NCD980602163_19841212_Warren County PCB Landfill_SERB C_1984 Warren County PCB Landfill Detoxification Report-OCR

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INTERGOVERNMENTAL WORKING GROUP FOR PCB DETOXIFICATION
Journal of Proceedings December 12, 1984
Purpose: Proposal by Sybron for Detoxification of the Warren County
PCB Landfill
Attending:
Dr. Daniel A. Okun, Chairman
Dr. Robert G. Lewis
Mr. William W. Phillips
Dr. Linda Little
Rev. Luther C. Brown
Mrs. Joyce Lubbers
Mr. George E. Shearin
Mr. Robert Jansen
Mr. William L. Meyer
Not Attending:
Visitors:
Mr. 0. W. Strickland
Dr. Robert Neal
Mr. Jesse Jones
Mr. Russ Edmunson
Rev. Clinton Mccann (proposed substitute for Mr. Henry Rooker)
Betsi Simmons
Kay Horner
Special Note:
Members of the group were made aware of the death of Mr. T. Henry
Rooker and expressed their sympathy and regret for his death and
respect for Mr. Rooker as a person and dedicated member of the
work group. Sympathy may be expressed to his wife, Mrs. Marie
Rooker at Route 2, Warrenton, N.C.
Sybron Proposal
1. Dr. Anne L. Kopecky, Research Microbiologist and Lois T. Davis,
Microbiologist, presented Sybron's proposal.
Sybron's proposal is based upon microbiological degradation of PCB's. A
c74 labeled PCB source was reported to be degraded by a select mixture of
mutant bacteria in a laboratory study.
The laboratory study consisted of inoculating an aqueous PCB mixture with
aerobic bacteria and nutrients in shaker tubes for several weeks. Aqueous,
organic, and off-gas fractions were monitored. Chemical analysis and
stoichiometric balances indicated that the PCB was decomposed to a 11 non-
detectable11 level in three to four weeks with no chlorinated or phenolic
by-products.
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Problems encountered with the study included a decrease in decomposition
rate with time (this was attributed to feedback inhibition resulting from
fatty acid production and accumu1ation). Decomposition products were not
extensively identified. An air t~ap failed to operate properly and off-
gases could not be analyzed for C 4.
Dr. Kopecky noted that apparently the mutant bacteria had developed metabolic
specificity for double ring structures and for the ring rather than attached
chlorine. The lab study indicated that metabolic by-products would require
removal to prevent inhibition.
Ms. Davis indicated that Sybron had considerable experience utilizing micro-
organism for land treatment of chemicals. General procedures outlined by
Ms. Davis included balancing carbon-nitrogen ratios, application of one pound
of select microorganisms per 100-120 ft.2 and repeated applications to main-
tain optimum conditions. It was stated that bench scale tests and engineer-
ing designs would be required for implementation of the Project.
Discussion of Sybron Proposal
Dr. Okun questioned the applicability of transferring interpretations of
aqueous media data to contaminated soils. He also asked about the types
of organisms involved and methods of treatment. Sybron reported that
the organisms were probably pseudomonas and originated from cultures from
contaminated soils. Sybron stated that decomposition of materials in aqueous
solutions should be similar for soils if moisture contents are controlled.
Sybron proposed to treat the PCB soil mixture in one-foot layers or by batch
reactor, both external to the landfill.
Dr. Lewis questioned the rate of decomposition and time required to reduce
PCB to an acceptable level. Sybron reported PCB decomposition to occur in
three to four weeks to a no "detectable" PCB level.
Dr. Little asked if soil column studies had been performed in the lab studies.
Sybron reported that none had been performed.
Dr. Lewis noted that the source of c14 -labeled PCB is a mixture of Aroclors
and decomposition was probably limited to the lower Cl saturated Aroclors.
Data presented to indicate microbial decomposition specificity for Aroclor
1260 may simply be decomposition of other Aroclors in the mixture. Dr. Lewis
commented that the chromatographs and table presentation of differences
between initial PCB concentration and final concentrations for Sybron's
DC-1006 PB is consistant with decomposition of Aroclor mixtures. The data
presents a range of initial concentrations from 250-1800 ppm PCB and a
relatively consistant 120-150 ppm reduction regardless of initial concentration.
Dr. Lewis commented that if anaerobic conditions were exhibited in biological
decomposition that phenolic compounds would probably be generated.
Mr. Meyer asked if the microorganisms had been evaluated as pathogens for
field crops. Sybron reported that the organisms had been tested for one
toxin and the results were negative.
•
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Dr. Okun asked Sybron if they had the inherent capability for all aspects of
detoxification of the landfill. Sybron stated that subcontracting of en-
gineering and other services would be required and that their primary interest
was as a supplier of organisms for decomposition.
Work Group Comments ori Sybron arid Other Proposal~·
Mr. Meyer supplied a brief written summary of all proposals to the work group
and Mr. Jansen requested that Dr. Lewis verbally summarize the proposals.
Dr. Lewis stated that the only proposals that had been successfully demon-
strated was solvent extraction of PCB from the soil mixture followed by
chemical reduction of the PCB extract. In general, each company offered
assurance of successful detoxification with very little factual evidence
to support this assurance. Dr. Lewis suggested further evaluation of
solvent extraction and chemical reduction as a detoxification alternative
by the work group.
Dr. Okun suggested that engineering aspects for implementation of the pro-
posals had not been evaluated. For this reason, he recommended that quali-
fied engineering firms be asked for proposals to determine engineering
considerations for detoxification.
A general discussion followed and included the following issues:
1. There is little assurance that in situ technology can be
successful.
2. Expansion of the landfill from in situ treatment may be
a major concern.
3. The integrity of the cover and liner systems may not be
maintained by in situ treatment.
4. It is apparent that engineering cost and implementation
has not been adequately evaluated.
5. The level of contaminants and constituents remaining in
the residues after treatment is a major concern.
The work group concluded that further evaluation of engineering technology
to either treat the landfill by chemical or biological methods should be
planned for the next meeting.
The work group concluded that in order to consider biological decomposition
the proposals must be evaluated for scientific demonstration of specific
decomposition of Aroclor 1260 and efficiency of decomposition. It was
suggested that one method of demonstrating the above would be to send
contaminated soil to biological treatment firms and for the state to
analyze the soils after treatment.
It was suggested that the group identify the total volume of existing
samples of PCB contaminated soil .
..
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The next work group meeting was scheduled for February 9, 1984. The
purpose of the meeting would be to receive proposals on engineering
aspects of landfill detoxification.
Respectfully submitted,
William L. Meyer
Contact
A L K ky PhD or Lois T. Davis nne . opec , ..
Research Microbiologist Microbiologist
Sybron Chemical Division
P.O. Box 808
Salem, Virginia 24153
[phone] [phone]
Telex: 843407 or 6851083
.. •
Mr. Robert Jansen
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL MONITORING SYSTEMS LABORATORY
RESEARCH TRIANGLE PARK
NORTH CAROLINA 27711
July 24, 1984
Office of the Governor
State of North Carolina
Raleigh, North Carolina 27611
Dear Bob:
Re: Intergovernmental Work Group on PCB Detoxification:
Conclusions and Reco1111lendations
On January 12, 1984, I prepared for the Work Group a report which
reviewed and evaluated five proposals for treatment of the PCB landfill
in Warren County. In that report, my conclusion was that the proposal by
Galson/Polybac was the only one worthy of further evaluation. Since that
time, Galson has provided additional information to the Work Group, much
of it under a confidentiality agreement with Bob Neal and me. In addition,
the Work Group has heard from Malcolm Pirnie, Inc. and Genex Corporation;
from Dr. Charles Rogers of the EPA Industrial Environmental Research
Laboratory in Cincinnati, Ohio; and from the N. C. Department of Trans-
portation.
I have also examined two other processes: (1) Plasma Torch Pyrolysis,
proposed by Plasma Energy Corporation of Raleigh (at your request) and
(2) high-temperature reduction by means of the Advanced Electric Reactor
developed by the J.M. Huber Corporation, Borger, Texas. The latter pro-
cess looks very promising to me.
The purpose of this memorandum is to sum1ari ze and update the i nforma-
ti on assembled over the past year and present final appraisals. My recom-
mendations to the Work Group are also contained herein.
The final proposal by Galson-Polybac, which was presented to the Work
Group on March 22, 1983, involved excavation of the landfill for external
treatment on the site property.. Three reactors of 18 cubic-yard capacity
each were to be utilized on a 24-hour-per-day basis for completion of the
job in about 14 months. The so1vent was to be reclaimed by distillation
and the wash water was to be decontaminated by centrifugation foll owed
by bio-treatment or disti11ation. The chemically treated soil would be
returned to the landfill after further bio-treatment. lhe chemicals and
solvents prcposed (revealed only under the confidentiality agreement) were
considered to be reasonably safe, but could present a potential health
hazard if substantial soil residues were left or if substantial releases
into the surrounding environment occurred. Of greater concern, however,
is the nature of the reaction end-products and by-products, particularly
if the reaction is focompl ete. Many questions remain unanswered regard-
ing the exact procedures to be followed, so that an accurate estimate of
,..
costs could not be made. Robert Peterson of Galson, however, suggested
that it may cost as little as two million dollars (or as much as $12
million). Approval of the Galson/Polybac treatment process would neces-
sarily be contingent upon completion of successful laboratory and pilot-
scale tests. Mr. Peterson estimates that these would cost $15,000 to
$40,000. Such tests could not be conducted without opening the landfill
to obtain soil samples (ca. 1 cubic yard).
During our meeting on February 9, 1984, Dr. Charles Rogers discussed
some field trials conducted for EPA by Galson on PCB-contaminated soils.
The results of these trials were somewhat variable and inconclusive, with
soil moisture content apparently a complicating factor. Dr. Rogers
theorized that the Ga 1 son process would work on soi 1 s with up to 8-lS't
water content. However, the soil in the Warren County landfill contains
about 30't moisture, according to Bill Meyer. The gas chromatograms shown
by Dr. Rogers also revealed a large amount of high molecular-weight
material of unknown composition after treatment of the PCB-contaminated
soils. Identification of these materials and toxicity testing, if indi-
cated, would be a very long and expensive process.
Another aerobic microbiological treatment process was presented to the
Work Group on March 22 by Genex Corporation. This process did not appear
to be substantially different than that proposed by Sybron or Biotecknika
International, and would be subject to the same limitations discussed in
my report of January 12, 1984. This was the only additional proposal heard
by the Work Group since December 1983. However, two thermal processes
were examined recently by the author.
One of these processes, called long-column plasma torch pyrolysis, was
suggested by Plasma Energy Corporation of Raleigh, N. C. I reviewed a
brief description of that process, which I had previously examined in
1979, and concluded that it would be too difficult and expensive to scale
up to the level required to deal with the Warren County landfill. This
was corrmunicated to you in my letter of July 12, 1984.
The other process is a reductive thermolysis method developed by Huber
Corporation, in which soil is gravity-fed through a reaction chamber at
4000 to 5000°F under a nitrogen blanket. The PCBs are vaporized from the
soil and irrmediately reduced to carbon, hydrogen and chlorine or hydrogen
chloride. The soil, which is converted to spherical glass beads during
its free-fall through the reactor, is collected in a hopper. Gases are
passed through an el a borate system of cyclones, bag houses, activated
charcoal filters and liquid scrubbers. In EPA-authorized tests conducted
with the $4 million Huber pilot-scale facility, sand containing 3000 ppm
of Aroclor 1260 was fed at 60 lb/min through the reactor with 99.999999+ i
destruction efficiency. No chlorine or chlorinated products were detec-
table in the stack gases. Operating at 24/hr/day (85-90't up-time), the
unit could process 20,000 tons/yr at a cost competitive with standard
(rotary kiln) incinerators ($250/ton and up).
While the reductive thermolysis process looks very promising, the
existing Huber unit would require three years or more to process the soil
in the landfill. Obviously, a larger unit would be required and the cost
(not including construction of the unit) would be over $8 million.
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The best perspective on the situation facing us, I believe, was made
by Drs. Paul Busch and John Henningson of Malcolm Pirnie, Inc. in their
address to the Work Group on February 9. They estimated that chemical
treatment would cost $8-14 million and take 1 to 2 years; excavation and
incineration at a co11111ercial site (e.g. Rollins in Houston, TX), $85
million and 4.5 years; on-site incineration, $6.4 million and 3 years;
and excavation and landfilling at Chemical Waste Management's Alabama
facility, $8 to 10 million. Furthermore, they do not believe that the
technology currently exists for in situ decontamination of the Warren
County 1 andfi 11. They see the s ffi a's'a we 11-des i gned, secure 1 andfi 11
and reco11111ended that a commitment be made to maintenance and monitoring.
They also suggested that a contingency plan be developed to deal with
unexpected problems and that periodic reviews of applicable detoxifica-
tion technologies be conducted.
At our last meeting on June 6, 1984, Bob Adams and Bill Johnson of the
State Department of Transportation discussed the maintenance procedures
for the landfill. There was also discussion within the Work Group, pri-
marily involving Bill Meyer, of the on-going monitoring activities at the
site. Maintenance and monitoring appear to me to be adequate at this time.
After reviewing all of the presentations and associated materials
from the last year of the Work Group's tenure, my own conclusions are as
follows:
1. The Warren County PCB l andfi 11 is a state-of-the-art, high secu-
rity landfill, which exceeds the design requirements under the
Toxic Substances Control Act. PCBs are not presently leaking
from the site through any route and are unlikely to ever leak
from the site.
2. There are no microbial or chemical processes which have been
satisfactorily demonstrated to be effective at degrading PCBs on
soils under the conditions prevailing in the landfill. The PCBs
there are (a) present only at low concentrations (100-200 ppm);
(b) are highly chlorinated (primarily Aroclor 1260); (c) are
probably mostly associated with charcoal; (d) are in soil that is
heavily moisture-laden; (e) are in the soil which is anaerobic;
and (f) are at temperatures which are unfavorable for microbial
acthity (40°F). In addition, not enough is known to assess the
potential health hazards associated with the agents, reagents,
so 1 vents, break down products and by-products involved in these
processes.
3. Thermal destruction of the PCBs contained in the soil may be pos-
sible, although demonstrations have only been made on uniform-
sized, artificially fortified soils. Rocks, organic matter and
high water content must be dealt with in burning the soil con-
tained in the landfill. As a practical matter a thermal treatment
facility would have to be built on site, as the expense and logis-
tics of transporting the soil to another site would be prohibitive.
The more efficient on-site thermal destruction would still require
years to accomplish and cost millions of dollars.
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4. The landfill is being properly maintained and monitored at pres-
ent.
Consequently, I would offer the following reco11111endations:
1. The Warren County PCB landfill should not be disturbed at this
time.
2. Maintenance and monitoring activities should be continued at the
level required for the lifetime of the landfill. Well water in
the surrounding co11111uni ty should be monitored for PCBs on a
schedule which would assure that no individual well goes more
than one year between tests.
3. A contingency plan should be developed by the State of North
Carolina to deal with unexpected repairs and maintenance and any
unforeseen effects of the 1 andfi 11 on the residents of Warren
County. Such a plan should receive statutory support.
4. A mechanism should be established within the State Government
(DNRCD and/or OHR} to continue the review of new technology for
the destruction/detoxification of PCBs as it develops. Close
liaison with EPA should be maintained in this regard.
I want to take this opportunity to express my appreciation to you and
to Governor Hunt for asking me to serve as a member of this Work Group.
It has been a rewarding experience. As the Work Group nears the end of
its tenure, I believe that it should be apparent that it has done a
thorough job in assessing every aspect of this very complex and contro-
versial problem. I am only sorry that the status of existing technology
will not permit us to make more positive reco11111endations regarding treat-
ment of the Warren County facility.
cc: Dr. Dani el A. Okun
Sincerely yours,
~ Dr. Robert G. Lewis
Chief
Advanced Analysis Techniques Branch
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INTERGOVERNMENTAL WORK GROUP FOR DETOXIFICATION OF PCB
Proceedings of June 6, 1984 Meeting
Attending
or. Daniel A. Okun, Chairman
Rev. Clinton McCann
Mrs. Joyce Lubbers
Mr. George E. Shearin
or. Robert A. Neal
or. Robert G. Lewis
or. Linda Little
Mr. Robert Jansen
Miss Rebecca Manning
Mr. Bill Meyer
Not Attending:
Rev. Luther C. Brown
Mr. William W. Phillips
Mr. o. w. Strickland
Visitors
Mr. Joe Lennon
Mr. Bob Adams
Mr. Bill Johnson
Purpose:
Presentation of PCB Landfill Site Maintenance.
Report by Members on Confidentiality Agreement with Polybac, Inc.
Review of Galson/Polybac Engineering Aspect Plan.
Committee work session for developing a report to the Governor.
Program and Presentations
The meeting was called to order by or. Okun. The journal of proceedings of
the March 22, 1984 meeting were adopted with no corrections.
Presentation on PCB Landfill Maintenance
Mr. M.C. (Bob) Adams, Head of Maintenance and Equipment Branch -D.O.T.
Mr. W. D. Johnson, Head of Landscape Unit in the Construction Branch -D.O.T.
Mr. Adams reiterated the total committment by The Department of
Transportation, in accordance with both the Superfund Agreement and PCB
landfill permit standards, to prevent deterioration of the warren County PCB
Landfill. Three aspects of this committment include; the maintenance of an
all weather access road for the site, maintaining all security fences and
gates, and maintaining vegetative cover to prevent erosion.
Mr. Johnson presented slides of existing conditions and current stabilization
procedures being utilized on the landfill. A program to treat the landfill
surface, including additional seeding with burmuda and fescue grasses, heavy
mulching of lightly vegetated areas, and repairs to silt control devices, has
been initiated. In order to establish full vegetation protection on the
landfill, the Department of Transportation is implementing the following
procedures:
Authorize the District Engineer or warren County Maintenance
Supervisor to perform routine maintenance work on the landfill.
Monthly inspections by the District Engineer or Maintenance
Supervisor to include erosion protection, burrowing animals, surface
subsidence, and other general observable conditions.
Semiannual seeding and fertilization for 2 years.
After the initial 2 years of establishing cover, annual applications
of fertilizer top dressing and seeding for cover maintenance.
Mow twice per year to a 6 inch height to preclude woody growth.
Treat fence perimeter for vegetation control with Roundup.
Provide entrance and egress to the site by ensuring a 10 inch stone
surface and proper drainage for the access road on an annual basis.
Vegetative control for the access road will be the same as the
landfill.
The above procedures will be implemented with routine highway
maintenance appropriations.
work Group Comments on DOT Proposal
It was the general agreement of the work Group that the Department
of Transportation proposal for stabilization of the landfill surface and
access road would ensure proper protection of the landfill.
Dr. Okun suggested that subsidence of the landfill be measured as
soon as possible and procedures for continuing monitoring of subsidence be
established.
In response to Dr. Okun's comments on subsidence, Mr. Adams of the
Department of Transportation and Mr. Bill Meyer of the Department of Human
Resources assured the work Group that subsidence would be included in the
monitoring program. This would be accomplished by comparison of existing
surface elevations to final construction grade elevations and would be based
on existing permanent bench marks on the landfill site. Any unusual or rapid
subsidence would be noted on the monthly landfill inspections. Any major
reconstruction required by subsidence on the landfill would require approval
by the U.S. Environmental Protection Agency and is already included as a
permit condition for the landfill.
work Group Comments on Monitoring Landfill Site
During a general discussion of erosion control measures on the
landfill, Mrs. Lubbers raised a concern that several people in warren County
had addressed to her. Mrs. Lubbers informed the work Group that several
people, whose wells had been sampled in January, 1983, had expressed concern
that there was no apparent continuing effort to monitor their wells. Mrs.
Lubbers further stated that these people and herself were of the opinion that
the State had promised to monitor their wells on a routine basis.
A general discussion of the total monitoring activity associated
with the PCB Landfill was generated by questions concerning monitoring private
water supply wells. Mr. Lennon, warren County Health Director, and Mrs.
Lubbers expressed concern about the frequency of monitoring and the reporting
of monitoring results to the Health Department.
It was the concensus of the work Group that Mrs. Lubbers had
expressed a valid concern and the State should continue to monitor private
water supply wells as a part of the committment to monitor health effects of
the PCB Landfill. In addition, the work Group indicated that the State should
develop a written schedule for all monitoring activity and a table of
analytical results for reporting to the Health Department.
Dr. Neal suggested that in addition to reporting monitoring results,
that an interpretation of the results be included in reports to the warren
County Health Department.
The work Group recommended that the Department of Human Resources
sample and perform PCB analysis on 10 percent of the private water supply
wells within a 3 mile radius of the landfill on an annual basis. This is the
same area and wells that were sampled in January, 1983. The work Group
further recommended that a copy of all analysis be established in a reasonable
form and include interpretations for submission to the warren County Health
Department. (Attachment I. -identifies all private water supply wells within
a 3 mile radius of the landfill).
Confidentiality Agreement with Galson/Polybac
On March 22, 1984 Galson/Polybac offered to enter into a confidentiality
agreement with members of the work Group to evaluate chemicals involved with
their proposal for chemical extraction and decomposition of PCBs. or. Neal
and or. Lewis participated in a confidential evaluation of these chemicals
with Galson/polybac and reported their finding to the work Group.
Questions:
or. Neal's Comments on Toxicity of Galson/Polybac Chemicals
The chemicals are "off the shelf" rather than exotic.
Metabolies of the chemicals have not been extensively evaluated for
toxicological effects, however, the following effects are known -
high concentrations cause cataracts in animals, the chemicals can
pass through tissue and liner membranes, and the overall health risk
at low concentrations would be small.
Breakdown products are not very toxic but odorous and may cause an
esthetic problem with off gases.
or. Lewis's Comments on Chemical Aspects of Galson/Polybac Chemicals
The chemicals are relatively volatile, or evaporate easily.
The chemicals are polar, or have separate positive and negatively
charged sites, that increase the potential for adsorption on charged
soil and organic particles; however,
The chemicals are water soluble and can be desorbed or washed from
these particles.
There is no novelty in the chemistry of the chemicals and they ar:i,....-
similar to alkaline metal -ethylene glycol type se~neo.;.a . (U A r"l.(.
Moisture may interfere with extraction.
Extraction experiments performed in 1978 indicated successful
extraction in some cases and not so successful in other cases.
~,.,.
The Galson/Polybac process is still an expermen~ed procedure
requiring further laboratory and pilot scale ex erimentation as
proposed by Galson/Polybac.
work Group Questions and Comments on or. Neal and or. Lewis's Report
Q. or. Okun: would U.S. EPA approval for detoxification of the landfill
utilizing these chemicals be required?
A. or. Lewis: Yes.
Q. Dr. Okun:
A. or. Lewis:
Q. Mr. Jansen:
A. Dr. Lewis:
Q. Dr. Okun:
A. Dr. Neal:
Q. Dr. Okun:
A. Dr. Lewis:
Comments
would Toxic Substance Control Act Personnel in Washington
be the proper agency to grant approval?
No, approval could be granted by U.S. EPA, Region IV.
Will the combination of PCB-soil-asphalt-carbon-organic
matter affect the action of the chemical, and has any
testing of similar combinations occurred?
() i-1 ( '.P .-
The chemicals used by Polybac could serve as a solvent and
catalyst for reactio in a mixture of materials, but this
specific combination has not been tested.
Is the toxicity of chlorinated substances associated with
the number of chloride atoms on a molecule?
No, to_v.city is associated with the position of the K
chlor:ij'es on a molecule more than the number of chloriJ es.
The hl:eakdown products of the reaction of these chemicals
with the PCB may include chlorinated and non-chlorinated
substances, particularly if the reaction does not go to
completion. The toxicity of these decomposition
by-products is not known and is a major concern.
Are there any other existing sites with similar PCB
contamination that could be used to test the Polybac
proposal?
Gals on/Polybac may be looking to the warren County site as
a f "rst project, but other sites with PCB soil mixtures are
available.
Mr. Jansen distributed a copy of the Galson/Polybac reported titled,
Engineering Aspects of warren County Landfill Decontamination to all members
of the Work Group. This report is to be considered a part of the
Galson/Polybac proposal.
()f,<St"""'
or. Lewis noted that the olybac proposal would require large volumes of
solvents and the concentration of solvents in the treated residue may not be
as low as the existing concentration of PCBs. This may result in no change in
the toxicity currently presented by the PCBs. For example, a high
concentration of a substance with low toxicity offers equivalent toxicity when
compared to low concentrations of a substance with higher toxicity. Dr~ Lewis
commented that the proposed solvents were relatively stable, but water
soluble, and even though the solvents have a relatively high attraction for
soil particles, they would migrate rapidly through a soil. He stated that
both risks and benefits of the proposal should be compared to existing
exposures.
Dr. Neal stated that two factors of the proposal, potential increase in
leachability and the risk of producing toxic by-products, may be similar to
jumping from the frying pan into the fire. He stated that his concern was
directed to decomposition by-products rather than the proposed solvents. He
also noted that the treated residue would not serve as a good carbon source
for biological degredation.
Dr. Little commented that rapid movement of potential by-products should be
compared to the existing slow permeability within the landfill.
Dr. Okun indicated that it was apparent that a combination of type of
by-product and concentration and water solubility may stress groundwater to a
greater extent than existing landfill conditions. He stated that the Polybac
proposal was the most promising alternative; yet, it may generate a different
set of problems. Dr. Okun indicated that the State should be hesitant with
implementation until the proposal could be demonstrated to be effective at
other available sites.
Committee Work Session
Dr. Okun requested that the work Group present recommendations for conclusions
and development of a final report on the work Group activities.
Dr. Lewis summarized the various proposed alternatives for detoxification of
the PCB landfill. estated that one could safely conclude that biological
treatment and radi nt energy degredati,9n.,_
1
~fC e not likely to succeed. This
leaves only typical alkaline metal ~t chemical treatment as an
alternative; however, even this alternative is 2 to 3 years away from being
demonstrated to be an effective treatment for decontamination of soil and PCB
mixtures. one problem with existing data is the lack of exact identification
of both products and by-products before and after testing. Without proper
detection and identification, the basis for making a good scientific decision
is not available. Dr. Lewis suggested that warren County should not become an
experiment for developing technology, especially at the present time, since
there is an existing high degree of control at the site.
Mr. Lennon stated that continuing maintenance and monitoring of the landfill
site was extremely important to assure the citizens of warren County that no
adverse public health impact would occur. He indicated that although the
Governor had promised warren County to detoxify the landfill as soon as it was
technically feasible, it was apparent that the technology is not currently
available. He wanted assurance that the State would continue to investigate
technical feasibility rather than put the project on a shelf. When the
technology is demonstrated to be effective, then the State should implement
procedures for detoxification at that time.
Mr. Shearin reiterated the need to address the concern of warren County
citizens with respect to contamination of groundwater and drinking water. He
suggested continuation of maintenance and monitoring and publication of the
results with an explanation of the results, in the warren Record in addition
to sending copies to the Health Director. This would serve as one assurance
to warren County. He also expressed the need to publicize the fact that if
attempts were made to detoxify the landfill without first proving the
technology, that more harm than good could result. Mr. Shearin also proposed
that a contingency plan be developed in the event that groundwater
contamination were to occur.
It was suggested that the State summarize all existing monitoring data in a
tabular form, including an explanation of the data, and submit a copy to the
warren County Health Director and include it in the minutes of the next work
Group meeting. (Attachment II. -summarizes all existing monitoring data.
Attachement III. -summarizes EPA monitoring requirements).
Rev. Mccann recognized that while there are hazards associated with
detoxification of the landfill, that this should not preclude implementing a
pilot scale study. Dr. Okun and Dr. Lewis concurred with the concept of pilot
scale study. However, this should be done with a "made soil-PCB mixture" to
reduce experimental variables and definitely not require excavation of
materials from the landfill to obtain the volume of materials required for
pilot scale testing. If pilot scale tests on other soils contaminated with
PCB are successful, then the State should evaluate applicability to the warren
County PCB Landfill. Rev. Mccann proposed that major potential problems that
could occur on the landfill be identified, and procedures to correct these
problems be formally institutionalized within the structures of state
governmental activities.
Dr. Okun identified the development of a contingency plan for major tragedies
that could occur on the landfill as a priority. He also expressed a concern
that the residents of warren County should be made aware of how the State
would react and compensate for damages from catastrophic events. He
recommended that these procedures be legalized within the structures of State
government. Dr. Okun observed that the citizens in warren County still view
the landfill as it looked when erosion problems existed and large areas of
liners were exposed. This causes warren County citizens to perceive the
landfill as another disaster of our generation. He indicated that the public
should be made more aware of positive aspects of the project.
Mr. Shearin and Rev. McCann reiterated that maintenance and monitoring were
extremely important from a health protection, esthetic, and public perception
prospective. Maintenance and monitoring were recommended to be
institutionalized.
Mrs. Lubbers encouraged the State to keep abreast of efforts by the scientific
community to detoxify materials similar to the PCB Landfill and implement a
detoxification program when it becomes technically feasible.
Mr. Jansen noted that the current maintenance and monitoring efforts had been
assigned to various state agencies for implementation and would continue. He
also reminded that work Group that any decision concerning remedial action or
contingency planning on the landfill would require participation and approval
by the U.S. Environmental Protection Agency and that EPA must be considered an
equal partner in our actions. Mr. Jansen informed the work Group that the
State had paid expenses for all persons participating in presentations before
the group. These presentations included consideration of typical reactions in
all known potential alternatives for detoxification of the landfill and
fulfilled one charge to the work Group.
Dr. Little commented the work Group had proceeded through a rational process
to evaluate alternatives and apparently reach conclusions that include
maintenance, monitoring, contingency planning, and the need for formal
assurance of continuity. She suggested that public participation and
perception should be a major driving force for future activity concerning the
landfill.
Dr. Okun requested that individual work Group members submit written reports
to him for inclusion in a report to be written by the Chairman summarizing the
activities, conclusions, and recommendations of the work Group. Mr. Shearin
stated that the members from warren County would submit a single report
through Rev. Mccann.
Dr. Okun tentatively scheduled the next meeting for August 9, 1984 to review
the draft report of activities and recommendations of the work Group.
Dr. Okun adjourned the meeting.
Attachment I.
LIST OF RESIDENTS WITHIN 3 MILE RADIUS
State Road -1603
House u R. L. Williams
State Road -1604
House #2 Tommie & Diane Harmon
House #3 John R. Limer
House #4 R. Edgar Limer, Jr.
House i5 Earl Limer
House i6 Al Kimball
House #7 Larry & Joyce Lubbers
House #8 E. N. Brantley
House #9 Ethel Tharrington
House uo Durwood Patterson
10A Empty Cabin
10B Empty House
House Ul Dennis Harris
House U2 Pope Trailer
State Road -1605
House #13 Massenburg Kearney
13A Farm House
House #14 Emma Alston
House us Wilbur Alston
House U6 Lugenia Kearney
State Road -1604 (continued)
House U7 Charles Edmonds
State Road -1604 (continued)
House #18 Albert Tuck
House #19 Janie Valentine
House t20 James Kearney
House t21 Larry Green
House #22 Ed Sommerville
House t23 Large White House-Empty
State Road -1650
House t24 Rosa O'Neal
House #25 Phillip Lynch
House #26 Lucious O'Neal, Jr. -Trailer
House t27 Campbell -Trailer
State Road -1604 (continued)
House t28 Empty House
House t29 Walter c. Burroughs
House #30 Arthur Gooch
House #31 Jerry Abbott
House #32 David Munn
House #33 Mattie Bledsoe -Trailer
House #34 James Henry Williams
State Road -1600
House #35 Eugene B. Ingram
House #36 George P. Alston
House #37 Spencer Davis House
House #38 Percy Davis
State Road -1600 (continued)
House #39 Haywood Perry
39A Empty House
House #40 Bay Williams
House #41 Willie Williams -Trailer
House #42 Mary Williams -Trailer
House #43 Henry Twitty
House #44 Mr. Doris
House #45 Mr. Dryden
House #46 Mr. Parker
House #47 Mr. Paynter
House #48 Mr. Campbell
House #49 South warren School
House #50 Eugene Ingram
House #51 Samuel Davis
House #52 Raeford Pernell
House #53 Jack Marshburn
House #54 Joey Mustian
12
l l 15 I i
,:s::iw:~1;ii;i·J:_/ _ _..
J _/
l
l \ /
\ /
\
n
/
\ \
I
\
\
\
\
\ i
,,{ '>;:~·
/ ·. ;
'\
i
(
/ r8 ·,. ~ ... J ,1 i
',,\~ 1, '.t:)
,I('
..,J
Groundwater
WlA
WlB
W2A
W2B
W3A
W3B
W4A
W4B
surface water
RCUSA
RCUSB
RCDSA
RCDSB
UTUSA
UTUSB
UTDSA
UTDSB
surface water Sediments
RCUSA
RCUSB
RCDSA
RCDSB
UTUSA
UTUSB
UTDSA
UTDSB
ND -None Detected
Attachment II.
PCB LANDFILL ROUTINE MONITORING
ANALYSES FOR PCB's
11/29/82 5/5/83 11/21/83
ND ND ND
ND ND ND
ND ND ND
5/3/84
ND
ND
ND
-For all water samples, none detected means < 0.1 parts per billion.
-For all sediment samples, none detected means < 0.1 parts per million.
PCB LANDFILL
TREATMENT WORKS ANALYSES FOR PCB's
Date Influent (ppb) Effluent (ppb)
3/7/83 .43 .24
3/11/83 ND ND
3/14/83 ND ND
3/16/83 ND ND
3/21/84 2.47 .18
3/22/83 1.41 .294
3/23/83 1.35 ND
3/24/83 ND ND
3/28/83 ND ND
3/29/83 ND ND
3/30/83 ND ND
3/31/83 .279 ND
4/1/83 ND ND
4/5/83 ND ND
4/7/83 ND ND
4/11/83 ND ND
4/12/83 ND ND
4/13/83 ND ND
4/14/83 ND ND
4/18/83 ND ND
4/19/83 ND ND
4/20/83 ND ND
4/25/83 ND ND
4/26/83 ND ND
4/27/83 ND ND
5/10/83 ND ND
5/25/83 ND ND
6/1/83 ND ND
7/20/83 1.63 ND
7/29/83 ND ND
11/21/83 ND ND
12/29/83 ND ND
1/26/84 .3 ND
3/7/84 ND ND
4/3/84 .2 ND
5/3/84 .6 ND
6/17/84 .3 ND
ND -None Detected
-For all water samples, none detected means<. 0.1 parts per billion.
PCB LANDFILL MONITORING CODE
RC -Richneck Creek
UT -unnamed Tributary
DS -Downstream
US -Upstream
SW-CON -Spring Discharge 30 feet above UT
SW-HEAD -Spring Discharge 500 feet above UT
Wl -Groundwater Monitoring Well u
W2 -Groundwater Monitoring Well t2
W3 -Groundwater Monitoring well t3
W4 -Groundwater Monitoring Well t4
A -Replicate A
B -Replicate B
Attachment III.
FINAL APPROVAL CONDITIONS FOR PCB CHEMICAL LANDFILL IN WARREN COUNTY, NORTH
CAROLINA, CLOSED AND POST CLOSURE CARE FOR BY THE STATE OF NORTH CAROLINA ON
PROPERTY FORMERLY OWNED BY CARTER C. POPE AND LYNDA DUTCH POPE FOUND IN DEED
BOOK 278, PAGE 252.
The Monitoring Program
1. Leachate collection will be monitored monthly and collected ,,,.--
leachate disposed of properly if required as per (761.41 B, 7).
2. General Requirements
3.
The parameters for ground and surface water monitoring program
found 40 CFR 761.4l(b) (6) (iii)A,B,C. The samples should be
collected and analyzed in accordance with EPA approved
procedures.
Groundwater Specific
a. Background -each well must be sampled three times and the
data submitted to Region IV prior to any disposal. A
minimum of one week should elapse between sampling. At
each sampling, a minimum of two replicate measurements for
each value or concentration must be made.
b. During operation or for a period of one year whichever is
shorter, all wells must be sampled monthly.
c. Post closure -each well must be sampled on a semi-annual
basis.
4. Surface Water Specific
a. Background -EPA Region IV will designate surface water
sampling points. These locations will include, as a
minimum, two sampling points per surface water body (one
upstream and one downstream). Each of these will be
sampled each time the groundwater wells are sampled for
background quality.
b. During operation -each of the designated surface water
sampling points will be sampled monthly during operation of
the facility.
c. Post closure -each of the designated surface water
sampling point will be sampled on a semi-annual basis
during post closure.
5. Changes in program -Upon a determination of the state or EPA
that containment has failed the sampling frequency of either
ground or surface water sampling may be modified. EPA may also
require the installation of additional monitoring wells and an
expansion of the list of monitoring parameters.
6. Well locations and screened elevations shall be coordinated with
EPA Region IV in the field or by telephone as appropriate.
_ ..
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27611
JAMES 8 . HUNT, JR.
GOVERNOR May 7, 1984
NOTICE OF MEETING
The next meeting of the Governor's Working Group on
PCB Detoxification will be held on Wednesday, June 6,
commencing at 1:30 p.m. Pl.ease note the change of
date and location due to conflicting events on the
State's schedule of activities.
This meeting will be held in the Conference Room
(Room 150) of the Transportation Board. This room is
located on the first floor of the Highway Building
on the corner of New Bern Avenue and Wilmington
Street. Parking may be a greater problem than usual,
and you are encouraged to allow extra time to meet
this contingency.
The Chairman has stated that the committee will be
evaluating the presentations received from various
companies. We will be reviewing the options available
to the State at this time and we will plan the work of
the committee for the next seven months. Please make
every effort to attend the entire session.
Enclosure: Minutes of March 22 meeting
AY R 188.
STATE OF NORTH CAROLINA
OFFICE OF THE GOVERNOR
RALEIGH 27611
JAMES 8. HUNT, JR.
GOVERNOR April 16, 1984
MEMORANDUM
To: Intergovernmental Working Group on
PCB Detoxification
From:
Re:
,n~ r1
Robert Jansen }~
i ~\
Time and Place of ~ext Meeting
Please note that the time of the next meeting of the
committee has been changed to Wednesday, June 6, at
1:30 p.m. It will be held in the conference room of
the Transportation Board (Highway Building -Room 150)
at Wilmington Street and New Bern Avenue. Our chairman
has indicated that this session will be used to plan
our next steps including the development of a report
and recommendations.
Enclosed find a copy of an article from a recent EPA
publication. I believe that it is timely and it has
special significance for our work.
Enclosure
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'-l
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\TI. ~ . __ r~~
--..W,.,.;.._J
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____ __....
..
t? "-·t NJ'/ IJ 1r 1-I
.. _ -: -
. -. PROCESS CHEMISTRY .. -lfl!!l'~---
Jf" .• ---------
PCB FORMATION
BIPHENYL + CHLORINE -> POLYCHLORINATED BIPHENYL (PCB)
(biodegradable, water so l uble)
PCB DESTRUCTION
PCB+ REAGENT ->
DECHLORINATED
(not bi odegradable,
not water soluble)
DECHLORINATED BIPHENYL + CHLORIDE
(biodegradable, water
soluble)
------I. __ --· -·----· BIPHENYL + BACTER IA -> CO2, WATER , BIOMASS
"'. ..,. .
----..--.~------···
REA CTI ON DATA -
SAMPLE PREPARATION
ROAD SAND MIXED WITH PCB IN TRANSFORMER OIL
---
PCB CONCENTRATION BEFORE REACTION
PCB CONCENTRATION AFTER REACTION ( l HOUR)
PCB REMOVAL EFFICIENCY
CONCLUSIQ~
PROCESS REMOVES PCB FROM SOIL TO
LEVELS BELOW 0.1 PPM
PROPOSED ACTION
l. DEVELOP CONSENSUS ON CLEANUP LEVEL DESIRED
2. GENERATE CONSENSUS PROTOCOL FOR LABORATORY TEST OF PROCESS ON WARREN LANDFILL SOIL
-DATA ON SOIL SPECIFIC FACTORS
210 PPM
< .04 PPM
> 99.98'%
-CONSENSUS ON PROCESS FEASABILITY
3. CONDUCT LABORATORY TESTING
4. RUN PILOT STUDY TO CONFIRM LABORATORY RESULTS
5. FULL SCALE CLEANUP
. --------· ----------
I ;t
;. -...
~ .. -.. -~=--
. .:., --...
.-
PROCESS CHEMISTRY
PCB FORMATION
BIPHENYL + CHLORINE -> POLYCHLORINATED BIPHENYL (PCB)
(biodegradable, water soluble)
(not biodegradable,
not water soluble)
PCB DESTRUCTION
PCB+ REAGENT -> DECHLORINATED BIPHENYL + CHLORIDE
(biodegradable, water
soluble)
DECHLORINATED BIPHENYL + BACTERIA -> CO2, WATER, BIOMASS
REACTION DATA
SAMPLE PREPARATION
ROAD SAND MIXED WITH PCB IN TRANSFORMER OIL
PCB CONCENTRATION BEFORE REACTION
PCB CONCENTRATION AFTER REACTION ( 1 HOUR)
PCB REMOVAL EFFICIENCY
CONCLUSION
PROCESS REMOVES PCB FROM SOIL TO
LEVELS BELOW 0.1 PPM
PROPOSED ACTION
1. DEVELOP CONSENSUS ON CLEANUP LEVEL DESIRED
2. GENERATE CONSENSUS PROTOCOL FOR LABORATORY TEST OF PROCESS ON WARREN LANDFILL SOIL
-DATA ON SOIL SPECIFIC FACTORS
210 PPM
< ,04 PPM
> 99.981
-CONSENSUS ON PROCESS FEASABILITY
3. CONDUCT LABORATORY TESTING
4. RUN PILOT STUDY TO CONFIRM LABORATORY RESULTS
5. FULL SCALE CLEANUP
PROCESS CHEMISTRY
PCB FORMATION
BIPHENYL + CHLORINE -> POLYCHLORINATED BIPHENYL (PCB)
(biodegradable,
water soluble)
PCB DESTRUCTION
PCB+ REAGENT
DECHLORINATED
->
(not biodegradable,
not water soluble)
DECHLORINATED BIPHENYL + CHLORIDE
(biodegradable, water
soluble)
BIPHENYL + BACTERIA -> CO2, WATER, BIOMASS
REACTION DATA
SAMPLE PREPARATION
ROAD SAND MIXED WITH PCB IN TRANSFORMER OIL
PCB CONCENTRATION BEFORE REACTION
PCB CONCENTRATION AFTER REACTION
( 1 HOUR)
PCB REMOVAL EFFICIENCY
210 PPM
< .04 PPM
> 99.98%
GALSON/POLYBAC PROCESS FOR REMOVAL OF
PCBs FROM SOIL
R. L. PETERSON
GALSON RESEARCH CORP
CONCLUSION
PROCESS REMOVES PCB FROM SOIL TO
LEVELS BELOW 0.1 PPM
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INTERGOVERNMENTAL W0RK GR0UP F0R DET0XIFICATI0N GF FtB
1:30 p.m.
3:30 p.m.
5:00 p.m.
Thursday, March 22, 1984
Thifd Floor Conference Room
Bath Building
Raleigh, North Carolina
1:30 p.m. -5:00 p.m.
Proposed Agenda
Call to Order
Roll Call
Announcements, etc
Chairman
Presentation by Galson Research Corporation/
Polybac Corporation Mr. Robert Peterson ~
Mr. Tony Nassef
Presentation by Genex Corporation
Discussion
Break
Planning Session
Adjournment
Dr. David Eaton V
Mr. Reid Parramore
Chairman
UTILITY SERVICES
DIVISION EASTERN
ELECTRIC
REPLY TO:
P .O.BOX12446
RALEIGH. N. C . 27605 DIAL RALEIGH
919/781-0115
MEMBER
<€!>
1908
SU PPLY INC.
P. 0. DRAWER 1160
ROCKY MOUNT, N. C. 27801
March 6, 1984
Mr. 0. W. Strickland
Division of Health Services
Post Office Box 2091
Raleigh, N.C. 27602
Reference: P.C.B. Testing Equipment.
Dear Mr. Strickland:
We are very interested in demonstrating the P.C.B. testing equip-
ment to the meeting of the group responsible for the public inst-
ituti ans.
We appreciate your interest in the equipment and ask for approx-
imately 45 minutes to an hour to make the presentation.
If this can be arranged please advise the place and time of the
meeting and both Wes Schrom of McGraw Edison and I will want to
attend.
mrr
cc: Mr. Wes Schrom
McGraw Edison, P.S.D.
4904 Waters Edge Drive
Suite 167
Raleigh, N.C. 27606
Very truly yours,
EASTERN ELECTRIC SUPPLY CO., INC. £~4-~~
Jerry B. Cooper
[phone]
T ELEX: 73-8458
February 10, 1984
J. M.Huber Corporation
P. 0. Box 2 831
Borger, Texas 79007
Mr. 0. W. Strickland, Branch Head
Department of Human Resources
Solid & Hazardous Waste Management Branch
P.O. Box 2091
Raleigh, NC 27602
Dear Mr. Strickland:
The Huber Technology Group (HTC) has developed a high-temperature,
advanced hazardous waste treatment technology capable of extremely high
destruction and removal efficiencies in the treatment of these wastes.
To inform responsible professionals, we periodically issue newsletters
summarizing the status of this technology and progress toward its full-scale
operation. Outlined in this newsletter are several major points concerning
recent equipment and process design improvements and the results of our
recent EPA/TSCA Certification Tests using PCB.
The Huber Technology Group Advanced Electric Reactor (AER) detoxification
process has five inherent advantages over most competing technologies:
(1) Extremely high operating temperatures.
(2) A very low gas-phase flow rate.
(3) The ability to process contaminated soils as well as gases and liquids.
( 4) An absence of oxygen in the process gases.
( 5) Mobility.
The first advantage cited of the extrer,ely high operating temperature is
obvious--high destruction efficiency. The AER operates at 4000°-4500° F vs.
less than 3000°F for rotary kiln incinerators.
The second advantage above is more subtle. The AER is heated with elec-
trical power ... not by combustion and therefore does not generate large
quantities of gaseous combustion by-products to be vented to the atmosphere.
The advantage of this low gas flow rate is two-fold but may not be obvious.
First, the very low gas flow rate (i.e., approximately 500 scfr, in a 150
tons/day commercial-scale plant) permits very high gas-phase residence times
at a reasonable capital cost. For example, a five-second residence time at
The Advanced Electric Reactor Newsletter Page 2
2500°F would require an insulated cylindrical vessel 12' long with a 5' inside
diameter. This high temperature residence time is provided in the insulated
post-reactor vessel shown on the accompanying process flow sheet. For
comparison purposes, a rotary kiln incinerator typically has only a one-to
two-second residence time and requires much larger equipment.
Another advantage of a very low gas flow rate is that it permits the use of
economica I, small-sea le equipment to more intensively clean the gases. As the
gases exit the insulated residence vessel, they pass through a water-jacketed
vessel for cooling and then pass through a cyclone and baghouse filter to
remove particulates, a caustic scrubber to remove chlorine and HCI, and an
activated carbon bed to remove any residual traces of the organic feed and
decomposition by-products. With this type of small scale, off-the-shelf stack
gas treatment equipment, we can achieve gas-phase DREs as close to absolute
destruction and removal as a given application requires. An additional ad-
vantage of the activated carbon beds is that they provide a safety backup for
removing hazardous organics from the process · gas stream in the unlikely
event that a problem results in hazardous material reaching the stack gas
treatment equipment.
The third cited advantage, the demonstrated ability to treat commercial quan-
tities of contaminated soils, is unique. With the Huber Advanced Electric
Reactor process, the melted soil particles never touch the hot reactor interior
walls due to the patented fluid-wall effect. After treatment, the soil particles
are cooled below their melting point prior to collection thus producing a
free-flowing, nonhazardous, granular material ideal for landfill.
The major significance of the fourth cited advantage (the absence of oxygen)
is that oxygen containing by-products such as dioxins and furans cannot
theoretically be formed even in trace amounts. Tests have verified this
prediction.
All of the above advantages are even more significant when the fact that the
AER detoxification system will be available in a transportable modular form.
Being able to move the unit for on-site treatment of waste adds a dimension
of attractiveness not available with most other fixed base processes. Being
able to move the unit to the waste instead of vice versa avoid many environ-
mental and economic problems.
Because of these and many other features, the technology is uniquely suited
for the treatment of extremely hazardous materials such as dioxin-
contaminated soils or liquid dioxin concentrates such as still bottoms. The
Office of Technology Assessment, the technological support arm of Congress,
has recognized the AER process as one of the most promising for soi Is treat-
ment and has recommended its evaluation as a potential method to detoxify
500,000 tons of dioxin soils in Missouri. (See the enclosed OTA preliminary
response report excerpts.)
An EPA Certification Test for destroying PCBs in soils was conducted under
TSCA regulations at our Borger facility on September 27, 28, and 29. The
test was witnessed by representatives of the U.S. EPA Region VI, the Texas
Department of Water Resources, and the Texas Air Control Board. (See the
attached summary of results table.) Briefly, the results of these tests were:
The Advanced Electric Reactor Newsletter Page 3
(1) Typical Destruction Efficiencies (DE) of 99.9999%.
(2) Typical Destruction and Removal Efficiencies (DRE) of 99. 999998%.
(3) Solid-phase (i.e., treated dirt) PCB concentrations of 0. 0005 to 0. 001
ppm PCB (down from 3000 ppm PCB in the feed and far below the 50
ppm required by EPA under TSCA regulation).
( 4) No HCI, Cl 2 , volatile chlorinated hydrocarbons, dioxins, or furans were
observed at the stack.
(5) Only trace amounts of particulates and NOx were observed.
An additional point of consideration is that the quantity of PCB in all four of
the DRE and three out of the four DE samples were below their corresponding
analytical "blank" values, thus it is not certain that PCBs were even present
in any of the process exit gas samples. All of these results far exceeded the
EPA/TSCA requirements; however, we do not believe they reflect the ultimate
potential of this technology.
The certification test results were submitted to EPA Region VI on October 31,
1983. EPA certification is expected during the first quarter of 1984.
We believe the Huber Advanced Electric Reactor process has a major role to
play in the treatment of hazardous wastes. We will inform you as other
progress is made.
Should you have any questions concerning our work, please call me at our
Borger, Texas, office ( 806) 274-6331.
Regards,
~:~~:§;~
Manager, Marketing & Product Development
pv
Enclosures
1:30 p.m.
5:30 p.m.
INTERGOVERNMENTAL WORK GROUP FOR DETOXIFICATION OF PCB
Thursday, February 9, 1984
EPA Research Center Annex
Research Triangle Park
1:30 p.m. -5:30 p.m.
Proposed Agenda
Call to Order
Roll Call
Announcements, etc.
Presentation by Roy F. Weston, Inc.:
Chairman
Engineering Assessment of Detoxification Proposals
Drs. Robert B. Pojasek and Robert J. Schoenberger
Presentation:
Dr. Charles Rogers
U.S. Environmental Protection Agency
Cincinnati, Ohio
Presentation by Malcolm Pirnie Inc.:
Engineering Assessment of Detoxification Proposals
Dr. Paul Busch
Dr. John Henningson
Adjournment
. ubi,~,.,p~·?fl~ ~~/%Y
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•
l
INTERGOVERNMENTAL WORKING GROUP FOR PCB DETOXIFICATION
Journal of Proceedings for February 9, 1984
Attending
Dr. Daniel A. Okun, Chairman
Dr. Robert G. Lewis
William W. Phillips
Dr. Linda Little
Robert Jansen
Mr. George E. Shearin
Rev. Luther C. Brown
Rev. Clinton Mccann
William L. Meyer
Mrs. Rebecca Manning
Not Attending
Dr. Robert Neal
Mrs. Joyce Lubbers
0. W. Strickland
Visitors
Joe Lennon, Warren County Health Director
Reid Parramore, Genex Corporation
Robert L. Peterson, P.E., Galston Research Corporation
Dr. Charles Rogers, U.S. EPA
Dr. Paul Busch, Malcolm Pirnie, Inc.
Dr. John Henningson, Malcolm Pirnie, Inc.
Purpose:
Evaluate presentations by Roy F. Weston, Inc. and Malcolm Pirnie, Inc.
on engineering assessment of PCB detoxification and the U.S. EPA on
chemical detoxification.
Presentations
Dr. Okun gave a brief history of the PCB detoxification efforts
of the working group and detoxification proposals evaluated by
the group. He also announced that the Rev. Clinton Mccann had
been appointed to the working group as a replacement for Mr.
Henry Rooker.
Presentation by Roy F. Weston, Inc.: Engineering assessment of
Detoxification Proposals Ors. Robert 8. Poj~sek and Robert J.
Schoenberger.
Dr. Robert B. Pojasek summarized proposals submitted to the work group
including:
Location of Remedial Actions
l. Removal for off-site treatment or disposal
2. Treatment on-site but external to the landfill
3. Treatment within the l andfi 11 (in situ)
General Remedial Alternatives
l. Off-site landfill
2. Incineration
3. Solvent extraction
4. In situ treatment
Specific In Situ Treatments
l. Fix in place by grouting landfill
2. Liquid extraction of PCB
3. Microbiological extraction
4. Chemical neutralization, fixator or degradation
5. Electro-osmotic processes
Technical Feasibility Considerations
l. Short and long term cost -time for implementation and rate of
decomposition to an acceptable level
2. Environmental concerns -off gases; partitulate emi~si6ns, ground .
water contamination
3. Risk alternatives -Dr. Pojasek stated that risks could be determined
by technical evaluation of all available alternatives; and, acceptable
or least risk alternatives, not engineering or economics, would be the
primary basis for remedial action.
4. Peer review -any remedial program should include careful scientific
and public review.
Dr. Robert J. Schoenberger Summary of Comments
Detoxification Alternative Evaluation
1. Dr. Schoenberger challenged the work group to consider creative
alternatives for detoxification of the PCB landfill.
2. Toxicity of intermediates, emissions, and pathways of migration are
primary concern.
3. Concentration and toxicity should be evaluated as a single risk
element. It was noted that high concentration and low toxicity
exhibits an equivalent risk when compared to high toxicity low
concentration.
4. Quality assurance for treatment alternatives should be a major
consideration. Dr. Schoenberger indicated that non-isotropic
conditions in the landfill may result in poor quality control
of in situ treatment alternatives and ttlt! incineration would
result in little gain at tremendous cost.
5. In summary, Dr. Schoenberger indicated that quality assurance on
construction and maintenance of the existing landfill was excellent
and migration potential from the site was low. However, he en-
couraged the work group to be creative in consideration of all
available options for detoxification.
Dr. Little asked about the problem of addressing liability of
contractors for implementing projects similar to detoxification
of the PCB landfill. It was noted in general discussion within
the group that contractors are normally bonded for the value of
a contract yet the potential exists for causing damages that
exceed several times that value. No solution was offered for
this problem.
Presentation by Dr. Charles Rogers, U.S. EPA
Dr. Rogers presented a review of research at the EPA Cincinnati, Ohio
Laboratory that utilizes a glycol extracting reagent with a molecular
weight ranging from 300-600 fo r chemically removing the PCB from soil
materials. The toxicity of the reagent is low and is deactivated by
water. Maximum extraction efficiency is reported to be 75-85 %.
Potential concerns expressed by the work group include (1) demonstration
of successful field projects rather than rigidly controlled lab conditions,
(2) the small pore space in the landfill does not allow water movement to
the leachate collection system and circulation of a viscous reagent would
be difficult, (3) more data on the toxicity of reagents and by-products
would be required, and (4) maximum extraction efficiency is 75-85 % and
would be lower under field conditions.
Presentation by Malcolm Pirnie, Inc.: Engineering Assessment of
Detoxification Proposals by Ors. Paul Busch and John Henningson
View of Existing Conditions
The landfill is a secure engineered structure in an isolated location
and is a unique mixture of soil, PCB, activated carbon and asphalt.
Materials for testing or demonstrating effectiveness of a remedial
treatment alternative are not available unless the integrity of the
landfill cover is breached.
Basis for Considering Remedial Alternatives
There should be a significant demonstration of improvement over
existing conditions.
No short or long-term negative imminent health or environmental
risks should occur with selected alternative . One element of risk
is the time that the landfill will be open to implement remedial
treatment. A specific example given was landfill manipulation for
4 years if the PCB soil mixture were incinerated at 3 tons per hour.
There must be an agreement on cost benefit reasonableness.
Basic Remedial Alternatives
The basic remedial alternatives include chemical treatment, biological
treatment, thermal destruction and landfill disposal.
In situ treatment with solvents or microorganisms is probably not
practical due to problems with circulation of liquid media within
the landfill. Landfill conditions already demonstrate that water
within the landfill cannot be readily removed due to small pore
size. This problem would be magnified when injunction, circula-
tion and removal of other liquid media are considered.
The applicability of radiant energy (U.V.) for degradation of
PCB mixture has not been demonstrated.
Sodium and potassium reagents for extraction of PCB is "developing"
and is a promising future alternative. However, this will require
excavation of the landfill, mixing and a long treatment process.
It was estimated that the cost of chemical treatment will range
from $130 -330/yd3 or $8 to 14 million dollars.
Thermal destruction would require a rotary kiln. If the material
were excavated and transported off-site to a commercial kiln, it
would cost an estimated $85 million. It would also require ap-
proximately 2 years and the exclusive dedication of a commercial
kiln, which is not possible.
An on-site rotary kiln, if it were available, would require 3-4
years and cost an estimated $6-10 million.
Excavation and removal to an out of state landfill would cost
an estimated $8 to $10 million.
It was suggested that one alternative for reducing risks would
be to purchase all homes and property within some range (l/2 -
l mile) of the landfill site. No cost estimate is available
for this alternative.
Summary of Proposals
There is no demonstrated in situ technology that is applicable to
the unique situation offered by the Warren County Landfill site.
If any off-site or external treatment is considered, then potential
benefits and risk associated with that treatment must be very care-
fully evaluated.
Recommended Action
There is no data to indicate that any problem exists with the Warren
County PCB Landfill. Therefore, the recommended actions should i~clude:
l. A high level of commitment by the state for site monitoring and
maintenance.
2. Schedule a review of developing detoxification alternatives that
can clearly demonstrate effective remedial treatment for the
landfill.
3. Develop a clear and effective contingency plan for rapid action
in the event that monitoring indicates a problem.
4. Commitment by the state for on-going funding for the above
objectives.
I, ES8cT
Phasing out PCBs
Whatever the outcome of the debate
over their health effects, they must go eventually
Polychlorinated biphenyls (PCBs)
have been shown to be environmentally
persistent and bioaccumulative. So far,
however, few, if any, data have been
able to link them directly to serious
human health effects. Although some
PCBs and their pyrolysis products
have been associated with chloracne,
a skin affliction, even that effect does
not appear permanent, though it may
last several years. Nevertheless, PCBs
are ultimately to be banned in the U.S.
under the Toxic Substances Control
Act of I 976 (TSCA).
PCBs have been used in transform-
ers and capacitors since the early
I 930s because of their highly desirable
dielectric, flame-resistant, and heat
transfer characteristics. The Yusho
rice oil poisoning episode in I 968
(ES & T, January I 983, p. I 2A , and
March I 983, p. I 27 A) plus the some-
what later discovery that PCBs persist
in the environment and bioaccumulate
began the chain of events leading to
PCB bans in the U.S. and elsewhere.
The degree of persistence increases
with the chlorine content of these
chemicals.
Some scientists are beginning to
query whether the chemical "bad ac-
tors" that triggered the chloracne were
not PCBs but rather compounds, such
as polychlorinated dibenzofurans
(PCDFs), formed when PCBs are
heated in the presence of oxygen. In
Addis and Komai: Compliance at the
lowest possible cost
the Yusho incident, heat transfer oil
and rice oil were mixed at fairly ele-
vated temperatures. Fires can subject
PCBs to temperatures that may cause
or enhance toxicant formation. Under
such conditions, PCBs can be trans-
formed into PCDFs. The source of
polychlorinated dibenzo-p-dioxins
(PCDDs) is thought to be the result of
heating chlorobenzenes, a PCB diluent
in transformer fluids, to high temper-
atures.
From the regulatory standpoint, any
proof of whether PCBs are very dan-
gerous or completely innocuous is now
immaterial. As Gil Addis and Ralph
Komai of the Electric Power Research
Institute (EPRI, Palo Alto, Calif.) told
a conference on PCBs that they orga-
nized and held at Atlanta, Ga., in De-
cember, "It does not matter whether
you think laws and regulations con-
cerning PCBs are unjust. The rules are
the rules, and our job is to bring about
compliance at as low a cost to electric
utilities as possible."
Health effects
This could be worded, "What health
effects?" according to John Brown of
General Electric (GE). He observed
that "now, we have five times as much
information on PCBs as we did when
Congress took its action against them
in I 976. This includes several studies
on extensively exposed human popu-
lations."
Brown outlined a GE study involv-
ing 152 male and 42 fem ale capacitor
workers who had been exposed to
Aroclors 1016, 1242, and 1254-listed
in ascending orders of chlorination-
for periods of 2-35 years. These indi-
viduals were found to have absorbed a
minimum of 2.5-88 g of the lower
chlorinated PCBs and 0.1-1.2 g of the
higher PCBs. These values were re-
ported for blood; however, Brown said
0013-936X/84/0916-0043A$01.50/0 © 1984 American Chemical Society
:~:1~ _Rules and rulemaking
, . .r,•,·:., ,· '_,, '
,.f< Removing ail PCBs in the U.S. would
, ~ a formidable task; ?bout 758 million JI, are still in use, mostly as capacitor
t'and transformer dielectric fluids.
· Moving in this direction, however, EPA
promulgated certain regulations on
; Aug. 25, · 1982. For example, large
. p igh-voltage capacitors and PCB-
. '.containing capacitors near human food
0 and animal feed must be replaced by
:,Oct .. 1, ,1988. PCB-containing trans-
' formers ·near food and feed must be
:' emoved by Oct. 1, 1985. However,
:_~e Is no date for retrofilling and re-
. tplacement of nonleaking transformers
;located in places of restricted access.
-Jn those cases, PCBs may stay for the
.'transformers' useful lives.
, . !Jnder a court order, EPA's Office of
l>esticides and Toxic Substances must
'-<:!evelop regulatory strategies con-
:· earning PCB fires, PCB substitutes,
,retrofilllng, replacements, and other
"_aspects. M Advance Notice of Pro-
'posed Rulemaking is expected this
l March and proposed regulations are
{!Xpected in October. Final rules are
scheduled for July 1985. . ~-\ /~~-<-<~;-S_:r._·: . :.:_/=-:;,.; -~~· --.-
that from them, concentrations in fatty
tissue could be calculated. He told
ES& T that the ongoing study began in
I 976 and that a report should appear
in Environmental Health Perspectives
later this year.
"Despite this massive dosage , we
observed neither chloracne, nor an y
rise in serum lipids," Brown added.
"The latter would be found if there
were a liver dysfunction or any evi-
dence of cardiovascul ar or pulmonary
effects. What we did see was a slight
transitory induction of drug-metabo-
lizing enzymes, prolonged retention of
Environ. Sci. Technol., Vol. 18, No. 2, 1984 43A
.. " ... .,.-...... ,-------------------
the higher PCB congeners, and clear-
ance of most of the lower PCBs. The
absence of chloracne should not be
surprising. If PCBs themselves could
cause it, we should have been seeing
lots of it since the I 930s, when their
widespread usage began." .
Brown described a National Insti-
tute for Occupational Safety and
Health (NIOSH) study of the mor-
tality of 2567 people who had worked
with PCBs during the period 1938-
75, representing a total of 39 018 per-
son-hours of exposure. Of these, 60
had died of cardiovascular causes, 39
of cancer. 13 in accidents, 11 of ner-
vous system involvements, and 40 of
other causes. Statistically, NIOSH
had "expected" 62.93 cardiovascular,
43.79 cancer, and 12.95 nervous sys-
tem death causes. ''There were also no
significant increases in any indicidual
k_ind of cancer," Brown said. That
study was published in 1981 .
Retrofill or replace?
Richard Addison of the Bedford
Institute of Oceanography (Dart-
mo1,1th, Nova Scotia, Canada) listed
and discussed potential environmental
effects of 14 PCB replacement fluids
for transformer and capacitor dielec-
trics and other uses (ES & T, October
1983, p. 487 A). They consisted of six
aromatics, four ester-based materials,
two paraffins, and two silicones. In
addition, one replacement consists of
perchloroethylene, which is recom-
mended for transformer replacement
only, not for retrofilling.
· Which course is more advanta-
geous-to retrofill an existing trans-
former with a replacement fluid or to
r~place the transformer entirely? Pa-
cific Gas & Electric (PG&E, San
Francisco, Calif.) decided to replace its
PCB-tilled distribution capacitors and
network transformers containing PCB
fluids. This could cost the utility mil-
lions of dollars, and final disposal of
PCl;ls from the equipment being re-
placed will add to this cost. In general,
PG&E elected to use silicones as sub-
stitute transformer fluids . At least four
other utilities are expected to follow
suit.
T. L. Forrester of PG & E said that
depending on the type of fluid used,
retrofilling may allow existing equip-
ment to be used. Advantages of retro-
filling include no major construction,
less cost and need for added manpow-
er, and, possibly, less media and public
attention. One problem is that of re-
sidual PCBs. If a transformer is re-
placed, on the other hand, the PCB
probiem disappears, but then one faces
lengthy, costly construction work.
i4A Environ. Sci. Technol., Vol. 18, No. 2, 1984
Removal and disposal
After equipment retrotilling or even
a spillage, disposal of PCBs and
PCB-contaminated material is re-
quired. After replacement, both fluids
and capacitor and transformer "car-
casses" must be disposed of. For PCBs,
incineration above 1200 °C is pres-
ently the only permissible option.
PCB-contaminated materials ( < 500
ppm) and carcasses may be disposed of
in secure landfills. A spokesperson for
SUNOHIO (Canton, Ohio) told
ES & T that chemical destruction
technology for PCBs in the 500-
2500-ppm range has proven successful
and is available commercially. Inci-
dentally, TSCA does not specifically
address cleanup technologies.
Leo Weitzman, research manager
of Acurex Waste Technologies, Inc.
(Cincinnati, Ohio), says that for
chemical transformer oil cleanup, his
company's technique is to use sodium
metal as a reagent to strip off chlorine
and "salt out" sodium chloride. The
finely divided sodium attacks PCBs
dissolved in a proprietary solvent; the
reaction occurs under a nitrogen
"blanket." For capacitors, a mobile
approach soon to be demonstrated will
use sodium metal also under a nitrogen
blanket to strip chlorine. SUN OHIO,
S.D. Myers, Inc. (Akron, Ohio), PPM
Inc. (Tucker, Ga.), and several other
companies are also using chemical
destruction. A major advantage of
chemical PCB destruction is the ability
to reclaim the rest of the dielectric
fluid. In addition, a thermal technique
that produces high-grade gaseous or
aqueous HCI is available (ES& T, July
1983, p. 290A).
Microbial treatment
Suppose PCBs contaminate soils or
sludges, which cannot be cleaned
chemically and are very expensive to
incinerate. Microbes might be an an-
swer. Walter Kim of the National
Aeronautics and Space Administra-
tion (Cleveland, Ohio) said that at-
tempts to decompose PCBs in sewage
sludge with Pseudomonas aeruginosa
were unsuccessful. The bacteria ap-
parently absorbed the PCBs, but re-
leased those compounds after they died
or lysed.
On the other hand, Donna Bedard
of GE reported the isolation of more
than 12 strains of PCB-degrading
bacteria from sites containing PCBs.
Two of these, a Corynebacterium
species and Alcaligenes eutrophus,
degrade a number of PCBs, including
several pentachlorobiphenyls. She
postulated that the A. eutrophus uses
a previously unknown dioxygenase
enzyme to attack at the 3,4-position,
while the Corynebacterium may at-
tack at the 2,3 site. Breakdown prod-
ucts seem to include chlorobenzoic
acids, which should be amenable to
further microbial decomposition.
Bedard suggested that bacteria ex-
posed to more highly chlorinated PCBs
may already have developed an ability
to decompose congeners previously
thought to be refractory to biodeg-
radation. She said that studies are
under way at GE to gain a full under-
standing of the genes that govern pro-
duction of PCB-degrading enzymes
and of the biochemical pathways of
this degradation.
-Julian Josephson