NCD980602163_19811103_Warren County PCB Landfill_SERB C_Draft PCB Sampling Memorandum of Understanding-OCR

PCB SAMPLING
MEMORANDUM OF UNDERSTANDING
BETWEEN
THE STATE OF NORTH CAROLINA
AND
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV .
I. BACKGROUND STATEMENT OF PROBLEM
11/3/81 DRAFT
Between June, 1978 and August, 1978, several thousand gallon~ of industrial
liquid waste material identified as polychlorinat ed bi phcnyl (PCB) were
deliberately dischar ged along 210 miles of .highway shoulder s in 14 North
Carolina counties. The PCB waste sites are centered around Raleigh, where
the material was distributed for disposal . This area includes a variety
of geological, biological, topographical, peological, and environmental
settings that may offer differing degree.s of contamination through
migration.
See also Environmental Impact Statement Historic Resume Attachment "A",
which by reference 1s made a part of this MOU.
II. GENERAL OBJECTIVES OF PROJECT
A statistical study has been designed to redefine the physical limits
of the PCB laced oil and associated contaminated soil along 210 miles of
North Carolina roadway.. Specifically, the investigation is designed to
identify any lateral and vertical migration of PCB contaminants as well
as any dilutions or reconcentrations that may have occurred due to natural
processes.
III. TO ACCOMPLISH THESE OBJECTIVES, TIIE STATE AND EPA AGREE AFTER EXECUTION
OF THIS MEMORANDUM OF ·UNDERSTANDI NG THAT:
A. EPA will fund the required sampling program t hrough Federal contracting
authority. The major contracting mechanism to be used
will be the EPA Field Investigation Team (FIT) from the firm of Ecology
and Environment, Inc. EPA will be directly r esponsible for supervision
of the FIT Team and will consult with the appropriate State official,
as specified in this Memorandum of Understanding, before
major decisions are made.
B. Both the State and EPA agree to the s ampling program scope of work as
shown in Attachment 11811 to this Memorandum of Understanding. All
analytical work will be performed by a labora tory(s) apJrroved by EPA
and revie1-1ed by the State. The EPA, Region IV, Environmental Services
Division will assume primary r esponsibility for qu ality control of
all analytica l data , including protocols for sample collecting and
shipping . The State may per-form such additional quality assurances
as it deems advisable, but at its own expense. ~1e State will be
responsible f or securing proper s ite acces s permits that may be
required for both public and priva te sampling sites.
' ..
C. Both the State and EPA agree to the Community Relations Program as
outlined in the Community Relations Plan in Attachment "C" to this
Memorandum of Understanding which by reference is made a part of
this MOU. News media contacts will be managed by the State and
EPA representatives named in Attachment "C" •.
D. In the event the National Response Team (NRT) or Regional Response
Team (RRT) determines
that an environmental emergency exists, the NRT or RRT in
fulfilling their responsibilities may temporarily suspend this
Memorandum of Understanding. The NRT or RRT will assume primary
responsibility for emergency response and mitigation and will
determine when the emergency is over~ Recovery of any funds
expended by the NRT and RRT is not pre-empted by this Memorandum
of Understanding.
E. Termination of this Agreement may occur in any of the following
ways:
1. Termination due to conflicts that cannot be resolved between
parties to the Memorandum within thirty (30) days •.
2. Substantial non-compliance by any party with terms of the
Agreement.
3. Mutual termination after completion of the report specified
in paragraph A herein.
F. This Agreement may be modified by mutual consent of the parties
to delete, augment, or revise any of the provisions herein.
IV. NORTH CAROLINA DECISION MAKING
Sampling program inquiries should gq to the State Coordinator, Tom
Karnoski (see chart). Major program decisions will be made by O. W.
Strickland, Head of Solid and Hazardous Waste Management Branch.
Technical decisions will be cleared by Tom Karnoski through Bill Meyer
and 0. W. Strickland at the Branch level. Technical assistance on the
State/EPA MOU will be provided by Emil Breckling, Environmental Planner
w_i th the Branch. Decisions involving Secretary Morrow or Governor
Hunt will be cleared by O. W. Strickland through the proper official (s)
to Secretary Morrow. Community relations/newsrelease inquiries should
go to Bryant Haskins, Public Affairs Coordinator for the hazardous
waste management program. Bryant will be responsible for coordinating
with Gary Pearce, the Governor's press Secretary, and with EPA media
contact person on the release of information.
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I . '
* ( 919) 733-5811
* Sarah T. Morrow
[phone]
Division Level
III. STATE PCB SA~PLING
DECISION MAKING CHART
Governor
James B. Hunt
Governor's Press
Secretary * Gary Pearce [phone]
Secretarial Dept.
of
Human Resources
*
[phone]
Proper
Official
Public Information
* Bryant Haskins [phone]
r-1---ir-----J----.
[phone]
* O. W. Strickland
* I Hazardous ''!as te
William r-Iever ___ _.__
* Tom Karnoski
(919).733-217S
3
Director of
Health Services
Dr. Ron Levine
Environmental
Health
Jim Stamey
Solid and
Hazardous
Waste Mgt.
Branch
* Emil
Breck ling
' ..
V. STATE AGENCIES PCB PROJECT RESPONSIBILITIES
(See Chart)
Department of Human Resources
Environmental Heal th Section -Solid and Hazar·dous Waste
Management Branch
The Solid and Hazardous Waste Management Branch is responsible
for State coordination of the sampling project. State Coordinator
Tom Karnoski will be responsible for coordination as indicated in
the project decision making chart.
Department of Justice
The Department of Justice provides legal support and is responsible
for legal action as a result of the PCB spill.
Department of Crime Control and Public Safe~
Coordinates all law enforcement and traffic control measures._
Provides any services or logistical support as may be directed.
Department of Transportation
Erects and maintains signs, lights, barricades, or other traffic
control devices as deemed ·appropriate to maintain or control
traffic along affected routes during sampling.
VI. PARTICIPATION IN DATA: COLLECTION, ANALYSIS, AND INTERPRETATION
EPA agrees to share with the state all information and data collected
relevant to this project.
North Carolina will be provided with multiple hard copies of all records,
written observations, documents , analysis, etc. that are generated by
and are directly related to the sampling prog·ram.
North Carolina will accept all data ( in final form) generated by the
sampling p.rogram to be factual. Final conclusions, recommendations,
interpretations, etc., based on the factual data, will be reviewed
by EPA and North Carolina, and will be publicly released according to the
community relations ptan.
North Carolina may provide representatives to be present during all
procedures and processes of the sampling program. These representatives
will meet the following requirements:
1. Have prior approval from the North Carolina Solid and Hazardous
Waste Management Branch.
2. Will act only as observers.
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Ul i Dept. of Justice AG Rufus Edmisten 733 I 3377 Legal -Bill Raney 733-5725 Robert --Reilly 733-4618 IV. STATE AGENCIES PROJECT RESPONSIBILITIES Governor James B. Hunt 1 Dept. of Natural Resources and Community Devel. Secretary -Joseph Grimsley 733 I 4984 Environmental """'Management Bob Helms 733-7015 r T Dept. of Human Resources Seci•etary -Sarah T. Morrow 733 I 4534 Public Informati·on Bryant:Haski°ns --733-4471 Solid and.Hazar-dous Waste Manage-1..ment Branch o. W. Str-ickland Tom Karnoski 733-2178 T Dept. of Crime Control and Public Safety Secretary -Burley Mitch~ll 733 I .2126 Assistant Secretary of .-Public Safety Dave Kelly 733-2126 Emergency 1-Management Division Jim Buffaloe 733-3867 .. l Dept. of Transporta-tion Secretary 7331 2520 Head of Equipme """'Branch M. C. Adams 733-233
3. Will not hinder or obstruct the sampl1ng program as outlined
in the work plan.
4. Will not release any information except as outlined in the
community relations plan.
VII. ACCESS TO STATE AND PRIVATELY OWNED LAND
Permission to go on property and collect soil samples from sampling
points will be received in written form. As outlined in the work
plan, an initial survey will locate all sample points in the field.
· -At this time the appropriate landowners (North Carolina Department
of Transportation or private individuals) will be identified so that
written permission to enter the property can be secured from them.
In the event a particular private landowner cannot be found or
actually denies entry to his property, an attempt will be made to
secure a warrant from the local magistrate.
VIII. QA/QC
EPA will conduct a quality assurance/quality control program on
random selection of soil samples collected by their contractor. North
Carolina will be provided with results of this program and will be
notified immediately of any discrepancies discovered or implied.
IX. EMERGENCY SITUTATIONS
The North Carolina Solid and Hazardous Waste Management Branch will
provide individuals responsible for 24-hour call should unexpected or
emergency situtations arise. The designees are:
Thomas C. Karnoski
Bryant Haskins
Emil Breckling
STATE OF NORTH CAROLINA
Department of Human Resources
By:
Date:
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Home Phone
[phone]
[phone]
( 919) 467-6571
Office Phone
(9+9) 733-2178
[phone]
[phone]
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
By:
Date:
Attachment "A"
Environmental Impact Statement
Historical Resume
The first deliberate discharge of what was later identified as PCB liquid
materials took place the last week of June, 1978, on remote roads of the Fort
Bragg Military Reservation. The discharge was investigated by Fort Bragg
personnel who secured liquid samples of the material. The next discharge
occurred on July 27 and July 29 on the roadway shoulders of NC 58, north of
Centerville in Warren County. This discharge was reported by prlvate citizens
to the N. C. Highway Patrol, who alerted the Divis ion of Health Services, Water
Supply Branch. Water Supply Branch personnel notified Division of Environmental
Management, Water Quality Program personnel in the Raleigh Field Office of the
spills. Raleigh Field Office personnel investigated the spill on July 31 as
an oil spill and on finding .no oil ponded or evidence in surface waters, returned
to their office without taking further action.
On August 2, the Water Quality Operations Branch, Division of Environmental
Management, received a call from a Johnston County farmer concerning a spill on
NC 210 in front of his farm. Because of the .description of the odor and the
effects on field workers being reported, a staff chemist was ·immediately dispatched
to investigate the spill and to take appropriate samples. Grass, soil, and water
samples were hand delivered to the Division of Environmental Management Laboratory
for analysis later that afternoon, August 2. The same chemist who investigated
the Johnston County spill encountered a similar spill near Snow Camp, North
Carolina on SR 1004, Alamance County, while returning to his home. A sample was
taken from the spill area and hand deli V(l'~ed to the laboratory the following
morning for analysis.
On August 4, the Laboratory's Analytical Section Chief notified the Water
Quality Operations Branch that the material spilled in Johnston County appeared
to be Aroclor-1260, a Polychlorinated Bi phenyl (PCB) substance. The Water Quality
Operations Branch immediately notified the Chief of the Environmental Protection
Agency, Region IV, Emergency Response Branch, of the Laboratory's findings. After
briefing the Director, Division of Enviro~~ental Management, a meeting was called
with representatives of the Attorney General's Office, the Department of Crime
Control and Public Safety, and Public Information representatives of the Secretary
of the Department of Natural Resources and Community Development. A notification
to all law enforcement officials was prepared and sent over the Po~ice Information
Network system during the late evening hours of August 4. A news release was
prepared and sent to local newspapers for publication in the Saturday morning
newspaper. The same day, the laboratory confirmed material discharged in
Alamance and Chatham Counties was Aroclor-1260, the same form of PCB material
found in Johnston and Harnett Counties. Also on August 4, the N. C. Highway
Patrol delivered soil samples obtained from Chatham County to EPA. The results
of the EPA laboratory analysis were reported to SBI on August 8.
On August 5, Water Quality Operations Branch met with concerned citizens
in Johnston County, investigated the spill areas in Johnston and Harnett Counties,
and conducted a door-to-door contact with people residing along NC 210. Because
of concern by some residents along NC 210, the Di vision of High\"lays • Department
of Transportation was requested to cover the spill with a laye1~ of sand in order
to suppress the noxious odors present. This was completed in late afternoon
August 5 and continued on August 6.
On August 6, the Raleigh Regional Office wa s directed to secure samples
of the spill area in Warren County to determine i f similar material had been
deposited along NC 58. Because of the publicity being given by the newspaper
and TV to the spills, the Fort Bragg Environmental Coordinator requested the
Water Quality Operations Branch to analyze material secured from the spill at
Fort Bragg to determine if similar material was spilled on the mili tar·y res er-•
vation. Because of the publicity, reports of spills began coming in from many
different sources such as Highway Patrol, Department of Transportation Divis ion
Engineers, private citizens, and others in nine additional counties. It appeared
that most of the spills took place in the evenings of August 1, 2, and 3. While
it has not been conclusively determined, spills may have occured in Wilson County
the evenings of August 5 and August 8. The Division of Environmental Management
Laboratory continued to work ~round the clock to verify the material in the
spills in the other counties. ·
On August 7, a preliminary conference was held with representatives of the
Division of Highways, Division of Health Services, Attorney General's Office,
arid Public Information personnel. Specific information gathering activities
were spelled out and assigned to specific people . A coordination conference
was held with representatives of the Department of Human Resources, Department
of Agriculture, Attorney General's Office, the Department of Transportation,.
Environmental Protection Agency, and the news media, on August 10. A working
session was held following the briefing to news media to provide direction,
identify responsibilities and initiate specific actions concerning the spilled
material. Advice was solicited from the Environmental Protection Agency Office
of Toxic Substances, the National Center for Disease Control, Hevi Duty Electric
Company, the EPA Health Effects Research Laboratory, and various academic and
private sector personalities known as having expertise in handling this type
of material. On August 11, the EPA Health Effects Research Laboratory began
ambient air sampling at spill sites.
North Carolina State University was identified as having expertise in
detoxifying pesticides. The University was contacted to provide expert advice
and assistance. A proposal was submitted to the Governor for temporarily
deactivating the PCB materials to prevent its migration and to neutralize any
hazard to people coming into contact with the material on the shoulder of the
highway. The Governor provided directive authority to proceed on August 15,
1978. An activated charcoal solution was applied to the PCB contaminated
roadway shoulders during .the latter part of August. On August 15p the Governor
requested assistance from the President of United States. On August 17, a
special EPA coordinator was assigned to the problem.
Because the initial sampling procedures only gave gross approximation
to the concentration of PCB material on the grass and in the soil column,
several cross sectional samples were taken at one-inch intervals to determine
the magnitude of the penetration into the soil column and the strength of the
material at various depths. These samples were taken during the period of
August 21-28.
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On August 28 and 29th, the Epidemiology Section of the North Carolina
Division of Health S.::rvices convened a meeting of national experts on PCBs.
Those in attendance included scientists from the Environmental Protection
Agency, National Institute of Occupational Safety and Health, National
Institute of Environmental Health Sciences, and the Center for Disease Control.
State personnel in attendance were from the Division of Health Services,
Natural Resources and Conununi ty Development, Departm~nt of Agriculture, and
the Department of Transportation. Industrial users of PCBs were represented
by a person from Carolina Power and Light. The purpose of this meeting was
to assess the immediate risks to the persons who live along the spill routes
and to discuss the safety of those persons who would be participating in the .
removal and storage of the PCB contaminated soil .
On September 6, 13, and 19 alternative methods of removing soil from the
roadway shoulders were conducted on noncontaminated sections of roadway shoulders.
When the soil removal procedure had been formulated a test removal operation
was conducted. The test removal operation was performed on October 5, 1978 on
a one mile PCB contaminated section of NC 58 near Inez in Warren County.· The
PCB contaminated soil obtained during the test removal operation has been
temporarily stored at a disposal site in Warren County. The.purpose of the
test was to examine the practicality of picking up the contaminated material
as well as any possible health _~r environmental effects. On November 6, test
results indicated that the pick up of contaminated shoulder material was not
harmful to the environment or personnel.
On September 29, 1978, Governor James B. Hunt's request for assistance
from the Federal District Assistance Administration, Department of Housing
and Urban Development was denied. On October 4, North Carolina officials
were notified by the Federal Highway Administration, U. S •. Department of
Transportation, that the request for_emergency relief funds was denied.
During the month of December a Draft Negative Declaration was prepared
pursuant to the North Carolina Environmental Policy Act. The statement was
sent to State Clearinghouse on December 21, 1978 for circulation. Comments
received on the Draft Negative Declaration requested an EIS be prepared.
Therefore, a Final Negative Declaration was not prepared.
On December 12, an application was filed with EPA for approval of the
Warren County site for placement of contaminated PCB material. On January 4,
1979 a hearing was held on the Warren County site at the National Guard Armory.
During the period .January 25-31, 1979 additional soil samples were taken
by the Division of Environmental Management to substantiate the location of the
contaminated material and determine if any migration had occurred. Test
results indicated that the material was present and had not migrated. On
January 29, 1979, a meeting was held in Washington, D. C. between representa-
tives of the State of North Carolina and EPA officials to discuss the current
PCB regulations and to discuss alternative solutions. On February 6, the state
of North Carolina filed petition with EPA to amend the rules under the Toxic
Substances Control Act to allow consideration of alternate methods of
treatment.
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On February 15, 1979, a test was run on a contaminated section of NC 210
in Johnston. County and on March 22, on a contaminated section of SR 1004 in •
Alamance County to determine the feasibility of utilizing the theory of PCB
fixation with activated carbon.
On June 4, 1979, the EPA Administrator, Douglas Costle, ruled against
the petition of February 6 to change the regulations to allow consideration
of alternate methods of treatment. The Region IV EPA Administrator, John
White, on June 4, 1979 approved the State's application to construct a land-
fill jn Warren County .for disposal of the PCB contaminated soil.
Definition of PCBs1
PCBs (polychlorinated biphenyls) are a class of chlorinated, aromatic
compounds which have found widespread application because of their general
stabilities and dielectric properties. PCBs have been prepared industrially
since 1929 and are now produced in many foreign industrial countries. The
Monsanto Company's preparations of PCBs were termed "the Aroclors". Produc-
tion of PCBs ceased in the United States in mid 1977.
The outstanding physical and chemical characteristics of PCBs are their
thermal stabilities, resistance to oxidation, acid, bases, and other chemical
agents as well as their excellent dielectric (electrically insulating) proper-
ties. These and other properties have led to numeroas uses of PCB such as
dielectric fluids (in capacitors and transformers), industrial fluids (use in
hydraulic systems, gas turbines, and vacuum pumps), and plasticizers (adhesives,
textiles, surface coating, sealants, printing, and copy paper).
PCBs were prepared industrially by the chlorination of biphenyls with
anhydrous chlorine, using iron filing or ferric chloride as catalysts. The
crude product was generally purified to remove color, traces of hydrogen
chloride, and catalyst which was usually achieved by treatment with alkali
and distillation. The resulting product was a complicated mixture of chloro-
phenyls with different numbers of chlorine atoms per molecule. (This fact
is responsible for the physical state of PCB preparations). Most individual
chlorophenyls are solid at room temperature whereas commercial mixtures
are mobile oils.
The most important physical properties of PCBs from an environmental
point-of-view are solubility and vapor pressure. The solubility of PCBs in
water is low and decreases with increasing chlorine content. Values given
by Monsanto are 200 ppb (parts per billion) for Aroclor 1242, 100 ppb for
Aroclor 1248, 40 ppb for Aroclor 1254, and 25 ppb for Aroclor 1260. Studies
on the solubility of PCB in water are complicated by the fact that these
compounds are strongly sorbed onto various surfaces. PCB has been shown to
sorb relatively rapidly onto charcoal, plastic, glass, and silt or soil
particles.
l t· t 1 h ·t f Hu zinger 0. e • a., C emis ry o PCBs, CRC Pres
Cleveland, Ohio, 1974.
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PCBs have a high specific gravity (Aroclor 1260/1.566) and a relatively
high density (Aroclor 1260 weighs 13.50 lbs./gallon at 25°C). Loss of PCB
by evaporation is extremely slow, i.e. Aroclor 1260 exposed to loo0 c for six
hours would have an evaporation loss of Oto 0.1%. PCBs are very stable at
high temperatures. A temperature of 2000°c or greater is necessary before
these chemicals are destroyed.
In summary,, PCB compounds have been manufactured and used in this country
since 1929. Their uses have varied from the manufacture of many household
products to industrial uses. PCBs al'e very stable heat t•esistant compounds
that are fat soluble and some are known to build up in biological food chains.
PCBs are relatively insoluble in water but have strong absorption properties
onto such materials as clay, soot, charcoal, and grease. PCBs are found in a
wide variety of substrates throughout our environment~
Regulations Pertaining to PCB Spills
The Environmental Protection Agency has promulgated rules and regulations
pursuant to the Toxic Substance Control Act to protect the environment from
further contamination by PCBs resulting from improper handling and disposal
of PCBs • .Title 40 Part 761.10 (b} (3) of the Toxic Substances Control Act
spells out disposal requirements of PCB mixtures in soil. The regulation
initially defined PCBs to mean any mixture with 500 parts per million (PPM}
of PCB. This regulation was amended effective July 2, 1979. The amendment
in 40 C.F.R. 761.1 (b} lowered the concentration of PCBs which are covered by
the regulation from 500 ppm to 50 ppm (Federal Register, Vol. 44, No. 106,
May 31, 1979). The regulation requires that soil and debris contaminated
with PCBs must be disposed of either through incineration or in a chemical
waste landfi 11.
Criterion for any such landfill is contained in Annex II to the
referenced regulation. Specific wording in C.F.R. 40, Part 761.10 (b) (3)
is as follows:
"Soil and debris which have been contaminated with PCB as a
result of a spill or as a result of placement of PCBs in a
disposal site prior to the publication date of these regula-
tions shall be disposed of
(i} In an incinerator which complies with Annex I, or
(ii} In a chemical waste landfill."
The State of North Carolina petitioned the USEPA for a change in the
disposal requirements for PCB mixtures in 40 C.F.R. 761.10 (b) (3). North
Carolina requested that the regional administrator be allowed to approve
methods of disposal other than incineration or landfilling. The petition
for a rule change was denied by EPA on June 4, 1979.
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Need for the Proposed Action
In early August, 1978, the Water Quality Operations Branch received a
· call from a Johnston County resident pertaining to an apparent chemical spill
along the roadway shoulders of NC 210. Gra~s, soil and water samples were
collected from the spill site and analyzed. The laboratory analysis identified
_ the material taken from the roadway shoulders as Aroclor 1260 .. i:i. polychlorinated
biphenyl (PCB) substance. Reports of other chemical spills along sections of
roadway in various counties were reported and investigated in the first week
of August.
Because the initial sampling procedure only gave gross approximation to
the concentration of PCB material, a more detailed soil sampling and analysis
procedure was performed during late January 1979. The soil samples taken
served to quantify the PCB as to the level of concentration along the roadway
and to determine the depth in the soil column the PCB substance had penetrated.
The deliberate discharge of industrial waste material containing poly-
chlorinated biphenyl substance onto the roadway shoulders was identified in
fourteen counties of the state.. The 211 shoulders miles of roadway on which
the spills occurred were grouped .to form .15 spill site locations. Appendix A
contains county maps showing the locations where .the PCB industrial waste
material was discharged onto the roadway shoulders. Appendix A also contains
descriptions of the sampling site locations and the soil sampling results in
terms of mg/kg ofAroclor 1260, a PCB substance.
Polychlorinated biphenyls are highly stable compounds that will remain
unchanged in the environment for a very long time. PCB will biologically
magnify in food chains and accumulate in the fatty tissue of both humans and
animals. The long term effects of_ human and animal exposure to low levels of
PCBs are not clearly documented; however, studies using laboratory animals
have shown potential chronic effects such as cancer induction, pigmentation,
and behavioral changes. The PCB contaminated soil may become translocated
into adjacent agricultural crop lands and may have an impact on agricultural
cash crops such as tobacco, feed and forage, and crops for human consumption.
The State of North Carolina considers the removal of the PCB contaminated
soil a necessary action to insure the protection of the natural and human
environment.
In addition to the above reasons for removal of the PCB contaminated
soil, the North Carolina Department of Transportation must periodically reshape
shoulders and ditches adjacent to state highway system travelways in order to
maintain safe egress for the traveling public and to maintain proper cross
slopes for storm drainage. While these operations are closely followed by
necessary erosion control measures to stabilize the loosened soil, there
nevertheless-follows a period of time during which the shoulders and ditches
are susceptible to erosion. In addition normal deterioration of the highways
caused by traffic, climate and age will require future modifications to the
contaminated areas including resurfacing and possible widening and realignment
of the highway facilities. All of these operations would tend to redistribute
the contaminated soil in a manner which would be very difficult if not impossible
to control.
6
The presence of PCB contaminated material along state highway system
routes has caused the Department of Transportation _to disallow all encroachment
requests along those roadway shoulders which involve activities requiring
excavation or redistribution of the soil structure. This has included place-
ment of utilities and commercial and private driveway pipes. These activities
involving the roadway shoulders are necessary in order to provide needed
services to property owners located adjacent to PCB spill areas.
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Attachment "C"
-COMMUNITY RELATIONS PLAN-_--PCB IN N.C.
-Media coverage of the PCB dumping in North .Carolina, and the civil
and criminal actions that have followed, has been extensive. Therefore
it will not be necessary to conduct a massive media or public awar~ncss
camp aign to inform the .citizens of the state about the PCB problem.
Several steps are recommended, however, to insure that all North
Carolinians are aware of the EPA's intent-ion to do more sampling, the
purpose of the sampling, and the sampling results when they become
available.
-(1) When a date for the -sampling is established, a press advisory
should be mailed to all weekly and semi-weekly newspapers in the state,
as well. as to all daily papers, both wire services, and all radio and
television stations. The advisory should be designed to fit the format
of the medium to which it 1s being sent.· A recorded public service
message could be mailed, for instance, to all radio stations if it is
deemed appropriate by the agencies involved. Special care should be
given to fully inform the media representatives in the 14 counties where
the PCB was dumped: Alamance, Chatham, Edgecombe, Franklin, Granville,
Halifax, Harnett, Johnston, Lee, Nash, Person, Wake, Warren, and Wilson
counties. All press advisories should explain as simply and as completely
as possible the sampling procedure, the reason for the sampling, and
other pertinent information. The name of a contact person in the state
should be included in the advisories in case additional information is
desired. This contact person will be the state spokesperson for the
project, and information should be released only with his prior approval.
His telephone number should be made available to the press. Since the
2
EPA will be the-lead agency for the project, a federal spokesperson also
should be appointed, and this person should approve all information before
it is released.
(2) All public officials in the affected counties (county commissioners,
c1 ty managers, county managers, city commissioners·, etc.)· should be 1nformed
of the ·sampling program before the information appears in the media. These
officials then will be able to respond to any general questions that might
arise from their constituents. An information packet could be provided to
county and city officials as well as to the press as one method of answering
any potential questions. A toll free number will be provided through the ·
Department of Human Resources' "Care Line" so that the general public can
call in any questions or concerns that they might have.
(3) The designated state spokesman for the sampling project should
visit as many sampling sites as possible during the first few days of the
program to familiarize himself with the procedures involved, and to be on
hand in case local media representatives have any questions. It should
be made clear to all consultants working with the sampling program that
no information is to be released without the approval of the state and
federal contact persons.
(4) The consulting engineer for the project should be utilized as
a source of information when compiling data for release to the media on
the more technical issues involved (the sampling procedure, for instance).
(5) While a state contact person should be on hand to handle press
inquiries, all written material should be released jointly through the
state and the EPA, or from the EPA regional office (with prior state
approval). At all times it should be made clear that information will
be released as quickly and as accurately as possible through the proper
sources. It is extremely important that this information come only from
. .
designated federal and state spokespersons in order to avoid confusion,
and to insure that correct information 1s released.
3