conducted for EPA by Galson on
PCB contaminated soils. The results were inconclusive with
soil moisture content apparently complicating factors. The
DRAFT, August 9, 1984 9
process would appear to work on soil with up to 15% moisture
content; however the soil in the warren County landfill is
estimated to contain about 30% moisture.
Another complicating factor in all the evaluations was
the uncert~in toxicity of the chemicals used for treatment
and more especially the chemical by-products of the
decomposition of the PCBs. Based upon experience with other
synthetic chlorinated hydrocarbons, it is not unreasonable
to expect that some of the degradation products may be as
toxic or even more toxic than the original contaminants.
Another process with possible promise, not reviewed by
the working group, is a reductive thermolysis method
developed by Huber Corporation, in which the contaminated
soil is fed through a reaction chamber at 4000 to 5000
degrees Funder a nitrogen blanket. The PCBs are vaporized
from the soil and immediately reduced to carbon, hydrogen,
and chlorine or hydrogen chloride. The soil, which is
converted to spherical glass beads in the reactor, is
collected in a hopper cyclone. The gases are passed through
an elaborate system of cyclones, activated charcoal filters,
and liquid scrubbers. In EPA authorized tests, sand dosed
with 3000 ppm of Aroclor 1260 was fed at 60 lbs/minute
through the reactor with almost complete destruction
efficiency. While this process looks promising, the
existing unit will require 3 years or more to process the
soil in the landfill and the cost, not including the
construction of the unit, would be over $8 million.
DRAFT, August 9, 1984 10
Several processes are emerging, some of which may
eventually have promise for application to the contaminated
soil in the Warren County landfill. However, all of the
processes to date suffer from the following difficulties:
1) They require 1iolation of the landfill, generally
over long periods of time, so that exposure of the
population to the PCBs in the landfill may be greater over
the period of detoxification than over the lifetime of the
PCBs in the landfill.
2) Some of the methods require the use of chemicals,
the toxicity of which in the amounts required is currently
unknown.
3) In the event that degradation is not complete, which
is the most likely situation in most such treatment
processes, uncertainties with regard to the toxicity of the
degradation products would require that extensive studies be
made on a laboratory, pilot, or field basis to examine these
by-products for their composition and toxicity before a
large project is initiated.
4) The disruption in the community from almost any of
these detoxification methods would be extremely great.
Included would be uncertainties regarding gaseous emissions,
noise, traffic, and possible contamination of nearby waters
from operations around the landfill.
5) All of the methods would be very costly, generally
far more costly than is anticipated presently.
DRAFT, August 9, 1984 11
The situation was best summed up by Dr. Paul Busch, a
consulting engineer with extensive experience in disposal of
PCB-laden soils. Consulting engineers would see the
potential for work for themselves in such detoxification
projects. Nevertheless, Dr. Busch recommended against any
detoxification at this time, based upon their estimates of
the costs and the local situation. They estimated that
chemical treatment would cost $8-14 million and take one to
two years. Excavation, transportation, and incineration at
a commercial site would require $85 million and 4-5 years;
on-site incineration $6.4 million and 3 years; and
excavation, transportation and landfilling at the chemical
waste management Alabama facility, $8-10 million. They do
not believe that technology for in situ decontamination of
the landfill is currently available.
He concluded that the warren County landfill is a
well-designed secure landfill and recommended that, based
upon our present knowledge, a commitment be made to
maintenance and monitoring and the preparation of a
contingency plan to deal with any unexpected problems.
Finally, he recommended that periodic reviews of applicable
detoxification technologies be conducted.
There are many far more hazardous PCB problems, similar
to that in warren county but which require urgent attack
because exposure is a current problem. Experience in
dealing with these may yield solutions or improvements on
existing methods that might in time be valuable for
DRAFT, August 9, 1984 12
application in Warren County. However, it is not
inappropriate that the burden of such investigations be
undertaken by EPA and by those who are required to deal with
these hazardous situations.
rt is incumbent upon the state to continue reviewing
technology as it develops, and, as important, to be aware of
engineering applications, because it is at that stage that
the data obtained can be translated for possible application
in warren County.
Conducting pilot studies at the warren County landfill
would be more attractive if it were unlikely that similar
studies would not be conducted elsewhere. The major
reservation concerned with such a study at the landfill is
that in order to obtain meaningful results, the landfill
would need to be opened. Furthermore, to ~et representative
material from the fill, samples would need to be taken from
several different points in the landfill. The appropriate
time to undertake such pilot studies would be when others
facing far more serious problems would have conducted pilot
studies leading to full scale engineering applications of
detoxification on a scale similar to that for the warren
County landfill. When such technology is at hand, it would
be appropriate to initiate pilot studies for a specific
application for the warren County landfill detoxification.
DRAFT, August 9, 1984 13
Maintenance and Monitoring of the warren county Landfill
While a concern for the maintenance and monitoring of
the landfill is not a charge of the working group, the
landfill itself is a baseline against which detoxification
technologies must be measured. For example, if the l~ndfill
were found to be leaking PCBs to the waters of the area,
threatening local water supplies, a technology that may not
yet be proven would be far more attractive in dealing with
an emergency than were the landfill to be known to be
secure. Accordingly, our conclusions that technologies are
not yet available to be applied ·to detoxifying this
landfill, is based upon the landfill being of high quality,
adequately containing the PCBs, and promising to do so for a
long period in the future, hopefully at least until such
time as a technology suitable for detoxification does become
available to those who have a far more urgent need for that
technology. Accordingly, the group is interested in the
program of maintenance of the landfill. A presentation was
made to the group by representatives of the DOT, which is
responsible for its maintenance. The following measures are
currently being taken:
* The District Engineer and the warren County
Maintenance Supervisor are authorized to perform routine
maintenance work on the landfill.
* The District Engineer or Maintenance supervisor is to
make monthly inspections of erosion protection, burrowing
DRAFT, August 9, 1984
animals, surface subsidence, and other observable
conditions.
14
* Seeding and fertilization are to be done semi-annually
for two years.
* After the initial two years, applications of
fertilizer, top dressing, and seedipg for cover maintenance
are to be made annually.
* Mowing is to be done twice a year to a 6-inch height
to preclude woody growth.
* The fence perimeter is to be treated for vegetation
control.
* The access road is to be maintained annually, insuring
a 10-inch stone surface with proper drainage and proper
vegetation control.
All of these procedures are to be implemented with
routine highway maintenance.
The working group was in general impressed with the
maintenance and monitoring but it needs assurance that this
will be continued and enhanced, if necessary, with
particular reference to monitoring of private wells as well
as observation wells.
Role of EPA
The EPA expects the state to maintain the facility and
conduct the routine monitoring of air and water and
security. It can be assumed that if PCB is detected in the
monitoring wells or if anything else portends difficulty,
DRAFT, August 9, 1984 15
EPA would participate in correction. It was reported that
EPA is developing a plan for "second phase" management of
cleanup facilities, but this program is at least several
years away. EPA would not permit funds for secondary
treatment of wastes, that is retreatment of waste which had
been satisfactorily handled under the superfund program, as
long as the best proven technology had been used and there
is no problem with it.
conclusions
1) The warren County PCB landfill is a
state-of-the-art, high security landfill which exceeds the
design requirements under the Toxic Substances Control Act.
2) PCBs are not now leaking from the site through any
route.
3) Technology has not yet been demonstrated for
microbial or chemical processes that would be at all
appropriate for detoxifying the contaminated soil in the
Warren County landfill. Even if such methods were feasible,
not enough is known to assess potential health hazards
associated with the reagents and solvents used in the
processes or with the degradation products evolving from
treatment of the PCBs.
4) Thermal destruction may be possible, but given the
nature of the contaminated soil and the massive earth
movement that would be required, and the risk involved in
keeping the landfill open for an extended period, probably
DRAFT, August 9, 1984 16
several years, it would entail greater risks than are
perceived by maintaining the landfill in its present state.
In addition, the cost for this would be exceedingly high.
5) While the landfill was well designed and in the main
very well constructed, its proper maintenance is exceedingly
important if the landfill is not to become a liability to
the community. One measure of the success of a landfill
project is a sound monitoring program.
6) There is inadequate perception among the public,
particularly in warren County, concerning the nature of the
landfill and the measures that are being taken to insure its
integrity. While the information concerning the results of
monitoring are public, insufficient effort has been made to
disseminate this widely nor to educate the public concerning
the status of the landfill.
Recommendations
In light of the findings, the following recommendations
are made:
1. warren County PCB Landfill should not be disturbed
at this time.
2. Plans for the routine maintenance of the landfill so
long as it contains PCB contaminated soils should be
institutionalized with the responsibility of the DOT being
clearly set forth both in the record and in public.
3. Plans for regular monitoring of the site and of
private wells in the area should be institutionalized. The
DRAFT, August 9, 1984 17
monitoring should include both structural monitoring as well
as sampling of observation wells. Again, the responsibility
for the former should rest with the DOT and the latter with
the Department of Human Resources, and these should be
spelled out.
4. A contingency plan should be prepared and be well
publicized, to come into play in the event of any damage to
the landfill or any evidence of PCB leakage from the
landfill. This contingency plan would state where the
responsibility for corrective action would rest, from where
the funds for such corrective action would come, and who
would be responsible for compensation to injured parties in
the vicinity. Again, this contingency plan should be
institutionalized with provision for periodic updating.
5. This ad hoc working group should be disbanded but a
mechanism should be established within state government to
continue surveillance of developments in PCB detoxification,
with representation from the appropriate state agencies as
well as liaison between this group and EPA, Warren County,
and the universities.
Finally, the working group is appreciative of the level
of concern that had been extended to this problem by the
Governor and state agencies and for the support given to the
group exercising in its responsibilities. Particular thanks
goes to Mr. Robert Janson, Senior Policy Advisor to the
D,RAFT, August 9, 1984 18
Governor, for his concern and assistance.
Signed,
List of Committee Members