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HomeMy WebLinkAboutNCD980602163_19941219_Warren County PCB Landfill_SERB C_Correspondence, 1994-OCRt·lC AF'/ BF.:EDL TO: Bill Meyer, Direot or MEMORANDUM December 19, 1994 f)j_vie.ion of Solid Wa$te Manag~ment North Carolina Department of Environment, Health and Natural Resources FROM: Ken Fer·ruccio, Co-Chair K f Joint Warren County/State PCB Landfill Working Gr oup SUBJECT: Pauline Ewald's recommendation ooncern1ng her preliminary and final report Pauline has recommended that you put your critique /concerns regarding her. preliminary report in writing and that the appropriate state official sign her final report . Dollie and I hava concurred . A written critique of Paulina's preliminary report will facilitate the oompletion of a mutually-agreed-upon final report and accelerate what seems to be a needlessly slow process . cc : Pauline Ewald TEL:1-919-733-9555 Dec 2 1,94 12 :35 No.003 P .02 December 13, 1994 Dr. Ronald Levine State Health Director cCEl\t , Hoatth Di recto( s . )1\1.1\l D H I. F\/11 lfC f t1 , N.C. Department of Environment, Health, and Natural Resources P.O. Box 27687 Raleigh, N.C. 27611-7687 Dear Dr. Levine: I am a citizen of Warren County living two miles from the PCB landfill in Afton, North Carolina. When tests were completed on July 27, 1994 dioxins were identified both inside the landfill and in two of the four monitoring wells on site. The dioxins identified included 2 ,3, 7, 8 TCDD_-"'.'one of the most toxic dioxins found anywhere in the world. As you are probably aware, the EPA recently reassessed the toxicity of dioxin and found that it is much more toxic than was previously suspected. As a result they lowered the only safe and accept- able level of dioxin to non-detect. I asked my County Health Director, Mr. Dennis Retzlaff, to test my well water for dioxins. He informed me that the county does not have the funds needed to pay for the test. I understand that Mr. Retzlaff forwarded a copy of both my letter and his response to your office. I am thus requesting that the test be performed at the expense of the State. I do not bert-eve that I am making an unreasonable request. The st~te, after all, put these dangerous chemicals in the ground and is responsible for the safe upkeep of the landfill and the safety of the citizens living around it. Si~ce no recent hydrogeological studies have been performed at this site, no one can assure me that the affected groundwater has not or will not contaminate my property and well. In his letter to Warren County on October 20t 1982, then Governor Jim Hunt promised to teat local wells within a three-mile radius at ·the State's expense. Now that dioxins have been identified in both the landfk1il and the monitoring wells I feel it is only reasonable tha . the State should test my well for dioxins also. I am sorry at the test is expensive but I do not believe that I should have to pay for the State's incompetence. I cannot understand how the State has neglected to test for dioxins for the past twelve years. TEL:1-919-733-9555 Dec 21 ,94 In fact the State only performed the Dioxin Scan in July at the ins!stence of the PCB Landfill Working Group and Ms. Pauline Ewald, the Environmental Consultant. I am hereby requesting that a specialized PCB and Dioxin Scan be performed on my well water using the same parameters and process used by the State to test the PCB site monitoring wells. As stated in my letter to Mr. Retzlaff, I will not be satisfied with the test results if they are sol0y conducted by the State of North Carolina. Frankly the State has done nothing concerning this matter to earn my trust. I feel that the State ha.a a vested interest in finding 11no d--trace" of-dioxin in my· water and so request that either a split-sampling procedure be utilized with an independent organization or that the test be performed soley by an independent organization. I am the mother of two beautiful baby girls and have been making baby bottles with this water for three years now. Maybe you can imagine the worry and heartache this whole series of events has caused. I have had no peace of mind since hearing of the test results. I thought my well was safe because I had it tested for the usual contaminants and the resultat were all negative. I was unaware and i gnorant, however, of the great likelihood of dioxins being present along with PCB 1 s in the landfill. I made the mistake of believing that my state government was watching out for us and monitoring the site to protect our health. I no longer believe that. I do not want to sacrifice my life or the lives of my children because of money or dirty politics. I want to know, for the sake of my family's health, if my water is contaminated with dioxins. I am appealing to you, my State Health Director, for your help. I would appreciate a prompt written response to this letter. Thank you for your assistance in this matter. ~ TO: BILL MYER (' l I FROM: JIM WARREN \; ''\J RE: DATA FOR THE WARS,EN COUNTY SCIENCE ADVISOR DATEt 12/12/94 ON BEHALF OF SEVERAL WORKING GROUP MEMBERS I AM WRITING TO EXPRESS OUTRAGE THAT DSWM S'l'ILL HAS NOT REMITT:E:D ALL DATA TO PAULINE EWALD AND ECO. I HAVE FULLY DISCUSSED THIS ISSUE WITH SHARRON AND WITH PAULINE AS WELL AS WITH OTHER SCIENTISTS. IT IS CLEAR THAT PAULINE 1 S REPEATED REQUESTS FOR THE QA/QC ON ORGANICS AND FOR THE CHROMATOGRAJ?HY FOR ALL PCB/DIOXIN DATA ARE WELL- FOUNDED, REASONABLE AND NECESSARY F'O.K HER FORMAL REPORT ON CHARACTERIZATION OF THE LANDF~LL. IT ALSO CLEAR THAT HER REQUEST IS BEING DENIED. SHARRON'S ASSERTION THAT THE QA/QC WAS INCLUDED lN THE ORIGINAL PACKAGE RINGS HOLLOW. WHETHER THAT IS ACCURATE IS IRR!'.:LBVANT; IT WOULD BE SIMPLE ENOUGH TO SEND IT AGAIN. SHARRON IS OUT OF LINE IN CLAIMING 'l'HAT CHROMATOGRAPHY IS NOT NEEDED. AS SCIENCE ADVISOR, PAULINE HAS THE RESPONSIBILITY TO ASSURE THE COMMITTEE OF THE ACCU.tU\'rE RESULTS OF THE TESTING, AND SHE INSISTS THAT HER ANALYTICAL CHEMIST HE ABLE TO REVIEW THE RTP LAB COMPUTER'S INTERPRE'l'A'l'lON OF THE DATA, ESFF.CIALLY WITH THE NON- STANDARD TECHNOLOGY USED AND S!NCE BOTH LABS SHOW INTERFERENCE FROM E'URANS. ACCORDING TO PAULINE AND OTHER SCIENTISTS, CHROMATOGRAPHS ARE A S'l'ANUARO PART OF ANY DATA PACKAGE. ECO'S LAB INCLUDED CHROMA'!'OGRAPHY AS PART OF IT'S ORIGINAL PACKAGE SENT TO THE STATE AND TO ECO. SHARRON'S CLAIM THAT PROVIDING CHROMATOGRAPHY WOULD BE EXTREMELY EXPENSIVE AND TIME CONSUMING SOUNDS DUBIOUS. SHE SHOULD HRING EVIDENCE OF THAT TO THE 12/15 MEETING, INCLUDING A COPY OF THE STATE'S CONTRACT WITH THE LAB. MEMBERS 01'' 'l'H!:: WORK.LNG GROUP AND CITIZENS OF WARREN COUNTY HAVE WAITED OVER 4 MONTHS FOR OFFICIAL RESULTS OF THE JULY TESTING. WE ARE VERY TIRED OF WAITING AND OF DSWM' S ST.1\LLING. YOU KNOW VERY WELL THAT WITHOUT THE SCIENCE ADVISOR'S FINAL REPORT WE CANNOT MAKE A PRESENTATION TO THE ENVIRONMENTAL REVIEW COMMISSION OR TO THE LEGISLATURE, TO SEEK THE FUNDING FOR DETOXIFICATION, WHICH THE WORKING GROUP APPROVED UNANIMOUSLY IN NOVEMBER. IF THERE IS ANY VALID REASON WHY ECO SHOULDN'T HAVE THE REMAINING DATA THEN YOU SHOULD CALL ME WITH IT TODAY. OTHERWISE, I MUST DEMAND THAT BOTH THE ORGANIC QA/QC AND ALL PCB/DIOXIN CBROMATOGllAPBY BE ORDERED SENT TO PAULINE TODAY BY OVERNIGHT COURIER. AND FOR YOU PERSONALLY---NOT SHARRON---TO CONFIRM TO ME OR TO THE CO-CHAIRS THAT THIS HAS BEEN DONE. BY THURSDAY 1 S MEETING WE NEED TO BEAR THAT ECO IS PROCEEDING 'l'OWA.KlJ rr '8 FINAL REPORT. pc: ALL WORKING GROUP MEMBF.~S F':01 State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director .RA DEHNR December 9, 1994 TO: Billie Elmore FROM: Sharron Rogers SUBJECT: Battelle Northwest Laboratory's BCD work for US Navy Billie, I was able to get names and phone numbers for contacts at Battelle Northwest Labs (BNL) almost immediately after you suggested the lead. However, all 8 individuals involved had just left for Guam for 3 weeks to perform a "hot test" of their method for the Navy. Thus, it took until today to get some conversation time with the project manager. Unfortunately, there are no reports at this time, so I will write a brief narrative of my discoveries here for our future reference. The project manager is Mike Brown, 509-375-3791. Other names involved are Harley Freeman, 509-376-8561 and Dave Eakin, 509-375-3796. These gentlemen are in Battelle's Chemical Technology Department, Chemical Process Development Section at Richland, WA. The US Navy Engineering Lab at Point Hueneme, CA is their client. (DB Chan is the project manager). The Navy had developed a bench-scale process based upon Charlie Rogers work at EPA Cincinnati, and contracted with Battelle to design the field scale trial system and to perform the testing. Battelle's 50 ton "hot test" was of a one ton-per-hour rotary kiln demonstration plant at the Guam Navy Rework Facility. The Rework facility is a W.W.11 and later transformer rework center for the Pacific area. Brown indicates that it is surprisingly uncontaminated by other hazardous constituents such as solvents. Dioxins are present at anticipated levels (low ppt) for those levels of PCB contamination (PCB' s 300 ppm average with isolated spots to several thousand ppm). EPA has set dioxin cleanup to 2 ppb, which is below existing levels at the site, and there is no evidence that dioxins formed during the test. Tests showed dioxins and furans below detection by EPA method 8280, which had a detection limit of about 1 ppt. The Navy has accepted Battelle's demonstration as a success, and has contracted with IT Corp. to operate the existing demonstration model, rather than to construct a larger model or to dispose or decontaminate the existing one. IT Corp will operate the one ton model to complete the cleanup of the 5,000 to 6,000 cu yds of contaminated soils at that location. The change in contractors is normal since Battelle is an R&D company that does not directly do remediation. :J ,. 5 A-,· /,-.,,.._/., . ,vi,,_ •• ~✓~L-'-~' 1)~ ~ ~ ,,K'""-,,,. CC<-? k--,_ • P.O. Box 27687. Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper To: Shar on Roger s •· From: Michael D. Brown To: Sharon Rogers 12 December, 1994 Ms. Sharon Rogers FAX 919-715-3605 Dear Ms Rogers : From: Michael D. Brown Date: 12/12/94 Time: 12:50:06 12-12-94 12:51pm p. 2 of 3 ()Bane11e Pacific Northwest Laboratories Battelle Boulevard P 0 . Box 999 Richland, Wash ington 99352 Page 3 of 3 Telephone (509) 375-3791 Fax (509) 375-6858 E-Mail md_brown@ccmail.pnl.gov Thank you for your recent inquiry regarding PCB treatment and the Base-Catalyzed Destruction Process. I enjoyed talking with you . Let me summarize some background on the process and Battelle's role in its development. First of all , the technology is an evolution of work that has been done at the USEPA's Risk Reduction Engineering Laboratory in Cincinnati, OH for over 10 years . The process has evolved from research by Dr. Charles Rogers , Dr. Al Kornel , and Harold Sparks directed at a variety of processes employing Potassium Polyethylene Glycol (APEG) to dechlorinate PCB-containing soils. As a result of this research , a series of patents were granted for this technology. In 1987 the USEPA approved the establishment of KPEG as the best developed alternative treatment technology for PCBs, and spent solvents contaminated with dioxins and furans . EDS was also successfully treated with KOH and tetraethylene glycol and an additional US patent (4,675,464) was granted. Since 1987, EPA has continued to make process improvements to the base-catalysis technology. Additional patents (5,064,526 5,039,350 and 5,019,175) were granted to Rogers, et al in functional nucleophiles to replace the chlorines surrounding the PCB molecule. The product of the reaction is primarily non- hazardous biphenyl. In the mid 1980's, the US Navy realized that this technology might be used to treat many highly contaminated sites controlled by the US Government. Dr. DB Chan of the Naval Civil Engineering Laboratory (NCEL) in California performed a large field test in cooperation with the USEPA in 1988, employing a 400 gallon batch system on a Navy site on the island of Guam. Soil batch size ranged from 2800-5100 lbs and contained PCB levels from 300-2000 ppm, which were reduced to 0.2 to 6.5 ppm following a single treatment. Typical treatment times were 2-3 hrs at 150C. Based on these favorable result, the US Department of Energy's Pacific Northwest Laboratory (PN L) was asked to assist the Navy in designing and building a 1 ton per hour continuous treatment system for demonstration and deployment on Guam . Battelle operates PNL for the Department of Energy and staff at both Richland, WA and in Columbus, OH were utilized for this task. The completed system is To: Shar.on Rogers From: Michael D. Brown 12-12-94 12:52pm p. 3 of 3 ' From : Michael 0 . Brown To: Sharon Rogers Date: 12/12/94 Time: 12:50:09 Page 4 of 3 Page 2 12 December, 1994 Navy-owned and was assembled and cold tested at a Navy site in Stockton, CA prior to shipment to Guam. The system was shipped to Guam in August 1992, cold tested in June and July of 1993, successfully hot tested with 16 tons of PCB-contaminated soil during Jan 1994, and again with 50 tons in Nov 1994. All systems (except for the reactor, crushing plant, and mixing plant) are modular in nature and skid-mounted for placement in a 40 foot overseas shipping container. Because of the remote location , a complete analytical laboratory (GC/MS) and a shop were also built into containers. After testing is completed, the BCD system is scheduled to be deployed at Naval Sation , Guam by IT Corporation. Following excavation and feed preparation, the process is carried out in two steps : 1) a solid phase reaction using an indirectly heated rotary reactor, and 2) a liquid phase reaction using a stirred tank reactor. The solid process uses a base (e.g. sodium bicarbonate), and an organic source of hydrogen to partially decompose and volatilize any PCBs in the soil at 350C for one hour. Offgas from the primary rotary reactor will be cleaned by a cyclone, baghouse, and venturi scrubber to remove al l traces of PCB prior to venting. Any PCBs recovered this way will be treated in the liquid- phase stirred tank reactor utilizing a base (usually sodium hydroxide), an aliphatic hydrocarbon solvent, and a catalyst at temperatures of 350C for 1-2 hrs. Treated soil has been demonstrated to meet treatment criteria of less than 2 ppm per resolvable PCB congener. The BCD Development team (NCEL, USEPA, PNL, and Battelle's Columbus Laboratory) and the BCD process was recently recognized at one of the top 100 new processes/products of 1992 by R& D Magazine and in 1993 by Popular Science. PN L(and Battelle's) role ts a technical resource and technology transfer bridge to help demonstrate and fully commercialize the technology. Battelle-PNL can design and build prototypical and demonstration systems and can assist in training , permitting, start up , and demonstration. However, Battelle is not a remedial action company and does not perform site cleanups. If you have specific questions regarding the technology and how Battelle might be able to assist you in your technology development and selection , please contact me at (509) 375- 3791 or by fax at (509) 375-6858. The technology is covered by several USEPA patents and is available for both domestic and foreign licensing. While EPA retains domestic rights, all foreign rights have been granted to the inventors, who are now doing business as The BCD Group. Discussions regarding your company's specific interests should be directed to The BCD G·roup's Dr. Charles Rogers at (513) 385-4459 or USEPA's Dr. Carl Brunner at (513) 569-7655. Sincerely, ~Ll-~ Michael D. Brown, PE Senior Research Engineer Chemical Process Development To: Shar.on Rogers From: Michael D. Brown 12-12-94 12:50pm p. 1 of 3 • From: Michael 0. Brown To: Sharon Rogers ~ich~I D. Brown, Sen. Research Engr. Pacific Northwest Laboratory K2-40 PO Box 999 Date: 12/12/94 Time: 12:50:04 Page 2 ol 3 Richland, WA 99352 ph 509-375-3791 fax 509-375-6858 EMAIL md_browncmail.pnl.gov Fax Cover Sharon: Attached is a summary that I send out regarding our PCB project and its genesis. As I gather more information in the next few weeks on our final report I will try to get you a draft copy. Call me if you have any specific questions. Thanks, Mike Brown To: Sharon Rogers !From : Michael D. Brown \. ( C C C '< < ( ( ( r.-~1 ~~f Wtf1~1ff/,t;/;,f,g'/Jf!1llW..Tfs1WJTPb~ 'lftfJ~Ef'Jitff;,f$111~~ ~p /M:'t~. LOCATIONS. QUESTIONS? CALL 800-238-5355 TOLL FREE. PACKAGE TRACKING NUMBER 'Jal! {Ji' .;j,!:)!, , .. 112:ltN 7l27l73CfSS .,...,,..,,_Ell'IEDAt:l:IIIIITAUlall ..... 1043""''!>6&-c, From (Your Name) Please Print ,r..,, I ""'iri,•:,1 ,. ( .. \•' . . i ~pany'.L .. L.L .\ '!',-_ ~ ·:..:_:~ • ...:. ...... .L Date I . ( I I ·-:, ~/ 'j --. . . . . .. ! 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Asheboro, NC 27203 Dear George, The enclosed materials include a number of basics about the design and environment of the Warren County PCB Landfill. Also, copies of the water level data for several years from the GW monitoring wells and the leachate collect,on system from within the landfill. Bob Glaser is continuing his analysis and modeling of this information, and will be completed soon , including recommendations for additional monitoring wells. As your evaluation of the project continues, we would like to invite you to come back and visit for an extended conversation with Bob and myself about this work. Also, by that time the State Geological survey will have installed a benchmark at the site so that we can convert the current estimated elevations to true elevations. Very truly yours, Sharron Rogers Assistant Director 't y • l ' PCB LANDFILL FACT SHEET The State owned PCB Landfill in Warren County, North Carolina is located on a 142 acre tract of land located just off State Road 1604. The actual containment area occupies approximately two and one-half acres. The landfill is 24 feet thick and contains 40,000 cubic yards of PCB-laden soil with an average contamination level of 125 parts per million. PCB's are extremely persistent and resist both biological and chemical decomposition. It is estimated that PCB's have a half-life in soils of approximately 60 years. PCB's are stable up to temperatures approaching 1600 degrees Fahrenheit. They are relatively insoluble in water and evaporate very slowly. PCB's accumulate in the fatty tissue of both humans and animals. Acute human health effects include a skin rash known as chloracne and liver damage. In studies on animals, PCB's were shown to cause an extremely high rate of embryonic death. Chronic effects may include an increased cancer risk and behavioral changes. Persons working on or around the site are in little danger as long as the top cover and plastic liner remain intact. During monthly inspections, the soil cover layer is checked for erosion and the presence of tree saplings, which have roots that could eventually damage the top cover and synthetic liner. The most significant impact that the landfill has on Warren County is the taking of approximately 20 acres of land (this includes the containment area and the buffer zone surrounding it) out of agricultural production for an indefinite period of time. The remaining 122 acres have been deeded to Warren County. The county may lease a portion or all of the 122 acres for agricultural or other compatible land uses. The Solid Waste Management Section is responsible for monitoring water quality at the landfill two times each year. This includes sampling four ground water monitoring wells which surround the site and sampling Richneck Creek both upstream and downstream of the landfill. These samples are analyzed at the State Laboratory of Public Health for the presence of PCB. To date, the PCB landfill has had no detrimental effect on water quality in the region. July.1978 July 30 August .1978 . August 2-5 August 10 August 15 August 18 September'l978 September 6-19 Ottober ·1973 October 5 ·Novemberl978 November 6 APPENDIX A Clrn.ONOLOGY First.report of a chemical spill which was later·identified as PCB on N.C. 58 in Warren County. PCB locatedalong roadsides in several other North Carolina counties including Johnston, Alamance, and Chatham. Conference held with representatives of the Department of Human Resources, Department of Agriculture, Attorney General's Office, Department of Transportation, Environmental Protection Ar.ency, nnd the news media to discuss the PCB dumpings. Activated charcoal solution and liquid asphalt applied along 210 miles of North Carolina highways·where shoulders had been contaminated by PCB. This action was taken at the recom- mendation.of specialists at North Carolina State University, who. submitted a plan for temporarily deactivating the PCB to prevent migration and to reduce any haza·rd to the public. The N.C. Department of Transportation began applying a solution of activated carbon and liquid asphalt to the 210 miles of contaminated roadside. Tests conducted along uncontaminated road shoulders to determine the safety and effectiveness of equipment to be used in picking up .the PCB. Test conducted along a cont~minnted rood shoulder on Highwny 58 in Warren County. Test results of the pick-up of contaminated soil along the roadside in Warren County show that the contaminated soil can be picked up· and treated without hnrming the environ- ment or personnel involved. ·' 1' .. December 1978 December 1 December 12 January·1979 January 4 January 17 February · 1979 February 2 June ·1979 June 4 June 4 June 6 August 1979 August 16 Sept -Dec 1979 July -Aug 1979 September 1980 . September 12 - 2 - The state obtained an option on 142 acres of land in Warren County to be used to dispose of the contaminated soil that would be picked up along the roadsides in 14 North Carolina counties· •. Application-filed with the EPA for approval of the Warren County site as a disposal area for the PCB contaminated soil. Public hearing on the Warren County site conducted· in Warrenton National Guard Armory. Robert Burns and sons pleaded guilty to a violation of the federal Toxic Substances Control Act. Burns received an active jail sentence and his sons were placed on probation. North Carolina petitions EPA to.modify its regulations to permit alternative methods of disposal of ~CB contaminated soil and debris (i.e. in-place treatment). EPA denies North Carolina's petition. EPA's Region IV administrator approved Warren County site, and the state's application to construct n PCB landfill there. Robert Burns and sons plead guilty to state charges surrounding the PCB dumping in Halifax County Superior Court. Burns later received an active jail sentence and his sons were placed on probation. Buck Ward was found not guilty on state charges. Suit filed by Warren County. Draft EIS prepared, filed on December 28, 1979. Comments received on EIS. Engirteering·consultant firms were interviewed by the state and a recommendation was made to the Cnpitnl Building Authority for selection l i • ) ----- May 1981 May 22 ·Novcmber ·l981 November 25 May · 1982 May 13 May 26 May 26 June 1982 June 21 ·July 1982 July 2 August . 1982 . August 4 August 10 -3 - of a firm to develop plans for a PCB landfill .in Warren County. Buck Ward tried and found guilty of a viola- tion of _the federal Toxic. Substance Control Act. He received an active jail sentence and a· $200,000 fine. Judge Earl W. Britt gr.:tnts summary judgment in'favor of state and EPA in Warren County and Twitty suits, resolving legal obstacles delaying constructing of land£ ill. Appeals taken· in.both cases. Contract for construction of the PCB landfill awarded by the Capital Building Authority pending the approval of federal "Superfund" money· to fund the PCB cleanup project. The contract was awarded to the low bidder, Jim Lineberger· Grading and Paving Company of Gastonia. North Carolina and EPA.officials announced the signing of a cooperative agreement which provided $2.5 million in federal "Superfund" money to construct a PCB landfill in Warren County, and to clean up the PCB contaminated soil along 210 miles of North Carolina roadsides. 120 acres surrounding the landfill site deeded by state to Warren County as buffer zone. Voluntary dismissal taken by Warren County in suit on appeal. Construction began on the PCB landfill in Warren County. NAACP files discrimination suit in federal court requesting preliminary injunction to prohibit placement of soil in Warren County. Hearing held before Judge Earl Britt. Preliminary injunction denied. .,,,,.... __ September ·l982 September 15 Octoberl982 October 6 October. 12 October 27 November ·19a2 November 1 ·Deccmber·19a2 December December 13 December 27 ·Jot'l.unry ·l983 January January 26 - 4 - Removal of PCB from roadsides begins by DOT crews •.. Protests begin in Warren County and · a total of 423 adult arrests were made and 100 juveniles were taken into custody over the. following 4½ weeks.· Fort nragg begins removal operation for PCB on base.· State finishes ·roadside removal of PCB. There were 2_41 shoulder miles· picked up; 6,455 truckloads. taken· to landfill. Fort Brag~ finishes removing PCB from base; 76.8 truckloads put in landfill. Total state/Ft. Bragg truckloads _7,223. Capping operation begins; plastic liner and clay liner in place, soil layer added. Bad weather prevents final soil layer and seeding of cap to be accomplished. Heavy rains cause soil erosion on cap and exposes plastic liner. Bubbles develop in exposed liner· from gas in the landfill caused by decomposition of vegetation mixed in with soil.· Bubbles·vented, soil erosion temporarily corrected and a temporary seed cover is installed on the cap. Landfill will be completed in Spring. Buck Ward begins sentence at Danbury, Connecticut, Federal Prison after being denied petition for certiorari by U.S. Supreme Court. Federal Appeals Court affirms Judge Britt's ruling in Twiddy case. EPA monitors ens venting from landfill and reports no significant emissions of PCBs. U. ·s. Files civil suit in federal court against Buck Ward and·Ward Transformer, Inc. ,, . · February 1983 February 17 · ·Ma.rch ·l983 March 4 'M.1J" 1983 May 11 May 24 JulJ'1983 July 14 July 15 July 23 August'1983 August 3 -5 - State dismisses state law suits. against Buck · Ward and·state _allowed to intervene in federal suit~ All counterclaims dismissed by Ward against state. Voluntary dismissal. taken by plaintiffs in discrimination-suit. Contractor resumes work on completion of landfill construction. ·EPA grant . period .. extended until July 23, · 1983. Construction completed. Inspection held at the site and acceptance made by state officials. Grant period ended.· Inspection held.at the site by EPA officials and approval given. State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director 6?!·;~ Ji~ --• a a DEHNR April 26, 1994 MEMORANDUM TO: FROM: Members of the joint Warren County and state PCB Landfill working group Bill Meye~ SUBJECT: Sampling Analysis, and Leachate Removal Activity 1982-1993 Enclosed is a summary of sampling and analysis of groundwater monitoring wells, surface stream water, stream sediment, leachate and miscellaneous samples. This report does not include approximately 35 private water supply wells sampled and analyzed in 1982-83 or the recent well testing conducted by the Warren County Health Department. None of the wells tested positive for PCB's. There are also approximately 12 O blood samples taken the last quarter of 1982 to establish a background PCB blood level. The blood samples are preserved and will be analyzed if there is a release from the landfill. If you have any questions please contact me at (919) 733-4996. WLM:aw Attachment P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper LEACHATE REMOVAL, SAMPLING AND ANALYSIS OF PCB LANDFILL 1982-1993 TABLE OF CONTENTS PAGE I. PCB LANDFILL-SUMMARY OF LEACHATE REMOVAL, SAMPLING AND ANALYSIS EVENTS FOR PCB 1982-1993 1 II. PCB LANDFILL, LEACHATE REMOVAL AND ANALYSIS 1983-1993 2-5 III. MONITORING WELLS, SURFACE WATER STREAM SEDIMENT SAMPLES 1982-1993 IV. MISCELLANEOUS SAMPLES 1983-1993 V. PRIVATE WATER SUPPLY WELLS 1982-1990 6 7 8 :, ..... PCB LANDFILL SUMMARY OF SAMPLING AND ANALYSIS FOR PCB'S LEACHATE PRIVATE MONITORING SURFACE STEAM REMOVAL ANALYSIS WATER DATE WELL WATER SEDIMENT I" E* Well SOIL OTHER 1982 8 8 8 1983 16 16 16 33 33 26 4 (1 • 1984 8 16 16 11 10 9 1985 16 16 16 11 10 9 1986 16 16 16 3 0 1 1 1987 4 4 4 0 0 0 1988 8 8 8 0 0 0 1989 8 8 8 1 1 0 1 (2· 1990 8 8 8 7 6 6 1 5 6 {3* 1991 8 8 8 10 0 3 1 1992 8 8 8 11 1 0 1993 5 2 2 1 (4* TOTALS 108 116 116 92 63 56 3 5 12 *1) Air Samples; 2) Lagoon.sediment basin water; 3) Grass.treatment system; 4) Lagoon sediment basin sediment LEACHATE I = Influent, E = Effluent ' . , ,r, Page 2 PCB LANDFILL LEACHATE SAMPLES DATE GALLONS INFLUENT EFFLUENT 03-07-83 0.42 PPB 0.24 PPB 03-07-83 0.44 PPB 03-08-83 0.34 PPB 0.28 PPB 03-08-83 0.25 PPB 0.043 PPB 03-08-83 2.80 PPB 0.062 PPB 03-14-83 <1.0 PPB 03-16-83 <1.0 PPB <1.0 PPB 03-21-83 2.471 PPB 0.184 PPB 03-22-83 1.408 PPB 0.294 PPB 03-23-83 1.349 PPB 0.107 PPB 03-24-83 <0.1 PPB <0.1 PPB 03-28-83 <0.1 PPB <0.1 PPB 03-30-83 0.279 PPB <0.1 PPB 04-01-83 0.10 PPB <0.1 PPB 04-05-83 0. 40 PPB 0.10 PPB 04-07-83 0.20 PPB 04-11-83 0.20 PPB <0.1 PPB 04-12-83 0.50 PPB <0.1 PPB 04-13-83 1.114 PPB 0.708 PPB 04-14-83 0.708 PPB 0.196 PPB 14-18-83 <0.1 PPB <0.1 PPB 04-19-83 0.22 PPB 0.21 PPB 04-20-83 0.27 PPB 0.24 PPB 04-25-83 0.60 PPB <0.1 PPB . ,, Page 3 DATE GALLONS INFLUENT EFFLUENT ()4-26-83 0.20 PPB <0.1 PPB 04-27-83 <0.1 PPB 05-10-83 0.20 PPB <0.1 PPB 05-25-83 0.10 PPB <0.1 PPB 06-01-83 <0.1 PPB 07-20-83 1.63 PPB 07-29-83 <0.1 PPB 01-21-83 <0.1 PPB <0.1 PPB 11-29-83 <0.1 PPB <0.1 PPB 01-26-84 0.30 PPB <0.1 PPB 03-07-84 <0.1 PPB <0.1 PPB 04-03-84 0.60 PPB <0.1 PPB 05-03-84 0.60 PPB <0.1 PPB 06-06-84 100 <0.1 PPB <0.1 PPB 07-17-84 90 0.30 PPB <0.1 PPB 08-16-84 90 <0.1 PPB 09-11-84 135 0.20 PPB <0.1 PPB 10-10-84 135 11-05-84 140 0.20 PPB <0.1 PPB 12-11-84 135 =690 <0.1 PPB <0.1 PPB 02-18-85 90 <0.1 PPB 03-26-85 90 <0.1 PPB <0.1 PPB 04-23-85 112 <0.1 PPB <0.1 PPB 05-24&25-85 90 <0.1 PPB <0.1 PPB 06-27-85 90 <0.1 PPB <0.1 PPB 07-16-85 90 <0.1 PPB <0.1 PPB / Page 4 -PATE GALLONS INFLUENT EFFLUENT 08-13-85 90 <0.1 PPB <O.l PPB 09-18-85 90 <0.1 PPB <0.1 PPB 10-24-85 90 <0.1 PPB <0.1 PPB 11-13-85 135 = 967 <0.1 PPB <0.1 PPB 03-04-86 90 <0.1 PPB <0.1 PPB 04-24-86 5 <0.1 PPB 05-06-86 5 = 95 0.18 PPB 03-21-89 <0.1 PPB 02-26-90 22 04-19-90 100 <O.lppb <O.lppb 05-03-90 105 <0.lppb <O.lppb 05-08-90 100 <0.lppb <O.lppb 08-28-90 130 <O.lppb <O.lppb 09-27-90 120 <0.20ppb <0.lppb 10-25-90 75 = 652 <O.lppb <O.lppbO 03-20-91 75 + 85 04-24-91 75 04-25-91 85 <0.1 ppb 5-30-91 75 + 85 <0. lppb 06-27-91 110 07-26-91 125 + 95 09-11-91 120 09-30-91 55 10-29-91 100 <O.lppb 11-27-91 165 = 1250 01-31-92 160 Page 5 . DATE GALLONS INFLUENT EFFLUENT -02-28-92 160 03-27-92 160 04-29-92 160 06-26-92 160 07-30-92 160 08-28-92 160 09-29-92 160 10-27-92 160 <O.lppb 11-24-92 160 12-23-92 160 = 1780 01-26-93 160 <O.lppb <O.lppb 02-26-93 160 03-26-93 160 04-23-93 160 05-21-93 160 = 800 <O.lppb <OzlPPb PPB -PARTS PER BILLION PCB'S INFLUENT -LEACHATE PRIOR TO ENTERING TREATMENT WORKS FILTRATION SYSTEM EFFLUENT -LEACHATE AFTER DISCHARGE FROM TREATMENT WORKS FILTRATION SYSTEM PCO lANDflU. SJ\MPUNG DAI A DATE MONITORING WEI I. SAMPLES SURFACE WATER SAMPLES 1982 1129 <O I pre (8 SAMrl ES) <0. I rre (8 SAMPl ES) 1983 <O. 1rre (8 SAMrLESI < 0. I rre (8 8"Mrl ~SI 05 05 11 -21 <0.1 PPB (8 SAMrLESI < 0 I rre (8 SAMPLES) 1984 0606 <0 I PPB (4 SAMPI ES) <0 I PPB (8 SAMPLES) 12-11 <0.1 PPB (4 SAMPLES) <0.1 PPB (8 SAMPLES) 1985 05 24 <0 I PPB (8 SAMPLES) <0 I PPB (8 SAMPLES) 11-13 <0.1 PPB (8 SAMPLES) < 0 I PPB (8 SAMPLES) 1986 0506 < 0 I PPB (8 SAMPLES) < 0 I PPB (8 SAMPLES) 11 -18 <0.1 PPB (8 SAMPI ES) < 0 1 PPB (8 SAMPLES) 1987 0604 <0 I PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES) 1988 02 02 < 0. I PPB (4 SAMPLES) <0 I PPB (4 SAMPLES) 07-06 <0.1 PPB (4 SAMPLES) <0 I PPB (4 SAMPLES) 1989 03-21 <O 1 PPB (4 SAMPLES) <0 I PPB (4 SAMPLES) 10-25 < 0 . 1 PPB (4 SAMPLES) < 0.1 PPB (4 SAMPLES) 1990 04 -19 < 0 . 1 PPB (1 SAMPLES) < o. 1 PPB (4 SAMPLES) 10 25 < 0 1 PPB (4 SAMPLES) < 0. I PPB (4 SAMPLES) 1991 04-24 <0 1 PPB (4 SAMPLES) < 0. I PPB (4 SAMPLES) 10-28 < 0 .1 PPB (4 SAMPl ES) <0.1 PPB (4 SAMPLES) 1992 05-13 < 0 I PPB (4 SAMPl ES) <0 I PPB (4 SAMPLES) 11-24 < 0 . I PPB (4 SAMPLES) <0.1 PPB (4 SAMPLES) PPB = PARTS PER BILLION PCB"S PPM = PARTS PER MILLION PCB"S STREAM SEDIMENT SAMPLES < 0 t PPB (8 SAMPLES' <0.1 PPB (8 SAMPL~S\ <0 t ?PB (8 SAMPLES) <0. I PPM (8 SAMPLES) <0.1 PPM (8 SAMPLES) <0.1 PPM (8 SAMPLES) <0 I PPM (8 SAMPLES) <0 I PPM (8 SAMPLES) <0 1 PPM (8 SAMPLES) <0.1 PPM (4 SAMPLES) <0 1 PPM (4 SAMPLES) <0 1 PPM (4 SAMPLES) <0.1 PPM (4 SAMPLES) < 0. 1 PPM (4 SAMPLES) < 0. 1 PPM (4 SAMPLES) <0.1 PPM (4 SAMPLES) < 0 1 PPM (4 SAMPLES) <0.1 PPM (4 SAMPLES) <0 1 PPM (4 SAMPLES) <0.1 PPM (4 SAMPLES) The PCB landlill has 4 monlto,lng wells, 4 surlace water sampllng sites and 4 stream sediment sampling sites that are currently sampled semi-annually. ••• . . PCB LANDFILL HISCELLANEOUS SAMPLES J2ATE SAMPLE LOCATION 01-06-83 GAS VENT EXHAUST 01-06-83 LEACHATE COLLECTION PIPE EXHAUST 01-12-83 AMBIENT AIR SAMPLES 01-12-83 GAS VENT EXHAUST 08-28-89 LEACHATE LAGOON WATER 05-03-90 SOIL SAMPLE 04-18-90 GRASS (4 SAMPLE SITES) 04-18-90 SOIL (4 SAMPLE SITES) 04-18-90 CHARCOAL FROM TREATMENT WORKS 04-18-90 LEACHATE LAGOON SEDIMENT 10-29-91 SOIL 02-26-93 LEACHATE LAGOON SEDIMENT PPB -PARTS PER BILLION PCB'S PPM -PARTS PER MILLION PCB'S ND -NONE DETECTED RESULTS 3.00 PPB <1.0 PPB .. ND 2.00 PPB <0.1 PPB <0.1 PPM <0.1 PPM <0.1 PPM <0.1 PPM 0.27 PPM <0.1 PPM 0.12 PPM . ) ' . ,· . DATE 08-24-82 08-24-82 01-13/19-83 07-16-85 03-16-90 PPB -PARTS PER BILLION PCB'S PRIVATE WATER WELL SAMPLES SAMPLE LOCATION PRIVATE RESIDENCE WELL PRIVATE RESIDENCE WELL PRIVATE RESIDENCE WELL (35 WELLS FOR 45 RESIDENCES) PRIVATE RESIDENCE WELL PRIVATE RESIDENCE WELL RESULTS < 1.0 PPB < 1.0 PPB < 1.0 PPB <0.1 PPB <0.1 PPB , I Relative Ground water Elevation in MW-1 Elev of Water Level (feet) * Date MW-1 11/16/94 68.11 10/24/94 68.43 9/26/94 68.87 8/26/94 69.29 7/28/94 69.6 6/27/94 69.69 5/18/94 69.17 4/28/94 68.74 3/25/94 68.03 2/24/94 68.03 1/25/94 68.37 12/17/93 68.85 11/18/93 69.29 10/22/93 69.67 9/27/93 70.11 8/30/93 70.51 7/23/93 70.81 6/25/93 70.77 5/20/93 70.19 4/23/93 69.39 3/26/93 68.62 2/26/93 68.07 1/26/93 67.63 12/23/92 67.65 11/24/92 67.79 Page 1 • I • Relative Ground water Elevation in MW-2 Elev of Water Level (feet) * Date MW-2 11/16/94 60.54 10/24/94 60.94 9/26/94 61.58 8/26/94 62.38 7/28/94 63.21 6/27/94 64.12 5/18/94 64.68 4/28/94 64.42 3/25/94 63 2/24/94 61 .74 1/25/94 61.34 12/17/93 61 .12 11/18/93 61.44 10/22/93 62.04 9/27/93 62.76 8/30/93 63.66 7/23/93 64.92 6/25/93 65.7 5/20/93 66.28 4/23/93 65.78 3/26/93 64.64 2/26/93 63.58 1/26/93 62.66 12/23/92 62.66 11/24/92 61.67 Page 1 Relative Ground Water Elevation in MW-3 Elev of Water Level (feet) * Date MW-3 11/16/94 67.42 10/24/94 67.68 9/26/94 68.14 8/26/94 68.82 7/28/94 69.57 6/27/94 70.63 5/18/94 71 .86 4/28/94 72.51 3/25/94 72.19 2/24/94 70.1 1/25/94 69.3 12/17/93 68.48 11/18/93 68.12 10/22/93 68.42 9/27/93 68.9 8/30/93 69.7 7/23/93 71 .02 6/25/93 71.98 5/20/93 72.98 4/23/93 73.94 3/26/93 73.24 2/26/93 71.59 1/26/93 71 .22 12/23/92 71.22 11/24/92 69.17 Page 1 Relative Ground water Elevation in MW-4 Elev of Water Level (feet) * Date MW-4 11/16/94 67.79 10/24/94 68.01 9/26/94 68.37 8/26/94 68.87 7/28/94 69.45 6/27/94 70.27 5/18/94 71.19 4/28/94 71 .64 3/25/94 71 .55 2/24/94 70.93 1/25/94 69.99 12/17/93 69.39 11/18/93 68.49 10/22/93 68.75 9/27/93 69.13 8/30/93 69.71 7/23/93 70.67 6/25/93 71.39 5/20/93 72.09 4/23/93 72.89 3/26/93 72.43 2/26/93 71 .21 1/26/93 72.41 12/23/92 72.41 11/24/92 69.67 Page 1 Relative water Level Elevation in the Landfill Date WL elev in LF(ft) 11/16/94 101 .11 10/24/94 101 .01 9/26/94 101.20 8/26/94 100.82 7/28/94 6/27/94 100.33 5/19/94 100.05 4/28/94 99.85 3/25/94 100.33 2/24/94 100.78 1/25/94 100.32 12/17/90 100.41 11/19/93 100.95 10/22/93 100.69 9/27/93 100.93 8/30/93 100.60 7/23/93 100.33 6/25/93 99.80 5/21/93 99.81 4/23/93 99.80 3/26/93 99.86 2/26/93 99.97 1/26/93 100.06 12/23/92 100.62 11/12/92 100.81 ~ /fe ' It A tw1,? h e *l}{C< l • f &.r_ l "ff -CA eyJ'l,J /,, t tJ I'.' f- l "-L,'--ic ,1 ~ Ii e (' ,1,, ~,_, Cl /Iv:,,, fLt ~-M ,;5 "'f tJw ~c1:rrt1tc1✓t cl t1t ,l /;;1ta-1 tc.1tfi t-ii,. fk lci1wf[, // ,_s a~s· u~l//tf d c/t,, Jie__ I? -I 4 -f Y?e c/: Page 1 State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr ., Governor Jonathan B. Howes, Secretary William L. Meyer, Director Mr. Charles H. Gardner Director, Division of Land Resources 51 2 North Salisbury Street Raleigh, NC 27604 Dear Charles: .NA DEHNR November 29, 1994 To follow-up on our preliminary conversation, I request that your Division assist us as soon as possible in establishing a registered geological benchmark adjacent to or on the state property of the Warren County PCB Landfill. We stand by to assist your team in any way possible. Please contact Sharron Rogers of my staff for direct assistance on planning, site access, or coordination with the Department of Administration, the official landowner of the facility. Sincerely, "t. William L. Meyer Director Dept. Fax # 'f(Yl Phone # Fax # P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper :·Mf:MO T;BI ~\ me ye• µ-, b-ll\-DATE, _j \ -1 , -er + susJEcT, \No. rre n ( Du. ri+ Y ·-:pcB 1 \ ~ \ K e ~ ~o-D , · · \ ctu.1,,1 /'le_ "-1 V'.J.Si f . f C ,-f> r~o. y -sY'°'e.. L0D n+s +he__ yo c...0 c.\a._ to...... -f r b o'f". -\--h.-e.... \cc 6 -':I o ..,.__ K n o L-0 i-VI f':_. s+r;ps v:i\ +he..-,,bLps" ShorDr; Wet .s de.scr, b, 'o The o+-he_, da. y. µ ex c,. h e (Yl ~ s. +-l,l)(.,. n + s. \--n s. 1:' e_ + h e rY\ . ~ I \ rf\ 12-+ n fY\ o r n u..::i o._ +-( '11 '4) s 3 q -'I D 7 1,e, ~ I -From: ______________ _ North Carolina Department of Environment, Health, and Natural Resources @ PrintedonRecyctedPaper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director November 18, 1994 Ms. Pauline Ewald ECO 106 Robinson Street Ashland, VA 23005 Dear Pauline: .NA DEHNR Attached is a copy of a note which Bill received from Terese Vick indicating your need for additional data. We respectfully request that you specify to us the specific data that you require. A fax to myself or Bill will suffice. Can we assume from the request that you wish to receive copies of some of the chromatograms from the organic chemical analyses from the July 27 and 28 sampling event? If you will send a list of the tests where your chemist needs to study them, we will be glad to facilitate getting copies for you. Please realize that the chromatograms are not in our possession, nor have we reviewed them. We will have to request copies from the Health Services Laboratory that performed the analyses and that maintains these details. I wish to repeat that you were provided with all the data that we received or have used regarding this sampling event. Also, that we will be glad to assist in getting copies of those chromatograms that are necessary to your comparative analysis of the data or to resolve scientific questions. Enclosure xc H. Lancaster D. Burwell K. Ferruccio W. Meyer Very truly yours, Sharron Rogers Assistant Director P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper WO~MARY TITLE: Joint State/Warren County PCB Landfill Working Group DESCRIPTION: The Secretary for the Department of Environment, Health & Natural Resources has organized a citizen/state working group to investigate issues relating to the contents of the PCB Landfill's containment technology; the costs of maintaining the landfill in its current condition; and, the feasibility of detoxifying the landfill via an acceptable technology. It is intended that the working group's composition reflect a correction of social, political environmental and economic interests in Warren County. WHAT WILL BE ACCOMPLISHED: ► Establish a list of interest groups to comprise the working group ► Identify county resident~ to serve on working group based upon the commitment to put in long hours in and out of formal meetings. ► Identify state employee to participate on the working group based upon proposed levels of subject matter expertise. ► Identify any other individuals to serve whose subject matter expertise may contribute to goals of the working group. RESOURCES: It is estimated that $5,000 will be needed to support Working Group activities concerning this issue. These funds will come from existing resources. PERFORMANCE MEASURES: This activity will result in the creation of data sampling report on the contents and integrity of the landfill, dissemination of that information to the general public, selection of a recommendation to the Secretary of EHNR and the Governor with respect to the future of the landfill, and a public outreach campaign to the NC General Assembly, the US EPA and interested citizen and business groups. WARREN COUNT_V PCB LANDFILL OPERATIONAL OBJECTIVE: Expansion of the Working Group ACTION STEPS PERSON START DATE COMPLETION DATE Establish list of interests needing Lancaster 8/02/94 8/19/94 representation on Working Group (Howes, Meyer, Rimer) Meet with County Officials and Lancaster 8/22/94 8/31/94 Working Group Members Draft Proposed Expansion for Lancaster 9/01/94 9/07/94 Review by Department and Working Group Present Proposal to Working Group Lancaster 9/08/94 9/16/94 and Department for Review and Comment Final Approval of Proposal with Working Group 9/19/94 10/12/94 Amends by Department and Working Howes Group Official Appointment of Expanded Howes 10/17/94 10/21/94 Group (Lancaster) State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director Ms. Pauline Ewald ECO 106 Robinson Street Ashland, VA 23005 Dear Pauline: November 14, 1994 Upon close reading of your report to the Joint Warren County and State PCB Working Group of November 3, we noticed the statement in the introductory Summary about needing to wait for •necessary raw data• from the Division. We need to receive clarification from you as quickly as you can provide it. To the best of my knowledge, all raw data and accompanying laboratory documentation was shipped to you as soon as we received it. Several data packages were sent to your attention including chemical analysis results performed by the NC Health Services Laboratory (principle PCB, organic and inorganic analyses), results from Triangle Laboratories (contract lab performing the dioxin analyses), and specialized analyses by EPA's Athens, GA laboratory and by GE's Corporate R&D Laboratory on detailed PCB congener determination in the landfill contents. These results were all sent by overnight courier express, and we received verification of your receipt of these packages. Therefore, we know of no additional data or documentation in our keeping that you did not receive in a timely fashion. The last data package shipped to you contained the single results of the •equipment blank•, which we had analyzed for dioxins by Triangle Labs to assist in interpretation of the previously acquired dioxin data. This result was sent to you on September 29 with accompanying letter. Please let us know what you believe we have not provided, or any data that is not readable, so that we can provide it for you immediately. If specific blocks of data cannot be identified, you can send an inventory of what you have received and we will provide any shortfall by overnight courier. cc: Henry Lancaster Dollie Burwell Ken Ferruccio Very truly yours, Sharron Rogers Assistant Director P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-71~3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director MEMO NA DEHNR TO: Members of Joint Warren County and State PCB Working Group FROM: Sharron Roge~~ DATE: November 10, 1994 SUBJECT: For your use --EPA Factsheets on Base-Catalyzed Decomposition (BCD) used at the Koppers' Superfund Site to cleanup pentachlorophenol and dioxin-contaminated soils. You may find the following EPA summary information, written for the public, useful as we continue to evaluate BCD as a method for detoxifying the PCB Landfill contents. These documents are part of the collection of information on treatment technologies that we have acquired to support the Working Group's consideration of technology options. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper .. SUPERFUND FACT SHEET UPDATE BCD DECOMPOSITION TREATMENT FOR THE KOPPERS, INC. SUPERFUND SITE Morrisville, Wake County, North Carolina June 1994 INTRODUCTION The Record of Decision signed on December 23, 1992, for the Koppers Site in Morrisville, North Carolina, selected off-site incineration as the preferred alternative for treating dioxin and pentachlorophenol. The Record of Decision also stated that a "treatability study" of the Base Catalyzed Decomposition (BCD) innovative technology would be conducted to determine its' ef9ctiveness on the contaminants of concern. Based upon the results of the treatability study a determination would be made between utilizing incineration or the BCD technology at this Site. The treatability study was conducted from August 23 - September 10, 1993, by EPA's SITE (Superfund Innovative Technology Evaluation) Program . On August 31, 1993, the public was invited to an open-house and viewing of the BCD technology in operation. Approximately 100 people attended the morning meeting and afternoon Site visit. The results from the treatability study have been finalized and based upon those results, the Agency has selected the BCD treatment technology to be utilized at the Kopper's Site to treat contaminated on-site soil. The following is a brief synopsis of those results. Since we are describing a very technical process, it presents a challenge to write this information in an easily understood manner. This fact sheet is not to be considered a technical document. .. It is prepared for the public to provide a better understanding of the procedure. TECHNOLOGY DESCRIPTION The Base Catalyzed Decomposition (BCD) process was developed to detoxify [convert, remove, destroy} chlorinated organics in soils, sediments, and sludges . The BCD process is a chemical and physical process that decomposes and detoxifies chlorinated organic compounds by removing the chlorine atoms from the atomic structure in each such compound. The BCD process was developed by EPA's Risk Reduction Engineering Laboratory (RREL), which has patented the process. Under a license agreement with RREL, ETG Environmental, Inc. and Separation and Recovery Systems, Inc. (SRS) developed the SAR~ THERM- 0-DETO~ system to commercialize the BCD process . The SARE~ THERM-0-DETO~ system consists of four major processing steps: (1) preconditioning (screening and mixing) the contaminated soils/sludges with an additive which enhances the process; (2) heating the mixture in the Medium Temperature Thermal Desorber to begin breakdown of the toxic contaminants ; (3) separating them from the soil as a vapor, recovering all the vapors from the desorber in a vapor recovery system which collects and condenses them back into liquid form, and (4) condensate treatment which completes the chemical decomposition (or conversion) of the liquids into non- toxic compounds. [See Figure 1 of schematic and picture of system constructed on Site during the treatability study.] THE PROCESS The process begins by mixing sodium bicarbonate reagent into the soil that is to be processed. [A reagent is a substance used in a chemical reaction to detect, examine, measure, or produce other substances.} This mixture of soil and reagent then travels on a conveyor belt into the medium temperature thermal desorber, where it is heated for approximately one hour at 650 to BOO degrees ., . Fa\fenheit in an atmosphere of inert gas. [Inert gas in this process is a vapor substance that has no chemical activity and only acts as a carrier.) The desorbed organic compounds, including decomposition products, are carried out of the desorber in an inert gas stream to the vapor recovery system. In the vapor recovery system the gas stream enters a series of scrubbers that use nil and water sprayed directly into the vapor stream to capture or trap and condense the desorbed organic compounds, products of decomposition, water vapor, and any fine substances still in the gas stream (i.e., dust). A specially designed oil scrubber uses a high boiling point oil to capture and condense the organic compounds, water vapor, and fine substances. Water scrubbers and demisters {functions to remove moisture] are employed to further reduce the contaminants remaining in the gas stream before a final carbon adsorption step. The oil scrubber condensate is recycled through the system and is eventually transferred to the liquid tank reactor for final treatment. [Condensate is the water or liquid removed from the vapor during this step.) The cooling water is recycled through the system and reused. Upon demobilization, the cooling water is further treated through granular activated carbon canisters and the water is then discharged to an on-site wastewater . treatment plant or publicly owned treatment works. [Granular activated carbon filters out any remaining contaminants. It functions much like the charcoal filters in an aquarium.) In the liquid tank reactor, the oily condensate is mixed with a high-boiling-point hydrocarbon, sodium hydroxide, and a proprietary catalyst [an ingredient that enhances and increases the rate of chemical reaction) for the final step of the process. The liquid tank reactor is an indirectly heated tank processor, with a paddle-type mixer, that is designed for high efficiency electric heat transfer. The liquid tank reactor is designed to operate at approximately 650°F for 4 to 6 hours; however, this temperature and residence time will vary based on contaminant and matrix characteristics. RESIDUALS FROM TREATMENT PROCESS The advantage of this technology is that it offers long- term protection of the environment by eliminating soil contamination. This treatment process generates five primary waste streams: treated soils, wastewater, scrubber oil, medium temperature thermal desorber off-gas, and spent granular activated carbon. Treated soils can be deposited on Site after thermal processing and verification of effective treatment. Reactor off-gas from the desorber is treated in the vapor recovery system prior to discharging to the atmosphere. Emission control requirements for the thermal desorbers must comply with federal, state and local regulations. Scrubber oil from the vapor recovery system is treated in the liquid tank reactor to complete the dechlorination of contaminants removed from the soil. The treated scrubber oil will require shipment off-site to a facility permitted to receive waste oil for recycling. Wastewater from the various stages of the treatment process will be treated to remove contaminants prior to discharge. Other solid wastes generated during the treatment process include disposable equipment that comes in contact with contaminated media, i.e., thick plastic or rubber liner of the containment pad, personal protection-equipment, hoses, and other materials. SITE REQUIREMENTS · The SAR~ THERM0-0-DETO~ system consists of a medium temperature thermal desorption unit with vapor recovery system, liquid tank reactor, water storage tanks, a heat exchanger, and a water chilling unit. The entire treatment system is transported on three flatbed trailers. The system can be operational within two or three days if all necessary facilities, equipment, utilities, and supplies are available. After the treatment is completed, the system can be demobilized and moved off-site within three to four days. Access roads are needed for equipment transport and a level area is needed to accommodate the treatment unit. Also, a containment pad with curb sidings or an impermeable liner to control contaminant migration from the treatment area . ..... ,. Site preparatton requirements for contaminated soil excavation include construction of siltation fencing, and dust control. Screening and blending of soils can be performed in a roll-off container. Soil particles larger j .. ,; ' ., \ MORE INFORMATION Copies of all documents developed during the Superfund process to-date are available for public review in the local area repository: Wake County Public Library, Cary Branch 31 0 South Academy Street Cary, North Carolina 27511 Phone: (919) 460-3350 ---------------------------------- To receive technical information or copies of some of the available literature, please contact: Beverly Hudson, Remedial Project Manager Diane Barrett, Community Relations Specialist North Superfund Remedial Branch U.S. E.P .A., Region 4 345 Courtland Street, N.E. Atlanta, Georgia 30365 Phone: 1-800-435-9233 --------------····· ---------------- To be added to the Kopper's mailing list, please complete the following information and return to Diane Barrett. ADDRESS CITY, STATE, ZIP CODE PHONE (Opticoal) ---------------------------------------------------------------------·---------------------- SUPERFUND FACT SHEET UPDATE KOPPERS, INC. Morrisville, Wake County, North Carolina INTRODUCTION The U.S. Environmental Protection Agency (EPA) in accordance with the Record of Decision signed on December 23, 1992, for the Koppers Site in Morrisville conducted a treatability study utilizing the Base Catalyzed Decomposition (BCD) dechlorination technology from August 23 · September 10, 1993. The EPA's Superfund Innovative Technology Evaluation (SITE) Program located in Cincinnati, Ohio was responsible for conducting the study of the BCD technology developed by EPA using the SAREX-THERMO-O-DETOX111 system developed by ETG Environmental, Inc. and Separation and Recovery Systems, Inc. (SAS). The purpose of the treatability study is to determine ~ the BCD technology will effectively remove pentachlorophenol (PCP) and dioxins from the soil. The Record of Decision had selected ott-si1e incineration as the preferred remedy for treating these contaminants because incineration is a proven method which destroys pentachlorophenol and dioxin. However, the citizens that live around the Site strongly preferred that the Agency try dechlorination Instead of hauling the contaminated soil off to some else's backyard to be incinerated. . Based upon public preference, the Agency conducted a treatability study of the BCD innovative technology. If the technology proves to be effective in destroying the contaminants of concern, the BCD treatment method will be used at the Koppers Site. CJ ,_,, ..... N•K• l"I', It<._,...._.,....,..... __ ,.._ •tt •,-,.ctU1111 ,ic --••1on ....... • ~u ... ~..,... ....... :. ... •····· ·""' .... September 1993 BRIEF SITE HISTORY The Site was used as a wood processing facility from 1959 until 1986. Pentachlorophenol was used in the CELLON wood treating process between 1968 until 1975. Pentachlorophenol was used in this process. In 1980 the State of North Carolina conducted an inspection of the Site where high levels of pentachloropoonol were found in the soils of the lagoon and CELLON treatment areas. Koppers, Inc. installed monitoring wells in 1980 around the plant area to test the grounctNater. They also conducted two removal actions in 1980 and 1986 to remove soil from the former lagoon areas. The Site was proposed for the National Priorities List in June of 1988 and was finalized In March of 1989. A Remedial Investigation was then conducted which identified pentachlorophenol; polychlorinated dibenzo-p-<Jioxins; poly- chlorinated dibenzo furans; and isopropyl ether as the major contaminants of concern. The Feasibility Study studied methods for effectively treating these various contaminants. Based upon Information provided by the Study, It was detennlned that incineration was the only proven method of the day that was capable of destroying ~se contaminants .. The .dechlorination process was also considered but because It was not a proven method of treatment and there was no available field data to indicate the method was efficient, it was not selected as the . preferred remedy. [Site map, Figure 1.) -0-:=- ""'-lnrtl ~ . -- C) -~\-// '·-· .,.... .--· ~ 0 // 00 .. // . .,,m - ... BASE-CATAL VZED DECOMPOSITION (BCD) On August 31, 1993, EPA's SITE program held a demonstration of the BCD technology for the public providing those attending with a personal observation of the process, what It looked like and the opportunity to ask questions. The day started off with a meeting held in the auditorium at the EPA laboratory facility in Research Triangle Park (ATP}. Approximately 100 people attended the morning meeting. After the morning session participants were transported via bus from ATP to the Koppers Site to view the operation in process. For those of you that were unable to attend the event the picture above shows what the operation looked like. The process in a nutshell is as follows: · (1) excavated soil mixed with a reagent is placed into the bin where it is screened to remove large particles;· -:. .. : . ·,,.. .. -. - (2) the soil travels up the conveyor belt and goes into the feed hopper;· ---. .,. · . · ·· · ··-·· - (3) the soil then moves through a medium-heat thermal desorption unit which causes the volatile organics to· separate from the heated soil and which also causes decomposition of some of the chlorinated contaminants; · (4) treated soil next moves through a conveyor system where the soil is cooled; (5) next the cooled soil is sprayed with cold water for dust control and is placed in 55-gallon drums. The clean treated son can then be either placed back on the Site or used for other purposes. (6) the volatile organics that separate from the soil in step 3 travel into a vapor recovery system where they are captured in a hot oil scrubbing system; · · · (7) the oily mixture is then treated in the BCD tank; The treatment process is a totally closed system and operates on electricity. · · The EPA expects to have the results from the treatability study in approximately 6-9 months. at which time we will prepare another fact sheet informing the public ·of the results of the study and whether or not the BCD technology will be used as the treatment remedy at this Site. -· · .:-· · · ·· · · In the meantime, should you need more information about Site activities, you can either visit the local . information repository to review all of the documents developed to date located at: Wake County Public Library, Cary Branch 31 0 South Academy Street Cary, North Carolina 27511 Phone: (919) 460-3350 Hours: Monday -Thursday: 9:00 am -9:00 pm Friday -Saturday: 9 :00 am -6:00 pm Sunday: 1:00 pm -5:00 pm EPA Region 4 Record Center 345 Courtland Street, Ground Floor Atlanta, Georgia 30365 Phone: (404) 347-0506 Hours: Monday -Friday: or, either write or telephone: 8:00 am -5:00 pm Beverly Hudson, Remedial Project Manager or Diane Barrett, NC Community Relations Coordinator North Superfund Remedial Branch Waste Management Division US EPA, Region 4 345 Courtland Street, NE Atlanta, Georgia 30365 Phone: 1-800-435-9233 ~------------------------------------------------------------------------------------------~ If you would like to be added to the Koppers, Inc. Site malling 11st, please complete the following, and mall to Diane Barrett at the above address. Thank you. NAM __________________________ _ ADORE$ _________________________ _ -~ .. •,.·. ·----------------.....,...-------------- PHONE NO. ___________________________ _ . . . . . AFFILIATION (If a"""il· '+-.-----------,..------------- L--------. ------------------------------------------------------------ I . I ' I . . I . I I .. ~~ WARREN COUNTY HEALTH DEPARTMENT 544 WEST RIDGEWAY STREET WARRENTON , NORTH CAROLINA 27589 November 10, 1994 TELEPHONE: 257-1185 FAX II: (919) 257-2897 Ms. Roberta Riley Rt. 4, Box 458 Warrenton, NC 27589 Dear Ms. Riley, The Warren County Health Department does not have the funds to provide the immediate testing tor dioxin in your weli water as you requested in your letter of November 7, 1994, since I have heard no evidence which would suggest that there is a likelihood of dioxin in your well coming from the PCB Landfill. Ms. Pauline Ewald, a professional consultant trusted by the most avid opponents of the PCB Landfill, stated in your hearing that she did not believe there is any present danger to citizens around the area from the PCB landfill. The publicity regarding the dioxin found in the PCB monitoring wells has created sufficient concern among our citizens that I am researching the topic to find the most up-to-date information to share with our citizens in the near future. In conjunction with this we will be considering the appropriateness of requesting the testing of area wells for dioxin, either as part of the long-term plan to be developed through the PCB Landfill Working Group or independently as a public health intervention. In addition to the aforementioned testimony of Ms. Ewald the following items lead me to conclude that there is no evidence of discernible health risk to anyone near the PCB Landfill from dioxin from the Landfill: 1. The most likely explanation for the levels of dioxin detected in the PCB Landfill monitoring wells is background contamination of the equipment used for sampling. 2. If indeed there is a detectable amount of dioxin in the monitoring well water it is most likely not from the PCB Landfill for the following reasons: A. Essentially the same levels of dioxin were found in both the up and down gradient wells which would not conform to expected patterns of groundwater contamination migration. B. Since the Landfill contains much higher concentrations of PCBs than dioxins and since PCBs and dioxins have similar migration patterns the presence of dioxins and absence of PCBs would indicate that the dioxins came from a source other than the PCB Landfill. Riley November 10, 1994 Page 2 c. Available evidence including the retention of vast amounts of water in the Landfill and the absence of water in the secondary leachate collection system beneath the Landfill liner points to no leakage from the Landfill. D. Dioxins are present in our environment from numerous sources and the amount detected in the monitoring wells was so small that it is perfectly raasonable to theorize that sources other than the Landfill were responsible for the dioxin found in the monitoring well. 3. Dioxins do not have characteristics which promote migration in the groundwater. Even if there was evidence that the Landfill was leaking (which there is not) it would be highly unlikely that, given the extremely low level in the wells right next to the Landfill, dioxin would have migrated as far as two miles away. We will continue to review matters related to dioxin or any other potential health threat of concern to our citizens. If evidence is forthcoming which points to a significant risk to our citizens we will take necessary action. I am forwarding your request and a copy of my response to Mr. Bill Meyers, Director of the North Carolina Division of Solid Waste Management, and to Dr. Ronald Levine, State Health Director, for their review. I regret that I cannot meet your current request. I will be happy to review any additional information you have which may change my view on this matter. .~tJ /~ sirrr71y, ~~ ~nnis W. Retzl f, ~ctor CC: Warren County Board of Commissioners Warren County Board of Health Mr. Bill Meyers Dr. Ron Levine WARRE~ CO H~ALTH ~t-if Fax Note 7672 DRAFT 9192572897 11-10-94 04=10PM [26) ~1 ,;:. ,:P,,1,1;c, !5 '.,'U'.c,;Da!ii) I c/w ~:~•) '\,.~:'C(r frc:n 7 )cJ)/li5 kt. fz_.}() Fl "~"'~~'· 1 lc.,a.nu ) Cc... ; k:ri-//h D ( .. }r- ~v=.:::r: Df.r.,l.\)Y.:lc~1:, C?~i::~ :::!'::,::~~r::::: PLEASE CALL ME IF YOU HAVE SERIOUS CONCERNS. THANKS Ms. Roberta Riley Rt. 4, Box 458 Warrenton, NC 27589 Dear Ms. Riley, The Warren County Health Department does not have the funds to provide the immediate testing for dioxin in your well water as you requested in your letter of November 7, 1994, since I have heard no evidence which would suggest that there is a likelihood of dioxin in your well coming from the PCB Landfill. Ms. Pauline Ewald, a professional consultant trusted by the most avid opponents of the PCB Landfill, stated in your hearing that she did not believe there is any present danger to citizens around the area from the PCB landfill. The publicity regarding the dioxin found in the PCB monitoring wells has created sufficient concern among our citizens that I am researching the topic to find the most up-to-date information to share with our citizens in the near future. In conjunction with this we will be considering the appropriateness of requesting the testing of area wells for dioxin, either as part of the long-term plan to be developed through the PCB Landfill Working Group or independently as a public health intervention . In addition to the aforementioned testimony of Ms. Ewald the following items lead me to conclude that there is no evidence of discernible health risk to anyone near the PCB Landfill from dioxin from the Landfill: 1. The most likely explanation for the levels of dioxin detected in the PCB Landfill monitoring wells is background contamination of the equipment used for sampling. .. tor sampling. ' 2. If indeed there is a detectable amount of dioxin in the monitoring well water it is most likely not from the PCB Landfill for the following reasons: A. Essentially the same levels of dioxin were found in both the up and down gradient wells which would not conform to expected patterns of groundwater contamination migration. B. Since the Landfill contains much higher concentrations of PCBs than dioxins and since PCBs and dioxins have similar migration patterns the presence of dioxins and absence of PCBs would indicate that the dioxins came from a WARREN CO HEALTH ' 9192572897 11-10-94 04:llPM [26] ij2 source other than the PCB Landfill. c. Available evidence including the retention of vast amounts of water in the Landfill and the absence of water in the secondary leachate collection system beneath the Landfill liner points to no leakage from the Landfill. D. Dioxins are present in our environment from numerous sources and the amount detected in the monitoring wells was so small that it is perfectly reasonable to theorize that sources other than the Landfill were responsible for the dioxin found in the monitoring well. 3. Dioxins do not have characteristics which promote migration in the groundwater. Even if there was evidence that the Landfill was leaking (which there is not) it would be highly unlikely that, given the extremely low level in the wells right next to the Landfill, dioxin would have migrated as far as two miles away. We will continue to review matters related to dioxin or any other potential health threat of concern to our citizens. If evidence is forthcoming which points to a sifnificant I am forwarding your request and a copy of my response to Mr. Bill Meyers, Director of the North Carolina Division of Solid Waste Management, and to Dr. Ronald Levine, State Health Director, for their review. cc: Warren County Board cf Commissioners Warren County Board of Health Mr. Bill Meyers Dr. Ron Levine cone WARRE~ CO ~_f-ALTH 9192572897 11-10-94 04=12PM [26) t::3 Novembe~· 7. 1994 Mr. Dennis Retzlaff Warren Co. Health Director 544 Ridgeway St. Warrenton, NC 27589 Dear Mr. Retzlaff: I am writing co your agency as a concerned citizen of Warren County regarding the recent te.sting · completed at the PCB landfill. I understand that dioxins were identified bocb inside the landfill and in two of the monitoring wells on site . As a resident living only tw'o miles from the landfi 11, I .am reqiies ting that my water be t:esce<l for dioxin imm e diately. ·:· ._ ··: ~: · ... · .. In addition I know chat l will noc be satisfied with the test results if they are solely conducted by the Stace of Ncirth Carolina . I fe~l that the state has a vcsteu interest in finding '1no trace11 of dioxin in my \,,,later and so request thar eith1..~r a split-sampling pro- cedure be utilized with an independent organization or th,:'.lt the test be performed solelv hv an irnfopendPnt organizarinn. I understand that this test is quite costly and I do not believ£ that I should have to pay for it. The state has previously committed to test private wells around the landfill within a three mile rudius, and I am well within that boundary. I am requesting a written response to this letter no later than Thurs- dc1y, Ifovember 10, 1994 . Sincerc~ly , Roberta Riley Rt. L+ Box Li58 Warrenton > NC 27589 cc: NC Div Solid Wuste Mngmt . State of North Carolina \ f Department of Environment, i ; Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director November 8, 1994 Mr. Kurt Fehn Superfund Branch US Environmental Protection Agency 345 Courtland Street NE Atlanta, GA 30365 Dear Kurt: ~!·;2\ ... li.ii:wJ tws a a n DEHNR During a meeting of the Joint Warren County and State PCB Working Group last week, Pauline Ewald, the Working Group's Science Advisor, submitted the enclosed report along with an oral presentation. You will recall that I had promised to provide you with copies of all technical summaries resulting from the sampling event in July. This is the first. During the presentation Ms. Ewald also reported that she will prepare a technical comparison of the state's data and ECO's split sample results for the state. I will provide you with a copy of that report as well, when we receive it. Copies of all laboratory data prepared by state laboratories or contract labs were delivered to Ms. Ewald in August upon our receipt (One additional sample result was sent in September), thus we would not expect substantial delay in receiving this report. In addition to the ECO report, I have enclosed a copy of the Sampling Plan as it was approved by the Working Group. ~ . cc. Pauline Ewald Enclosures Very truly yours, Sharron E. Rogers Assistant Director • P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper ' t I. State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary WIiiiam L. Meyer, Director MEMO JULY 12, 1994 TO: Members of Joint Warren County end State PCB Working Group FROM: ~r I Sharron Rogers SUBJECT: Transmittal of Draft Sampling Plan A draft of the Sampling Plan for the Warren County PCB landfill is enclosed for your review. Please find en opportunity to review the document prior to the next meeting of the Working Group, which we understand is scheduled to meet at 4pm on Tuesday, July 19 et the Episcopal Church in Warrenton. Please contact us in advance of the meeting if you would like additional information or if we can assist in any way. Additional Distribution: L. Rimer H. Lancaster P.O. Box 27687. Raleigh. North Carolina 27611-7687 Telephone 919~733--4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50'1, recycled/ 1°"' post-consumer paper FIELD SAMPLING PLAN FOR WARREN COUNTY PCB LANDFILL Draft Draft July 12, 1994 Prepared for Draft Joint Warren County and State PCB Working Group by North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management FIELD SAMPLING PLAN FOR WARREN COUNTY PCB LANDFILL FIELD SAMPLING OVERVIEW TEAM ORGANIZATION OVERSIGHT SITE SAFETY PUBLIC AND MEDIA OBSERVATION METHODS AND PROTOCOLS LANDFILL CONTENT SAMPLES • PURPOSE" FIELD SAMPLING METHODS FIELD SAMPLING LOCATION SAMPLING PERSONNEL REQUIREMENTS FIELD EQUIPMENT REQUIRED PERSONAL PROTECTIVE EQUIPMENT CHEMICAL TEST METHODS QUALITY ASSURANCE PLAN LANDFILL LEACHATE SAMPLES GROUNDWATER SAMPLES SURFACE WATER SAMPLES SURFACE SOIL SAMPLES CARBON & SAND FILTER SAMPLES SEDIMENTATION BASIN SUBSTRATE SAMPLES SITE SAFETY PLAN . Outline details of this section are repeated in each following section. FIELD SAMPLING OVERVIEW TEAM ORGANIZATION All field efforts by staff of the Division of Solid Waste Management or its contractors will be lead by the Site Manager of the field effort. A Site Safety Officer will be appointed by the Director of the Division and will be independent of the direction of the site manager. The field team, reporting to the site manager, will consist of adequate numbers of staff to safely complete all required field sampling, labeling, and reporting tasks in an efficient manner. Individual members of the field team will coordinate with the disciplinary task leader developing the methodologies and protocols for the field sampling and analysis effort. These disciplines include: Environmental chemistry Environmental engineering Hydrogeology Environmental toxicology Environmental statistics Analytical chemistry OVERSIGHT The Science Advisor to the Joint Warren County and State PCB Landfill Working Group or her staff will be allowed to directly oversee all field activities of the Division of Solid Waste Management or its contractors at the field sampling effort upon the following qualifications: All such oversight individuals must be currently trained by 4O-hour OSHA hazardous waste worker standards and must attend a site safety briefing held by the Site Safety Officer prior to field activities. SITE SAFETY A site safety plan has been prepared for this sampling and analysis event. All individuals present during this effort as team members, oversight personnel, or observers will be required to adhere to the requirements of this plan. The Site Safety Officer will be the authority for the site safety plan's implementation. This authority is separate from the authority of the team manager, who has the overall field sampling plan responsibility. 2. Sample analysis reguest -this form accompanies samples from the field to the laboratory. It lists individual samples uniquely by listing the unique sample identification number from the sample label and directs the analytical laboratory to perform the appropriate analysis on each sample. 3. Recejpt of samples form -this form is used when the original sampling team releases split, duplicate, or original samples to another person or group. This form will be used in this field sampling exercise when split or duplicate samples are relenquished to the science advisor. 4. Examples of two field sampling labels have been attached to a page for demonstration. These labels have distinct computer generated identification numbers which aids in quality control and field eff eciency. Separate label systems exist for samples to be analyzed for organic constituents and those to be analyzed for inorganic constituents. To the extent practical all methods and protocols used during the · Warren County PCB Landfill environmental characterization will be published protocols or standards, or modifications of such necessary for the specific conditions of this effort. In general, all planned field sampling activities and subsequent chemical analyses follow or are derived from: U. S. Environmental Protection Agency, 1991, Environmental Compliance Branch Standard Operating Procedures and Quality Assurance Manual. N.C. Department of Environment, Health, and Natural Resources, Division of Solid Waste Management, 1993, Sample Collection Guidance Document. Occupational Safety and Health Administration Directorate of Technical Support. 1 990. Instruction CPL 2-2.20B CH-1, Chapter 1 Personal Sampling for Air Contaminants. U. S. Environmental Protection Agency Office of Solid Waste. 1994. SW- 846. Test Methods for Evaluating Solid Waste Physical Chemical Methods. Sampling and analysis methods not modelled after the above published methods are considered survey or research methods and will be used in addition to, not in replacement of, published methods, where applicable. All sampling and analysis of samples will be conducted under standard chain-of-custody methods of the Division of Solid Waste Management, which comply with all federal environmental regulatory requirements. Page_of_ SOUD WASTE MANAGEMENT DMSION Receipt for Samples Name of Firm Firm Address Firm Owner, Operator, or Agent Title SAMPLE '2LI,it~EI2 SAMpu: TYPE NUMBER DATEITIME WATER:soILIOTHER ./ Receipt for the sample(s) described above is hereby acknowledged: Signature of Inspector Title ~~PLIC!IE Sf.HPLE Sf.H:eLt ~Q!;;!IlQH OFRD 1ACPTIRJCTD ONSITEIOFFSITE Receipt/rejection of duplicate or split samples is hereby acknowledged: Signature of Finn Owner, Operator, or Agent Title Comments: _______________________________ _ 5 (A:\COCR.FRM) Purpose: Preparation: Enforccmmt and compliance with the N.C. Solid and Hazardou, Wutc Managem=t Rules. A aample analyses requat form must be completed for each type of evaluation requeatcd (inorsanic or orsanic). Each sample container should be labeled. Sample containen for orsanic analysis abould be identified with organ: labels and containers for inoraanic analysis with inor,anic labels. To assist in trackina the umples, a unique samph. ·• identification number (pre-printed on the label) abould be uaiped to the umplea from ea.ch sampling point. All oraanic sample containm from the ume aample point may be ide.ntified with the ame unique sample ID number, and likewiae for inoraanic aample containers. Blank label• can be provided for additional containers. Do not submit an analysia requeat form without any parameters indicated. Equivalent mcasuremmts: ppm• l'Slml • mgll •"'''•milk& ppb c "'fl c l'J/1000& • l'Jlk& DEFINITIONS/INSTRUCTIONS Site Number• A unique twelve-diJit lite/location identifier (i.e., the EPA identification number). Name or Site• Name of facility, landfill, etc. Site Location • City and county. Sample ID Number/Name • a unique ample identification number which i, preprinted on the sample label and the umple -name which may be an identifier for the sampling point (1Ucb as MW-1 or SS-2). Collected By • Name and staff identification number of collector. Date and Time Collected • Self-explanatory. EnTironmental • Naturally occurring materials such u sround water, surface water, or 10il1 which may be contaminate Concentrate Comments • Waste material, including but not limited to, sludges, resins, treatment effluents, or dnunmed wastes. • Include sample or sample point data (e.J. umple location, well number, phase separation, and/or odor). lnoriank Chemistry • Check (I) the desired parameters for analysis. Jf not listed, eater parameter in the space provided. Orianic Chemistry • Check (I) the desired analytical acan (P&T:GC/MS IC&DS for volatile organic compounds, and Acid:B/N Ext. IC&D.J for semi-volatile organic compounds). If not listed, mter the compound in the apace provided. TCLP Compounds • Check (I) the desired parameters to be analyzed. TCLP can only be performed on 10Jid or semi- 10lid samples. For totals of the inorsanic pan.meters, check (I) the correapondina parameter under lnoriank Chemistry. For totals of the organic parameten, check (I) the corresponding parameter acan under Orianic Cbemlstry. Distribution: 1. Send or deliver the original to the Laboratory Services Division. 2. The Lab then sends a copy (with results) to the Solid Waste Manaaement Division. 3. The Solid Waste Management Division aends a copy to the field person or collector. Disposition: 'Ibis form may be destroyed in accordance with the Environmental He&Jth, Solid and Huardous Waste Section of the Records Dis;positjop Schedule as publilbed by the North C&rolina Division of Archivea and His~ry. Additional forms may be ordered from: Solid Waste Management Division Haz.ardous Waste Section P.O. Box 27687 Raleiib, N.C. 27611•7687 '1 LANDFILL CONTENT SAMPLES PURPOSE • Collect samples of contents of Warren County PCB Landfill to determine chemical content of all PCB isomers, dioxin and di-benzo furan isomers, general organic chemical scans for volatile and semi-volatile organic contaminants, toxic metals, and the Toxicity Characteristic Leaching Procedure (TCLP). • Collect samples of landfill contents for analysis of physical soil characteristics and nutrient availability • Determine water level within landfill • Collect and analyze sample of gases within the landfill • Construct a temporary water level sampling system through the air vent • Establish gas sampling port, to support any future sampling, during reconstruction of air vent. FIELD SAMPLING METHOD Following collection of a preliminary air (gas) sample from within the landfill, the Schedule 40 4 • PVC air-vent pipe will be cut off just above ground level. The gas sample will be acquired using a Gilliam personal air sampling pump, collected a known volume of gases from within the landfill through a specialized air sample filter containing charcoal as a collection media. Landfill content (soil) samples will be acquired by all terrain vehicle (A TV) mounted with a 1" hydraulic Geoprobe sampling device ("Scorpion") and/or hand auger. Three or more continuous soil column samples will be acquired first. These samples will be sleeved in PET plastic tubes. Subsamples from these columns will be directed for chemical analysis. Additional bulk landfill content samples will be squired by Geoprobe or hand auger and will be directed for the bulk physical analyses. ·. FIELD SAMPLING LOCATION($) (ATTACH SKETCH IF APPROPRIATE) All samples will be taken at or within the central air vent for the landfill. A schematic drawing of this unit is included with this description. SAMPLING PERSONNEL REQUIREMENTS Air sampling and site preparation will occur one day before the major field sampling exercise. A minimum of two, 40-hour OSHA-trained field staff will be required. On the main sampling day, in addition to the two operators of the Scorpion-Geoprobe unit, two 40-hour OSHA-trained field staff will be required for sample preparation, recordkeeping, and general field support activities. All samples will be labelled using a number controlled unique sample label. Chain-of-custudy procedures of the Division of Solid Waste Management will be used on all samples, continuing throughout the sample transport and chemical analysis steps by all laboratories. An example of DSWM labels, Chain-of-custody Record, Receipt of Sample, and Sample Analysis Request Form are included in the overview section of this field sampling plan.1 Field collected samples of the contents of the landfill targeted for PCB analysis will be duplicated for analysis by the EPA Lab in Athens, GA and GE Corp Environmental Laboratory in Schnectady, NY. In addition, duplicate/split sample{s) of up to 25% of landfill content samples will be prepared for a CLP laboratory selected by the Working Group's scientific advisor; Sample{s) for dioxin analysis will be prepared. One or more field or .,trip blanks" will be prepared for analysis by the State Health Services Lab. 1 This condition will apply to all elements of this plan, and will not be repeated throughout the document. 11 July 5, 1994 MEMORANDUM TO: FROM: RE: Sharon RogersC'()f, David J. Lown ~ Approximate Thickness of Waste at the Gas Vent PCB Landfill, Warren County · The thickness of the PCB contaminated waste at the landfill may vary ~rom 22.5 to 25.5 feet thick. During the sampling of the waste through the gas vent, I recommend the following: 1) sample runs be reduced to a maximum of six inches per run at a depth of 24 feet below the top of the concrete slab at the gas vent; and 2) sampling be stopped when any of the components of the liner at the base of the landfill are identified. The components of the liner that should be identifiable include, in descending order, the fabric filter, nine inches of sand, compacted clay. The compacted clay is five feet thick and overlies one foot of fill and the 30 mil PVC liner. Figure l shows the details of the bottom liner. The estimated original thickness of the landfill is based on the drawings that you provided... Figure 2 is copied from the drawing labeled "Cross-sections." Table 1 shows the measured thicknesses of the landfill at the gas-vent slab. Changes in the thickness of the waste is based on survey data found in Randy McElveen's files on the landfill. The slab may have settled two to three feet. The data was collected by the Solid Waste and the Hazardous Waste Sections for the elevation of the monitoring wells and the concrete slab at the gas vent. This data is shown in Table 2. The concrete slab at the gas vent and the four monitoring wells were surveyed after completion of the landfill. This data is shown on the as-built drawing "Misc. Details." The concrete slab and the monitoring wells were resurveyed in 1991 and 1992. The accuracy of this data is questionable. On the as-built drawing, the monitoring well elevations are only given to the nearest foot and what was surveyed at the well (top of casing, top of concrete slab) is not indicated. The Hazardous Waste and Solid Waste Section survey data differ by as much as 0.22 feet. 13 C.LAY U .IDG!NG-l"ATE~IAL LtAC. MAT!s c.ouEc., T ION SUSGR.At)! LAND FILL C,ouNrY 1-______ 5.._""'d 'f I/ C. I°'! s' F.-il ,, So..."'d q't -'JO MIL PVC.. BoTToM LIN!.R S-..p...-ol;Je. 15 of" LAtJOFILL... e ve~+ 5 7, z_ '::)Ct,J..,Vt:..£ ~ As .-bwfr c::fra..wij '' {!,r¢$-sc~-fio11ts."' 5 e. c--t ; o ~ IO I " 3 N, 17 LANDFILL LEACHATE SAMPLES PURPOSE • Collect sample of leachate (liquid content of landfill) from Warren County PCB Landfill to determine chemical content of PCB isomers, dioxin and di- benzo furan isomers, general organic chemical scans for volatile and semi- volatile organic constituents, and toxic metals. FIELD SAMPLING METHOD The method used in collecting samples of leachate from the landfill will follow those used in previous leachate sampling efforts. Use of the sample sampling method will allow comparison of previously acquired data to the new information. Sufficient sample will be withdrawn from the leachate collection system sampling port and from the inlet the the filter system to conduct the required chemical analyses. In addition, a sample will be drawn from the outlet from the filter system. A variety of sample sizes and containers is required. Samples for organic chemical analysis may be filtered, and b.Q1h the liquid fraction and the filter media will be submitted for analysis. This would be necessary with samples with high particulate content to determine the actual location of any complex organic molecules, i.e., are they in the water itself or in the solids suspended in the water. FIELD SAMPLING LOCAJION(S) (ATTACH SKETCH IF APPROPRIATE) The leachate collection system engineered into the design of the landfill includes an access or sampling port located near the pump house on the north end of the fenced area. A diagram of the sampling port is enclosed. In addition, the leachate can be sampled from the inlet to the filter system (as noted in the drawing accompanying the sample plan for the sand and carbon filter section). SAMPLING PERSONNEL REQUIREMENTS Two teams of two hydrogeological sampling personnel will complete this task along with the sampling of the four monitoring wells during the main sampling day's efforts. FIELD EQUIPMENT REQUIRED Standard, portable field sampling equipment will be required. A variety of sample bottles will be available to be properly labeled for the required organic and inorganic analyses. Portable decontamination equipment will also be employed to prevent any cross-contact with the chemistry from one sample to another. .,. PLACE IN H.IGH.Poi~frOF. LANOFILf.'.' . ' .. · . . ; .,\ ... :fi~:~~~:~ .. EOULE: ~~~ 2..PROVIOE _IZ-1• DIA: HOLES IN. BOT.TOM ~ · fEET •. _. . .;y~ f/~:1:·t .~"-;.;r.:AHO :cA!rr;.1~ COHCI . . .. . . , . , · • "·. • ti·, · '"'"'NCRETE .AND p•1t • (2 PER ROW~ 12•· CENTERS .. 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REQUIRE ••-•'"·"·''i.·•~,..-.~ .. ,,. -,..;,• ...... :!•··-'···'i. •. • • • •. • • • • •••• , ,.. • • . • .• .,.... .., ••• 1 .: .• • -('!•-., ·i . • ! .••••• • •• ,.,. • • •• , •••• -• ,..,.,~.• :; • _ •• ,,.,,.." .... •'~-• .•• .,., ... .:~, .,~-?---'r:..:~ ... ·r..·m •• · ,.:...----:_, .. -.• ,..; :d' . .-~.,,, " . · ' · ' . . .• · ·.it RE~~IR.;~{~~:. uPP~~~~~~~~~-:_~~1:i:UEC.l lu!!iS°!S'.".1:-.M~;~n ~ ~: .. •~ Duplicate samples, that approximate split samples by alternately filling paired sample containers, can be prepared as required. True split samples cannot be prepared because of the risk of lowering measurable levels of any volatile organic chemicals during any required mixing. PERSONAL PROTECTIVE EQUIPMENT Level D protective equipment for sampling personnel will be required. This includes long-sleeved shirts, long-legged pants, safety shoes, impact protective eyeware, and disposable surgical gloves. CHEMICAL TEST METHOP(Sl Samples will be transferred to the appropriate laboratory under chain of custody. All samples to be analyzed for organic chemicals will be maintained at a temperature below 4°C to maintain any organic chemicals in the sample (required by standard protocol). PCB analysis by EPA Method 8290. Other types of chemicals to be analyzed and their corresponding tests include: volatile organics (Method 8240), semivolatile organics (Method 8270), pesticides and herbicides (Method 8081 and 8141 ), and toxic metals (various methods). QUALITY ASSURANCE PLAN/INCLUDE SPLIT SAMPLES AND ALTERNATE LABS) As selected by the science advisor, up to 20% of the individual samples collected from the groundwater monitoring wells will have duplicates prepared for the independent verification. A •trip blank" sample, containing organic-free water will be prepared to accompany the sample containers during the entire sampling process, transfer to the laboratory, and through final chemical analysis. This technique is a standard part of the quality assurance program for this sampling protocol and is a routine practice of the Division of Solid Waste field sampling staff. SURFACE WATER SAMPLES PURPOSE • Collect and analyze water and stream sediment samples to determine if PCB congeners are present. FIELD SAMPLING METHOD Standard field methods for collecting samples of flowing water and stream bottom sediments will be used. Care must be taken to minimize disturbance of the stream, e.g., downstream samples taken before upstream, water samples taken before stream bottom sediment samples, and all sample collection equipment and containers carefully decontaminated by organic-free methods before and after use. Subject to the amount of flow present in the stream at the time of sampling, surf ace water samples are obtained by standing downstream of the water to be sampled, turning the container sideways, partially submerging the container allowing water to fill the container with minimal agitation. Floating debris must be prevented from entering the sampling container. Stream substrate samples are collected by forcing a hollow tube into the sediment to a depth of up to 8 ", followed by capping the tube before removing it from the sediment, then transferring this collected material to the sample container that will be sent to the laboratory. This step is repeated until adequate quantity of sample is acquired. In the event of a rocky or impenitratable substrate, a glass sample container is used in place of the sample tube. In this case, substrate is collected by secondary container and transferred. Samples will be taken at four locations, two each on the two streams near the Landfill. To maximize the value of the data, samples will be taken at the permanently established locations for which considerable comparable data already exists. FIELD SAMPLING LOCATION(S) (ATTACH SKETCH IF APPROPRIATE) The four existing stream sampling locations are located on the detailed (large) Warren County PCB Landfill map that has been provided to the Working Group and on the enclosed topographic insert. SAMPLING PERSONNEL REQUIREMENTS Two individuals will be required to perform this sampling event. The two hydrogeological sampling personnel will conduct this effort. ~-t-= t:::--'///,;.Ii ,,. ' .. " u •o:.....a:4 1000 =-2:'° JOOO ==-: . JO !iOOO 1<JOO · 1000 rm .. ·· Q~ . · · ·\ ~ I ! 0 I llllOMtftlt \ E=C:::F-1 E3 -.++I EH ~ "" _!:".!'._ CONTOUR INTERVAL 10 F£ET tr-~% ,. ..... AFroll., /flt: 7 ! ,,,,.,, tPl/tAl'"" IS MEAN ••• l[V[L ,r---·u ,.,,,,-...J,,I i~ ~) • , N · . ,V U ..... .___.... ~~ ~!~ ' . . \4 ~ ·-. ~-~~(_\ -. -~ . ,~.,9~~ ~~ ,n ' ' ~~,4F~ ~ · ..,,. " h 'r , . n~ (-t~ ' . • I ~J. .;fi} ~'c,JJ ' '-::1/.V,I )'-=--I V " y rf!!, Cc -i> ~-~ ,~~ EPA DESICN\TED STRFJ\M SAMPLING IOCATIOOS ~J ~(_ , 'ffc .'-J~....-...., . . •. -.. -. . KEY: RC -Richneck Cn!ek f( ~ a / I~ ur -Unnanm Tributary ~ • . ,. ; 1\ DS -Downstream ~ -~ ~ ,_,,. . tlS -Upstrean . ( . I • Ir ~rl\,.111:-tn· m~p_l.';; ·, . .", ...... , {{~ !I\A~II. ',A· ' ~ ·•-~.::5; : . :,._;;, / '~ I . I::\ 11-1 I · (\ fl n)"-.....:. N36°20' 30. 3" ~ 00Q' S3. 9" ' !J ~ :~.: ~ 0 4 ~ ' ~ . ·---·--. -...... ·-. . . -~ --. -.... ----·· --·---.... . .. . . ---·-·-·-......... _ ·---------·-----......... 1 ,I' --.. ------------------------- -----------------------------------------------------------------·1 -., ,l~~1tt~,w~~~,11 FIELD EQUIPMENT REQUIRED Standard soil sampling equipment will be used including scoops, bowls. or buckets that can be decontaminated or are disposable. Field portable decontamination equipment will be required. PERSONAL PROJECTIVE EQUIPMENT Level D protective equipment for sampling personnel will be required. This includes long-sleeved shirts, long-legged pants, safety shoes, impact protective eyeware, and disposable surgical gloves. CHEMICAL TEST METHOD($) Soil samples collected in this sampling effort will be analyzed by EPA Method 8081 for PCB content. QUALITY ASSURANCE PLANIINCLUDE SPLIT SAMPLES AND ALTERNATE LABS) Soil samples from this effort will be available for true split sampling up to the 20% number established by the Working Group. I fol) ~ I.I.I ~ ~ u ~ = < .... Q z < Q z < fol) I SITE HEALTH AND SAFETY PLAN A. GENERAL INFORMATION Site Name Warren County PCB Landfill o &; M ID # NCD 980 602 l 63 Location lust off SR l 604 Warren County NC Proposed Date of Investigation luly J994 Date of Briefing lu!y ] 994 Date of Debriefing luly J 994 Health Department Official Contacted Date of Contact luly J 994 Site Investigation Team: All site personnel have read the Site Health and Safety Plan and are familiar with its provisions. Personnel Responsibilities · Si&nature Plan Preparation: Prepared By: Reviewed By: _____________ _ D. WORK PLAN INSTRUCTION Map or Sketch Attached? w Perimeter Identified? w Command Post Identified? .D.Q Zones of Contamination Identified? w Personal Protective Equipment/Level of Protection: ____ C __ X_D Modifications: The site can be toured and sampled in level P protection. Steel-toed work boots will be worn while sampling PE or PVC sloves will be worn while coHectins water or soil samples The HNU or OVA will be used to monitor breatbins zone air while soil augerins and samplinc of soils, Jyyek suits will be worn while avserinz It is recommended that no obseryers be allowed within JO meters of the saroplins sites Level P personnel protective egvipment including chemical protective boots will be cecuired of all obsecvecs Qbsecvecs are to be accompanied at all times by a person properly trained by 29 CFR 1910120 to 40-hr standards Surveillance Equipment: ____ HNU ____ OVA ____ Combustable Gas Meter Decontamination Procedures ____ Detector Tubes and Pumps 02 Meter ---- Radiation Monitor ---- ___ Level C Respirator wash, respirator removal, suit wash (if needed), suit removal, boot wash, boot removal and glove removal. _X __ Level D Boot wash and rinse and boot removal, suit removal, glove and goggle removal. Modifications --------------------------- C.hemical Emergency Information Centers ASHEVILLE 704-255-4490 CHARLOTTE 704-379-5827 DURHAM 1-800-672-1697 GREENSBORO 919-379-4105 Poison Control Center -State Coordinator Duke University Medical Center Telephone: 1-8~72-1697 P.O. Box 3024 Durham, NC 27710 Western NC Poison . Control Center Memorial Mission Hosp. 509 Biltmore Ave. 28801 Mercy Hospital 2001 Vail Ave, 28207 Duke Univ. Med. Center Box 3007, 27710 Moses Cone Hospital 1200 N. Elm St. 27420 HENDERSONVILLE 704-693-6522 Ext. 555,556 HICKORY 704-322-6649 JACKSONVILLE 919-577-2555 WILMINGTON 919-343-7046 Margaret R. Pardee Memorial Hospital Fleming St., 28739 Catawba Mem. Hosp. Fairgrove Chur. Rd 28601 Onslow Mem. Hospital Western Blvd. 28540 New Hanover Mem. Hospital 2131 S. 17th St. 28401 31 t • • •.I SPECIAL SAMPLING ANALYSES REPORT WARREN COUNTY NORTH CAROLINA PCB LANDFILL NOVEMBER'i994 A E C 0 ,. • ' I 1.0 -SUMMARY This report has been prepared for the information of the Joint Warren County and State PCB Landfill Working Group, and is not intended to represent final work product for the technical reporting of sample analyses. ECO intends to prepare a final, technical document containing data validation and QA/QC analysis as soon as necessary raw data is provided by the Division of Solid Waste to allow completion of this task. 2.0 -CASE NARRATIVE Pursuant to a request from the working group, ECO participated in a field sampling event at the PCB landfill located in Warren County on July 27 and 28, 1994. ECO staff were on-site during all field activities, and video taped and/or photographed random sample collections and recorded field notes regarding all split sample collections. In addition, ECO received sample splits from pre- selected sample locations. These splits were delivered directly to ECO staff, immediately cooled and packed as per protocol, and maintained under constant surveillance by ECO staff until relinquished to the overnight courier service for shipment to the laboratory. All samples were analyzed by independent, out of state facilities with State of North Carolina and EPA certification. ,• JOINT WARREN COUNTY AND STATE PCB LANDF1U WORKING GROUP SPECW., SA}JPLE ANALYSIS REPORT NOVEMBER 1994 Analytical results were reported directly to ECO. A duplicate data package, containing all reporting sheets, and raw and QA/QC data was sent to the North Carolina Division of Solid Waste directly from the laboratory. 3.0 -SAMPLING PARAMETERS As agreed to by the Working Group, all splits collected ( except as noted in Section 6.0 -Field Changes) were analyzed for a broad range of contaminants including Volatiles, Semi-Volatiles, Metals, BNAs, Pesticides, PCBs, PCDD and PCDFs (Dioxins and Furans), as well as for Toxicity Characteristic Leaching Procedure or TCLP which determines whether a sample may be classified as a regulatory haz.ardous waste. All analyses were performed using EPA approved methodologies and protocols in accordance with Standard Methods 17th Edition; the Solid Waste Manual SW-846 and /or 40 CFR part 136 as follows: ANALYTE Volatile Organics Pesticides BNAs PCBs PCDD/PCDFs METHOD 8240 8141 8270 8081 8280 ENVIRONMENTAL COMPLIANCE 0 RGANIZATION JOINT WARREN COUNTY AND STATE PCB LANDFIU WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 4.0 -ECO SAMPLING RESULTS FOR ROUTINE PARAMETERS ENVIRONMENTAL COMPLIANCE 0 RGANIZATION •. ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION IC -001-SS SOIL surface soil near air vent SAMPLE CONTAMINANTS DETECTED barium -81.4 ppm chromium -26. 7 ppm lead -26.4 ppm tetrachloroethene - l .89J ppm. ~,M@t%t%ii1MJiiM:f~-%i~■-:rn1t~rtf,:!~~r1,~~1:--~~;,IMl~fi\~1~~wr,~_-=g~1tlt{ft)f~f={t~tJtt!~t~w.?~if.~!~,%fl;ltpw~¥t.w.it%t~lftW~\ll@1¥W~tii\Z¾~1M%rWm ;-~·:--~i~'~--=-~t~;s *'f:~'?;'' -~.. .~·ci;·;;ea-~•)" .· ... . vlii' ~<a6 -.•.-~ $ ~Q· , ... A . @i . .. ._., . ..~ . .... .. ...,~-'~'k}iiHo·; ~ . . . ... .. . . . .. ... ~, ...... .. . :-.:•a*:s.M IC -002-SS SOIL surface soil from seep on slope barium -136 ppm chromium -24.4 ppm mercury -0.018 tetrachloroethene -4.08J ppm ~~~~itil:::~@j;;i~i~iti;~~tj~,i~itiilialr;~1~1t=it~~1t,1~t-•-~t~--~~~~1~■1~~--litfr~a~L~~if~~~~ll-i~~fA~ii]~£~ii IC-001-GW GROUNDWATER water from monitoring well #2 barium -0.034 ppm tetrachloroethene -0.005 ppm ( regulatory level= 0.70 ppm) TCLP at non-detect or well below regulatory limits ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION IC-002-GW GROUNDWATER water from monitoring well# 4 SAMPLE CONTAMINANTS DETECTED bariwn -0.045 ppm chromiwn -0.008 ppm tetrachloroethene -0.005 ppm ;::~::.::~:~~::;£:i~;.~,~'ii-~t~'.'fu\:·\~~~>w,~a~~:,lt;;zi:J.,,'tiltk~-d~~:~~~ha~I\dhtaiSt~-1--#1M:fil'.~iiillii IC-001-LC SOIL dry landfill contents acetone -76.3J ppb benzene -1. 98J ppb chlorobenzene - l 08 ppb 1,2 dichlorobenzene -10.6 ppb 1,3 dicblorobenzene -25.3 ppb 1,4 dichlorobenzene -63. l ppb :~!®.;l1l]ii:11:i:::r11ww11,l\1~illJS~:::~;1t*la1\11~~1■l1:~~111~1iil-r;~wwJ~,1i~1t~~it1t:tt1Jti1ui~w:::1,u11t1~1=~~~1;1l11:m~~t;lf!~~i1fili:~:EtlmJ~;w:1@r!Irl IC -002-LC SOIL duplicate dry landfill contents bariwn -28.8 ppm chromiwn-15.6 ppm lead -61.8 ppm acetone -82. 7 J ppm chlorobenzene -252 ppm 1,3 dichlorobenzene -23. 9 ppm 1,4 dichlorobenzene -420 ppm 1,4 dichlorobenzene -474 ppm ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION IC-003-LC SOIL IC-001-SED SEDIMENT wet landfill contents downstream sediment Richneck Creek SAMPLE CONTAMINANTS DETECTED barium -26. 7 ppm chromium-17.0 ppm lead -46.9 ppm chlorobenzene -132 ppm 1,3 -dichlorobenzene -12.3 ppm 1,4 dichlorobenzene -211 ppm 1,4 dichlorobenzene -388 ppm barium -12.3 ppm chromium -14.7 ppm TCLP at either non-detect or well below regulatory levels m;~icy~J:~jii£~l=~~~i§~£~~~iii:i iiiff~li;11~11iif.iir-~i;iiiiifiiiijiil,ii@liiili[i~iit-liil~~~1ti:~lit~#~1iitfa;i1f:lf~~ill*I¥i1i@ IC-003-SS SOIL sediment basin outlet ravme barium -122 ppm chromium -23. 7 ppm mercwy-0.041 ppm TCLP at either non-detect or well below regulatory levels ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION IC -001-LCH LEACHATE filter system inlet SAMPLE CONTAMINANTS DETECTED barium -0.224 ppm benzene -2.58J ppm xylenes -4.76J ppm tetrachloroethene -0.005 ppm ~11i~1~:~;1w@~11::ttM~J.{i;t1faMf''\~m~w~~~J&t~Fitt?-1~¥1@¾1-'w~i?~~~~J.tuwPi~wim'1Mw:J0~~tff.Jj~~t;§i:111•J■w1;~lirt1~1~■1~~~,i~lwl~~~-1~1m&i'.tl&t1 IC-003-GW WATER water sample from Limmer well only analyzed for PCBs JOINT WARREN COUNTY AND STATE PCB LANDF/ll WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 5.0-ECO SAMPLING RESULTS FOR PCBs-PCDD/PCDFs E NVIRONMENT AL COMPLIANCE 0 RGANIZATION ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION IC -001-SS SOIL surface soil near air vent SAMPLE CONTAMINANTS DETECTED AROCLOR 1260 -0.008 J ppm OCDD-2.9478 J ppb &¥1fi&ttw11m · · < • •· · · · · · · · · · ·•· · · · ·•·•• •• .•. -. .. .,, • •• ·• •••• -•.• -. ........ •• ·•·• ••••·,-. · •••• ,· • u,, •'• • • ·•· · ·• • •· •·••·•·••·•·•~-.·•~ ••• < ·•• • H ~·• ••• ,•.,••'•'-V ·• · ·••••" ,·,·,v,._,-.., ~-"-'•u• ,·, •• •• • · .. -.. IC -002-SS ~z;g&l¥%Ni%'if"ffii'M'W<it¾ffi IC-001-GW IC-002-GW SOIL surface soil from seep on slooe GROUNDWATER water from monitoring well #2 GROUNDWATER water from monitoring well# 4 AROCLOR 1260 -0.004 J ppm OCDD -0·51~i$!1il?J\lf:tl\-PCB/PESTICIDES -NON-DETECT PCB/PESTICIDES -NON-DETECT ■ti~ff:*:;pr~1%\@WMrnwtw?J~t&w~w1~l::~w,\~v¥Nit¾Mi~*1l1mwtf'%~'tn111M:l\~t611M0r%ttl~it,■l~~1~,,r~111■,1*■1i1Eu~\i~tJJ!~■l~l■tt1■ IC-001-LC SOIL dry landfill contents AROCLOR 1248-146 ppm AROCLOR 1260 -880E ppm " ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION SAMPLE CONTAMINANTS DETECTED IC -002-LC SOIL duplicate dry landfill contents AROCLOR 1248 -63 ppm AROCLOR 1260-303 ppm 2378 TCDF -0.5214 J ppb 12378 PeCDF-0.ll71 J ppb 23478 PeCDF -0.4418 J ppb 123478 HxCDF -4.7069 ppb 123678 HxCDF -0.5958 J ppb 234678 HxCDF -0.3657J ppb 1234678 HpCDF -3.0825 ppb 1234789 HpCDF -1.7253 J ppb OCDF -14.4435 ppb ECO SAMPLE NUMBER SAMPLE MEDIA SAMPLE LOCATION SAMPLE CONTAMINANTS DETECTED IC-003-LC SOIL IC-001-SED SEDIMENT wet landfill contents downstream sediment Richneck Creek AROCLOR 1248 -60 ppm AROCLOR 1260 -303 ppm 2378 TCDF -0.1133 J ppb 12378 PeCDF -0.0329 J ppb 23478 PeCDF -0. l 188J ppb 123478 HxCDF -1.1452 J ppb 123678 HxCDF -0.1712 234678 HxCDF-0.1010 J ppb 1234678 HpCDF -0.8958J ppb 1234789 HpCDF -0.5491 J ppb OCDD -0.3237 J ppb OCDF - 4.2072 J ppb PCB/PESTICIDES -NON-DETECT OCDD -0.2774 J ppb ECO SAMPLE NUMBER IC-003-SS SAMPLE MEDIA SAMPLE LOCA TJON SOIL sediment basin outlet ravme SAMPLE CONTAMINANTS DETECTED PCB/PESTICIDES -NON-DETECT OCDD -1.1889 J ppb •urnr@1wmrum@1@iM~i~l¥1:■11wfttllliiiiilB11\:1t1ww1wt1t\iMJiwW:r11m1;wtt\1!1i1mt@wrl@i~ul~iB$JwJ¥~tt¥0i~i@tl1W1tl IC -001-LCH LEACHATE filter system inlet PCB/PESTICIDES -NON-DETECT liW\%t:~i]#'W¥¥::@lfl{[q~@~~MKWl~i'.~~rtTuWtMi~W~~tli;~iii%lt.W1l~~m:1~1m=im*■i-l\t~l\B~m:■a111■■l-~lli1~:1t1,~ltfl~]ll~~~~t!fif&W1%fil IC-003-GW WATER water sample from Limmer well PCB/PESTICIDES -NON-DETECT . . JOJNF WARREN COUNTY AND STATE PCB LANDFIU WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 6.0 -FIELD CHANGES TO SAMPLING PLAN Several changes to originally planned sampling order were necessitated by field conditions. The following changes/additions to the scheduled sampling effort were made in the field: ECO SAMPLE SAMPLE LOCATION FIELD CHANGES NUMBER IC -001-LC dry landfill contents only enough dry material recovered for VOC and PCB analysis IC-002 -LC duplicate dry landfill . sample duplicate of wet landfill contents contents because not enough dry material recovered for analysis IC -003 -GW Limmer well added sample -PCB analysis only E NVIRONMENT AL COMPLIANCE 0 RGANIZATION JOINT WARREN COUNTY AND STATE PCB LANDFIU WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 7.0-DATA INTERPRETATION Analytical results reported by laboratories are subject to a set of notations known as data qualifiers. Data qualifiers consist of a numeric or letter notation immediately following a reported value, and give added information regarding the data reported that may influence how information should be used in decision making. In the data sets reported by ECO, the only data qualifier present is the notation J. The J data flag denotes an estimated value due to the result being outside the calibration limit for the analytical equipment. 8.0 -QUALITY ASSURANCE /QUALITY CONTROL As noted earlier, a complete technical report will be prepared discussing and documenting data validation and QA/QC concerns in detail. General quality parameters affecting validity of the data reported here, including holding time limits for sample extraction and analysis, and initial and continuing calibration of analytical equipment were met. Additionally, matrix spike and matrix duplicate recoveries were generally within EPA specified quality control limits. No target analytes were detected in method blanks and all laboratory control sample criteria were met. ENVIRONMENTAL COMPLIANCE 0 RGANIZATION JOINT WARREN COUNTY AND STATE PCB LANDFIU WORKING GROUP SPECIM SAMPLE ANALYSIS REPORT NOVEMBER 1994 9.0-SAMPLE RESULTS The general analysis of both soil and water revealed no significant contamination with volatile organics, BNAs or pesticides. With the exception of borderline significant lead contamination in samples IC -002-LC and IC-003-LC, there were no metals detected in soil or water at levels of regulatory concern. Likewise, no pesticides were detected via EPA method 8081 which revealed AROCLOR 1248 and 1260 (PCBs) in samples IC-001-SS, IC-002-SS, IC-001-LC, IC-002-LC, IC- 003-LC, with reported levels ranging from 0.008 ppm to 303 ppm. Numerous congeners of dioxins and furans were detected in all samples of landfill contents. The less toxic octa congeners of dioxins and furans were also detected in samples taken from the surface soils located outside the landfill and sediment sampled downstream from Richneck creek. 10.0-DISCUSSION OF DATA AND RECOMMENDATIONS The purpose of this field event was, in part, to perform comprehensive characterization of the landfill contents. Fewer metals and organic contaminants than expected were detected in this sampling event, but in accordance with expectations, numerous congeners of PCDD/PCDFs were found to be co-located with the PCBs originally demonstrated as the Constituents of Interest (COis). ENVIRONMENTAL COMPLIANCE 0 RGANIZATION .. JOINT WARREN COUNTY AND STATE PCB LANDFILL WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 The presence of dioxins and furans in, and around the landfill elevates the level of concern about this containment facility, due to the generally accepted belief that dioxins and furans are considerably more potentially toxic to human health and the environment than even the toxic PCBs. The recent EPA draft reassessment of dioxin toxicology confirms previous data indicating that even trace amounts of dioxins can be detrimental to human health and the environment, and are capable of producing numerous health difficulties and abnormalities in addition to being suspected carcinogens. Dioxins are of further concern because of their ability to persist in the environment and resist degradation for very long periods of time. This chemical property has implications for the long term storage and/or disposal of dioxin contaminated wastes, and requires the implementation of permanent containment and/or destruction technologies for successful outcome. The Superfund Amendment and Reauthorization Act (SARA), the most comprehensive site remediation regulation, creates a statutory preference for on-site, permanent destruction technologies for the treatment of dioxins and other wastes wherever possible. This scientific and statutory imperative for the on-site, complete destruction of dioxins and other wastes is crucial to preventing continual monitoring and liability of potential off- site contaminant migration at all sites, including the Warren County PCB landfill. ENVIRONMENTAL COMPLIANCE 0 RGANIZATION .. • > .. •• JOINT WARREN COUNTY AND STATE PCB LANDFJU WORKING GROUP SPECIAL SAMPLE ANALYSIS REPORT NOVEMBER 1994 Several technologies are suggested by the particular waste stream of the Warren County PCB facility, but only Base Catalyzed Decomposition (BCD), or some closed loop treatment train employing BCD, would meet the criteria of being EPA demonstrated as effective on similar waste streams on North Carolina sites, EPA and State approved and most importantly, acceptable to the community. Therefore, it our ECO's recommendation that the Joint Warren County and State PCB Landfill Working Group immediately begin the process of formally soliciting proposals for the complete remediation of the Warren County PCB landfill from all relevant vendors of BCD technologies and treatment processes. We further suggest that ECO staff, integral to use of BCD at Morrisville and Statesville North Carolina sites be utilized in the formulation of Requests For Proposal, bid specifications, remedial specifications and the interviewing and selection of an appropriate vendor, in order to ensure that all technical and regull'tory requirements are satisfied or exceeded. ENVIRONMENTAL COMPLIANCE 0 RGANIZATION Telecon: Joan Blake U.S. EPA 401 M Street SW MC 7404 Washington, DC 20460 Phone: 202-260-6236 with Sharron Rogers October 25, 1994 Ms. Blake heads the Permit riters Group for EPA Headquarters for TSCA. They are the sole issuer of T CA cleanup permits in US. Under CA, only two treatment technologies are approved for PCBs (meet EP performance standards) : Incineration and Landfilling. Her unit does ite Research and Development Permits for trials for innovative technol 1es. Such permits are strictly limited as to method, quantity of material ial), and time. These permited sites are closely monitored by the Pro ra~including comprehensive environmental sampling (analysis done by c tracto lab -SW Res Inst. Kansas City.) If in. novative technology is nruc I ss ul, and to date .all.have been unsuccessful (time is us ly the I' iting ctor , then material from site must be incinerate or Ian fil . I I Ms. Ba sen ing Me o ndum f gli hi hligH s their o onfir ation f the above along with a ith Federal Superfund program which ~ty ... I ~-------------------~ .. ,. <;/2Jt{lllft1 -PCB -!llf t'f/Jx.l'i,~ ~ v-l~I\-T (P"i___ C:()Wt\ ~ \*D TO ~o /J'iliiJ _ . ( 1) CCJ)y oJ lrf/l .i)tJ-rA-FJM111 c:1¥2lrCR_ 1Jt12.-. <Qu_+l,t1, :Srz--t{)1r,S -JD ~. ~\'MOe'tt )'T U,c-.L 1 Y. c;_ v-~"-D· -tS.S' U1-\N(-tfl-1 Oi 1)_ Tlri.-"Snt-l'i.. {ov De)t.X)~j J<u,~ ~ i),t-1.J."'/ Nl~ ~~£. ~U\tl~ VJffs~ t V\ lJ'. (l~tli¼ cc/<£ (?) Colp b c)d _~c:.~ I ~l\9oif Y¾i°ll<. <isTUll '( tJ v-.. \20-Pr.D ~l~v ~u_ ~g:, -S:-~ \_S:S'll~ ~ f\Sau~ -'D lS.1f\,l6U-t-u.J -~ l}~0Jc(l.fe11~ cic ,... OCT 12 '94 10:34AM WLFL FOX 22 To: The North Carolina News Network From: Deborah Ferrucciof}:f- Oirector: Ecumenical I Environmental Leadership Coalition (919) 257-2604 P.2/2 Subject: Independent Science Consultant to Present Interpretation of Test Data On Warren PCB Landttll Date: October 7, 1994 ~OI FOB NEWS AELEA§I Independent Science Consultant for the Joint Warren County I State PCB Landfill Working Group Pauline Ewald of Environmental Compliance Organization will present her interpretation of test data concerning the contents of tne PCB landfill and monitoring wells to committee members and citizens on October 12, 5:30 p.m., at the Warren County Courthouse. Ewald'a Interpretation of the data Is expected to lndic11te the presence of the most to>dc kind of PCBs (arochlor) and the most toxic kind of dioxin known to man: 2,3.718 tetra chloro dlbenzo dioxin (tetra dioxfn) i,n tht l1ndfltt. Tetra dioxin prompted the permanent evacuation of Time& Beach, Missouri, in 1983. Tetra dioxin was also responsible tor the cessation of the spraying of Agent Orange. owing to concern aboUt the birth defects it was apparently causing. A single ounce of tetra dioxin is said to be capable of killing hundreds of thousands of people. Although Ewatd'a Interpretation of the data le expected to confirm the presence of dioxins In the monftoring wens, there Is uncertainty here concerning the kind of dioxins !n the mol)ltoring wells and whether the landfill ;s seeping its contents into the groundwater. Citizens are hoping that Ewald will be able to answer such questions. On September 19th the state catted a special meeting of the Joint Warren County f State PCB Landfill Working Group in Warrenton and released infcirmation indicating the presence of Peas and dioxins in the landfill and the presence of dioxins in the monitoring wens. Ewald was unable to attend the meeting and present her interpretation of the data because of insufficient notice. Since then, concerned citizens have been anxiously awaiting EwGlion. \-~) ~---/ r,-,-.~ ~ 1-1(""-7 '( 2nd CITIZENS' CONFERENCE ON DIOXIN July 29-31, 1994 St. Louis University, St. Louis, Missouri RESOLUTION OF CONFERENCE It is our conviction that the general spread of dioxin and dioxin-like' compounds has already reached dangerously critical levels, thereby threatening the integrity of our own species and making the risk of inaction too high to accept. WHEREAS, dioxin and dioxin-like c~unds are the most .potent poisons currently known, are persistent in the environment and bioaccU11Ulate in living organisms; · WHEREAS, even the U.~. Environmental Proteotion Agency has concluded that: Dioxin causes cancer in hllll8ns; lrrm.me system and reproductive effects appear to occur at'or near body burdens approximately 100 times lower than those associated with cancer; Current exposure levels to dioxin appear to place people at or near a body burden where sensitive responses may occur, especially for nursing infants and recreational and subsistence anglers; WHEREAS, established international peer-approved scientific research demonstrates that dioxin and other dioxin-l i,ke c~unds can be expected to have transgenerational non-cancer 'effects in wildlife and hunans, including: Disruption of endocr\ne hormone systems, especially those related to sexual development; specifically by mimick'ing, interfering with, or amplifying the effects of estrogen especial ly during fetal development. . Disruption of critical stages of embryonic development, for example the nerv9us system; Damage to the developing irrm..,ne system, leading to increased susceptibility to infectious diseases. WHEREAS, the International Joint Corrmission, the monjtoring body of the Great Lakes Water Quality Agreement of 1978, identified dioxin and dioxin-like c~unds as persistent toxic substances and recorrmends zero discharge; THEREFORE, be it resolved that the 2nd Citizens' Conference on Dioxin demands: 1. An immediate halt to the incineration of municipal, hazardous, medical, military, and radioactive waste; and any such wastes incinerated in cement or aggregate kilns, or any other open- ended device. 2. An immediate commenceme~t of a ,phase-out of the industrial production and use of organic chlorinated compounds (including the plastic, PVC). Conference Sponsors : Gateway Green Alliance, PO Box 8094, St. Loui s, MO 63156. Tel: 314-727-8554. Waste Not , 82 Judson St . Canton, NY 13617. Tel: 315-379-9200 Fax : 315-379-0448. NC WARN, 5301 Rolling Hill Rd,· Sanford, NC 27330. Tel: 919-774-9566 Fax 919-774-7498. /lift/_ . ]y/tJ -Ir /'J(g// + , 3!J t7f' J //J //' State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director DEHNR September 14, 1994 To: MEMORANDUM Bill Meyer, Division Director~ Mike Kelly, Deputy Division Director Thru: From: Jack Butler, Remediation Branch Head, Superfund Sectio~ Priscilla Tyree, Remediation Brru,.c '_j Subject: Joint Warren County State PCB Landfill Working Group The purpose of this memorandum is to provide you with my understanding of my current duties and assignments in the Division. I have been participating in two activities outside of my work assignment with the Remediation Branch. These activities include serving on the Division's Environmental Justice Committee and acting as recorder for the Joint Warren County State PCB Landfill Working Group. I have prioritized these activities according to its importance and have provided an explanation for its priority. Activity Priority Explanation Superfund Section, Remediation Branch This is my official position. And as such, no outside activity may interfere with my duties and assignments to the Section. Environmental Justice Committee Appointed by Branch Head, Jack Butler, I represent the Remediation Branch on this committee. Joint Warren County State PCB Landfill I volunteered to serve as the recorder, Working Group provided that this position would not conflict with other duties and assignments. I can serve as recorder for the Joint Warren County State PCB Landfill Working Group provided that meeting dates do not conflict with Superfund Section, Remediation Branch or Division Environmental Justice Committee activities. Pat Williamson and I have discussed creating a schedule that will provide a recorder at Joint Warren Count State PCB Landfill Committee meeting without conflicting with Division/Section assignments. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper _ , SEP 14 '94 01:01PM EHNR·PUBLIC AFFAIRS • State of North Carolina Department of Environment, Health and Natural Resources Legislative & Intergovernmental Affoirs James B. Hunt, Jr., Governor Jonathan B, Howes, Secretary Henry M. Lancaster IL Director FAX MEMORANDUM P.l/4 -~A.VA DEHNR TO: Bill Merer, Dollie Burwell, T onuny Cline, Jim W .u-ren, Ken F errucio, Dennis R.e£zla.ff, Billie Elmore, Daria HolcomL FROM: Henry M. LancAster, II , ...... . SUBJECT: Memora.n.lum Warren County PCB LAndfill W ork:i..ng Group DATE: Septcmher 14, 199-4 ■ Ple.ue find. A draft for yolll' perusol of the Al>ove referenced material. Than.1. you. •.• . ·.· P.O Box 27687, Raleigh, North Carolina 27611-7687 Telephon® 919·733-4984 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% posr-consumer paper ,, SEP 14 '94 01=01PM EHNR·PUBLI C AFFAIRS State of North Carolina Department of Environment. Health and Natural Resources Legislative & Intergovernmental Affairs James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Henry M. Lancaster II , Director MEMQRANPYM P.2/4 ~A -..-am 1,; ,I.~ DEHNR TO: FROM: MEMBERS OF THE .JOINT WARREN COUNTY/STATE PCB L6.NOf"ILL WORKINO GROUP HENRY M. LANCASTER, II 1'M,l. DATE: SEPTEMBER 08, I 994 SUBJECT: STRUCTURAL AND PROCEDURAL AMENDMENTS TO THE JOINT WARREN COUNTY/STATE PCB l.ANOf'ILL WORKING GROUP PURSUANT TO CONVERSATIONS HELO WITH Cl>CHAIRS DOLLIE BURWELL ANO KEN f"ERRUCIO ANO OTHER INTERESTED PARTIES CONCERNING THE MAKE-UP ANO OPERATION OF THE WoRKINO GROUP, !HE FOLLOWING IS OFf"EREO f"OR YOUR CONSIDERATION, COMMENT ANO ACTION AT THE SEPTEMBER I 5, 1994 MEE:TINO: SUGGESTED COMPOSITION Of" WORKINO GROUP BEPBfSFNDNG 0Ff"ICE OF' THE GOVERNOR (I) OFF"ICE OF THE SECRETARY, EHNR ( I ) A. 01V. Of" ENVIRONMENTAL MANAOEMENT ( I ) OFFICE Of' THE SECRETARY, ADMINISTRATION ( I ) WARREN COUNTY GOVERNMENT A. COUNTY COMMISSION ( I ) 8. HEAL TH DEPARTMENT ( I ) C . PUBLIC SAFETY ( I ) BUSINESS/CHAMBER OF' COMMERCE ( I ) RELIOIOUS COMMUNITY (3) YoUll-1 (2) ENVIAONMENTAL COMMUNllY (4) PRIVATE CITIZENS (4) EDUCATION ( I ) STATE LEOISL.ATORS (WARREN COUNlY) APPOINTER GOVERNOR HUNT SECRE:TARY JONATHAN 8 . HOWES SECRETARY KATIE G. DORSETT COMMISSION CHAIR COMMISSION CHAIR CITIZENS GROUP CITIZENS GROUP CITIZENS GROUP, SECRETARY HOWES CITIZENS GROUP, COMMISSION CHAIR CITIZENS GROUP/SUPERINTENDENT OF SCHOOLS Ex OFFICIO CTHEIR CHOICE) P.O. Box 27687 , Raleigh, North Carolina 27611-7687 Telephone 919-733·4984 An Equal Opportunity ,A,ftirmative Action Employer 50% recycled/ 10% post-consumer poper SEP 14 '94 01:01PM EHl'lR·PUBLIC AFFAIRS RULES OF PROCEDURE JOINT WARREN COUN"TY/STATE PCB LANDFlU.. \NORKJNG GROUP I. MISSION STATEMENT A. EvALUATE SAFETY OF' LANOF'ILL AND MAKE RECOMMENOAllONS TO DEHNR TO ENSURE INSTITUTIONAL CONTROLS/PROCEOURES/ANO FUNOINO ARE AVAIL.AaLE TO PROVIDE LONO- TERM PROTECllON 01"' THE cmZENS Of" WARRE;:N COUNTY. II. GOALS/f ASKS A. < I > ASSESS CURRENT CONDITIONS AND SAFETY Of" LANDFILL ANO MAKE RECOMMENDATIONS TO OEHNR FOR ADDRESSINO ANY UNSAFE CONDITION IDENTIFIED. (2) ASSESS NEED TO REMOVE RAINWATER F'ROM LANDFILL AND RECOMMEND TO DEHNR THE BASIS AND TECI-INOLOOY FOR REMOVAi.. OR ALLOWING RAINWATER TO REt-WN IN THE LANDFILL. (3) IDENTIFY ANO EVALUATE TECHNOLOGIES FOR DETOXIFICATION OF LANDI-ILL ANO MAKE RECOMMENDATIONS TO OEHNR ON APPROPRIATE ANO ECONOMICALLY FEASll:ILI!: TECHNOLOOIES FOR DETOXIF'ICATION. (4) IDENTIFY ANO RECOMMEND IMPLEMENTAllON STRATEOY TO DEHNR FOR ALL GOALS/TASKS INCLUDING INFRASTRUCTURE ANO FUNDINO. (5) DEHNR TO IMPLEMENT 1-UNDED RECOMMENDATIONS FOR LONG-TERM MAINTENANCE AND, IF APPROPRIATE, DETOXIFICATION OF' THE LANDFILL. Ill. OFFlCERS A. B. C~HAlRS. THe'.RE SHALL BE THREE: (3) Co-CHAIRS Of'" THE WORKINO GROUP. Two Co- CHAIRS SH.ALL BE MEMBERS 01"' THE WORKINO GROUP AND ELECTED BY THE MEMBERS. ONE CO-CHAIR SHALL BE APPOINTED SY THE SECRETARY Of'" THE NORTH CAROLINA DE'.PARTMENT OF ENVIRONMENTAL, HEALTH AND NATURAL RESOURCES AND SHALL BE A MEMBER OF" THE WORKING GAOUP. SAJO TERMS SHALL BE FOR ONE YEAR, AND THEY SHALL BE ELIGIBLE FOR REAPPOINTMENT, THE Co-CHAIRS SHALL OECICE ALL POINTS OF' ORDER AND PROCEDURE, SUBJECT TO iHESE RULES, UNLESS DIRECTED OTHERWISE aY A TWO-THIRDS MAJORITY OF THE WORKINO GROUP IN SESSION AT THE TIME. THE Co-CHAIRS SHALL APPOINT ANY COMMITTEE FOUND NECESSARY TO IHVESTIOATE OR STUDY MATTERS BEFORE THE: WORKINO GROUP. SECRETARY. A SECRET.ARY SHALL BE APPOINTED BY THE CO-CHAIRS OF THE WORKINO GROUP EITHER FROM WITHIN OR FROM OUTSIDE ITS MEMBERSHIP, TO HOLD OFFICE DURINO THE TERM OF' THE SECRETARY Of' THt: DEPARTMENT AND/OR UNTIL A SUCCESSOR SECRETARY SHALL HAVE Bl::EN APPOINTED. THE SECRETARY SHALL BE EUOIBLE FOR RE.APPOINTMENT. THE SECRETARY, SUBJECT TO THE DIRECTION OF' THE Co-CHAIRS ANO THE WORKING GROUP, SHALL KEEP ALL RECORDS, SHALL CONDUCT A.l.L CORRESPONDENCE OF' THE WORKINO GROUP. THE SECRETARY SHALL KEEP THE MINUTES OF EVERY WORKING GROUP MEl::"TINO, WHICH MINUTES SH.ALL BE A PUBLIC RECORDS. THE MINUTES SHALL SHOW THE RECORD OF ALL IMPORTANT FACTS PERTAINING TO EACH MEETINO AND HEARINO, EVERY RESOLUTION ACTED UPON BY THE WORKING GROUP, AND ALL VOTES OF THE WORKING GROUP MEMBERS UPON ANY RESOLUllON CR UPON THE FINAL DETERMINATION OF ANY QUESTION, INDICATING THE NAMES OF MEMBERS ABSENT OR f'.All.lNO TO VOTE. SEP 14 '94 01:02PM EHNR·PUBLIC AFFAIRS .. IV. MEETINGS A. B. C. D. E. REGULAR MEE]]NQS. MEETINGS OF THE WORKING GROUP SHALL SE HELD IN WARRENTON, NORTH CAROLINA, PROVIDED THAT IF THE CO-CHAIRS SO DIRECT, MEETINOS "'4AY BE HELO AT ANY OTHER PLACE IN THE STA'fE. THE WORKINO GROUP MAY ESTABLISH A SCHEDULE OF REOULAR MEETINOS, §eEclAL MEEJ)NOS. SPECIAL MEETINGS OF THE WORKING GROUP MAY t3E CALLEO AT ANY TIME BY THE Co-CHAIRS. MEETINGS MAY BE CALLED BY 1WELVE ( 12) OR MORE MEMBERS OF' THE WORKING GROUP. AT LEAST FORTY-EIGHT (48) HOURS NOTICE OF THE TIME ANO PLACE OF SPECIAL MEETINOS SHALL BE OIVEN BY THE SECRETARY OR THE CO- CHAIRS TO EACH ._,.EMBER OF THE WoRKINO GROUP; PROVIOED THAT THIS REQUIREMENT MAY BE WAIVED BY ACTION OF A MA.JORITY OF' THE ME'.MBl::RS. CANCELLATION Of MEaJNOS. WHENEVER TI-iERE IS NO BUSINESS FOR THE WORKING GROUP, THE CO-CHAIRS MAY DISPENSE WITH A MEETINO BY OIVINO NOTICE TO ALL THE MEMBERS NOT LESS THAN lWENTY-FOUR (24) HOURS BEFORE THE TIME Se:T f"OR niE MEETING. QUORUM. A QUORUM SHAU. CONSIST OF A MAJORITY OF MEMBERS OF THE WORKINO GROUP. CONDUCT OF MEE"[JN~. ALL MEETINOS SHALL BE OPEN TO THE PUBLIC. THE. ORDER OF BUSINESS SHALL BE OPEN TO THE PUBLIC. THE ORDER OF BUSINESS SHALL BE AS FOLLOWS: (A) ROLL CALL; {B) RO.DINO ANO APPROVAL OF THE MINUTES OF THE PREVIOUS MEETING; (c) REPORTS OF COMMITTEES; (0) UNf"INISHEO BUSINESS; (E) NEW BUSINESS, PARLIAMENTARY PROCEDURE SHALL BE IN COMPLIANCE WITH ROBERTS Rur.,c; OF ORDEB. f. ~. THE VOTE OF A MAJORITY OF THOSE MEMBERS PRESENT SHALL BE SUFFICIENT TO DECIOE MATTERS BEFORE TI-iE WORKINO GROUP PROVIDED A QUORUM HAS BEEN OULY RECORDED. G. THE CO-CHAIRS MAY RECOMMEND TO TI-iE SECRETARY Of" THE DEPARTMEN'r REMOVAL OF ANY WORKINO GROUP MEM8ER WHO WITHOUT AN EXCUSED ASSENCE FAILS TO ATTEND THREE (3) CONSECUTIVE REOULAR MEETINGS. V. REPORTS COPIES OF MINUTES WILL BE DISTRIBUTED TO ALL WORKING GROUP MEMBERS, THE COUNTY MANAOER, MEMBERS Of' THE STATE LEOISLATOR THAT REPRESENT WARREN COUNTY, THE SECRETARY OF THE NORTH CAROLINA DEPARTMENT ENVIRONMENT, HEALTI-i ANO NATURAL RESOURCES AND THE GOVERNOR, PERIODIC PROORESS REPORTS WILL SE SUBMITTED AS DEEMED NECESSARY BY l"HE WORKING GROUP OR CO-CHAIRS. VI. AMENDMENTS THESE RULES MAY, WITHIN THE LIMITS ALLOWED 13Y L>JN, BE AMENDED AT Al-('( TIME l:IY AN AFFIRMATIVE VOTE OF NOT LESS THAN FIFTEEN ( 15) VO'llNO MEMBERS OF THE WORKINO GROUP, PROVIDED THAT SUCH AMENDMENT SHALL HAVE f"IRST 6EEN PRESENTl::D TO THE MEMBERSHIP IN WRITING A'f A REOUl.AR OR SPECIAL MEETING PRECEOINO THE MEETING AT WHICH THE VOTE IS iAKEN. .•Y •. --c-'. ◄ ~ 09113/9~ 12:23 G'706 546 3252 EP • .\-ATHE~S, G . .\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ENVIRONMENTAL RESEARCH LABORATORY HO COLLEGE STATION ROAD ATHENS. GEORGIA 30605·2720 iaioo1 September 12, 1994 o,ir,ct: oF RESEARCH AND DEVELOPMENT Sharon Rogers State of North Carolina Department of Environment, Health and Natural P.O. Box 27687 Raleigh, North Carolina 27611-7687 Dear Sharon, C)PTl()NA. FOAM Ill (7 110; FAX TRANSMITTAL °""'·'•q (,; DE If Ai tf 6 -S-'ll-sf6 Fu, 9 I,_ 71.S--36 o.r ~-/j70o -S"'/t-?2-S-'l- N!.1' 7M0~~1·217•7.6i 5011i-1~1 C.!N!l'IA:. ~t:'1Vlt,;t:S ";JM NI> A ;_,, Please find attached a preliminary report of congener specific PCB analyses for the North Carolina (Warren County) landfill samples that we receiv~ on August 2, 1994. Although the report contains data from only one of the two samples, the results are essentially the same for both soil samples. Be advised that these results arc preliminary and arc for research purposes to assess the extent of PCB transformation in samples originally contaminated primarily with Aroclor 1260. The data have not been subjected to riJ:orous statistical analyses and additional standards should be analyzed prior lo final congener identification or quantitalion. Also note that the extraction procedure used in this investiaation (12 hour solvent shake) is a modification of the EPA aonication proce.dure. Results from this modified extraction procedure have ~ comparable to the extraction efficiency of both the Soxhlet and sonication methods approved by EPA. I will be available to discuss these preliminary ~ults at your convenience. Sin1y yo~, (! -~L: r~ I : V W.Jack Jones Ph.D. Rest.arch Microbiolopst Athens Environmental Research Laboratory cc: Dr. Robert Swank (Director of Research, AERL-US EPA) Dr. John Rogers (AERL-US EPA) Mr. Curt Fehn (Re&ion 4-US EPA) -09 / l3 /'94 12: 23 tt706 546 3252 EPA-ATHE~S, G..\ Table 1. Results of congener specific PCB analyses (weight ~ determination; mean of triplicates) of a landfill soil sample (sample 12) collecled in July 1994 from the Warren County PCB land.fill, North Carolina. ~ener specific PCB analyses of Aroclor 1260, as reported by Schultz et al. (1989), are also presented for reference. The differences in the wei&ht • of congeners in the N.C. sample and that reported by Schultz are presented. The weight Ii values calculated for the PCB congeners from the N.C. sample were based on a mndard PCB con1encr mix consisting of Aroclors 1232, 1248, and 1262 (2.5; 1.8: 1.8). Results indicate a decrease in the weiaht 9' of some higher chlorinated PCB congeners, compared to the PCB congener profile of Schultz et al. (1989) for Aroclor 1260, and an increase in the weiaht 9' of 10me lower cblorinated PCB congeners. Some specific ewnples are as follows, and the dccrP.aSeS tn the specific congeners listed below indicate a pattern in which meta chlorines are removed if flanked by either onho or para chlorines. 'Ibis type of dechlorination pattern (pattern N)..-is similar to thal observed hy Quensen et al. (1990) and Bedard et al. (1990), but other dechlorination scenarios must not be ruled out at tha time. Coniener D~rt,asg Congener Increase 22'455' (#101) 22'45' (#49) 22'34'5'6 (#149) 22 '34 '6 (#91) 22'46' (#51) 233'44'6 (#158) 24'6 (#32) 22'344'5' (#138) 22'44 I (#47) 22'33'44'5 (#170) " Other dechlorination patterns are possible, as the preliminary results suggest significant cit.creases in congeners #179, # 153, #132, and #136. Befrn:oces Bedard, D.L., H. Van Dort, S.C. BUMell. 1990. General Electric Company ~ch and Development Program for the De.ffl'UCtion of PCBs, Ninth Progress Report. General. Electric Corporate Research and Development, Schenectady, New Yorlc. Quensen, 1.F., m, S.A Boyd, J.M. Tiedje. 1990. Appl. Environ. Microbiol. 56:2360-2369. Schulz, D.E., G. Petrick, J.C. Duinlccr. 1989. Environ. Sci. Tcchnol. 23:852•857. la] 002 '.09113194 12:24 t,706 S46 3252 EPA-ATBE~S, G.~ NC#2J<LS --+ ___ 1f...;SCl'I=_ ulz i __ _ NC#2 Ar 1260 i ---· .1 .• -=--~;;.....;.:~....:...-- IUPAC # i Wt% Wt% jdiffcr~ I (1) 3.739 01 -(3) o.m o; --I (4. 10) ' 0.0'1◄ 0: ---1-----1------+ 0 1 3.739 ? 0.228 -0.044 -0.021 (7, ') 0,CJ2 j I -----+----~---+--(') 0.J63 0 ! 0.163 -----+-----..----+- ($, I) __ 1 ___ o.6_04-----'I --Jl o.604 (ls>) . n.~90 0 . 0.390 ~ OJ.I02 0 I 0.002 05. 11} I -_-o_.-6_,-u~~+-f .... _-_-_-_-_-_--'o ... t __ o_-.6~ (17) I 0.445 I O ! 0,445 (2◄, 2-7)--1 -0-.0-12-..;..1 -•. -0 i 0.012 i. I <•c;,121 0.101 • o; 0.101 ._ __ ........, ___ , i ---- (J', 54) i 0.005 j O i o.oos I i oi (29) . 0.00} \ I 0,001 ------·- (l') Ii 0.'07 1 o i 0.407 (?S) --+-.-0-.1-17-1-. 0 , 0,117 Ql). ___ l _o_.Rs_-,_-,..1 _ 0.05...___0_.8_04-I (21.50) I u6s I o.os1 1.41s " t-'-------+-------- t'J0,21,.13,.~) j l.041 ! 0 t J .041 ¥ z !'/'/ zz. ·,,, -... tn_._5_•)--+-_o._79_1 __ i · ... ol · o.7!H -It 0.12, 1· oj 0.129 ---+----➔---.... i-;.<•_G>;...._ _____ o.0_12_ 1 ____ . ol o.oy~ (43, !l. 73) ' 2,2()7 i 0.56 1.647 .... <•'> I s.333 O 3.333 .-, ('7) ___ .... l _ Ull _ _,. __ ~!1 j 0.523 <• 75..) 0.027 D.09 -0.063 ·-(35) 0.000 I O 0,000 --------------•·---------1 (44, 10.f) 0.7'4 0 0,754 ... .. <37,◄2."> I 0.1•2 o o.742 .- :_""11,?J) 1: o.Gl-4 1 -0.1 0 ,. ·· o.544 ~ v·v1 0.079 I l 0.079 (~) ···-. ➔_ ,-0_1_2?_-4 ___ 0'! . 0.127 (57,'7,I00,1i O.l!JIJ ' o! 0.193 "c;., Q) j 0.03<1 ! 0 ! 0.034 -----------------~) . j o.33◄ j O I 0.33-4 (61, 70, 1~ . o.878 l 0.09j 0 .. 788 -fl <603. 95) · 1 3.so, I 3.04 . 0.468 Page 1 Ill 003 I I , / -(, 6(6'MttS .it.11,'1tfi'~ f n- /tt'•c.(c, l,co \/1+-lu" °l -' . ·--'·' -•' ' .. 09113194 12:24 t5'i06 546 3252 EPA-ATBE!\S,GA ..... .. z. J~'t/'/'fz&'JJ'f'' - I 1.1 t(t('SS' zz. ':,3 1 s ,, ' _ • NC#2.XLS (55. fl,'8) l 0.427 o; 0.-t27 (16,.0) 0.'47 -o' 0.647 -· . . 1- ~_!2,1!5) 0.9S6 1.15 i -0.194 ··-· --(t0, 101) U04 I 5.88 , -4.'76 ~-. --··•--"91 0.)4¥ 0.11 1 0.438 (112, 11,. 150 0.177 O: 0.177 ['l.1, 199) CUl9 o: 0.119 (l(i. '7. 152) 0.131 0.23! -0.099 (11,1'7.JJl,JU 0.271 0.82 -0.549 -----------Sl5-ll') -0.0116 0: 0,086 (11') 0.!27 2.23: -1.703 (7'7, 110) 1:104 1.e : -0.796 ....... -·· (12) 0.046 o; 0.046 (151) 4.144 ! 3.67 : 0.474 (lM, 135) J UHi 1 2.56, -0.742 (197, IOl,1 0.045 0 0.045 (1U6, 1~8.14')~7 e.4 -3.563 <Jl'-lJ.a.14.i 0.2)11 o.e2 -0.3G2 (122, l3J, 1.0.1 0.082 0.46 ! -0.378 ---·• (J46.H1) I l.124 1.-19 --0.366 -· .. (105,U2) i J.32S ! 3.76 •2.435 (15.1) I .. :.:!!!.._J_ .!O'.~ .• -2.923 i (141) 2.108 ' 2.56, 0.24R I (17') i U.l84 1.79 -1.506 (137,176) ! 0.462 ! 1.01 : -0 . .548 (131,1'0,163' 5.662 6.18 : -0.518 (151) 0.424 1.951 -1.526 ~129) 0.118 1.11 -0.992 -·-(178) o.,u ~ .. 62, -· -~-635 (1'75) 0.170 0.23; -0.060 (11n. UC7) . ·-,~j; -. 3.97 i -0,154 --i-. (12tr) I 0.000 I 1.06 . -1 .060 ··-1.76 j (1113) I 1.951 ! 0.191 I (1G7) 0.104 0.26 -0.156 (JIS) 0."39 1.34 .(J,901 ~ .. ·-(1'74, 112) 2.ns 3.85 .0.965 (177) 1,795 2.21 , .0.-11S (15', 171) 1.630 2.38 . .0,7.50 (211%) 0.049 0.9 i -0.851 --· . (173) 0.05!1 0.36 1 -0.301 ~!.2CM) 0.311 0.99 -0.679 0.75 .. ·•·-(172.ttl) 0.647 .0.)03 . .. -· --(190) 7.361 7.12 0.241 (ttl) ' 0."81 0.66: .(J,172 (191) i 0.1t'7 ! 0.25 .· ..0.063 I .. (1'9) ! 0.148 0.051 0.098 (1'70.D.Bl.") ' 4.151 l 3.91 0.2.41 I I I (1,0) 0.991 ! 0.79! 0.201 Page2 State of North Carolina Department of Environment, Health and Natural Resources Division of Epidemiology James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary September 12, 1994 MEMORANDUM TO: William Meyer, Director Division of Solid Waste Management THROUGH: John I. Freeman, D.V.M., M.P.H., Environmental Epidemiology Secti FROM: Kenneth Rudo, Ph.D., Toxicologi ~a Environmental Epidemiology Section SUBJECT: Health Risk Evaluation Warren County Landfill Samples This memo is a follow-up to the September 7, 1994 memo that evaluated PCB and chromium contamination in the Warren County Landfill. In addition to the compounds commented on previously, the following chemicals were identified: 013921 -88 ppm barium -Leachate pond 942795 -62 ppb chlorobenzene -dry landfill contents 23 ppb 1,4-dichlorobenzene 942797 and 013919 -wet landfill contents 60 ppb chlorobenzene 48 ppb 1,4-dichlorobenzene 2 ppm arsenic 23 ppm barium 35 ppm lead 013909-0.23 ppm barium -landfill leachate 013914 -0.05 ppm barium -monitoring well #1 013917 -0.08 ppm barium -monitoring well #4 013918 -0.08 ppm barium -monitoring well #4 duplicate 013920 -16 ppm barium -Richneck CK-DS sediment 013922 - 2 ppm arsenic -west side landfill 94 ppm barium 013923 -72 ppm barium -air vent area soil The levels of barium, arsenic, lead, chlorobenzene, and 1,4- dichlorobenzene in all the above soil and sediment samples should not pose any increased health risks upon prolonged exposure. P.O. Box 27687, Raleigh, North Carolina 27611-7687 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper l William Meyer Page 2 September 12, 1994 The EPA MCL for barium is 2 ppm and the North Carolina groundwater standard is 1 ppm. Barium levels detected in the monitoring wells are below both standards and should not pose any increased health risks if this groundwater source was utilized for consumption. If you have any further questions, please feel free to contact me at 733-3410. KR:td cc: Grover Nicholson John Neal State of North Carolina Department of Environment, Health and Natural Resources Legislative & Intergovernmental Affairs James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Henry M. Lancaster II , Dire ctor MEMORANDUM TO: DOLLIE BURWELL, REGISTER O F DEEOS KEN FERRUCIO LUCIOUS HAWKINS, CHAIR, WARREN COUNTY COMMISSIONERS FRANK BALLAHCE, STATE SENATOR FROM: HENRY M . LANCASTER, II DATE: SEPTEMBER 8 , I 994 REGARDING: STRUCTURAL AHO PROCEDURAL AMENOMEHTS TO THI!: JOINT WARREN COUNTY AHO STATE PCB LAHOFILL WORKING GROUP PURSUANT TO CONVERSATIONS HELD WITH VARIOUS INTERESTED PARTIES CONCERNING THE MAKE-UP AHO OPERATION OF THE WORKING GROUP, I AM OFFERING THE FOLLOWING FOR YOUR CONSIDERATION: SUGGESTED COMPOSllfoN OF WORKING GROUP REPRESENTING OFFICE OF THE GOVERNO,R ( I ) OFFICE OF THE SECRETARY, EHNR ( I ) A. DIVISION 01" ENVIRONMENTAL MANAGEMENT ( I ) OFFICE OF THE SECRETARY, ADMINISTRATION (I) WARREN COUNTY GOVERNMENT A. COUNTY COMMISSION ( I ) B. HEALTH DEPARTMENT (I) C. PUBLIC SAFETY ( I ) BUSINESS/CHAMBER 01" COMMERCE ( I ) RELIGIOUS COMMUNITY (3) YOUTH (2) ENVIRONMENTAL COMMUNITY (4) PRIVATE CITIZENS (4) APPOINTER GOVERNOR HUNT SECRETARY JONATHAN B . HOWES SECRETARY KATIE G . DORSETT COMMISSION CHAIR COMMISSION CHAIR CmZENS GROUP CmZENS GROUP CmZENS GROUP, SECRETARY HOWES CmZENS GROUP, COMMISSION CHAIR P.O. Box 27687, Raleigh, North Carolina 27611 -7687 Telephone 919-733-4984 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper RULES OF PROCEDURE JOINT WARREN COUNlY/STATE PCB LANDFlLL WORKING GROUP I. MISSION STATEMENT II. GoALS/fASKS Ill. OFFICERS A. Co-CHAIRS. Co-CHAIRS SHALL BE APPOINTED BY THE SECRETARY OF THE NORTH CAROLINA DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES. B. SAID TERMS SHALL BE FOR ONE YEAR, AND THEY SHALL BE ELIGIBLE FOR RE- APPOINTMENT. THE Co-CHAIRS SHALL DECIDE ALL POINTS OF ORDER AND PROCEDURE, SUBJECT TO THESE RULES, UNLESS DIRECTED OTHERWISE BY A TWO- THIRDS MAJORITY OF THE WORKINO GROUP IN SESSION AT THE TIME. THE Co- CHAIRS SHALL APPOINT ANY COMMITTEES FOUND NECESSARY TO INVESTIGATE OR STUDY MATTERS BEFORE THE WORKING GROU_P . SECRETARY. A SECRETARY SHALL BE APPOINTED BY THE Co-CHAIRS OF THE WORKING GROUP EITHER FROM WITHIN OR FROM OUTSIDE ITS MEMBERSHIP, TO HOLD OFFICE DURING THE TERM OF THE SECRETARY OF THE DEPARTMENT AND/OR UNTIL A SUCCESSOR SECRETARY SHALL HAVE BEEN APPOINTED. THE SECRETARY SHALL BE ELIGIBLE FOR REAPPOINTMENT. THE SECRETARY, SUB.JECT TO THE DIRECTION OF THE Co-CHAIRS ANO THE WORKING GROUP, SHALL KEEP ALL REC6RDS, SHALL CONDUCT ALL CORRESPONDENCE OF THE WORKING GROUP, AND SHALL GENERALLY SUPERVISE THE CLERICAL WORK OF THE WORKING GROUP. THE SECRETARY SHALL KEEP THE MINUTES OF EVERY WORKING GROUP MEETING, WHICH MINUTES SHALL BE A PUBLIC RECORD. THE MINUTES SHALL SHOW THE RECORD OF ALL IMPORTANT FACTS PERTAINING TO EACH MEETING AND HEARING, EVERY RESOLUTION ACTED UPON BY THE WORKING GROUP, AND ALL VOTES OF THE WORKING GROUP MEMBERS UPON ANY RESOLUTION OR UPON THE FINAL DETERMINATION OF ANY QUESTION, INDICATING THE NAMES OF MEMBERS ABSENT OR FAILING TO VOTE. Ill. MEETINGS A. REGULAR MEETINGS. MEETINGS OF THE WORKING GROUP SHALL BE HELD IN WARRENTON, NORTH CAROLINA, PROVIDED THAT IF THE Co-CHAIRS SO DIRECT, MEETINGS MAY BE HELD AT ANY OTHER PLACE IN THE STATE. THE WORKING GROUP MAY ESTABLISH A SCHEDULE OF REGULAR MEETINGS. B. C. SPECIAL MEETINGS. SPECIAL MEETINGS OF THE WORKINO GROUP MAY BE CALLED AT ANY TIME BY THE Co-CHAIRS. MEETINGS MAY BE CALLED BY TWELVE ( I 2) OR MORE MEMBERS OF THE WORKING GROUP. AT LEAST FORTY-EIGHT (48) HOURS NOTICE OF THE TIME AND PLACE OF SPECIAL MEETINGS SHALL BE GIVEN BY THE SECRETARY OR THE Co-CHAIRS TO EACH MEMBER OF THE WORKING GROUP; PROVIDED THAT THIS REQUIREMENT MAY BE WAIVED BY ACTION OF A MAJORITY OF THE MEMBERS. CANCELLATION OF MEETINGS. WHENEVER THERE IS NO BUSINESS FOR THE WORKING GROUP, THE Co-CHAIRS MAY DISPENSE WITH A MEETING BY GIVING NOTICE TO ALL THE MEMBERS NOT LESS THAN TWENTY-FOUR (24) HOURS BEFORE THE TIME SET FOR THE MEETING. D. 0UORUM. A QUORUM SHALL CONSIST OF A MAJORITY OF MEMBERS OF THE WORKING GROUP. E. CONDUCT OF MEETINGS. ALL MEETINGS SHALL BE OPEN TO THE PUBLIC. THE ORDER OF BUSINESS SHALL BE OPEN TO THE PUBLIC. THE ORDER OF BUSINESS SHALL BE AS FOLLOWS: W ROLL CALL; (B) READING AND APPROVAL OF THE MINUTES OF THE PREVIOUS MEETING; (C) REPORTS OF COMMITTEES; (D) UNFINISHED BUSINESS; (E) NEW BUSINESS. PARLIAMENTARY PROCEDURE SHALL BE IN COMPLIANCE WITH ROBERTS RULE OF ORDER. F. ~-THE VOTE OF A MAJORITY OF THOSE MEMBERS PRESENT SHALL BE SUFFICIENT TO DECIDE MATTERS BEFORE THE WORKING GROUP PROVIDED A QUORUM HAS BEEN DULY RECORDED. IV. REPOITTS COPIES OF MINUTES WILL BE DISTRIBUTED TO ALL MEMBERS, THE COUNTY MANAGER, THE SECRETARY OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES AND THE GOVERNOR. PERIODIC PROGRESS REPORTS WILL BE SUBMITTED AS DEEMED NECESSARY BY THE WORKING GROUP OR Co-CHAIRS. V. AMENDMENfS THESE RULES MAY, WITHIN THE LIMITS ALLOWED BY LAW, BE AMENDED AT ANY TIME BY AN AFFIRMATIVE VOTE OF NOT LESS THAN TWELVE ( I 2) VOTING MEMBERS OF THE WORKING GROUP, PROVIDED THAT SUCH AMENDMENT SHALL HAVE FIRST BEEN PRESENTED TO THE MEMBERSHIP IN WRITING AT A REGULAR OR SPECIAL MEETING PRECEDING THE MEETING AT WHICH THE VOTE IS TAKEN. .. , \. State of North Carolina Department of Environment, Health and Natural Resources Division of Epidemiology James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary .NA DEHNR MEMORANDUM TO: THROUGH: FROM: SUBJECT: Se~tember 7 , 1994 William Meyer, Director Division of Solid Waste Management ~6hn I . Freeman, D. V. M. , M. P.H. , Chief Environmental Epidemiology Section Kenneth Rudo , Ph.D. , Toxicologist [(krL Environmental Epidemiology Section Health Risk Evaluation Warren County Landfill Samples After evaluating water, solid, and soil samples from the Warren County PCB landfill and the adjacent areas (#942748-942829 and #013909-013923) the Environmental Epidemiology Section (EES) would like to put forward the following comments and recommendations. The majority of the samples did not indicate any PCB c ontamination and levels of other compounds were low and should not pose any health risks upon exposure to the soil, solids, or water. The following soil or solid samples did indicate measurable levels of PCBs and/or chromium: 942752 -0.53 ppm PCB (1260) -leachate pond -middle 942753 - 1 .15 ppm PCB (1260) -leachate pond -filter 942781 - 1 .45 ppm PCB (1260) -leachate pond -filter 942782 -0.22 ppm PCB (1260) -east side -landfill 942796 -301.4 ppm PCB (1260) -dry landfill contents 942799 -151.8 ppm PCB (1260) -wet landfill contents 013919 -12 ppm Chromium -wet landfill contents 013921 -12 ppm Chromium -leachate pond 013922 -12 ppm Chromium -west side landfill seep 013923 -16 ppm Chromium -Grid 14-3-air vent outfall outfall Although these sample results were taken on the landfill property, EES feels that steps previously taken to restrict access to these contaminated areas, should prevent exposure to P.O. Box 27687, Raleigh, North Carolina 27611-7687 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper I . William Meyer Warren County Landfill Samples Page 2 September 7, 1994 the soil in these areas that could pose an increased health risk over time. EES considers significant exposure to the landfill contents, leachate pond area, etc., to be unlikely, as long as access restrictions have been taken. If you have any further questions, please feel free to contact me at 733-3410. KR:lp Attachments cc: Grover Nicholson, Superfund Section John Neal, State Laboratory of Public Health MESSAGE DISPLAY FOR HENRY LANCASTER To Henry Lancaster CC Lois Artis CC Linda Rimer CC Greg Wilshusen CC dgl From: Douglas Lewis Postmark: Sep 02,94 8:48 AM Host: EHNR Delivered: Sep 02,94 8:48 AM Subject: Reply to: Warren County PCB Working Group Reply text: From: Douglas Lewis:NCSTGOV Date: Sep 02,94 8:48 AM No, not this question. The committee needs to have official status; apointment by the G.A., Gov., or the Secretary. Once that is done they can qualify for travel and per diem. Greg's staff are the travel experts and can help you accomplish what you want. Lois had asked about the contract to evaluate the landfill. A budget revision was approved April 30 to move $40k of lapsed salary to support about half of the project. That money was encumbered by May 31 but we find no payments made last fiscal year and it was not eligible for carry forward because it was lapsed salary. On Aug 15 a budget revision was approved that again moved DSWM lapsed salary to support the contrpct in the amount of $40k. Options: You can use lapsed salary from DSWM (they will generate it later in the year) or look elsewhere in the Environmental Divisions for lapsed salary. I do not recommend using Bill's or any one elses contract money for this purpose this early in the fiscal year. Preceding message: From: Henry Lancaster Date: Sep 01,94 5:26 PM Has Lois talked to you about identifying money to reimburse Warren County committee folks for telephone and travel expenses? And if so, how do the chances look? -------========X========------- .. f PnaJ.M f I, Plt..D. ....... lianlmdia1ica--= Prop-am ~. r:'Jaborek,cy 08/26194 Dear Sharon, GE Corporate Research and D•velopment .._, Xl, ILoom 3C7 P.O. Jim I, I b :lady, NY 12301--000II l'boaa: 511317-7470; Fu: 511317-7611 Dial c:c.am: l-&33-7470 5-..u ID: Ne 1 W"CaaiJOl.-11.,..oam Here is a copy of the report on the samples we analyud from the landfill. If you have any questions, please contact Dr. Donna Bedard, as I will be out of the office until September 8. Best Wishes, 4-/. Frank 1. Mondello Donna L ledard, Ph.D. Group uader Biomnediation Rnearch Program Environmental Laboratory August 23, 1994 To: Frank Mondello GE Corporate Re.search Mid Development Building K1, Room 3B12 P.O. Box 8, Schenectady, NY 12301-0008 Phone: 118 387-5914; Fax: 1518 387-7811 Dial Comm: 8 • 833-5914 From: Donna L. Bedard, Ralph May, and Lynn Smullen Subject Assessment of PCBs in North Carolina soil sample Two PCB-contaminated soil samples were received from the Division of Solid Waste management/Superfund Section at the Nor.th Carolina Department of environmental health and Natural Resources in Raleigh, North Carolina. These samples were labelled 'W1-002-LC 7/28/94 landfill contents." We have extracted the PCBs, performed congener-specific analysis by GC/MS, and done a preliminary interpretation of the results. The PCB concentration in the two samples was approximately 315 to 340 µg/g soil. The PCBs appear to be composed primarily of unaltered Aroclor 1260, a lesser amount of partially dechlorinated Aroclor 1254, and a small amount of partially evaporated Aroclor 1242. This interpretation is based on limited data and a semiquantitative comparison of the congener distributions in Aroclors 1242, 1254, and 1260 with those in the samples received. This interpretation should therefore be considered tentative. A more conclusive interpretation would require more information regarding the nature of the PCB contaminant and history of the sample, rigorous quantitation and a mother-daughter analysis of presumptive dechlorination substrates and products. The mono-, di-, and trichlorobiphenyls present are typical of Aroclor 1242, but their relative proportions are altered relative to Aroclor 1242. With the exception of 26-3-CB and 25-3-CB, the proportions of all mono-through trichlorobiphenyls eluting prior to 25-4-CB and 24-4-CB are decreased relative to the latter congeners. This is _· most likely due to evaporation. There is no evidence of increased proportions of ortho- enriched congeners such as 2-CB, 2-2-CB, 26-2-CB, or 2-4-CB. However, the propor- tions of 26-3-CB and 25-3-CB are increased relative to 25-4-CB and 24-4-CB. Most likely the elevated levels of 26-3-CB and 25-3-CB result from partial dechlorination of Aroclor 1254. The tetra-and pentachlorobiphenyls appear to be derived -from a combination of partially dechlorinated Aroclors 1254 and 1260. Peaks 47 (25-34-CB), 61 (236-34-CB), 53 (245-25-CB), and 69/5 (245-34-CB) are all notably decreased relative to Aroclor 1254, and have probably been dechlorinated. Peaks 31 (25-25-CB), 32 (24-25-CB), ... J .. ' --.. ----.. ··--------------- Page -2- which are typical of Process H or Process P decnlorination, are notably increased. The tetrachlorobiphenyl 25-26-CB (peak 25) is also present. The latter congener is not a significant component of any Aroclor and is also indicative of dechlorination. It is probably derived from 236-245-CB (peak 69/6). The hexa-, hepta-, and octachlorobiphenyls are typical of unaltered Aroclor 1260. The dechlorinations can be summarized as follows: 25-34 236-34 234-245 236-245 245-245 ➔ 25-3 ➔ 26-34 ➔ 26-3 ➔ 245-24 ➔ 24-25 ➔ 236-25 ➔ 25-26 ➔ 245-25 ➔ 25-25 Thus the dechlorination appears to result fr~m a limited para dechlorination similar to Process P. State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director .MA DEHNR August 24, 1994 MEMORANDUM TO: Linda Rimer FROM: Bill Meyer j}J!'/ SUBJECT: PCB Landfill Expenses I am requesting assistance from the Department in budgeting funds for expenses incurred at the PCB Landfill in Warren County. As you know, there is a personal services contract in place for recommendation of evaluation procedures and long-term controls for the landfill. This contract totals $82,950. The Division has completed Revision #12-0578 to budget $40,000 from Division lapsed salary to fund a portion of this contract .. It was agreed that the Department would identify funds to cover the balance of the contract. We are requesting that the remaining $42,950 be budgeted from Department funds as soon as possible. The balance remaining in this contract is $25,478.34. However, invoices totaling approximately $31,000.00 are outstanding and we do not have adequate funds to pay these bills. Funds are also requested to pay for mileage to and from meetings and related telephone charges for members of the Joint Warren County State PCB Working Group. The work group members were told that they would receive this compensation from the state, and charges have been submitted. I am estimating that these could total approximately $5000 in fiscal year 94/95. The Division will process all related travel reimbursement forms and consult with members concerning required documentation. However, we need correct budget codes identified in order t9 have Fiscal Management process the reimbursement requests. We appreciate your help in identifying these funds. Please let me know if you need additional information. cc: Lois Artis Henry Lancaster P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 0% post-consumer paper SEP 09 '94 11:22AM 3MGMT 14 FP.OM NC DIU HA2EROU5 WAST~ 09.09.1994 P.1 !' .1 ... ,,,...,r_ cit No I rol/na n vlronment, of Resources II e Monogemant It Hu:rit ovarnor o~ B. H Secretory L; M$y~r DI actor l:!I ' : '! . I I• ' ' . August 24, 1gg4 J DUM I Gtef W~lshusen l, .. L:: •• :::l :;:: 'pJi~ TO ~ • Ttav l roil!lburaemant ~he bepar mi· tis involved in a Joint Stat -warren county PCB La d iil Work! g Group to discuss i11aues a~rrounding the PCB lad iil. So~ ima ago Department officials assured work group ri' that ha state would reimburse them for work rell!lted ~. ~• oall a~d for mileage to and from work group meetings. ! -•lllhers . aV:e recently submitted reimburs~rnent requests for l : ::and pho e oharqea in fiscal year 92/9 1 3 and tisoal year , :aa w•ll s current charges. i~hiuqh o ioy dictates that travel I expenses not be r• tor r or fisoal years, I am reque•t~ng an .exception to 1 y.· 1 ure to provide thesa reimburaamenta oould cause 1 0~.o true nd confidence. /ii,th .be h~py to provide detailed ~nfo ation conoerning t~queat. fleaae call me at 733-4996 if you have nny i9~s. I I : .o Box 2768?. ~al&! h, torth Carolina ~?6 l 1•7687 An EqLJQI OpP()rl ttv I ffirmoillM Acflori fmployar Telop/'1ori& 910--733·4 96 FN<. 919·'16-MOS fiOCr, r•cVcl&d/ l 0% I I I -! •• I • F• • 1 State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director NA DEHNR August 24, 1994 MEMORANDUM TO: FROM: SUBJECT: Greg Wilshusen Controller 4-Jll\ Bill Meyer y \ Travel Reimbursement ✓ The Department is involved in a Joint State-Warren County PCB Landfill Working Group to discuss issues surrounding the PCB landfill. Some time ago Department officials assured work group members that the state would reimburse them for work related telephone calls and for mileage to and from work group meetings . Group members have recently submitted reimbursement requests for travel and phone charges in fiscal year 92/93 and fiscal year 93/94, as well as current charges. Although policy dictates that travel expenses not be reimbursed for prior fiscal years, I am requesting an exception to this policy. Failure to provide these reimbursements could cause erosion of trust and confidence. I will be happy to provide detailed information concerning this request. Please call me at 733-4996 if you have any questions. P.O. Box 27687 , Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper To: Members of the Joint Warren County I State PCB Landfill Working Group From : Ken Ferruccio ~ Subject: Formulating Agenda Date: August 19, 1994 As co-chairperson, it's my responsibility along with Dolly Burwell to see to it that the agenda for the meetings are formulated jointly. This process can be facilitated if research , education, and other initiatives are worked out jointly at the behest of the working group and if we schedule joint procedures involving Pauline well in advance. Today I had to spend several hours on the phone in the attempt to work out an agenda that would reflect various concerns. We tentatively planned to have a presentation explaining the chemistry of PCBs and various detoxification methods that might be applicable and to have this information presented jointly by Sharron and by Pauline. However, after talking with Pauline, I learned that a joint presentation would not be possible because Pauline had not been notified early enough for the joint presentation. There were also other considerations: 1. The presentation would be of limited value if not presented jointly. 2. It was agreed at the last meeting that a consideration of detoxification methods prior to an evaluation of sampling data would be premature. 3. The presentation would not only be premature, it would not be the best use of our time since some things would need to be repeated at future meetings. 4. The discussion would not be scientifically and technically substantive at this time because of the absence of the needed sampling data base. 5. We could make better use of taxpayers' money and better use of our time by having Pauline attend only those meetings dealing with issues that are scientifically and technically substantive and by precluding needless repetition. Because of the above considerations, I decided that this committee as well as the taxpayers could best be served by presenting information concerning the chemistry of PCBs and concerning detoxification after sampling data have been evaluated and after concentrations of contaminants have been related to EPA environmental standards. This left us with the remaining agenda items that had been mutually agreed on: 1 . Considerations concerning Pauline Ewald 2. Security issues at the PCB Landfill 3. Replacing voting members who are unable to attend 4. Vouchers: Procedures and records On August 5, at 1 :45pm, a citizen of Warren County, who asked not to be identified, reported seeing activity at the state-owned Warren County PCB Landfill. Mr. L B Falkner, a resident who lives very close to the landfill was seen at the closed locked gate to the landfill property on August 3 at approximately 4:30 pm. At the same time, three men, who were unknown to the local citizen reporting the siting, were seen on the west slope of the facility just outside the fence that surrounds the landfill itself. These individuals had portable radios and were seen to use an auger to take three samples from the ground and place those samples in a brown cardboard box. The three samples were taken approximately 6 to 8 feet apart. The individuals were wearing yellow gloves. The Warren County citizen reported the observation to Pat Williamson, DSWM PIO on August 5 at 1 :45. August 4, 1 994 TO: Dee Strickland FROM: Sharron Rogers MEMO SUBJECT: Scope of Work for Triangle Laboratories Triangle Laboratories is to perform chemical analyses for seven (7) environmental samples, soil and water, by EPA Method 8290. This method is required to determine the amount of the chemical species of dioxins and dibenzo furans in the samples. Triangle is to perform this work under CERCLA-level chain of custody and with a high standard of quality assurance. A written report with supporting documentation of the anaylsis and quality assurance procedures will be prepared for each sample. _' n · ;;.:.{t.7'. 3¥4&4!WW State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director August 1 , 1 994 Ms. Alfreda Jordan-Webb County Manager, Warren County P.O. Box 619 Warrenton, NC 27589 Dear Ms. Jordan-Webb: .RA DEHNR The team from the Division of Solid Waste Management wishes to thank your team for their assistance during the environmental sampling effort at the Warren County PCB Landfill on July 28, 1 994. Emergency Management personnel, Gary Robenolt and Dennis Pascal, were excellent council to standby during the extraction of methane from the landfill. We appreciate their efforts and the hospitality of Warren County during our activities. Very truly yours, ~~~:,s xc: Bill Meyer Grover Nicholson P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director August 1, 1 994 Mr. Kenny Clayton Chief, Warrenton Rural Fire Department c/o Mr. Gary Robenolt PO Box 619 Warrenton, NC 27589 Dear Mr. Clayton: .RA DEHNR Please accept our sincere thanks for the assistance during our environmental sampling effort at the Warren County PCB Landfill. Our special thanks to the fireman who delivered the fan and stood by while we removed the methane from the gas vent prior to our sampling. This assistance kept us on schedule and contributed to our team's safety. We appreciate the hospitality of Warren County and especially the assistance of the Warrenton Rural Fire Department. Very truly yours, ~~---~ -~(---~ ~arron Rogers xc: Bill Meyer Grover Nicholson P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAx 919-71&-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director August 1, 1 994 Mr. Clarence Thompson County Maintenance Supervisor NC Department of Transportation Rt 4, Box 703 Warrenton, NC 27589 Dear Mr. Thompson: .NA DEHNR Please express to your staff our appreciation for the continuing high quality of care they give to the Warren County PCB Landfill. Their cooperation and quality of work is an asset to the state. During our recent environmental sampling effort, July 27 and 28, the preparation of the site, mowing and signage, was excellent. Thanks to your staff for their valuable assistance. Very truly yours, ~r~ xc: Bill Meyer Grover Nicholson P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper I'll ... ENVIRONMENT & l~U>I INFRASTRUCTURE ECEtvc:; ,. <'.? Otid Was• -,e --------------------------------------+~-2 19[)4 July 29, 1994 Mr. William L. Meyer, Director Division of Solid Waste Management Department of Environment, Health and Natural Resources Post Office Box 27 687 Raleigh, North Carolina 27611-7687 Re: Warren County PCB Landfill Afton, North Carolina Dear Mr. Meyer: RUST Environment & lnfras 551 0 Six Raleigh, Tel. (919) 676-5100 • FAX (919) 676-5259 I would like to take this opportunity to thank you again for taking the time to discuss with me upcoming activities at the Warren County polychlorinated biphenyl (PCB) landfill. It is my understanding that the State of North Carolina, owner of the landfill, will seek bids for qualified contractors in the future to detoxify the waste contents of the landfill. RUST Environment & Infrastructure, along with our sister company RUST Remedial Services, has significant expertise in innovative technology including thermal desorption and in-situ treatment of PCBs. Therefore, the RUST family of companies is uniquely positioned to assist the state in this effort. Please consider this letter as RUST's official request to be notified of upcoming bid opportunities in all phases of the work. Thank you again for providing RUST with an opportunity to assist your office in this endeavor. If you have any questions or I can provide additional information, please call me at (919) 676-5119. Sincerely, William M. Bremen, P.E. cc: Mr. David Priddy, RUST E&I G:\BD\CORRES\MEYERLTR Quality through teamwork 0 JAMES B. HUNT, JR. GOVERNOR STATE OF NORTH CAROLINA OFFICE OF THE GOVERNOR RALEIGH 27603-8001 ~uly 28, 1994 To the Joint Warren County and State PCB Landfill Working Group: In 1983, after the PCB landfill in Warren County was closed, I made a commitment that the State would monitor the condition of the landfill and the health of the citizens living near the landfill. North Carolina has maintained that commitment ever since. In addition, I made several other commitments to the citizens of Warren County. Since my return to the Governor's Office in 1993, I have taken a number of steps to reinforce those commitments, including the establishment of the Joint PCB Landfill Working Group at the request of Warren County. I am writing to you now to reaffirm those commitments and to thank you for your assistance in helping me fulfill them. I am pleased that you have been working for several months under the direction of the co-chairs from DEHNR and Warren County and that with the assistance of DEHNR, you have hired a technical advisor to assist you in addressing concerns about the landfill. You have identified three primary agenda items: (1) to perform a detailed environmental assessment of the landfill; (2) to evaluate technologies for detoxification of the PCB-contaminated contents of the landfill; and (3) to assess maintenance needs for the landfill's security, such as internal landfill water levels. While all three of these agenda items are important to ensure safety of the landfill, I am aware that detoxification of the contaminated soils is a priority concern. In 1984, a similar joint working group which I appointed to look at this issue recommended that detoxification was not feasible at that time. With ten additional years of information, research work, and practical experience with the clean-up of PCB-contaminated soils behind us, it is possible that a feasible means of detoxifying the landfill, which does not pose a threat to the community, may be found. . ~--.. ,. , Joint PCB Landfill Working Group July 28, 1994 Page Two I have instructed DEHNR to support your efforts to achieve all three of your agenda items. Funding has been made available to provide for your technical advisor. In addition, DEHNR has transferred $100,000 to Warren County to maintain and improve the PCB landfill. This $100,000 may be used for such items as improved security, lighting, electricity to the landfill site, or funding the environmental site investigation. All environmental studies conducted at the PCB landfill in Warren County to date show that there has been no release of PCBs to the area. Warren County remains a safe and heal thy community to live in, and I am committed to doing what is necessary to keep it that way. With warmest personal regards. cc: Warren County Commissioners I 1-800-9-ANALYSIS, INC. July 25, 1994 Sharron Rogers NC Division of Solid and Hazardous Waste 401 Oberlin Road Suite 150 Raleigh, NC 27605 Dear Ms. Rogers, I would like to take this opportunity to inform you of our capabilities and desire to be considered for any special analysis projects which may arise in the future. We are 1-800-9-Analysis, Inc., a full service chemical analysis laboratory located in Research Triangle Park. In addition to the normal range of analytes, we are also able to offer dioxin determination by high resolution mass spectrometery. Our certification number with the Division of Environmental Management is 436 and our laboratory number with the Public Water Supply Section is 37747. If there is ever any occasion for which our services could be useful, we would very much like the opportunity. Please do not hesitate to contact me at 919-558-1111 if there is any additional information I can provide you. Glenn Powell Laboratory Manager P.O . Box 12012, 85 T.W. Alexander Drive• Research Triangle Park, North Carolina 27709 Tel : 919-558-1111 (1-800-9-ANALYSIS) • Fax: 919-558-2222 (1-800-9-FAX-ANALYSIS) I State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management Jomes B. Hunt, Jr., Governor Jonathon B. Howes, Secretory William L Meyer, Director July 21, 1994 Mr. and Mrs. Ken Ferruccio Rt 2 Box 163-J Novtina, NC 27563 Dear Ken and Debbie: We would like to request your assistance in our completing the meeting records for the Joint Warren County and State PCB Landfill Working Group. As you noticed, we taped the meeting in the courthouse, and we plan to have a transcript of that meeting prepared to place in the notebook along with the formal minutes documenting the Group's work. If you could provide the audio and video tapes of the first several meetings, we will transcribe and copy them for inclusion. With these materials the record would be complete. Your foresight in making this record was excellent, and we appreciate your assistance in making the tapes available. We promise to take good care of the materials and return them to you when we complete the transcription. Very truly yours, ~~ Sharron Rogers xc Bill Meyer Henry Lancaster Members of the Joint Warren County and State PCB Working Group P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James 8. Hunt, Jr., Governor Jonathan 8. Howes, Secretary William L. Meyer, Director MEMO MA ·a-.-.1 DEHNA. JULY 12, 1994 TO: Members of Joint Warren County and State PCB Working Group FROM: ~er / Sharron Rogers \ SUBJECT: Transmittal of Draft Sampling Plan A draft of the Sampling Plan for the Warren County PCB Landfill is enclosed for your review. Please find an opportunity to review the document prior to the next meeting of the Working Group, which we understand is scheduled to meet at 4pm on Tuesday, July 19 at the Episcopal Church in Warrenton. Please contact us in advance of the meeting if you would like additional information or if we can assist in any way. Additional Distribution: L. Rimer H. Lancaster P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ HJ% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director July 1 2, 1 994 TO: Shaun Walsh FROM: Sharron Rogers NA DEHNR Department of E vironment, Health, and Natural Resources Division of Solid Waste Management 733-4996 71 5-3605 fax SUBJECT: Draft of Potential Letter from Governor Hunt to the Joint Warren County and State PCB Landfill Working Group As we briefly discussed, a letter from the Governor has been promised. The focus is a demonstrated commitment to the safety and security of the Warren County PCB Landfill. There are diverging agendas among the Working Group members in that some will be satisfied only with total detoxification, others want the facility to be secure and detoxification studied as an option. This facility is very important to the Governor. It's other name is "Hunt's Dump". A copy of the Governor's Open letter to the citizens of Warren County ( 1 982) is attached along with the new draft. Current consensus is that new letter will best be addressed directly to the members of the Working Group (about 16). We have a mailing list. In addition to the Working Group members, it may be appropriate to send copies to the County Manager, County Commissioners, Legislative delegation, and other key elected officials with whom the Governor routinely communicates in Warren County. The Working Group is meeting in Warrenton next Tuesday (July 1 9). Because the commitment for this letter (or press release) was made nearly two months ago, getting this letter ready before that date would be desirable. We stand by to assist in anyway appropriate. Thanks for taking the point on this for us. ,1 fso ~ U-n~ ~ ~ o<'°~~ ( ~~-1-1 'f 1) I) E//A-1/,(7 ~ ,~ ~-t"c___ ~ , P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-71&3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper Draft Draft Draft Draft Draft Draft Draft ..-Jm Ie-xx, 1994 '7\n Update for the Citizens of Vv'arren €-ot:tfft-v-r-- Many gallons of PCB transformer oils were dumped along roadsides in 14 North Carolina counties in 1978. After detailed consideration of all alternatives for protecting the citizens of our state, the United States Environmental Protection Agency decided that the only available option was to landfill this material. In 1983, these roadside PCB-contaminated soils were placed in a state-of-the-art chemical landfill near the Afton community in Warren County. This single purpose landfill is closed for any other use. North Carolina has maintained my promises to you by monitoring the condition of the landfill and the health of the citizen's living near the landfill. Since my return to the Governor's Office in 1993, I have taken a number of steps to reinforce my previous commitments to you. At the request of Warren County, I directed the Department of Environment, Health, and Natural Resources (DEHNR) to establish a Joint Warren County and State PCB Landfill Working Group. This working group has been formed and has met several times under the direction of co-chairs from the DEHNR and Warren County. The DEHNR has provided funding for a science advisor to assist the working group in addressing concerns about the landfill. The working group has identified three primary agenda items: perform a detailed environmental assessment of the landfill; evaluate technologies for detoxification of the PCB-contaminated landfill contents; and assess maintenance needs for the landfill's long-term security, such as internal landfill water levels. While all three of these agenda items are important to ensure safety of the landfill, I am aware that detoxification of the contaminated soils is a priority concern. In 1984, a similar working group recommended to me that at that time detoxification was not feasible. However, over the past 10 years much new information, research work, and practical experience with clean up of PCB-contaminated soils has occurred. t In an effort to help the working group with its agenda items, the DEHNR has proposed a design for a detailed environmental site investigation of the landfill. This study will include detailed chemical and physical analyses of samples taken from within the landfill. A preliminary workplan for this proposed study has been delivered to the working group members. Soil, surface water, groundwater, vegetation, and landfill content samples will be chemically analyzed. These results will be compared to similar findings from our routine sampling. This comparison will give a detailed current picture of the environment inside and near the PCB landfill. Knowledge of what has occurred to the PCBs and soils inside the liner of the landfill for the past 1 0 years will be critical to any consideration of detoxification options. At the working group's direction, I have instructed DEHNR to support the efforts of the working group in conducting a detailed technical review of feasible PCB-soil detoxification options. Findings and recommendations from this review will be reported to me and the citizens of the Warren County. The DEHNR has transferred $100,000 to Warren County to maintain and improve the PCB landfill. This money may be used for such items as improved security, lighting, electricity to the landfill site, or funding the environmental site investigation. All environmental studies conducted at the PCB landfill in Warren County to date show that there has been no release of PCBs to the area. This is a safe and healthy community to live in, and I am committed to keeping it that way. With proper care, this landfill can continue to be a safe repository for these materials for you and your grandchildren, while we continue to press for a feasible detoxification method. Draft Draft JA. .. U &. HUNT. Jf\. OOVE,.NOA 1:. . -..,, >• - STATE OF NORTH CAROLINA OFFICE OF l'HE GOVERNOR RALEIGH 27611 October 20, 1982 An Open Letter to the Citi~ens of Warren County: I appreciated the opportunity to meet with community leader~ and members of the executive committee of the Concerned Citizens of warren County on Friday, Octob@r 8. We had a full and frank discussion, lasting abo~t two hours. We did not Agree on everything, obviously. But it was A valuable meeting for me ~nd, I hope, for ~ll of you. I told your representatives that I Widerstand and respect your concerns about the PCB l~ndfill. Nobody w~nls a landfill of any kind in their community. Your representatives expressed your concerns in stron9, clear terms. They did not hold anything back, And I appreciated their frankness. In turn, 1 was frank with them. I told them that, in my jud9rnent, the State of North Carolina had no option but to place the PCB-tainted material in a safe and GQCUre landfill. The Environmental Protection Agency would not Approve handling the material in place along the ro~dside, I told your representatives that Warren County w~s chosen for the site solely on the basis of technical reasons. No other con5ideration whatsoever was involved. I also said during the meeting thAt the State of North Carolina does not intend to simply walk aw~y from Any responsibility once the landfill is completed. I made several commitments to that end, And l want to spell those out for you: l. At the request of your representatives, the state will sponsor a public meeting in Warren County at which our agency officiAl&, engineerG and scientists will review the safety features at the landfill and respond to your specific concerns and question». The meeting will b• held At 6:30 p.rn., Wednesday, October 27, in the NationAl Guard Armory in Warrenton. (more) r' ... Warren county Citizens Page 'l'wo October 20, 1982 .. r " . 2. The state will push as hard as it cAn for detoxifica~ion of the landfill when and if the appropriate and feasible technology is developed. We will seek to establish a joint local-state-federal working qroup to pursue this end. The State Board of Science and Technology, which l chair, will have the specific responsibility for pressing the Environmental Protection Agency to develop this process and for monitoring research to determine when detoxification is pos$ible. 3. The state will maintain continual monitoring of the landfill. Thi& will include the monitorinq systems included in the design of the landfill itself, monitoring df the residential well6 within A three-mile radius of the landfill and checking •treams Ana c.eek5 in the area. 4. The state will cooperate with your county health department in providing environmental and health monitoring for those persons who live, work or go to ~chool near the landfill. W~rren County Health Director Joe Lennon and or. Ronald Levine, the state's health director, will be responsible for developing a monitoring program that will guarantee that the health of the citizens in .the area is being protected. s. My administration will support legislation prohibiting any additional contaminated soil from ever being placed in this landfill and prohibiting the ~tate from ever placing another landfill in your county for any purpose. I understand that Frank BallAnce will be preparing legislation along these lines, and we will work with him on thi~ iasue. 6. 'l'he State Department of Commerce will make special efforts to help Warren County att~act ind\l'tStry and jobs. We will encourage businesses And industries to visit the county and consider sites there for expAnaion. The.e are the commitments I made on behalf of the State of North C~~olina. It ia my responsibility to see that they are carried out, and I tAke that responsibility seriously. (more) ... Warren county Citizens p4ge Three October 20, 1982 ,_ I know how controversial this matter hAs been, Again, I respect your concerns. And r take them seriou~ly. Your state government has A responsibility to you ~nd to all the people who live along the roads where the PCB materiAl wAs dumped, as well AS all the residents of North Carolina who might have been affected had that materi~l spread and entered the food chain. The state is convinced, on the basis of the best scientific evidence that is Available to us, that the landfill is safe and will remain safe in the future . But you and I have seen that scientists can disagree, and their disagreements concern Ui, That is why I intend to see that the State of North Carolina keeps its commitment t'o yo~, your children and your grandchildren to continue to press for detoxifioaton of the site, to closely monitor it And to guarantee its safety for generations to come. That is the pledge l maae to your representatives. in my office last Friday, ana it i5 the pledge I make to you I now. My very bast personal reqards. - STATEMENT BY GOVERNOR JIM HUNT Thursday, September 23, 1982 News Conference There has been a great deal of controversy over the PCB landfill in Warren County, and I think everyone should keep some important facts in mind. The dumping occurred more than four years ago. Since then, the state and the federal government have explored every alternative for disposing of this material. The Environmental Protection Agency has ruled out in-place treatment. This is the only alternative available to the state. We have looked at about 100 possible locations for a disposal site. The site in Warren County is the only one that met all the safety requirements and that could be obtained by the state. The federal courts have thoroughly reviewed this matter. All of us can understand the apprehensions people feel when any landfill is placed in their community. But we can assure the residents of Warren County that this landfill will be safe and will present no danger to them or to their families, now or in the future, and that no other material will be stored there in the future. Obviously, this is an emotional iss~e. Our society is having to learn to deal with hazardous waste issues, and it is tough. It is unfortunate that we have had to station more than 70 Highway Patrolmen in Warren County t0 handle these protests. All of /' us would prefer to have those pat olmeu on our state's roads and highways. But the responsibility of th~ State of North Carolina is to do what is right and what protects t live in Warren County as well as where the material was dumped. of our people --those who live in the 13 other counties The state will meet that resJ onsibility. TO: FROM: RE: DATE: MEMORANDUM VIA FACSIMILE SHARON ROGERS NCDEHNR PAULINE EWALD ECO DRAFT SAMPLE PLAN DATED JULY 8, 1994 JULY 12 , 1994 A review of the draft document reveals a standard approach and protocol with which ECO fully concurs. Two minor points include: • Potential desirability of one of the sampling parties analyzing the landfill contents forTCLP • Just for the sake of ECO's planning - a rough estimate of the number of samples you expect to collect for each area/media would be helpful - All other concerns regarding logistics of actually working on the site have either been covered in our previous conversations, or can be best handled by future phone arrangements. We are in the process of making a brief review of proposed protocols and methodologies just to the extent necessary to allow us to assure the working group that approved methods are in use. I will expect to discuss and settle other administrative matters after receipt of approval for the plan from the working group on the 19th. JAMES B. HUNT JA . GOVERNOR Mr. Heman R. Clark ST A TE OF NORTH CAROLINA OFFICE OF THE GOVERNOR RALEIGH 27603-8001 July 11, 1994 Parker, Poe, Adams & Bernstein Post Office Box 389 Raleigh, North Carolina 27602-0389 Dear Heman: • t Thank you for your recent letter concerning the situation with the PCB landfill in Warren County. I sincerely appreciate your offer to help with any explanations to the General Assembly. We are currently working with the Warren County PCB Landfill Working Group, which is composed of state officials and concerned citizens, to get their recommendations regarding testing, water removal, and detoxification. I hope to have their recommendations within the next few months. Thanks again for your concern and offer of assistance. Sincerely, James B. Hunt, Jr. JBH:wlm ,.• ·---Jon4tha11 B. HQwes Secret4ry "I Enl'ironment, ·Health,""" Natural Resources ...... -..... PI\TE: lJ) /I~ Pl.EASE: -.,._ Draft It reply for my signature And retum So me. -.,._ f(eply, noting Jh, leU~r was referred to yo" t>y m, (oopy lo ~retary'f Office). __,._Draft, reply for Sh~ C.Ovemor'a sign4ture AAd r,tumtom,. __ R~ply, noting Jh, l~tS.:r wo1s teferfe(f to yo" by GQv,mor HUil& (oopy to ~retary'a Office) _ FPr y PMr inloml41tion. -Toth 4pproprio1k: .iction. _ NoJt ~d tilt. _ Not, 11\d retum to me. _ Nott tfl41ff:f m, .-bout $his. _ Yo"r c:ommenti and/ or A!<X>mmendations. 512 N. Salisbury Street Raleig-h 27604 (919) 715-4101 ...., C jl1 z -: u; I rr: -i ji: -.... -~ I ' I -i fT1 I~ V I C z fTi -~ _j.,. -,n CD ..i.. rn ; . ..; ~,... 3: -..j J;.• °' tti z ~) rr; t·J;::: -✓ ,.._ LJ; ~ i:7 ;-; z ?:C G I X I 0:: I ~ H z ;-; • > r ' C en fTi I;:, -, .,.., fii -0 m z C iTi I t;:j ;o ;-: rr; c_r, w CJ: i-O C I'~ fT1 t;;H z ti:' Tl -< C ' rn oz ~ <. r I ....; z e' z CUHHE'.~F'UNDENCE HUUTIN(; !31-11:El ~ TO: LEGISUfl"IVE. COUNSEL -I..:; ATTN: BRAD WILSON ~"";-1-: ____ __ER.OtL ____ Ji.Q.Y.£.BJiOB Is OFFICE ---· ---I j ··<:'<:'lJE' ·t··1F(): c168 i::·• .. iu /I ''·1D1::·[I I . .I. ~1,.> . . I~ > i:;.I~ v, -f~I~ .. ·-_ I-~ RESPOND BY: 06/27/94 7! ... ~CASE NUMBER 332272 -DATE INITIATED: (·)6/09/</4 CLUSED: ' --·······-----------···-------·-,u~ME: CU:iHK HEMAN t'.l. ·" ADDHESS: 1::i{~H1< ER , POE, ADAMS .~, BERNSTEIN i:) .• o. BOX ~ms1 t_;-;: -·---· ··--'~.BJ-:-l;JL~l:!_ _______ NG 276(12 1-,, 1-t:: I I~' COUNTY: WAKE TELEPHONE: . REPENDED: R -RECE..IVED OFFICE OF THE SE-CRET,I\RY JUN 15 1994 ENV1Rp;uvlS.NT. Hu\Li:H ----··--'"S_ ----:i-;--s f 9 i.f ~I-· , ______ 1-:Q_l;_H'.WJJ: SEEKING HELP TO GET THE G.?l. JD APF~fUJPH1ATE H '.:iMhLL ,:.frlUUN·r OF"':MONfY TU. 1 • ~, DEHYDRATE TH£ P.l::~~LANDR-Il::L:.~1Nti44,ARREN~CO~l:Y· •. ,... , 20! 2 ,i ---·--·-·· ·---------·-··· ,22: r;; ___ SPECIAL PRIORTY -IMMEIHATE REPLY :,7 ___ ll_E;T_!.JRN (HJJ~_t:l:I_ED. Mi-lTEgJALS .... _ ~ ____ FOR YDLIR INFORMAT:CUN / COPY AND RETURN·· ~ ___ PHONE OR SEE ME AT YOUR CONVENIENCE 111 OTl_:I_ER -··--· ··--· . --------------·-. -•-·----· ---····---~81 .-1 [-;; PH EPA RE l~EPL Y SU IT ABLE FOR GOVl;HNOR ' S S :C GNA]J,J_BJ;;_ ANll _ _,_,_RE--·_.__.rt ..... JI_....U-J..,_ _____________ _ ~ "-:::-L_ ,~Cl<NOWLEDGE STATING GOVERNOR H£FERRl:::D. ~-RETURN LErrER AND COPY; OF CONSTlTUENTS Ll::TTl::R ~ ___ DRAFT REPLY SUITABLE FOR SECRETARY OR AGENCY. HEAU SIGNATURE AND RETURN . I 33! FURN lSH TH Is OFFICE w I TH I NFOJi.t1AL! OJL.f.Dfi:_R£.Se.oNS.E_I_O_lN..,..Q._wU ..... I,._,_R..,_,.Y~: --------------~ ___ IMMEDIATE REPLY BY PHONE -NO WR1·rTEN CORRESPONDENCE NECESSARY -RETURN FORM --------------------···---·--·---··· ---·· ---·. . j \i_ ~ ~ ~ ·!~----·-·-···_-·····---_· ------'---------: . ~ r ~ I____._,,-~ --. ----.. ----------~ ---LAW OfflCt:S Of PARKER, POE, ADAMS & BERNSTEIN P.O. BOX 089 ONE EXCHANGE PLAZA RALEIGH, NORTH CAROLINA 27602·0089 TELEPHONE 919·828·056-l FACSIMILE 919 ·tl:34·4564 CHARLOTTE OFFICE HEMAN R. CLARK 2000 CHARLOTTE PLAZA CHARLOTTE, NORTH CAROLINA 20244 TELEPHONE, 704-372·9000 FACSIMILE: 704·33••.a70G RESEARCH TRIANGLE PARK OFFICE P.O. BOX 13039 June 6, 1994 RESEARCH TRIANGLE PARK, N.C. 277011 TELEPHONE, 918·544·4500 f'ACSIMIL£: 818·1544-2788 liOUTHPARK OFFICE 4201 'i,ONGRESS ■T. au,n: 140 CHARLQrfE, NORTH CAROLINA 28209 Td£PHONE; 704·1550-8000 ,-AC51Mll£: 704·1580·800, The Honorable James B. Hunt Governor 116 West Jones Street Raleigh, NC 27603-8001 Dear Governor: our P.C.B. landfill in Warren County won't go away. FILE NUMBER DIRECT DIAL Now the 11protestors11 are saying we broke our promise to "detoxify'' (which would be a shameful waste of lUUch tax money) . I do think you should consider having the water pumped out of the landfill. You remember we had several heavy down-pours of rain fall just before putting the cap in place. There have been no leaks but we can ft say there never will be. It may not be a dangerous condition but it sounds bad. For a relatively small appropriation, the dehydration can be done. Bill Meyer the highly competent Chief of Solid Waste Management Section, knows exactly what needs to be done. As long as the water remains inside the liner, the protesters have a logical basis to continue their expert agitation in the community. They ar~ at it again, talling that far~ producto from the are~ are unfit for human consumption. If there is anyway I can help in explaining this need to the General Assembly please let me know. With warm regards and best wishes, HRC:bps - LAW OFFICES OP PA.BR.EB, PoE, ADAMS & BERNSTEIN L.L.P. P.O. BOX 089 ONE EXCHANGE PLAZA RALEIGH, .NORTH CAROU.NA 27602-0089 L 1 ~ f_ !_; i: i \ ::.T u:.1·,_:[Yf.Jc;; .. :·s OFF /Cf 91: JUN -8 Ml I/: I 6 Go,,.-o.\.t':•)'s oFr.'CE _____ ._t". ,1 _I_ :. .:.·.!..~:.....i.: I I The Honorable James B. Hunt Governor 116 West Jones Street Raleigh, NC 27603-8001 .., ... ltlll : : " I ,: II (' " 1' 1' I Ii ;,111 •; i !li Ii ii Ii II:! llll I! i I iii: 1 .•.• -.:. ··.-_· ·: .• r ::.; ,. ; : tf .• !· I ,C/ ,,:fid W, J/1. 12 To: Bill Myer, Director Solid Waste Management CC. Committee Members, Joint Warren County and State PCB Landfill Working Group Debbie Crane, Director, Public Affairs Dr. Ronald Levine, State Health Director Dr. J. N. MacCormack, Director, Epidemiology Division Dr. Sam N. Merritt, Director, Laboratory Services Linda Rimer, Assistance Secretary Environmental Protection From : Ken Ferruccio )(j Subject: June 24th Letter Concerning Mr. Larry Green's Well Date: July 9, 1994 Your June 24th letter to me inaccurately states what I said to the Joint Warren County and State PCB Landfill Working Group at the June 21 , 1994 meeting. For the record, I said that there are conflicting data concerning the Green well and that it therefore ought to be tested. I said the testing of this well was of particular concern because doctors have linked the kind of cancer that Alvin Green has to PCB poisoning. I did not indicate that the well was contaminated. I indicated that there are conflicting data concerning the question of contamination. I did not indicate that the level of contamination exceeded water level standards, I indicated that there are conflicting data concerning contamination in excess of water level standards. You should read my memo to Dennis Retzlaff concerning prejudgments. On June 28, Vicki Wesen of Emmanuel Episcopal Church called me in Columbus, Ohio, and read me your letter. After hearing the content of the letter, I immediately called you and explained the location of the well where the Greens presently reside, the well in question. Immediately following our conversation, Deborah mailed a sketch indicating the location of both wells, the location of the well at the Greens' present residence as well as the location of the well at their former residence. I'm informed that the Greens no longer use the well at their present residence, but each week use several containers of water from another source. I have been in their home and have seen for myself the many containers of water that they carry to their home each week. Split samples from the wells would perhaps afford the Greens some measure of certainty concerning the status of their situation. Enclosed are copies for people mentioned in your memo for whom we do not have addresses. Would you please see to it that they receive their enclosed copies? , f To: Dennis W. Retzlaff, Warren County Health Director CC. Jonathan Howes, Secretary Department of Environm_ent, Heath and Natural Resources . .. V. Alfreda-Jordan Webb, County Manager. -~ Members, Joint Warren County and State PCB Working Group From: Ken Ferruccio Kr Subject: Mr. Retzlaff's June 23rd Letter to Secretary Ho,wes Date: July 8, 1994 · Thank you for submitting to me, to County Manager Alfreda-Jordan Webb, and to members of the Joint Warren County and State PCB Working Group your recent letter to Secretary Howes. I commend you for your open participation in the process. It seems appropriate for the state to respond to the questions mentioned in your letter. I wish only to evaluate your position that prejudgment implies a closed mind incapable of making objective decisions involving several options. The loglcal fallacy lies In the assumption that a prejudgment necessarily Implies a closed mind. Your letter contains several prejudgments. Does It therefore logically follow th.at because you have prejudged, you have a closed mind? Of course not. Concerning the relation between prejudgment and objective decision- making, the Issue Is not the prejudgment, but the attitude of the mind toward the prejudgment. If the mind regards the prejudgment as a hypothesis to be tested and not as a reliable basis for action until the objective analysis has been completed, the mind is understood to be open, even when the prejudgment is stated as a belief, as in your letter to Secretary Howes, or as an intention, as in Bill Myer's statement to Pauline Ewald that he had no intention of detoxifying the Warren County site. To the extent that you and Bill are prepared to suspend your final judgments until an objective analysis has been completed, you deserve the benefit of the doubt -- namely, that your minds are open and capable of entertaining several options. If, on the other hand, the mind regards its prejudgment as an accurate description of reality, or as self-evident, and as providing a reliable basis for action prior to the completion of the objective analysis, the mind· would seem to have arrived at some measure of closure. For example, the regulatory and legal basis for constructing dangerous landfills on intrinsically unsafe sites was based on EPA's prejudgment (hypothesis) that engineering principles could transform unsafe sites into safe sites: (I) EPA Official Mat Strauss: And it was our feeling that if you could design a landfill to meet [ zerb percent discharge -nothing leaving the landfill], then you do not need fifty feet, or twenty-five feet; you only need sor:nethin'g ~like five feet [from woundwater]. Deborah Ferrucclo: What are you going to do if something happens? Strauss: Well, there are several things you can do. You can dig up what's there, or, no, what I'm tell ---well, it's designed not to leak. (transcript of conversations between Warren County delegates and EPA officials: Office ot· Toxic Substances, Washington, D.C., February 5, 1979.) So, on the basis of a prejudgment having a purely hypothetical status, regulations governing sitings were enacted Into federal and state laws authorizing the construction of landfills on Intrinsically Inadequate sites. Although EPA finally ad!Tiitted in its Federal Reg ister of 1981 that all landfills will eventually leak, and made a similar statement In the July 1982 Federal Register, it was too late. What had:been intended as a scientific rationale for siting landfills in intrinsically unsuitable ·places ( the prejudgment that unsafe sites could be transformed Into safe sites by engineering principles) had been changed by testing Into the final judgment that unsafe sites, Indeed, all sites, would eventually be transformed Into sacrifice zones. In September of 1982, two months after EPA's July statement that all landfills will eventually leak, Hunt used force to site and was met with resistance because EPA's final judgment, based on objective analysis of data, invalidated the prejudgment upon which the regulations and laws governing sitings had been (and continue to be) predicated. Concerning the siting decision, scientific criteria had yielded to political criteria, and political criteria to force needed to implement siting regulations and laws based not on science, but on a rationale for selective human sacrifice. Environmental rights had become civil rights. The 1982 civil rights movement was, In essence, a demonstration against basing crucial environmental regulations and laws governing siting on an untested prejudgment that threatened then as now the existence of targeted communities. So, you see, Dennis, It Is not necessarily the prejudgment that closes the mind that trips the wire that triggers the action that lorces the moment to Its crisis; It can be a final judgment, or It can be treating an untested (l) prejudgment as though it were a final judgment based on testing. Prejudgments and flnal j~dgments Inform negotlatlonal frameworks. Some things are negotiable, and some things aren't. Some things ar, open, and some things are closed. This Is true of the mutually-agreed- upon framework wl,hln wttlch we are working. You should read the framework, Dennis. You wllt find that although detoxification Is the central consideration, and although we are helping Governor Hunt fulfill his promise by helping the state push as hard as It can for detoxification, the framework Is Informed by a suspension of judgment concerning the nature of the flnal resolution. r : To prejudge is to be human. If we were God, perhaps we could assume a mental state of absolute neutrality concerning the minefield of conflicting interests and emotionally-charged issues confronting us. However, because we are human, prejudgment is inevitable. In research, ·a prejudgment is a hypothesis. Without it, selection of data would be random and meaningless since the purpos~ of the data is to test the hypothesis, and you -can't test what isn't there. We would do well to keep in mind the point I make to my students when I teach them research : Do not reach your final conclusion until you have completed your objective analysis. In the Ideal world, the mind can suspend even final judgments lndeflnlh!ly, regarding them as tentative at best, subject to reevaluation as needed. But In the real world, suspension of final judgment must finally end, and action begin after the completion of the objective analysis. Some say It's courageous to act on convictions. Others, that It's courageous to transform convictions Into hypotheses and to think about them. ijut perhaps the most enlightening position Is that by Integrating contemplation and action, one can change the whole configuration. The unenviable task of this committee Is to establish an Interpersonally agreed upon description of "reality" concerning the PCB situation with some measure of accuracy and to resolve the crisis through consensus within the mutually-agreed-upon framework. I believe that we can achieve this goal by working together and by treating prejudgments as tentative until the objective analysis has been completed. I have already encouraged a multlpllclty of perspectives and so have Secretary Howes, other state officials, and committee members. I have already publicly stated my view that you bring an Important perspective to the committee and that I am grateful for your participation. Thank you again for contributing to the dialogue. (3) TO: Hanna Asefa Bobby Lutfy David Lown Gray Stephens John Neal Pierre Lauffer (info only) Larry Perry (info only) FROM: Sharron Rogers MEMO July 5, 1994 SUBJECT: Meeting to review Draft Field Sampling Plan for Warren County PCB Landfill Reminder that we will meet Thursday, July 7, from 9 am to about 10:30 am in large conference room to review progress on the draft field sampling plan and our other related research efforts. Please let me know if you will be unable to attend. xc. Bill Meyer t State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr ., Governor Jonathan B. Howes, Secretary William L. Meyer, Director June 28, 1994 TO: Linda Rimer FROM: Bill Meye~ MEMO SUBJECT: WARREN COUNTY PCB LANDFILL AND OPPORTUNITIES FOR FEDERAL COOPERATION In 1978, many gallons of PCB transformer oils were dumped along roadsides in 14 North Carolina counties. After detailed consideration of all alternatives for protecting the state's citizens, the US EPA decided that the only available option was to landfill the material. In 1983, these roadside PCB-contaminated soils were placed in a state-of-the-art chemical landfill near the Afton community in Warren County. The clean up and construction of the landfill was funded by CERCLA funds. The landfill is permitted by TSCA rules. By state statute this landfill and a 25-mile radius are closed for any other hazardous waste management purpose. Since 1983, DSWM has maintained and monitored the landfill. The landfill is owned by the Div. of State Property in the Department of Administration. Upon return to office in 1993, Governor Hunt established the Joint Warren County and State PCB Working Group. Under this group's direction, DSWM has established a workplan that will result in an assessment of the current environmental conditions at the landfill, including the first sample of the contents of the landfill since its closure more than 10 years ago. The results of the field studies defined by this workplan (Field work will occur in late July by the current schedule) will support the next goals of the Working Group: 1) plan for the long-term maintenance of the landfill, including potential dewatering of excess water trapped in the landfill, and 2) evaluate options for detoxification of the landfill's PCB contents. As part of the preliminary design of the Workplan, EPAs Athens Lab and GE's Corporate environmental group were contacted because of their expertise on anaerobic PCB-contaminated soils. Both have expressed considerable interest in our planned work and have volunteered sample analysis and results interpretation. The contact at the EPA Lab in Athens chairs the lnterlaboratory work group on PCBs for EPA ORD and has requested time at their next meeting to share the results of our preliminary efforts. He anticipates EPA's continuing research interest and potential funding for our investigations and potentially for remediation activities. In addition to this source, other potential EPA funding opportunities that can be explored include the SITE (Superfund Innovative Technology Evaluation) program and the Superfund TAG (Technology system grant) program. Other sources remain to be identified. Can EPA assist in determining other potential funding sources or in capturing funding opportunities? ~ _' W fe I ~'?'(_ P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-c onsumer paper Dr. Daniel A. Abramowicz Manager, Environmental Laboratory General Electric Company PO Box 8 Schenectady, NY 1 2301 -0008 Dear Dan: June 27. 1994 There is no question that I felt like I had hooked in on a gold mine when we talked on the phone. The materials you sent me about anaerobic dechlorination of PCBs, together with the material that John Rogers provided has confirmed this. I waited to thank you in writing until our citizen's working group had a opportunity to approve our draft workplan, so that I could provide you with a copy. We are currently fleshing this out into a pre-mobilization plan for final approval on July 19. Hopefully, very soon after that date we will be sampling the PCB Landfill. We do, very much, wish to take you up on your offer to analyze a sample and to assist us in interpretation of the chromatograms. I will be in touch shortly to plan any necessary logistics. Very truly yours, Sharron Rogers Enclosure xc Bill Meyer State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management Jomes 8. Hunt, Jr., Governor Jonathon 8. Howes, Secretory William L. Meyer, Director Dr. John Rogers _,.,,.t:1/J -~- NA DEHNR June 27. 1994 EPA Environmental Research Laboratory 960 College Station Road Athens, GA 30605-2720 Dear John: Thanks so much for the excellent insight into anaerobic dechlorination. The materials you sent me, together with the literature that Dan Abramowicz provided has certainly confirmed the need for our continued investigation. I waited to thank you in writing until our citizen's working group had a opportunity to approve our draft workplan, so that I could provide you with a copy. We are currently fleshing this out into a pre-mobilization plan for their final approval on July 1 9. Hopefully, very soon after that date we will be sampling the PCB Landfill. We do, very much, wish to take you up on your offer to analyze a sample. I will be in touch shortly to plan any necessary logistics. EPAs interest in this project from both a research and a practical remediation perspective is very important to us. ;pi?_~ Sharron Rogers Enclosure xc Bill Meyer P.O. Box 27687, Raleigh. North Carolina 27611 -7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper tlldod tol.Uhtuo~-t~d 1.ot tr,nnb"'' tog 1nA01d,111 uo1f:,'1' n111to111~llv Attuhftoddc; ,-,nbi uv ~t~ll-AlA ~l 9M~·ttl·&l& tJtJoqd~f81 lff9l-lt9a bl.JltoJb:J t.ttJof..J ·ltt,tolbM · l99lt '<od ·o·J ·htta~ Atddng j~1~~ ~Ut~ttfjp p~:t~ttttttij:tUoo Atttit:ttt~:tod ~ti~tt:i tttojj Uo~.1:ed Au1? o:t ~.ih~od~~ t,~httt:tttoo ~tt~A~.:td t,i Uc,t :toV 6:tbt.:tdoJddt 8~~1 01 j~pjo Ut 8t~t~nod ~~ Uoon ~, 1~~h~d.i ftt~:t tt1fM 8oU~p.iotiol Ut t,el!t.1o1Ut a~ Uot~tAtd ~~1 1~~1 tijt:tU~ffft~ It it ·~tt~M ~s~~1 ~1t~ P~1ijtoo~~~ ~tt.:t~ottod tt:tte~tt btt~hd t,tttf tb:tlHHlUo.itAUa tUot1 stuUt,t,~ o:t A.i~~~~n~tt tittot:tn~ t;U~tlttltoo~.:t pttij ;~:ttihtVAd 181~5f~seAUt o:t :t.:tojjij ~1~fp8ttttttt Uij @:tijf1tUt ttfM ~ot11o tt1.:tt;:tod.:ttct tt1tt!~tt ~1~:H~ t,tti t,tt~ 1u~ttt1:t~d~d ttit~tttt l:tUht;j U~.i.it!M 'BUtift.:t~d pa1oa11a ~~1 ~1tH Uot1~:t~dooo Ut UotfttAtd lttt ·Atddttft .i6:t~M ~Uf~Uf~~ ~ ti~ httijA ~~ett1 ~Uthtt At1tta.:tJttd'8.i~ .id ~A~~ At!m :ttitt:t htto~j~d ~a~1o Au, pUij h:t9UMo jti ~~8.:tpt,ij pUf flMtiU ~~1 pUij ~tt~M .i~:tbA ~Ut~Uf.ip o~1 ijq1 jo nttot1~oot ~~1 jb Ubl~&of1t-!Uijpf ~ttoA g1ijto,Jdd~ PtnoM 1tl~ttt~6ijUbN ~1tt~M Pttos jo Uotftt td ft~t . •.:t91~~ ~Ut~Uf.:tp 30 oojhb~ ~ Hti tttA Atddtt~ Jd1~MpUttdJ~ v ~~sn ~u1? ttt1ptt~t ttnJ ~~1 01 A1ttttt*0Jd lftijto Ut pijAtt '1g~d ~q1 Ut 8tttf1 9mog 1~ •u~~J~ •jH ~tq1 p~:t~1ft ttoA 'Udf1tPP~ Ut ·U~d.:t~ ·JM l~ p~oU~f.:t~~~~ J~::;Uijo jo @oU~~toUt Uff ij:ttA ~8ittooftftij ~q 1~6t6t t,UV gp.1:~pu~-.,~ j~:t~M ~Ut,tUt.1p p~pfttto*i ttot1tttftttij1Ubo jo t~A~t ~~1 :t~~1 p~~~~tPUt b~tij hoA ·U~~j~ 'jN ~ jij loUftpf~~j tHt1 1tt ttftM :ht1~M 5Ut,tut.:tt, t,tt:ttUtttt~1ttoo otJtodd~ tf jt, ft.:tij~ti b.:t9H hoA ittt:t '6UJ:t~ettt •6~t 'tt ~Uttr @q11~ 1dttb.:t~ ~Uf~jijM ttt1t,UtM tt::,d t:t11t:Ut t,Utt A:tuno::, tie:fj~M 1Uto.r tt~1 b:t t,tt:t~dtt,Ut hoA Ht t -. _I C1 ---~ ~ .t;t;t '•i ~Uttr !ofoott.ij~J '.:tM jijijd t~9lt ::,U •~utAoN .r t~t ~bd ~ ~1ttoa otoon.:t.:t~A ~1ftUU8~ •jM Jot~e~d · JeAew ·1 WbflttM AJbtt:tJ:J9S ·~eMof~ ·g Ub~tbuor JolJJeA09 •·Jr 'tUhf-t 'd §eWbr tueweabubW et~bM bHoS Jo UofsfAld ~a::>Jhose~ fbJhtbN pUt:; \JtlbSt--1 'tUeWUoJtAU~ Jo tUSWtJbdSd bUfloJb:) lUJoN jo etbts ,, . dno~~ ~Uf~joM tttJpU~1 ttod B1b1S ptlij A1unoo U~jj~~ 1tttor '~j~qtit~W ~~11tttttttoo Uot1o~1dJd t~1Ug~UojfAU~ Ai~1@jo~S ffotl~1~t~~V 'J~Mtij tipUt1 ftffotAJgg Ajo1~jo1~1 'Jo1o~jtd 'i1tjj~N ·U fflij~ •jd U~fltAfd Afiototm~ptd~ 1Joiogjto •~o~ttt.i~~o~M ·h't •jct jo;o~.:ttd ~1t~~u ~1~1~ '8UfA~1 ~t~Udtt lJd IJf~jjV ~At1~t~l~81 ~httad 'Jo1o~jfd 'J~1~~dU~1 AJU@tt 1U~~dot~A~ct ottod ijtttt~d 'jo1o~jfd '~J~d~ttd U~or njt~111 oftqttJ 'jo;o~Jld '6UijJ~ 8fqq~d Jo1og.:ttd ~1t~~« A1utto~ tl~jj~M 11ijt!1~ij ftfUU~d A1unoo U~jj~M •~J~uot~nftlhttdj A;uno~ 30 pj~od ij~1 jo u~mjt~~~ 1httt~A~d htttoh1 !oo I tt t jo10~.:ttd ~~A~u ·1 m~ttttM . ("11~11 fl ~111(71, 'At~U~oUts 1tP!N1M -~nuodff~J ~oth~ .:tno~ 6UfAf8offJ 01 pj~Mjoj g~oot Uot~tAfd ~ij~ t 1t;~J otoottjJijA ~1dUUe~ ·JM •tf;t 1 •t ttUht .,,~ June 23, 1994 Mr. Kenneth Ferruccio Route 2 Box 1 63 J Novina, NC 27563 Dear Mr. Ferruccio: On June 21 , 1 994 at the meeting of the Joint Warren County and State PCB Working Group you made a statement to the committee and to the press of your anger that the state was taking no action regarding a drinking water well in Warren County. You report that chemical concentrations in the water sampled from this well exceed all drinking water standards and are associated with a cancer case. Despite repeated requests, you have been unwilling to divulge the name of the well owner or the street or mailing address of this location. The State Health Director with the cooperation of the Warren County Health Department is prepared to respond within 24 hours to conduct a chemical sampling and epidemiological and public health evaluation of this case. We cannot activate this process if you are unwilling to divulge the location or persons involved. You should be aware that if this case exists your failure to provide this critical information prevents the state from taking appropriate action to protect the public health. XC: Ronald Levine, State Health Director Respectfully, William L. Meyer Director Dennis Retzlaff, Warren County Health Director , . )I --'.,•• ... • •/ 9.nafh!Jn B. Howes Secretary of Environment, Health, and Natural Resources TI>. &....., . / ~-, RESPONDBY: C\ a,~ v DA TE: /_, -~ 7 -p PLEASE: REMA --"----1 Draft a reply for my signature and return to me. -----l Reply, noting the letter was referred to you by me (copy to Secretary's Office). ---+-Draft a reply for the Governor's signature and retumtome. --+-Reply, noting the letter was referred to you by Governor Hunt (copy to Secretary's Office) For your infonnation. ETake appropriate action. Note and file. . Note and return to me. __ Note and see me about. this. ___ Your comments and/or recomrne: 10 J),11 m~'&---~-~ ---30119 ...... ra-....c.' !!_CR~ ~ w-<.-!'l'e€-9 ~ ~'<--clo~ ~,!: <1, \\. L-1vl) s~~-\,5 512 N. Salisbury Street \f'IVo\u-tJ y-~ ~ b.JU. \-\e:;(;'11.-Raleigh 27604 (919) 715-4101 WARREN COUNTY HEALTH DEPARTMENT 544 WEST RIDGEWAY STREET WARRENTON , NORTH CAROLINA 27589 June 23, 1994 Mr. Jonathan House, Secretary North Carolina Department of Health and Natural Resources Post Office Box 27687 Raleigh, NC 27611-7687 Dear Secretary House, TELEPHONE: 257-11 85 FAX #: (9 19) 257-2897 I write to express my deepening concern regarding the "Joint Warren County and State PCB Landfill Working Group". It has been my hope that the purpose of the "Group" would be to work with state officials and an outside technical consultant to gather the best information possible on the degree of health threat posed by the PCB Landfill and assess the availability of reliable technology for detoxification of the Landfill. Armed with that information the "Group" could then make recommendations to the state for future management of the Landfill. The decision to recommend detoxification should be based on an assessment of the benefits to be derived from such a procedure balanced with the economic costs and other risks related to detoxification procedures. The "Working Group" is dominated by individuals who have demonstrated that their commitment is to seek detoxification. That perspective is a valid one but it should be one of the perspectives represented in this organization. I would request that you personnally review the procedures which were used to determine the membership of the "Working Group". Questions to be considered in such a review could include the following: 1. What role was given to duly constituted bodies representing the citizens of the County such as the Warren County Board of Commissioners and Board of Health in the early formulation of the members of the "Working Group"? 2. Were any guidelines developed to assure proper representation of a variety of Warren County interests? If there were any kind of guidelines used, were those ever put in written form? 3. Who from Warren County had significant input into the selection of the members of the "Group"? 4. When was the first official, written list of the membership of the "Working Group" made generally available? (I did not see any written list until Mr. Bill Meyers distributed a draft list last week). . , . " I • Mr. Jonathan House Page 2 I believe a review of the history of the development of this "Group" will demonstrate that the organization was created without sufficient input from local recognized leaders and is dominated by individuals who have prejudged the situation. The "Working Group" cannot, as presently constituted, do an unbiased assessment of the relative risks of the Landfill and make balanced recommendations regarding future management of the PCB Landfill. I would request your office to work with the leadership of the "Group" to expand the membership to include more members who have demonstrated concern for environmental and health matters but have an open mind regarding the various options available for the management of the PCB Landfill. Warren County citizens face health risks from a great number of sources and available resources should be allocated to those areas where intervention can be shown to be most effective. There are a number of environmental challenges facing the state and available resources should be allocated to those problems demonstrated to pose the greatest risks to our state. This "Working Group" will do a disservice to the citizens of Warren County and the State of North Carolina if it is allowed to pressure state officials into expenditure of funds for detoxification or other procedures for management of the Landfill which cannot be justified in terms of potential health protection for the citizens of Warren County. Thank you for your careful consideration of these concerns. si~rel:;W ;?!'hi LA De ~ Ret~~-f, fp"e'ctor CC: Members, Joint Warren County and State PCB Landfill Working Group V. Alfreda Jordan-Webb, County Manager State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director .NA DEHNR June 22, 1994 MEMORANDUM TO: Bill Meyer FROM: Brenda Rivers~ SUBJECT: PCB Landfill Contract Revision 12-0365 budgeted $40,000 in Solid Waste Management Division FY 93-94 lapsed salaries to fund approximately one-half of the PCB landfill contract. According to legislation passed in 1994, contract funds in object 1990 cannot be carried forward to subsequent fiscal years if they were funded from lapsed salaries. Therefore, this $40,000 will revert on June 30, 1994. The current contract will remain in place and the Division will rebudget funds after July 1 from projected lapsed salaries to support this portion of the contract. The total contract amount is $82,950. It is our understanding that the Department will identify the remaining $42,950 in FY 94/95 to support this contract. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper 11/11/1992 22:18 --.,-, ,f -~· 19192571971 MEMO WARREN CO FARM BUREA 1ct4d tu .\ I. J ' \ \J_R '-\.:) I 'J'-\ ' Q_Q"-....~ \u\ 'Jn ~ . b -a 2> _cl TO: MEMBERS OF JOINT WARREN COUNTY STATE PCB LANDFILL WORKING GROUP COPIES: Jarnea B. Hunt, Jr., Governor of North Caronna Jonathan B. Howe1, Secretary, DEHNR FROM: KEN FEARUCCIO SUBJECT: COMMENTS BY PAULINE EWALD: SCIENCE ADVISER DATE: JUNE 21, 1994 Pauline told me yesterday that she had not yet received the warren CouotY PCB Landfill Wo[kplan for eavlrpomental Sampling. I therefore called Bill Myer who told me that the draft had been mailed to Pauline at least a week ago. Nevertheless, Bill agreed to fax the draft immediately. Paufln••• Commenta: Spllt Samplet rm not happy with the fact that a year ago I said, fine, let the state do the wor1< that would have to be done, but let's have split samples (10% or 20 %) done by ECO. And that was the understanding. But now they're trying to aVOid split samples. Are these people [Division of Solid Waste] going to cooperate with us or not? It's a very simple, a very rationaJ thing we have asked for. For example, for every 10 samples they do. we split one and send It to another lab, preferably out of state. It's the best way to ensure the validity of your data. We can't control the amount of conversation going on between tho state and a lab. There has been manipulation of data because of political sensitMty. It's a good idea scientifteally and from the standpoint of public perception. The tab would be independent but EPA approved. This is a standard thing. Over a year ago I talked With Bill, and he agreed then to split samples. Now he seems to be doing somersaults to avoid letting that be done. If he can't do a $2,500 split sample or so for a scientific interpretation of the data, the commitment to detoxification would seem dOubtful. We have John Humphrey's views, but his views have not been brought hOme to Bill Myer. These are the people [Bill and Sharron] that need to be brought In line. PAGE Ell \VEO a\id wute ~ 22 \9M ~-(,S 11/11/1992 22:18 19192571971 WARREN CO FARM BUREA PAGE 02 ,, ~. Either these folks are going to cooperate or they are not. They haven't even sent me the most recent draft of the proposal. 1 'm very unhappy about that. Qufftlon: Speclflcally, what further points do you want me to ahare wHh the committee tomonow? (1) The channels of communication are going to have to be much better. I have no idea what the report says, whether she [Sharron] made the changes I suggested. It could be in Greek for all I know. I can't proceed until I have reViewed the draft I need to see the final drafts at least when everyone else does, if not before. I cant assume the changes are there. (2) The state is setting up an adversarial process that I had hoped to avoid. (3) The concern about budgetary restraints is not a valid excuse for not doing split samples and for not having full oversight participation. We don1 want to hear this any longer. It's a matter betWeen Bill and the budget offloe. We shouldn't have to hear about this petty administrative stuff. And certainly it is not an excuse for not being ablo to do what we need to do. It doesn't send a good message concerning their intention to do what was promised. I told them that I will not participate if ! find mysetf in a fraudulent situation. Myer and Humphrey need to settle things. They need to ten us that there's not enough money or that there's no problem. We need to know the bottom tine one way or the other. Either there are funds or there are no fundS. Why design good test plans that can't be funded? tf there are no funds, we need to find out why the money that was promised is not there. Presently, it's a waste of ttme and money tor alt of us to continue down this track. You have things being said pubUcty that are contradieted privately. You have state officials contradieting each other. All state Officials need to be on the same traek. Bill and Sharron -a minimization of their Input is warranted tf they don't have the will to carry this (process] through and if they continue to be obstructionists. They have shown nothing but bad faith, and I don't understand why. They know the PCBs are in there. Question: Do you think they're wonled about dioxin? Perhaps about dioxin and about whatever else might be in there. Question: Sharron said she thought perhaps the dioxin count would be low and that deto>dflcatlon would probably be mostly tor PCB8. Do you agree? What you have In there is very low.grade oil. usually very highly contaminated with dioxin, especially considering the time period of its production. Dioxin is now believed 11 /11 /1992 22:18 19192571971 WARREN CO FARM BUREA PAGE 03 '~ '- to be even more toxic than before -ten times more toxic than EPA said it was. It is very dangerous to human chemistry at very low levels. It needs to be dealt with as a separate contaminant. If they try to slide away from thiS, it's not going to help them. AbOut PCBs, Sharron said she's talking With a scientiSt who Claims that sou microorganisms can [neutralize?] buried PCBs if stored long enough. She says she's got the data. We can't find the data. We did a literature search. we can't find the research data in ~ to this. I don't know what's going on here, but I don't like any of it. Things have got to change, but not with ECO and the committee. The problems are originating with two people: Sharron and Bill. They need to be taken into a room and tokt what the policy is and stick to it. we don't need to play games with them any longer. We're wasting time and money. It's an insult to our intelligence and not productive. If they can't afford to do spltt samples and have them analyzed, they can't afford to detoxify. Maybe we should stop this charade right now. They need to have a meeting and get their plan straight. You can't have two high-level offtcials [Bill and John] saying and doing the opposite. One or the other of them is correct. We need to know which one. We shouldn't be involVed in a power struggle within state government. We need to know what the bottom line is so we can proceed. If the money's there, then we proceed scientifically. If the money's not there, then we need to proceed politically and find out Why money needed to futfill a promise isn't there. We need to know the bottom line so we can know how to proceed. Question: A statement concerning Governor Hunt's commitment to detoxify the PCB landflll 11 being drafted and wlll be made avallable to the news media, etc. Do you have any auggestlons on what thla letter ahould state? Make sure he reaffirms his commitment to detoxify and pledges firm financial backing, but also pledges that his personnel resources will be in line with the policy; otherwise, it will be an empty pn,mise. Someone should tell Bill to get in or get out. Subordinates are supposed to be in line with the poticies. Bill serves, I assume, at the pleasure of the Secretary of Natural Resources. The governor needs to pledge his personnel resources in support of this policy. State officials need to go in a room and decide what the policy is. We can't do what we're supposed to do until this internal administrative situation Is Cleared up. John's position -that Bill just doesn't understand how the money is to be available -isn't credible. That's the one thing Bill woutd clearly understand. Let's get this split in policy settled so we can get on with the substantive things we need to acc:omplish, things that will be important for the citizens of Warren County, and for the state and nation. (3) U N ITED ST A TES EN VIRONMENT A L PROTECTION AGEN CY REG ION I V REF: 4WMD/NSRB Deborah & Ken Ferruccio Route 2, Box 163-J Nolina, NC 27563 3 4 5 C O URTLAND STREET. N.E . ATLANTA. GEORGIA 3036 5 June 16, 1994 Dear Mr. & Mrs. Ferruccio: As discussed in our recent telephone conversation, enclosed is information on the Base-Catalized Decomposition (BCD) process. This process in conjunction with thermal desorption will be used at the Koppers Superfund Site in Morrisville, North Carolina, and the FCX, Inc. Superfund Site in Statesville. A "treatability study" of this treatment process was conducted at the Koppers site in September 1993. The results indicated that the process would be effective in reducing and eliminating the contaminants of concern which are pentachlorophenol (PCP), PCDD (polychlorinated dibenzo-p-dioxin) and PCDF (polychlorinated dibenzo-furan). Also enclosed are excerpts from different documents concerning the BCD process; as well as the Innovative Treatment Technologies Annual Report concerning the various technologies that have been used across the Nation. Please feel free to contact me at any time for more information on this or any other subject. Our toll-free number is 1-800-435- 9233 ext. 2073. Enclosures Sincerely, A~~ Diane F. Barrett Community Relations Specialist North Superfund Remedial Branch j " State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes. Secretary William L. Meyer. Director 13 June 1994 MEMORANDUM: To: Bill Meyer, Director e~,14\Y ~ Division of Solid Waste Mahagement Through: From: Mike Kelly, Deputy Director Division of Solid Waste Management Charlotte Jesneck, Head Inactive Hazardous Sites Branch Tom Power /fJ_ Inactive Hazardous Sites Branch Re: Division Policy for PCB Cleanup Levels l!lldWaste .fflll 13 1S This memo outlines our understanding of the Division's policy for establishing cleanup levels at sites with PCB contamination. Soils Based on a 1 x lOE-6 excess cancer risk, the Branch has calculated a target cleanup level of 200 ppb. In order to be more consistent with EPA guidance on PCB cleanup levels at Superfund sites, the Division has established a soil cleanup level of 1 ppm. One ppm PCB's in soils (with no other carcinogens present) represents a lifetime excess cancer risk of 5 x lOE-6. It is our understanding that the Division considers this risk level to be protective and consistent with the Branch's 1 x lOE-6 standard. The 1 ppm standard applies only to sites where no other carcinogenic compounds are present in site soils. For sites containing other carcinogens in soils, the Branch will establish PCB cleanup levels based on site-specific risk assessments. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50'£ recycled/ 10% post-consumer paper Bill Meyer Mike Kelly 13 June 1994 Page two For sites where remediation of soils down to 1 ppm is not technically or economically feasible, higher residual concentrations of PCB's may remain in site soils provided that the Responsible Party can demonstrate to the Branch's satisfaction that future land use has been restricted. In order to be acceptable, any land-use restrictions must be perm!nent and legally enforceable by the State. Since the Branch does not have the resources to research this issue and develop the specific legal mechanism for restricting future land use, that burden rests with the Responsible Party. Groundwater Based on a 1 x l0E-6 excess cancer risk, the Branch has calculated a target cleanup level of 0.00043 ppb. This level is several orders of magnitude below the current range of practical quantitation limits (0.5 to 1.0 ppb). Therefore, the Division's cleanup level for PCB's in groundwater has been set at the lower practical quantitation limit of 0.5 ppb. This is consistent with EPA guidance on PCB cleanup levels at Superfund sites, and with EPA's Maximum Contaminant Level (MCL) of 0.5 ppb. This policy may have to be revised depending on the recommendations of the Department's "how clean is clean" committee, and depending on the outcome of CERCLA reauthorization. Please let me know if you have any questions or comments. To : John Humphrey . From: Ken Ferruccio /<.::/ Subject: PCB Detoxification Credibility Question Copies·: Committee Members:-·state/Citizens Warren County PCB Landfill Working Group Date: June 9, 1994 1 . The State Will push as hard as it can for detoxification of the landfill when and if the appropriate and feasible technology ls developed. r Governor James 8. Hunt Jr. The Warren Record, 1982. I want to respond to several points you made during today's conversation. I think you mentioned your having put yourself on the line for Warren County and that things would not be going forward as they have been had you not convinced the governor's office that the Warren County situation is very important. John, I have indicated on several occasions that you did an excellent job. I think you fully understood the confrontational elements and that the only way to remove them was for the state t,o work within the proposed framework . To the extent that you needed to convince the state that it would be in its interest to resolve the crisis within the framework is the extent to which you must have felt yourself stating the obvious. The rationale that informed the framework made it clear that the nature of the resolution to the crisis would have far-reaching implications and that our plan was clearly consistent with the principles of waste reduction and justice, while the state's was not. Clearly, the state had a choice: it could resolve the crisis within a mutually- agreed-upon framework informed by principles that would win wide public support, or it could use force to implement its own plan. Not to put too fine a point on it is to repeat what I said to Martha Waggoner of the Associated Press in my memorandum to her of June 14, 1993 when she asked why the PCB crisis had not blown up in Hunt's face. Given the history, such an explosion would have been a reasonable expectation. But as I said to Waggoner, " Presently, the only thing standing in the way of a civil rights movement is a mutually-agreed-upon 5-point framework to resolve the PCB crisis. If the state abandons its commitment to working within this framework, a clvll rights movement Is inevitable." I might add, John, that to dismiss the framework would be to undermine the credibility of Governor Hunt, the credibility of Secretary Howes, and your own credibility. We would also risk losing the control of events because of inevitable resistance. f ~ You said that nobody except a few civil rights and environmental groups cares about the Warren County situation. On the surface, this sounds like a descriptive statement that matches "reality." However, you and I know it's a statement having purely hypothetical status. It is, in fact, very much like the hypothesis that prevailed between 1978 and 1982 ---nar;nely, th9t opposition in Warren County was insignificant, the expression of a "vocal minority." .Needless to say, Hunt tested this hypothesis in 1982, and the demonstrations punched many holes in it. I'm informed that a computer never repeats a losing sequence. If Hunt tests the "vocal minority" hypothesis once again, he will at least demonstrate the r · superiority of artificial intelligence over his own. He will also find it necessary to support me and X number of others at public expense. Given my service to Warren and the state over the years on this issue, it does seem only right that the state afford me comfortable accommodations. John, it seems to me to be an indisputable · fact that when Hunt prevails, it's just about impossible to stay out of jail. So what we are talking about fundamentally is the fulfillment of a promise to a poor and predominantly black community that just happens to be the birthplace of environmental civil rights, the birthplace of what has become known as the environmental justice movement, and the symbol of discriminatory and segregational siting patterns. This is the community stripped of its 13th and 14th amendment rights in 1982 by Hunt's use of force. Only detoxification will restore these rights along with the ecological integrity these rig,hts were meant to protect. How much these rights are worth to Hunt remains to be seen. Given the history, probably not very much. But other people do care, perhaps many more than you and I can imagine. Those who understand that the siting policies presuppose a contempt for their rights and lives may reasonably be expected to support our efforts. Those who understand that what Hunt did here represents regional and national trends detrimental to the continued existence of poor black and other minority communities of the South and of the nation (and, ultimately, to the continued existence of all of us) may reasonably be expected to demonstrate some expression of concern. I would seriously reassess the hypothesis that just a handful of environmentalists, civil rights and church people care about the situation here. If the state truly believed that, it would not be bothering to work through negotiations ; it would be attempting to resolve the problem through force. But force would be useless because we live here and have the rest of our lives to resist it. To test or not to test. That is the question. But before we test the "vocal minority" hypothesis, we should consider that we are involved here with complex and multifaceted issues that cannot be abstracted from historical, symbolic, and potentially explosive elements. After having put everything in perspective, we should remind ourselves that the PCB / dioxin? landfill is in a state of crisis, that by the state's own admission, continued pressure on the bottom liner could cause it to breach, and that we should therefore be accelerating detoxification procedures. However, the intention of the state seems to be to slow the process down. (2) The only reason the state is presently considering detoxification of the PCB landfill is because of Governor Hunt's 1982 promise in a public letter to the people of Warren County. It would therefore be very conducive to the credlbiltfy of the Hunt administration on this Issue If Hunt were to publicly reaffirm his commitment to detoxifying the Warren County site with a~suran9es that the funds will be available through the recently announced surphJs.~of funds, or through other means. I do believe that without such a statement from the governor, the attempt to resolve the PCB crisis through the work of the committee will fail. As one committee member recently put it "You folks are getting screwed." Another, _member: i, They want to drag this out until Hunt's out of office. That's all they're worried about." And yet another member: " If the message came from the top ('Yes, I'm committed to detoxifying the Warren County site, and yes, the funds will be available.') then we wouldn't have to worry about Bill having to guess about where the money's coming from ." . ' Finally, John, if you were the independent science advisor, what conclusions, if any, would you draw from the following statements? Pauline: The very first thing he [Bill] said to me: You 've got to go easy on me. Please don't use too much of your staff. Please don't bill me too much on this project. It's a bad situation in regard to the budget and in carrying on the work of the committee. We have no money to carry on the work the committee wants us tq-do . and later [Bill is speaking to Pa:uline]: Too expensive: there is no way we can afford to grab split samples and send them off for full-scan analysis at a private lab. Pauline to Ken: This [taking split samples] is a very common control procedure. EPA will do it internally in matters of litigation. It's a very normal, a very common practice to follow when you want to make sure you have good data. It's the best way to ensure the validity of your data. Bill to Pauline: The one billion dollar surplus will be all gone and diwied up by June 28th. No money has been asked for the iandfill or for detoxification. It will all go in other health and human seNices projects. Bill also stated to Pauline that he had no intention of recommending detoxification. I hope, John, you will understand why there Is a credibility problem that simply cannot continue without having serious implications. Surely, John, if you and Bill and other state officials are truly committed to detoxifying the Warren County PCB landfill, then regardless of whether you ask EPA for the money, you should be requesting money to detoxify the PCB landfill from the state surplus as well. If later, EPA were to appropriate (3) funds for detoxification, then the state could Jeturn the money it had received from the surplus.Hunt needs to convince the public that he's committed to detoxification and that he's committed to getting the funds necessary for detoxiflcatfon. ) . (4) 17 , . :t.,'/'' ', I ~,' ,:, .,· l·-· -~ I,, -'\,•II .·~ I I I \ ) 1171 .· I .7 _ . A ::T.:..::C:V- :r-r-:1':J;✓ "' -? 11:ll . -\__ l ·-. '\ (' . ,. · .. (• .. , '.{. \ \ \ r·\ I ' I / \ ~ \ / l b?')\~ /1 ;/ \ \ I \ \ I \ : I I ! I I I I I I I I I I I I I I 1 I I I : I l I I I State of North Carolina Department of Environment, Health, and Natural Resources 512 North Salisbury Street • Raleigh, North Carolina 27604 Division of Solid Waste Management James B. Hunt, Jr., Governor Telephone (919) 733-4996 Jonathan B. Howes, Secretary Dear Resident: Several families with ground water supply wells near the PCB landfill have requested their wells to be tested for PCB. In response to this request the county Health Department and the Department of Environment, Health, and Natural Resources would like to schedule a date and time to sample your wells. Every year since the PCB landfill was closed ground water and streams around the landfill have been tested for PCB. Eighty four groundwater samples and 92 stream samples have been analyzed and no PCBs have been found. Fifty-five residential wells within a three mile radius of the landfill have been previously sampled and no PCBs were detected. The retesting of your well will provide a continuing measure of the safety of the PCB landfill. This additional sampling effort will reaffirm the commitment by the County and State to provide you with assurance that your drinking water is safe. Please contact the Health Department at 257-1185 for a date and time that you would like for your well to be tested. The Environmental Science Laboratory in the Department of Environment, Health, and Natural Resources will analyze the samples for PCB and report the results directly to you and the Health Department in approximately four weeks. If you have any questions or concerns please contact Mr. Dennis Retslaff, Warren County Health Director or Mr. Bill Meyer, Director of Solid Waste Management at (919) 733-4996. We look forward to providing this service to you. DR:fja Sincerely, Dennis Retzlaff, Health Director Warren County P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4984 Fax# 91 9-733-0513 An Equal Opportunity Affirmative Action Employer @ SOll, rocydod/lO'llo pooi-<XINlllMI' paper " State of North Carolina D~pari'ment of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director MEMO .AVA DEHNR TO : Members of Joint warren county and State PCB Landfill working Group FROM: Bill Meyer &it!Jl"t,r} DATE: June 8, 1994 suBJECT: Draft workplan delivery, announcement of plan for next meeting, and membership list T R A N S M I T W O R K P LA N --A copy of a DRAFT workplan for the environmental sampling for the warren county PCB Landfill is enclosed for your review. Please read this draft and prepare comments prior to the next meeting of the working Group. This review should be the main agenda item for the meeting. M E E T I N G N O T I C E --At the request of the Committee Chair, it is proposed that the working Group meet on Thursday, June 23 at 2:30 pm in the Episcopal Church in Warrenton. A formal notice of this meeting will be mailed closer to the meeting time. M E M B E R S H I P L I ST --A draft membership list of the working group and known designees is attached. Please review this list to see if your entry is correct. Please let me know if you wish changes. we will have a formal list prepared for the June 23 meeting. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper DRAFT June 7, 1994 Prepared for the Joint Warren County and State PCB Landfill Working Group Prepared by North Carolina Department of Environment, Health, and Natural Resources Division of Solid Waste Management DRAFT Warren County PCB Landfill Workplan for Environmental Sampling PURPOSE SAMPLING PLAN Landfi 11 Content Samples Landfi 11 Leachate Samples Groundwater Samples Surface Water Samples June 7, 1994 OUTLINE Other Landfill-Area Environmental Surveillance Samples Liner Leak Detection Samples Landfill Surface Soil Samples Carbon and Sand Filter Samples Sedimentation Basin Substrate Samples CHEMICAL TESTING PLAN Organic Chemical Analysis PCB Analysis Dioxin Analysis EPA Appendix IX Analysis Physical Tests of Soils QUALITY ASSURANCE PLAN OVERSIGHT SITE HEALTH AND SAFETY PLAN 2 DRAFT Warren County PCB Landfill Workplan for Environmental Sampling June 7, 1994 The Joint Warren County and State PCB Landfill Working Group has requested that the Division of Solid Waste Management prepare a Draft Workplan for sampling and analysis of key environmental samples. The development of the Workplan have been done with review by the committee's oversight consultant. PURPOSE The purpose of the study described in this Draft Workplan is to evaluate the current chemical and physical status of the Warren County PCB Landfill, its contents, and environmental conditions within the landfill. SAMPLING PLAN Landfill Content Samples A representative sample of the contents of the landfill will be taken . The sample will be obtained through the 4-inch PVC air/gas vent pipe that was installed in the center of the landfill. By using this vent as an access point to take the sample, the liners and caps that protect the landfill will not be disturbed. A drawing of the gas vent is enclosed. The U- shaped cap on the air vent will be removed to allow access through the air vent to the landfill contents. When sampling is complete, the U-shaped cap will be replaced. Samples will be taken by a hydraulic-powered sampler mounted on an 4-wheel ATV or by hand auger. These methods of collecting the samples will prevent the need for large vans or drilling trucks to be on top of the landfill. Approximately 4.5 pounds of the contents of the landfill (PCB-contaminated soil) will be removed for detailed chemical and physical testing. These samples will be collected, preserved, transported and analyzed by approved methods described in the next section of the workplan . Landfill Leachate Samples The original design of the landfill included a piping system inside the landfill liner at the bottom of the PCB-contaminated soils that are in the landfill. Water that has separated from those original materials and water that fell into the landfill while it was under construction has flowed into this pipes. Samples of this leachate water will be taken and analyzed by methods similar to those for landfill's solid soil samples. 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VITH CL~;-,, .. ·::' .• ··,·:-::-. ,·•~ ~· _,: .. :. >~:·'.·:_:·;~-----~-:~: ~cEAG~AT~·~c.c:ctEc1;ro-N·.:s:ur0.~·/A.NDi7J;IPi6.;~.Q9rA111:\. . I . . _,, .. J .. , I " ....... ·····-······•· ••.,(ZREOUIREDf---·--. •-•···-"'~~-·,.,•':I ... :"'> ••.•.• , •• ~. · _ -.. -~ -·-______ -.... • .. , •·. • ·. .._., ..... •·~ --:~.::-.~r-~·!-...... ,t-.-._:._,.,;?·'·.-e.·-"'·-.. · .. c-.:-,· •.. ··.·~•-:~• .. ~-· . ·, :·.·:, . •'. •, ; . •.,.: :.;/:,:·:;;,~_·:··\iRE0~1(~~~bj:f?i:'hq·pp~~~~~-~~iiJij«t~~~tf.~~tfiJ~;~¢~t{}<~ Collection System was originally design for future sampling and no unusual techniques are required beyond normal sampling safety precautions. A drawing of the leachate collection system is enclosed. Groundwater Samples When the landfill was constructed, four groundwater monitoring wells were installed around the landfill, so that samples of groundwater could be taken frequently. Samples of groundwater have been collected and analyzed for PCBs throughout the lifetime of the landfill. During this sampling event, the state proposes to take groundwater samples for chemical analysis. In addition, the depth to the surface of the groundwater will be measured. This measurement will allow us to know in which direction the groundwater is flowing in the area under and around the landfill. Surface Water Samples Two stream flow near the landfill site. Richneck Creek passes several hundred yards to the north. An unnamed tributary of Fishing Creek passes several hundred yards to the south. The state has one permanent sampling site upstream and one downstream of the landfill in each creek, for a total of four permanent surface water sampling locations. During this sampling effort, samples will be taken of the water and sediments in each of the four locations and chemical analyses will be performed. Other Landfill-Area Environmental Surveillance Samples Other areas on or adjacent to the landfill will be sampled to evaluate the integrity of the landfill. Areas where environmental samples will be taken and analyzed for appropriate chemicals include: 1. Liner Leak Detection Samples -One-inch diameter holes will be punched in the surface cover soils to provide access to the area above the plastic liner covering the landfill. Gas present at this interface will be analyzed by portable infrared spectrophotometer or detection tubes for presence of methane or carbon dioxide gas. Measurements that register above natural background levels could indicate the present of escaped gas from within the tents of the landfill. Lower measurements could indicate the liner and vent system was working as designed. Samples will be taken based upon a random grid system to an adequate number for a statistically significant result. No widely accepted method is available for this portion of the study and results may or may not be scientifically valid. This method is proposed as the best available existing technique for evaluating some aspects of the liner's integrity. 2. Landfill Surface Soil Samples -Soil samples taken from the liner leak detection testing outlined above can be preserved for PCB analysis. Samples analyzed will be limited to those near or around the air vent and near the bottom of the slopes of the landfill or in other locations deemed of interest during the actual field event, with the advice and consent of the Committee's contractor. 4 3. Carbon and Sand Filter Samples - A diagram of the carbon and sand filter stuctures is enclosed. Representative samples wi 11 be taken of filter material from these structures for comprehensive organic analysis, including PCBs and dioxins. 4. Sedimentation Basin Substrate Samples -Multiple soil samples will be collected and composited to a depth of 12 inches from the bottom of the sedimentation basin. Comprehensive organic chemical analyses will be made. CHEMICAL TESTING PLAN Modern chemistry laboratories can measure very, very small amounts of the chemicals we must know about at the Warren County PCB landfill. These measures may be as small as one part of a chemical to one trillion parts of other materials. These very sophisticated chemistry tests are done only in laboratories that are approved (Accredited) for such tests. All chemical tests to be done on these soil and water samples will be done in accredited laboratories operated by the state or by private companies. All samples collected will be tested to see how much and what kind of PCBs they may contain. Other special chemical and physical tests will be done for many of the soil or water samples An outline of each type of chemical test that will be conducted on the appropriate soil and water samples collected during the sampling effort are listed below, Quality assurance goals, plans and procedures are presented below. These quality assurance procedures will be strictly adhered to during the sampling and chemical analysis portions of this workplan effort. Organic Chemical Analysis PCB Analysis .Identification and quantification of PCBs is done by standard EPA Method 8081 . Method 8081 is a component part of the EPA Appendix IX profile. In addition, a sample of the landfill contents will be analyzed by mass spectroscopy to confirm the identification of any breakdown products of PCBs (i.e., congener profile). This additional method is a research tool to look at the landfill's internal environment to see what has happened to the PCBs during the 11 years since the landfill was closed. Dioxin Analysis Analysis of samples of soil and/or water for dioxins and furans will be conducted by EPA Method 8290. This method is the most comprehensive test method for dioxins and furans. Method 8290 will measure the amount of all mono-through octa-isomers of dioxin and furan, plus provide data on the total dioxins and total furans present. This method is state-of-the-art and is sensitive to the part-per-trillion range. Only one commercial laboratory in North Carolina is accredited to perform this method -Triangle Laboratories of RTP, Inc. 801 Capitola Drive, Durham, NC 27713. The state will contract with this 5 °' :::e . ·. , ... I I . I·· I•··, . :".", ... ,,, .• , ...... , . ,t ! 1 · L ·:..-· . . .... , JN EACH TANK oVERt:Av".ALL 11ERF~'TEO-OUTl.£T'PIPEs wrrH· •· · ··· 1 .,:·. •; •. ,;·.,• 1:.'.•··•.· STANOARD"flEINf!°vnClcD CONC~ETE SEPTIC TANKS · · , . · .'.. 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'-··.•·· ., ·"· L4~6urLri'.~PiPE I • • • \~'.'.\ttlii\ " ~ ~ : t;hBBON EI\IEB -'::: ,-::·;. :. · -~::·. ;~-.\:•.• :~-~t~}-?.>·::.~;. l-:'t ;;~.;t ... +::...-.·.: ! ~ .,· ... . " ' . .. <~~~. ',: .·. : >.\Li I'. ·-j.. . -;;: . .-.:iNLEiPIPE· ;GRAVEL': ~·c111!or)iANDARD··sizE""reM' ~•~:rL;ET PtPE · · .·· · ...... · ---l'-·~;!.~ -:, •_;·;• .... l~• • .. •(.>_~:· .•.;~:~ 1, ••r .·: •-~-,~·•:\•.·:j SANC·N.C: OOT JsTtNDARD SIZE#zs · .... ; .. ,'•'· : "· .,.-••!'. N! ••-: . . _:._~•~ .. -~ ..... -:;:•-:,;/:.~ '/-!' . ;:_--: ~ ·:;~:1 :·i,:\ . !:. :• • • • . .1 I .)-\!'·:i ,;'(\ ,, .. •••1';_' I• i:, SAND AND FABRIC FILTERS -~~::-/'' . ' .. :, 'SECTfON A'-A -SCALE 1z-,-v-~ · .. , i.: IZ•40 MESH SIZE.''• .. ;.'.;: ... ,,:., ·1 ,., .t' ·, ., ..... i .~: :,.·;'.;:J_>,,);;_~{\. GROUT oR: "¢AuLJ<°'. To· stA~'w.mmcii!i:'· . ,:.(,ii{ .. :,•;·:~llf 11~~ OLTED.FLANGE (n!P)i ,· .. . ;!~:-·t.:-··1<: .:-.. ~11 laboratory to perform the required dioxin and furan analyses from samples from the Warren County Landfill. EPA Appendix IX Analysis An EPA Appendix IX analysis will be approximated by analysis of samples which may contain either the landfill contents or have been contaminated by these materials since the landfill was built. Specific chemical types to be tested and the appropriate EPA test number are: Chemical type EPA Test method Volatiles Semivolatiles Organochlorine Pesticides Herbicides 8240 8270 8081 8081 Organophosphate Pesticides 8141 lnorganics, including metals various Physical Tests of Soils The soil sample collected from the contents of the landfill will be rigorously analyzed for physical and standard soils tests methods by key state laboratories. Specifically, approximately 3 pounds of soil will be delivered under chain-of-custody to the North Carolina Department of Transportations Soils Lab for analysis by their "Quality Test" methods. Tests included in this group are: o Plasticity Index o Liquid Limit o Sieve Analysis o Moisture Content o Organic Content o Permeability As a companion to the Department of Transportation's analysis, approximately one pound of soil from the composite sample of the landfill's contents will be delivered under shain-of-custody to the North Carolina Department of Agriculture Agronomic Division's Soils Lab for evaluation by the "Standard Soil Test". Measures included in this test are: o pH (measure of acid/base balance in the soil) o Weight per Unit Volume o Percent(%) Humic matter (Measure of decomposed organic matter in soil) o Cation Exchange Capacity o Soil Nutrient Analysis (Calcium, Sulfur, Phosphorus, Potassium, Magnesium content) The results of these two soil test groups on the landfill content sample will assist the committee and the state in designing or reviewing any future treatment or management options for the landfill contents. 6 QUALITY ASSURANCE PLAN All samples collected as part of this project will be maintained under Chain-of- custody procedures approved by EPA. These procedures specify labeling, recordkeeping, and transportation requirements. Chain-of-custody prevents interference with the samples from the time they are taken until they are analyzed in the laboratory. In addition, the detail recordkeeping is valuable in maintaining precision in sample management and administration of the project through the final report. A number of quality assurance strategies will be used during these investigations of the Warren County PCB Landfill. Beyond chain-of-custody in sample handling, samples collected from the landfill contents will be sent for additional laboratories for independent analysis. The EPA laboratory at Athens, Georgia which specializes in PCBs has agreed to analyze a sample. Likewise, GE's Environmental Remediation Group in Schenectady, NY has agreed to participate in the analysis. These independent chemical analysis and interpretation by these expert laboratories can provide confidence in the quality of the process to Warren County citizens. In cooperation with the analytical laboratories involved in this project, trip blanks and laboratory blanks will be used. "Blanks" are dummy samples made up to look exactly like real samples from the field, but are material of known content. Once analyzed in the laboratory without the chemists knowledge, blanks can provide much information about the entire analytical process. Blanks provide much confidence in or point out errors in the results of the sampling process. Blanks can do several things, but typically are used to prove that no sample has received contamination from any source other than that being sampled (trip blanks), or to prove that the laboratory can actually distinguish between a clean and a contaminated sample (field blanks). In addition, all laboratories used in the project for chemical organic analysis participate in EPA -monitored "round robin" quality verification programs, where identical samples of known chemical content are sent to all laboratories for analysis and blind reporting for comparison of findings. This program requires the participating laboratories to have rigorous in-house Quality Assurance protocols, including laboratory blanks and spiked samples to prove the quality of their analytical results. OVERSIGHT In conjunction with the Committee, plans and procedures for the sampling period will be developed. These plans will include opportunities for community observation of activities through direct observation and film documentation. This section will be written following the Committee's review of the Draft Workplan. 7 SITE HEALTH AND SAFETY PLAN A. General Information Site Name Warren County PCB Landfill O & M ID# NCO 980 602 163 Location lust off SR 1604, Warren County, NC Proposed Date of Investigation luly 1994 Date of Briefing luly ,1994 Date of Debriefing luly 1994 Health Department Official Contacted Date of Contact luly , 1994 Site Investigation Team: All site personnel have read the Site Health and Safety Plan and are familiar with its provisions. Personnel Responsibi Ii ties Signature Plan Preparation: Prepared By: Reviewed By: -------------- B. SITE/ WASTE CHARACTERISTICS Waste Type(s) _X_Liquid _X_ Solid __ Sludge __ Gas Characteristics __ Corrosive __ Ignitable __ Radioactive Volatile _X_Toxic Reactive Other List Known or Suspected Hazards (physical, chemical biological or radioactive) on Site and their toxicological effects. Also, if known, list chemical amounts HAZARD PCBs WARNING PROPERTIES Odor Threshold ,on -no data (mild hydrocarbon odorl TLV O,SmglmJ. Facility Description: Size: Total -142 acres Landfill -2.54 acres Buildings: IlQile Unusual Features on Site (dike integrity, power lines, terrain, etc.): none known History of the Site: Between June, 1978 and August, 1978, over 30,000 gallons of industrial liquid waste material identified as PCBs (Arochlor 1260 and Arochlor 1262) were discharged deliberately along the shoulders of approzximatley 150 miles of NC highways. In June, 1979, EPA approved a tract of land (previously used for agriculture) in Warren County as the disposal site for the PCB-contaminated roadside soil. The landfill (constructed in 1983- 1984 and permitted under the Toxic Substances Control Act -TSCA) contains about 40,000 cubic yards of soil contaminated with PCBs. The concentration of PCBs in the landfill ranges from 46 to 200 ppm, averaging about 135 ppm. C. HAZARD EVALUATION The site can be toured in level D protection. Steel-toed safety shoes and chemical protection overboots shall be worn by all staff involved in sampling activities. lnvididuals touring or observing the site shall wear substantial laceup shoes with chemical protective overboots. Long sleeve pants and shirts are required. D. WORK PLAN INSTRUCTION Map or Sketch Attached? ¥eS Perimeter Identified? ¥eS Command Post Identified? .D.Q Zones of Contamination Identified? ¥e,S Personal Protective Equipment/Level of Protection: ____ C __ X_D Modifications: The site can be toured and sampled in level D protection, Steel-toed work boots will be worn while sampling, PE or PVC gloves will be worn while collecting water or soil samples. The HNU or OYA will be used to monitor breathing zone air while soil augering and sampling of soils. Tyyek suits will be worn while augering. It is recommended that no observers be allowed within lo meters of the sampling sites. Level D personnel protective equipment including chemical protective boots will be required of all observers. Observers are to be accompanied at all times by a person properly trained by 29 CFR 1910.120 to 40-hr standards. Surveillance Equipment: HNU ----Detector Tubes and Pumps ---- OVA 02 Meter -------- Combustable Gas Meter Radiation Monitor -------- Decontamination Procedures ___ Level C Respirator wash, respirator removal, suit wash (if needed), suit removal, boot wash, boot removal and glove removal. _X __ Level D Boot wash and rinse and boot removal, suit removal, glove and goggle removal. Modifications ---------------------------- EMERGENCY PRECAUTIONS Route of Exposure E irst Aid ~ . . . . . . . . . . . . . . . . . . . . . . irrigate immediately Skin . . . . . . . . . . . . . . . . . . . . . . soap and water wash Inhalation Ingestion fresh air and artificial respiration get medical attention immediately Location of Nearest Phone: unknown Nearest Hospital (Address and Phone Number) Marja Parham Hospital Ruin Creek Road at 1:85, Henderson NC 27536 can handle chemically contaminated patients Emergency Transportation Systems (Phone Numbers) Fire ill EMS ill Rescue Squad ill Emergency Route to Hospital Travel west on SR 1604. then turn left onto SR 1125, lust past Cokesbury, turn right onto SR 151 o, then left onto SR 1001, Stay on SR 1001 until just outs ide of Henderson, then turn right onto SR 1508, which will lead you to 1-85, Take 1:85 South to the Ru in Creek Road exit, the hospital is well marked, EQUIPMENT CHECKLIST __ Air purifying respirator __ Cartridges for respirator Dust Mask - _X_O2 Indicator _X_Eye Wash Unit X HNU X OVA X Combustable Gas Meter _. _Radiation Monitor __ Detector Tubes and Pump _X_ First Aid Kit _X._3 gal. Distilled H20 Rainsu it _ X _Gloves (PE/PVC/n itri le/cloth) _X_ Boots/Boot Covers _X_ Coveral Is (tyvek/saranex) _X_ Eye Protection _X_Hard Hat _X_ Decontamination Materials. Chemical Emergency Information Centers ASHEVILLE 704-255-4490 CHARLOTTE 704-379-5827 DURHAM 1-800-672-1697 GREENSBORO 919-379-4105 Poison Control Center -State Coordinator Duke University Medical Center Telephone: 1-800-672-1697 P.O. Box 3024 Durham, NC 27710 Western NC Poison HENDERSONVILLE Control Center 704-693-6522 Memorial Mission Hosp. Ext. 555,556 509 Biltmore Ave. 28801 Mercy Hospital HICKORY 2001 Vail Ave, 28207 704-322-6649 Duke Univ. Med. Center JACKSONVILLE Box 3007, 27710 919-577-2555 Moses Cone Hospital WILMINGTON 1200 N. Elm St. 27420 919-343-7046 Margaret R. Pardee Memorial Hospital Fleming St., 28739 Catawba Mem. Hosp. Fairgrove Chur. Rd 28601 Onslow Mem. Hospital Western Blvd. 28540 New Hanover Mem. Hospital 2131 S. 17th St. 28401 PROJECT MANAGERS PROJECT ACTIVITY REPORT PROJECT MANAGER: _____ _ PROJECT: ___________ _ INVESTIGATION DATE: _____ _ Materials Used (Please insert a number in the blank) Air Purifying respirator cartridges --Detector tubes == Eye Wash Units First Aid Kit == Gloves (polyethylene) Gloves(PVO Respirator Worn By Gloves (nitrile) Gloves (cloth) Boot covers __ Coveralls (tyvek) Coveralls (saranex) __ Auger Brushes Approximate Time in Respirator Air Monitoring Data (Include Calibration Reading) HNU: __________________________ _ OVA: __________________________ _ Combustable Gas Meter: -------------------- Radiation Meter: ----------------------- If the maximum personal protective equipment as outlined in the Hazard Evaluation Section was not used, please justify: Visitors Present Organization Represented DI/SR/Revised 5-94 JOINT WARREN COUNTY AND STATE PCB LANDFILL WORKING GROUP *JOHN HUMPHREY DEHNR BOX 27687 RALEIGH NC 27611 *BILLIE ELMORE 5301 ROLLING HILL RD SANFORD NC 27330 *LUCIUS HAWKINS RT 1 BOX 6 WARRENTON NC 27589 *CAROLYN COLEMAN 116 WEST JONES ST RALEIGH NC 27603 *KENNETH FERRUCCIO RT 2 BOX 163 J NOVTINA NC 27563 *JIM LEWIS 5806 SENTINEL DR RALEIGH NC 27609 ** KIMBERLY BURWELL PO BOX 254 WARRENTON NC 27589 * WORKING GROUP MEMBERS ** DESIGNEES *** INFORMATION DISTRIBUTION *VICKI WESEN EMMANUEL EPISCOPAL CHURCH PO BOX 704 WARRENTON NC 27589 *BILL MEYER DSWM 401 OBERLIN RD RALEIGH NC 27605 *TOMMY CLINE 116 WEST JONES ST RALEIGH NC 27603 *DENNIS RETZLAFF 544 WEST RIDGEWAY ST WARRENTON NC 27589 *ROBERT TERRY RT B 12D WARRENTON NC 27589 ** JIM WARREN PO BOX 61051 DURHAM NC 27715 ***PAULINE EWALD 106 ROBINSON ST ASHLAND VA 23005 *THERESE VICK PO BOX 740 RICH SQUARE NC 27869 *DOLLIE B BURWELL PO BOX 254 WARRENTON NC 27589 *EARL LIMER RT 4 BOX 413 WARRENTON NC 27589 *DEBORAH FERRUCCIO RT 2 BOX 163 J NOVTINA NC 27563 *JOYCE LUBBER 315 CHURCH ST WARRENTON NC 27589 ** MONICA PORTER 116 WEST JONES ST RALEIGH NC 27603 *** LINDA RIMER HENRY LANCASTER STEVE METCALF SHARRON ROGERS HEMAN R. CLARK LAW OFFICES OF PARKER, POE, ADAMS & BERNSTEIN P.O. BOX 389 ONE EXCHANGE PLAZA RALEIGH, NORTH CAROLINA 27602·0389 TELEPHONE 919·828·0564 FACSIMILE 9 19·834 ·4564 June 6, 1994 The Honorable James B. Hunt Governor 116 West Jones Street Raleigh, NC 27603-8001 Dear Governor: CHARLOTTE OFFICE 2800 CHARLOTTE PLAZA CHARLOTTE, NORTH CAROLINA 282•• TELEPHONE: 70-'•372-9000 FACSIMILE: 70•-33•••708 RESEARCH TRIANGLE PARK OFFICE P.O. BOX 13039 RESEARCH TRIANGLE PARK, N.C. 27709 TELEPHONE, 11111·!5,U·-'!500 FACSIM1LE: 919·!5••-2798 SOUTHPARK OFFICE •20t CONGRESS ST., SUITE 1,s CHARLOTTE, NORTH CAROLINA 28209 TELEPHONE, 70-'·!5!58·11800 FACSIMILE: 704-!5!58-9601 FILE NUMBER DIRECT DIAL Our P.C.B. landfill in Warren County won't go away. Now the "protesters" are saying we broke our promise to "detoxify" (which would be a shameful waste of much tax money). I do think you should consider having the water pumped out of the landfill. You remember we had several heavy down-pours of rain fall just before putting the cap in place. There have been no leaks but we can't say there never will be. It may not be a dangerous condition but it sounds bad. For a relatively small appropriation, the dehydration can be done. Bill Meyer the highly competent Chief of Solid Waste Management Section, knows exactly what needs to be done. As long as the water remains inside the liner, the protesters have a logical basis to continue their expert agitation in the community. They are at it again, telling that farm products from the area are unfit for human consumption. If there is anyway I can help in explaining this need to the General Assembly please let me know. With warm regards and best wishes, (,in/rely, ~ HRC:bps cc: rMir. William L. Meyer State of North Carolina Department of Environment, Health and Natural Resources Division of Solid Waste Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary William L. Meyer, Director Faxed to: 490-3745 June 3, 1994 Dr. Barry Katz Mycosearch, Inc PineCone Drive Durham, NC Dear Dr. Katz: PJ·,l\ ~'-5 ~ . n n a ... ----• DEHNR Please provide us with a brief description of your company's experience and capability regarding sampling and identification of soil biota. As we discussed, we will soon be sampling a chemical landfill ten years post closure and are interested in options to sample the flora and fauna that are will be present in the landfill upon opening. The contents of the landfill are soils contaminated with an average of 140 ppm of PCBs, primarily Arochlor 1260. I look forward to getting your materials and to further discussions with you about this possibility. yours, ~ Sharron E. Rogers Special Projects P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4996 FAX 919-715-3605 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper Draft Draft Draft Draft Draft Draft Draft June xx, 1 994 An Update for the Citizens of Warren County: Many gallons of PCB transformer oils were dumped along roadsides in 14 North Carolina counties in 1978. After detailed consideration of all alternatives for protecting the citizens of our state, the United States Environmental Protection Agency decided that the only available option was to landfill this material. In 1 983, these roadside PCB-contaminated soils were placed in a state-of-the-art chemical landfill near the Afton community in Warren County. This single purpose landfill is closed for any other use. North Carolina has maintained my promises to you by monitoring the condition of the landfill and the health of the citizen's living near the landfill. Since my return to the Governor's Office in 1993, I have taken a number of steps to reinforce my previous commitments to you. At the request of Warren County, I directed the Department of Environment, Health, and Natural Resources (DEHNR) to establish a Joint Warren County and State PCB Landfill Working Group. This working group has been formed and has met several times under the direction of co-chairs from the DEHNR and Warren County. The DEHNR has provided funding for a science advisor to assist the working group in addressing concerns about the landfill. The working group has identified three primary agenda items: perform a detailed environmental assessment of the landfill; evaluate technologies for detoxification of the PCB-contaminated landfill contents; and assess maintenance needs for the landfill's long-term security, such as internal landfill water levels. While all three of these agenda items are important to ensure safety of the landfill, I am aware that detoxification of the contaminated soils is a priority concern. In 1 984, a similar working group recommended to me that at that time detoxification was not feasible. However, over the past 10 years much new information, research work, and practical experience with clean up of PCB-contaminated soils has occurred. In an effort to help the working group with its agenda items, the DEHNR has proposed a design for a detailed environmental site investigation of the landfill. This study will include detailed chemical and physical analyses of samples taken from within the landfill. A preliminary workplan for this proposed study has been delivered to the working group members. Soil, surface water, groundwater, vegetation, and landfill content samples will be chemically analyzed. These results will be compared to similar findings from our routine sampling. This comparison will give a detailed current picture of the environment inside and near the PCB landfill. Knowledge of what has occurred to the PCBs and soils inside the liner of the landfill for the past 11 years will be critical to any consideration of detoxification options. At the working group's direction, I have instructed DEHNR to support the efforts of the working group in conducting a detailed technical review of feasible PCB-soil detoxification options. Findings and recommendations from this review will be reported to me and the citizens of the Warren County. The DEHNR has transferred $100,000 to Warren County to maintain and improve the PCB landfill. This money may be used for such items as improved security, lighting, electricity to the landfill site, or funding the environmental site investigation. All environmental studies conducted at the PCB landfill in Warren County to date show that there has been no release of PCBs to the area. This is a safe and healthy community to· live in, and I am committed to keeping it that way. With proper care, this landfill can continue to be a safe repository for these materials for you and your grandchildren, while we continue to press for a feasible detoxification method. Draft Draft FACSIMILE TRANSMITTAL FORM DIVISION OF SOLID WASTE MANAGEMENT FROM: BILL MEYER COMMENTS: OFFICE (919) 733-4996 FAX (919) 715-3605 1Zh_~ ;~~~~:;a to 1M,()tf &J 1' W f PIUJ ttJ fti plf£'f)tirQ E NVIRONMENTAL COMPLIANCE 0 RGANIZATION 106 Robinson Street Ashland, Virginia 23005 TO: FROM: RE: DATE: MEMORANDUM VIA FAX MR. BILL MEYER PAULINE EWALD IMPLEMENTING WARREN COUNTY LANDFILL PROJECT MAY9, 1994 I'm sorry that we have been missing each other over the telephone, but my schedule through this spring and summer is very full. Because of scheduling conflicts, I will not be able to make it to Raleigh this week. However, I have firmly reserved May 19 , 1994 for attendance at the planned meeting . ECO's participation in that meeting will be much more substantive if we can begin to read and review file data on the landfill, and I would therefore request that your staff begin to copy and send the relevant documents as soon as is feasible. Additionally, I would appreciate complete information on North Carolina travel regulations and requirements to assure in advance that our travel scheduling will be compliant with management and budgetary guidelines. Should you wish to meet in advance of the meeting on the 19th, or have a conference call to discuss the agenda for ECO's participation, I will make every effort possible to set aside a mutually convenient time to do so. Everyone at ECO looks forward to getting this project underway, and assisting the State and residents of Warren county in resolving this important project. PME/ms E NVIRONMENT AL COMPLIANCE 0 RGANIZATION 106 Robinson Street Ashland, Virginia 23005 PROFESSIONAL WASTE MANAGEMENT CONSULT ANTS (804) 798-4305 TO: FROM: RE: DATE: l\lEMORANDUM VIA FA.,X MR. BILL MEYER PAULINE EWALD IMPLEMENTING WARREN COUNTY LANDFILL PROJECT MAY9, 1994 I'm sorry that we have been missing each other over the telephone, but my schedule through this spring and summer is very full . Because of scheduling conflicts, I will not be able to make it to Raleigh this week. However, I have firmly reserved May 19, 1994 for attendance at the planned meeting . ECO's participation in that meeting will be much more substantive if we can begin to read and review file data on the landfill. and I would therefore request that your staff begin to copy and send the relevant documents as soon as is feasible. Additionally, I would appreciate complete information on North Carolina travel regulations and requirements to assure in advance that our travel scheduling will be compliant with management and budgetary guidelines. Should you wish to meet in advance of the meeting on the 19th, or have a conference call to discuss the agenda for ECO's participation, I ,viii make every effort possible to set aside a mutually convenient time to do so. Everyone at ECO looks fonYard to getting this project underway, and assisting the State and residents of Warren county in resolving this important project. PME/ms State of North Carolina Department of Environment, Health and Natural Resources Policy Development James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary John Humphrey, Director March 31, 1994 MEMORANDUM TO: FROM: RE: Joint State-Citizens PCB Landfill Working Group and Interested Parties John HumphreY\ 'r April 7, 1994 Meeting This memorandum is to remind you of our next meeting at 4 p.m. on Thursday, April 7. The meeting will be held in the parish hall at Emmanuel Episcopal Church at 127 N. Main Street in Warrenton. This is the same location as our March meeting. Our newly hired consultant Pauline Ewald is scheduled to attend the meeting to help us move forward on developing further our work plan. I look forward to seeing you on Thursday. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4984 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper State of North Carolina Department of Environment, Health and Natural Resources James B. Hunt, Jr., Governor Jonathan 8. Howes, Secretary Linda Bray Rimer, Assistant Secretary for Environmental Protection .NA DEHNR M E M O R A N D U M TO: FROM: DATE: Lois Artis' {l Linda Rime~ March 30, 1994 SUBJECT: PCB Landfill Contract A contract proposal (Form 101c) originating in the Solid Waste Division was submitted to the Department for approval on March 28, 1994. Contract services include evaluation and recommendation of necessary work on the PCB Landfill in Warren County. The associated budget revision (12-0365) requests that $40,000 of the $82,950 needed for this contract be transferred from the Solid Waste Management Division lapsed salary balance. The development of this contract was approved in a meeting with State Budget and Department senior management. It is our understanding that the remaining funds needed for this contract will be identified by the Department in fiscal year 94/95. Please call me if you have any questions or need additional information. LBR/cr cc: Steve Levita.7./ Bill Meyerv · P. 0. Box 27687, Raleigh. North Carolina 27611-7687 Telephone 919-715-4140 FAX 919-715-3060 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-c onsumer paper 4 • State of North Carolina Department of Environment, Health and Natural Resources James B. Hunt. Jr ., Governor Jonathan B. Howes, Secretary J1~A ~ ---~·1~~ CWWW-twwwa n a ,n -.----• C)EI-INFl March 23, 1994 Mr. Howard E. Tomlinson, Jr. 12 Hillcrest Point Littleton, North Carolina 27850 Dear Mr. Tomlinson, Thank you for your recent comments and copy of the resolution concerning the PCB Landfill in Warren County. The State is the owner of the PCB Landfill and responsible for providing long-term maintenance of the site. The Department is currently funding a scientific study to evaluate the safety of the landfill and identity risks to public health and the environment. If any risks are identified, the State will respond to ensure that the landfill continues to be safely maintained. Part of the study will be to determine the need for removal of water from the landfill and technical recommendations for removal of water if required. This is consistent with the Board of Health's resolution that recommends that the State make a decision on managing the water in the landfill and removal and appropriate disposal if necessary. The Board of Health, County Commissioners and the Department have the same objective, to make sure that the landfill is safe and make fiscally responsible decisions for any necessary corrective action. I appreciate your comments and urge you to participate with the joint Warren County and State PCB Landfill working group to provide solutions to the long-term maintenance of the PCB Landfill. ~~~~-~ Jonathan B. Howes JBH:wlm cc: William L. Meyer, Director Division of Solid Waste Management P. 0. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-715-4100 An Equal Opportunity Affirmative Action Employer 50% rocyc led/10% post-consumer paper ~ "' ... ,,. Jonathan B. Howes @., .. .,_-,~ ,. '.':w /. t( Secretary of Environment, Health, and Natural Resources ~ TO: ~/4._ ~ DA TE: :;J.. -;J..J-9 5/' RESPONDBY: 'O?au1._ )'i~ PLEASE: REMARKS: t/2raft a reply for my signature and return to me. ___ Reply, noting the letter was referred to you by me (copy to Secretary's Office). ___ Draft a reply for the Governor's signature and return tome. ___ Reply, noting the letter was referred to you by Governor Hunt (copy to Secretary's Office) ___ For your information. ___ Take appropriate action. ___ Note and file. ___ Note and return to me. ___ Note and see me about this. ___ Your comments and/ or recommendations. -. '-.. ~~----~ ........ . ..,.__ : 1 f 1994 -~:/ -:// -, ":::'!.2:.:;.:1:}>~~/ ~ l•• .. --., ·-· .. i ~ 512 N. Salisbury Street Raleigh 27604 (919) 715-4101 P•l!t aq Oi U •11e,ap aJOW YI!'~ wn,alt ew 04 Ado;, Yl!M 'JeMIU■ HH!d D 41anba.1 JnoA J8d O .A.1d•.1 o, ew JO¼ uo,,twJOJUf ... ~ ... d O _,... __ ~., .e:_:'11JaAuo, Jno ;ad D .,,,.,ue,, Aw JOf A1d•• OJldOJd D', 7..-::-..:r:.. 10.0,dd• JnoA J0,1 cd' uou1wJ0JUJ inoA ,~ O '!"il \noq• ~ aac put a,oN D Mllfd '1,ueww~ JOOA O ew 04 wn,aJ put ~ON D p.JtMJOJ put t•tuu! 'a.JON O ll!J put a,oN 0 NOU~V :s}!iawaH ?r'l{f/ PJO;f/~ 7/VO'd ~fr ,m;o=o.t 4•1 _ f!/-<,; •1•a SD~nOS3~ w~nl''V'N 0NV 'Hl lV3H '1N3WNOmt\N3 :10 1N3Wl~Vd30 VNllO~V::> Hl~ON :,. " "\ HOWARD E . TOMLINSON, JR. 12 HILLCREST POINT LITTLETON, NC 27850 February 22, 1993 ~Ir. Jonathan B. Howes, Secretary North Carolina Department of Environment, Health and Natural Resources P. o. Box 2768 7 I ,;::., L;,:_ ',I L ,_·_·_-__ . Raleigh, NC 27611 .. : · .. :.~:.:..::..:...[ Dear Sir: Warren County PCB Landfill I am a member of the Warren County Board of lle alth and I attended the Hay 24, 1993 public meeting held in the Courthouse to discuss the PC B Landfi 11. /\s a result o f that meeting the \-/arren County Ilea 1th Department initiated a well testing program involving about 35 private wells in the immediate vicinity of the Landfi 11. /\11 results were negative; the re was no indication of PCBs in any of the test samples. On October 4 the Harren County Board of Health adopted a resolution which was publlshed in the \-larren Record on October 13, 1993. A copy of this :iresolution ls enclosed. I have great difficulty trying to understand the threat of hydraulic pressure on the liner -throug h five feet of packed clay -or the effect of 12 to 13 feet of wa ter-soaked earth on the liner -when residential swimming pools contain over six feet of water directly on a plastic shell with a foot or two of packed sand beneath; these pools do not leak. I personally believe the hazard of PCBs to our citizens is absolutely minimal. Dr. Ronald H. Levine, State Health Director, acknowledged to my direct question at the aforementioned public meeting that there has never been a case of recorde d sickness or death attributed to PC Bs in the state of North Carolina. Dr. Ralph Heister, a respected environmentalist from Penn State University, has investig ated a problem of rcB .contamination of Valley Creek in Chester County, Pennsylvania. The creek has been stocked annually and fished for many years. Dr. Heister tells me there has never been a recorded case of sickness or death attributed to this PCB problem. I read a news review not long a g o on the toxic dilemma; regulation costs versus risks. It quoted Representative John Dingell of Michigan as saying "we have seen in recent episodes on asbestos, dioxin and PCBs where risks have been dramatical1ly overstated at simply immense cost to the public". To spend additional taxpayer money on this PCB project would be a g ross i njustice, especially whe n budgets are so tig ht and there are many, many tnore important problems to address. Please g ive this matte r .serious consideration before further action. ~J~h-Si 1 your~s, J . F· £ • 'f om l ins on, Jr ! RESOLUTION PCB L\NDF I LL IN WARREN COUNTY WHEREAS, the PCB Landfill located near Afton in Warren County ls the property of the State of North Carol Ina WHEREAS, lt has been determined by the State Department of Environment, Health and :~atural Resources that the PCB Landfl l l contains an excessive accumulation of water which may, or may not, be a threat to the inte~rity of the landfill liner WHEREAS, after :nany well tests for presence of PCBs in the viclnlty of the PCB Landf L 11, there is no evidence whacsoever of PCB concaminat ion emanating from the Landfill and hence no threat to the health and well- being of the cit l zens of Warren County WHEREAS, the State Health Department has verified the fact there has never been a recorded case of death or illness attributed to PCDs in the State of ~orth Carolina WHEREAS, the Warren County Board of Health is charged with the care and responsibility for the health interests of Warren County WHEREAS, in consideration of these aforementioned conditions, the \.larren County Board of Hea 1th does not believe the PCB Landf i 11 poses a hazard to the health of Warren County citizens THEREFORE, BE Ir RESOLVED, that the Warren County Board of Health recommends the State of North Carolina make the decision on whether or not to remove the excess accumulation of 'Water from the PCB Landfill and, if so, to use appropriate means of disposal. Adopted this day ______________ ,1993 Date -------------- -. State of North Carolina Department of Environment, Health and Natural Resources Jomes B. Hunt, Jr., Governor Jonathon B. Howes, Secretory AVA DEHNA March 22, 1994 v. Alfreda Jordan-Webb County Manager, Warren county 130 North Main Street P. o. Box 619 Warrenton, North Carolina 27589 Dear Mrs. Jordan-Webb: The Department of Environment, Health and Natural Resources is pleased to respond to your request for funds from the Solid Waste Grants Program by awarding $100,000 for capital improvements on the PCB Landfill. Although more funds were requested for Warren County, the great need for financial help by local governments required that the Department share funding equitably. It is my understanding that the General Assevbly may fund this program again in the upcoming short session. The state is the owner and operator of the PCB Landfill and has both responsibility and liability for all activity on the site and therefore, must agree with and approve any proposed capital improvement project before it is implemented. The funds are limited to being spent on capital improvements that include1 renovations, repairs, maintenance, landscape improvements, new construction, equipment purchases, utility modifications, and other appropriate capital improvements on the PCB Landfill. The Department of Environment, Health and Natural Resources and the Division of Solid Waste Management look forward to working with you to ensure the protection of Warren county citizens. Sincerely, · L\~~h.~ Jonathan B. Howes JBH:wlm P. 0. Box 27687. Raleigh. North Caollna 27611-7687 Telephone 919-71~4100 An Equal Opporh.nty Affimative Action Employer '5u1. recycled/lO'I. post-conuner paper ·= . •·. '.: .. •·. loO•DAY•Yl'I ¥OtD4BI ...,_. ~ '"'' s;; vr l'IVn In ~nv1.11""' DEPARTMENT OF ENVIRONMENT, HEALTH & NATURAL RESOURCES No. 4 4 336 5 P.Q,_BOX 27681. RALEIGH, N.C. 27611 . TOTAL NET AMOUNT DETACH HERE STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT. HEALTH & NATURAL RESOURCES RALEIGH, NORTH CAROLINA coo.,.__,. 100000.00 100,000.00 CHECK NUMBER 443365 4433&5 e&-1059 ~ $AMOUNT' ~ [ 3/22/94 443365 4931& t 100,000. 00*, PRESENT TO: STATE TREASURER PAYABLE AT PAR~ FEDERAL RESERVE SYSTEM PAY TO THE ORDER OF jWARREN COUNTY L L : . ~. =--~ . . -~--f ~ ·-~ ~ :.:.~.~----~-.. .,. / ... :-·:·-· .. ·· ---. 1-:.·. ·-:Y:° ·,::~. :: ~:::--~ ._ ·• .,.,. '·: ~ .. , ..• ··.• .... ,-•• ~,. , ••. _ _,-.,-,.=-. "r·' ... ,.., ...... · -~· .•...... ,. ~->'.--l~~~'.@' \: \~~·•····. ·'·"··.r.w __,,,.1:"'>-~.-",,,. . •',L_,~•·-,·=~~~-~-'~' ----. :: •· .. . -~~ .... ~: .· .•>" :--:.;. ,-;-~ :~~' ?\ ;· . . • .-. . . -✓ •. · • .,, J ' I L r e . -- .iv l)Jtt/./l lt--4 14 ~ ~W,ti /4o4-r~,,,J 1i., ~~-h'ili-_~ ~ -~l\.S-~_ ~~ ~-\Q~ ~~ ~"'h~--b~-~~~~ ~'~--~~~ '-~~~ k> ~ -~- ~-e?~ ~ ~~ ~ ~ .P--- -~ fry\-~ _Plbt>t~ ·\~~~~ ~ ~ ~~-) ~,~~---~~~!V'-' '' ' . ' . •·t I I • • •·t d I ., March 14, 1994 MEMORANDUM TO: Members of the Joint Warren County and State .PCB Landfill Working Group FROM: John Humphrey, Director Policy Department EHNR SUBJECT: Draft Scope of Work The Department has drafted an outline for a scope of work on the PCB Landfill as requested by the members of the work group at the January 18, 1994, meeting. Please review the draft and prepare any additions or deletions that you feel are appropriate. I encourage you to add any ideas that we may have not included. I hope we can finalize as much of the scope of work as possible at the next meeting. I look forward to working with you on the scope of work at our next meeting which is scheduled on April 7, 1994. JH:WLM:phj PROPOSED SCOPE OF WORK --PCB IANDFILL TASKS: • Select technical consultant for joint state and citizens working group. • Evaluate existing environmental conditions of landfill. • Determine methodology for removal of water from landfill. • Evaluate potential technologies for detoxification of materials in landfill. • Recommend detoxification technology and budget for implementation for consideration by General Assembly. • Recommend long-term institutional controls for perpetual maintenance of landfill. • identify options/strategy for funding of all tasks. • Identify indirect impacts of PCB landfill. TASK --Selection of Technical Consultant for Joint Working Group • Pauline Ewald, Environmental Compliance Organization (ECO) of Ashland, Virginia, has been determined to be technically qualified, has demonstrated good communication skills and has the ability to develop credibility, trust and confidence with the working group. • The major responsibility of the technical consultant will be to provide advice, guidance and leadership in the identification, development and implementation of all tasks identified by the working group to address the PCB landfill project. • The approximate cost of the technical consultant is estimated to be $65.00 per hour. • The state has agreed to provide funds for the technical consultant selected by the working group. • Recommended activity to complete selection of technical consultant: 1. Determine all tasks (scope of work) to be assigned to the technical consultant and draft generic personal services contract. 2. Present proposed contract to selected consultant(s) for final cost determination. 3. Make selection (working group) and prepare final contract. 4. Specify state funding and schedule of payment established. TASK --Evaluate, Existing Environmental Conditions on Landfill • Develop health and safety plan for all contractor personnel and on-site observers. • Water fluctuation study. • Leachate (water in landfill) volume study. v • Gas venting study. • Top liner evaluation. • Bottom liner evaluation. • Groundwater monitoring system study. • Leachate system evaluation. • Water treatment system evaluation. • Surface water/sediment evaluation. • Vegetation evaluation. • Chemical/physical sampling and analysis including all toxic constituents and specifically dioxin and furans. • Human, animal and wildlife evaluations. • Other evaluations/studies identified by working group. Note This task may be further defined as part of a proposed contract for t h e t e c h n i c a 1 consultant services or this task could be assigned to the consultant after the contract is presented. Note --It is estimated that this task will cost from $25,000 to $50,000. The major difference in cost will be the extent of chemical and physical testing and analysis. For example: dioxin and related compounds cost $1,600 per sample and total scans for all toxics will cost ( combined with dioxin) approximately $2,000 to $2,500 per sample. The state needs to know what extent state resources will be needed and or required. Note Note A source of funding for implementation of this task must be identified and contracts developed for implementation. TASK --Determine Methodology /Technology for Removal of Water from Landfill. • Feasibility study of removing water form landfill relative to protecting landfill integrity and detoxification efforts. • Design system for removal of water, treatment and on-site disposal. • • Alternatives include using existing systems with modifications or designing alternative system(s). Note --Regardless of design alternative electricity will need to be extended to site and a surveyed benchmark established. Note Note The cost is estimated to range from $50,000 to $200,000 for design and implementation for one year. Funding sources must be identified for multiple contracts (feasibility, design and implementation) for this task. TASK --Evaluation of Potential Technologies for Detoxification of Materials in Landfill • Review published data on technologies including chemical, physical, biological and thermal ( excluding incineration) amenable to -.r t •• detoxification of PCB materials. • Select applicable technologies. • Identify and select vendors with existing capability to apply selected technologies for detoxification of landfill. • Invite selected vendors to make presentations for proposals to detoxify landfill. Presentations should include all technical aspects and risks associated with technology, probability of success, on-site disposal of residues, schedules and budgets, cost and financial capability (liability and assets) of vendor. • Select applicable/successful technologies and determine cost estimates. TASK --Recommend Detoxification Technology(s) and Budget for Implementation for Funding/ Appropriation to General Assembly • Propose detailed reports and data sufficient to provide General Assembly with information to make decision for funding. • Plan efforts to work with elected officials at all levels to build support for detoxification. TASK --Recommend Long-term Institutional Controls for Operation and Maintenance of PCB Landfill • Plans developed for monitoring and upkeep of site. • Responsible agencies assigned for monitoring and care of site. • Budgets for long-term care. • Contingency plans in place for unanticipated events. TASK --Other Revision 03/11/94 TO: FROM: John Humphrey SUBJECT: Response to 3/12/94 Winston Salem Journal and Status of PCB Landfill * $200,000 is the estimated amount for capital improvements to initiate removal of water from the landfill. On March 18, 1994 $100,000 from the Solid Waste Grants Program was incumbered for capital improvements to the PCB Landfill. (Draft letter Department to Warren County enclosed) This is about one half the estimated cost and the Department will attempt to respond to any actual short fall from new appropriations, existing funds and staff resources. * $30 million is a rough estimate for detoxification of the PCB contaminated soils and water in the Landfill. Detoxification of the landfill is a major objective of Warren County citizens and is based on an October 20th, 1982 commitment by Governor Hunt to: "The State will push as hard as it can for detoxification of the landfill when and if the appropriate and feasible technology is developed. We will seek to establish a joint local-State-Federal working group to pursue this end" (copy of October 20, 1982 letter enclosed). * This commitment resulted in appointment of a working group (13 members) in June, 1983 and final recommendations in December, 1984. Two recommendations included, not disturbing the PCB Landfill at that time but "to continue surveillance of developments in PCB detoxification, with representation from the appropriate state agencies---, Warren County and the research community." (copy of ppl3-14, final report and recommendations of the intergovernmental working group on PCB detoxification, 12/12/84 enclosed) * In order to keep this commitment to continue con- sideration of PCB detoxification developments, the Department has appointed a 15 member joint Warren County/ State PCB Landfill working group. The working group met 1/18/94 and 2/10/94 with a third meeting scheduled 4/7/94. * A contract is being negotiated/drafted to hire a con- sultant approved by the working group. The consultant will be paid with Department funds and will primarily provide technical guidance to the Warren County members of the working group. * Major tasks of the work group include: (1) Evaluation of existing environmental and engineered conditions at landfill and recommend any required corrective actions (2) Evaluation of technology to remove rain water from landfill and recommend appropriate technology (3) Evaluate and recommend technologies that are "appropriate and feasible" for PCB detoxification (4) Estimate cost and funding options for all recommendations * The press will probably attend and publish articles on activity at each of the working group meetings. In addition to the technical funding, schedules of activity issues, Environmental Justice/Environmental Equity is a major issue. * "appropriate and feasible" contrasted with "detoxification at any cost" is expected to be an issue to be resolved by the working group. ~arr~ ~--d-cv,.,-w 9.ArO r ,4 ' Fax Transmittal Memo 'f ;To~y~ Company -D C-1 c.i q57 ;;?.;}_'17 7672 No. of Pages / 'From &.J_£ Company Today's Date S /} ~ ; Dept. Charge 1 I I 1 Location Location Fax# 1J5-3D(po I Telephone #, /•xi 7/£:-3/po i 1Telephone #733-$L99" -~ Comments ~ Origin~!. D Destroy 0Return D Call for pickup ' -D1spos1t1on: c5<'~ #AL-~~ ~ w 6-k --~, c1-o , i ~ UJ?!-!Ct a_ ~ +cJ ~ ~ ~ . ,'3 all,~ <' ' -(!-~---u () ____ rflr~u..Jl..~ _____ ____,; Post-it Mr. William Meyer, Director Department of Environment, Health and Natural Resources Division of Solid Waste Management Post Office Box 27687 Raleigh, North Carolina 27611-7687 Dear Mr. Meyer: March 1, 1994 Senator Frank Ballance brought to my attention the availability of solid waste grants to enable counties to make capital improvements on solid waste facilities. In order to ensure the protection of our citizens, Warren County requests $300,000 for renovations, repairs, maintenance, landscape improvements, new construction, equipment purchases, utility modifications and any other expenditures that are required and appropriate for capital improvements to the Warren County PCB landfill. Thank you for your consideration of this request, and if you need further information, please call me. Sincerely, Alfreda Jordan-Webb Warren County Manager Mr. William L. Meyer, Director Department of Environment, Health and Natural Resources Division of Solid Waste Management Post Office Box 27687 - Raleigh, North Carolina 27611-7687 Dear Mr. Meyer: March 1, 1994 Senator Frank Ballance brought to my attention the availability of solid waste grants to enable counties to make capital improvements on solid waste facilities. In order to ensure the protection of our citizens, Warren County requests $300,000 for renovations, repairs, maintenance, landscape improvements, new construction, equipment purchases, utility modifications, and any other expenditure required and appropriate for capital improvements to the Warren County PCB landfill. Thank you for your consideration of this request, and if you need further information, please call me. Sincerely, Alfredo Jordan-Webb Warren County Manager State of North Carolina Department of Environment, Health and Natural Resources Office of Policy Development James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary John G. Humphrey, Director February 2, 1994 MEMORANDUM: RA DEHNR TO: Members of the Joint Warren County and State PCB Landfill Working Group FROM: John Humphrey, Director Policy Department EHNR SUBJECT: Draft Scope of Work The Department has drafted an outline for a scope of work on the PCB Landfill as requested by the members of the work group at the January 18, 1994, meeting. Please review the draft and prepare any additions or deletions that you feel are appropriate. I encourage you to add any ideas that we may have not included. I hope we can finalize as much of the scope of work as possible at the next meeting. I look forward to working with you on the scope of work at our next meeting which is scheduled on Thursday, February 10 at 2 p.m. at All Saints' Episcopal Church in Warrenton. Directions All Saints' Church is on the corner of Front and Franklin Streets in Warren ton. From Henderson the church is at the first stoplight on Secondary Road 1001. If traveling on Hwy. 401 from Raleigh, turn left at the first stoplight in Warrenton. The church will be in the second block on your left. P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-715-4106 FAX 919-715-3060 An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper , FRDH HC DIU HAZEROUS WASTE . "" TASKSs 01.28.1994 12:45 · • Select technical consultant for joint state and clti2ens working group. • Evaluate existing environmental conditions of landfill. • Determine methodology for removal of water from landfill. • Evaluate potential technologies for detoxlficatlon of materials In landfill. • Recommend detoxification technology and budget for implementation for consideration by General Assembly. • Recommend longterm Institutional controls for perpetual maintenance of landfill, T.ASK -Select!on or Technical Consultant tor Jolut Working Group • Pauline Ewald, Environmental Compliance Organization (ECO) of Ashland, Virginia, has been determined to be technically qualified. has demonstrated good communication skills and has the ability to develop credibility, trust and confidenoe with the working group. • The major responsibility of the technical consultant will be to provide advice, guidance and leadership in the identification, development and implementation of all tasks identified by the working group to address the PCB landfill project • The approximate cost of the technical consultant is estimated to be $6S.OO per hour. • The state has agreed to provide funds for the technical consultant selected by the working group. • Reoommended activity to complete selection of technical consultant: 1. Determine all tasks (scope of work) to be assigned to the technical consultant and draft generic personal services contract. 2. Present proposed contract to selected consultant(s) for final cost determination. 3. Make selection (working group) and prepare final contract. 4. Specify state funding and schedule of payment established. TASK -Evaluate Existing Environmental Conditions on Landftll • Develop health and safety plan for all contractor personnel and onsite observers. • Water fluctuation study. • Leachate (water in landfill) volume study. • Oas veriting study. • Top liner evaluation. • Bottom liner evaluation. • Groundwater monitoring system study. • leachate system evaluation. • Water treatment system evaluation. p. 2 FRCM HC DIU HAZEROUS WASTE 01.28.1994 12:45 -"'' . .. • Surface water/sediment evaluation. lID!filfil~l • Vegetation evaluation. • Chemical/physical sampling and analysis Including all toxic constituents and specifically dioxin and furans. · • Other evaluations/studies identified by working group. Note -This task may be further defined as part of a proposed contract for the technical ~nsultant services or this task could be assigned to the consultant after the contract ls presented. Note -· It is estimated that this task will cost from $25,000 to SS0,000. The major difference in cost will be the extent of chemical and physical testing and analysis. For example: dioxin end related compounds cost $1,600 per sample and total scans for all toxics will cost ( combined with dioxin) approximately $2,000 to $2,500 per sample. Note --The state needs to know what extent state resources will be needed and or required. . Note -A source of funding for implementation of this task must be identified and contracts ·developed for implementation. TASK .. Determine MethodoloSY /Technology ror Removal or Water trom Landftll. • Feasibility study of removing water form landfill relative to protecting landfill integrity and detoxification efforts. • Design system for removal of water, treatment and onsite disposal. • • Alternatives Include using existing system& with modifications or designing alternative system(s). · Note --Regardless of design alternative electricity will need to he extended to site and a suiveyed benchmark established. Note --The cost is estimated to range from $50,000 to $200,000 for design and implementation for one year. Note -Funding sources must be identified for multiple contracts (feasibility, design ~d implementation) for this task. TASK •· Evaluation ot Potential Technologies for Detoxification or Materials In Landftll • Review published data on technologies including chemJcal, physical, biological and thermal (excluding incineration) amenable to detoxification of PCB materials. • Select applicable technologies. • Identify and select vendor& with existing capability to apply selected technologies for detoxification of landfill. • Invite selected vendors to make presentations for proposals to detoxify landfill. Presentations should include all technical aspects and risks associated with technology, probability of success, onsfte disposal of residues, schedules and budgets. cost and financial capability (liability and assets) of vendor. • Select applicable/successful Jechnologles and determine cost estimates. p. 3 J , ~RQM HC DIU HAZEROUS WASTE 01.28.1994 12:46 ~ +_' "I, ... . . .. TASK •· Recommend Deto:xlftcatlon Technology(&) and Budaet for Implementation tor Funding/ Appropriation to General Assembly • Propose detailed reports and data sufficient to provide General Assembly with information to make decision for funding. · • Plan efforts to work with elected officials at all levels to build support for detoxification . TASK•· Recommend Longterm Institutional Controls for Operation and Maintenance of PCB Landftll • • • • Plans developed for monitoring and upkeep of site . Responsible agencies assigned for monitoring and care of site . Budgets for longterm care • Contingency plans in place for unanticipated events . TASK•• Other p. 4 MEMORANDUM DATE: February 8, 1994 SUBJECT: Warren County PCB Landfill TO: John Humphrey FROM: Linda Rimer l).-l~ Although I have reviewed the documents related to the PCB landfill that Bill Meyer has been sending to both you and me during the last two weeks, I am concerned if I am the only one providing feedback to Bill. Due to insufficient communications, Bill was not aware of some of your efforts that are underway in Warren County. Bill was confronted by a local County official who was angry because he has not been notified about the initial organizational meeting that was held on January" 18, 1994. He was upset that he was not aware of the draft scope of work, selection of a consultant for the working group and that the next meeting had been established. Have you or Bill established clear lines of responsibility? of accountability? Have we established a comprehensive Departmental plan for this project? Bill feels a real sense of urgency and responsibility on this issue --as I know you do as well. Both of you have expressed the need for sensitivity in dealing with both the issues and the personalities surrounding this landfill. We will flounder on all fronts unless we are communicating with each other and working with each other closely . • I will appreciate your updating me on where we are currently, what the next planned steps are and who is going to be responsible for what. Thanks. cc: B. Meyer 2"d SclltJJjti J I78:nd·c:JNH3 WtiS0:60 t:'6, m 83J pc /_ DATE: / -/2 -7'-/ SUBJECT: ____ _ /,r,9i_-;:; J..~: ;-: 2 J J223-.1-.1..~~:.,.; __ -::ic2. ~ii.•---~ --· o •c (·c·0 •( 1 MEMO C:. < -G. . DATE:----- L el · --.!: TO: _______ _ SUBJECT: ____ _ ------ From: _______ _ ~\ North Carolina Department of Environment, o/ Health, and Natural Resources @ PrintedonAecycledPaper (J . ~ r e ( _: o•, ( Cl < .. ( ( 0 ( : o •r L Ci C MEMO DATE: ____ _ O e ( -r. · 11 If d. 1L r~ ~ ?1U..t:i uivJ._, C G ( (\~ ,lAJ ~ .,_.{ . C. ( ,'f~ C . - ( 0 ( ~ C • < L () < . G • < C • '-- From: ~ 0 -,, a , ~""~ ~c~~-~.,r~/Jili North Carolina Department of Environment, ~31 Health, and Natural Resources @ , .. ,,~."""""'~~· ~ortq Qlarolimt ®etteral J\ssemhl!l ~emde fil~umber SENATOR FRANK W. BALLANCE. JR. 2ND DISTRICT· BERTIE (PART). GATES. HALIFAX (PART) HERTFORD, NORTHAMPTON, VANCE (PART) AND WARREN HOME ADDRESS: POST OFFICE Box 616 WARRENTON. NORTH CAROLINA 27589 T ELEPHONE: (91 9) 257-101 2 Mr. Bill Meyer Division Director ~tute ]Gegislutiue ~uilhing ~uleig~ 27601-2808 January 13, 1994 NC Solid Waste Management Division 401 Oberlin Road Raleigh, North Carolina 27611 RE: SMALL WATERSHED AND SOLID WASTE GRANTS APPROPRIATED IN S.B. 26 Dear Mr. Meyer: 1 l ) ., ' . COMMITTEES: JUDICIARY I -CHAIRMAN A PPROPRIATIONS ON J USTICE AND P UBLIC SAFETY -VICE-CHAIRMAN ECONOMIC D EVELOPMENT -VICE-CHAIRMAN BANKS AND THRIFT INSTITUTIONS CONSTITUTION AND ELECTION LAWS INSURANCE L OCAL G OVERNMENT AND R EGIONAL AFFAIRS M ANUFACTURING ANO LABOR N EW LICENSING BOARDS RULES ANO OPERATION OF THE SENATE I understand that there may be additional funds available under the above-referenced bill. Warren County has a severe need for grant assistance for the PCB Landfill problem here in our county. I respectfully request that you consider Warren County in your next round of grants so that this problem can be resolved. Please feel free to contact the appropriate official in our county to further discuss this request. Very ' uly yours, -I tLP~lLYt Fra kW~Jr. State Senator 2nd Senatorial District FWBJr/jlb cc: Alfreda Jordan-Webb County Manager JAN 13 '94 05: 25PM EHl'lR· PUBLIC AFFAIRS . . State of North Carolina Department of Environment, Health and Natural Resources Jomes B. Hunt, Jr., Governor Jonathan B. Howes, Secretory January 13, 1994 MEMORANDUM TO: FROM: Steve Metcalfe Carolyn Coleman Monica Porter Bill Meyer John Humphre~ P.l/3 NA DEHNR RE: Meeting on Warren County PCB Landfill with Community Representatives our first meeting on the Warren County PCB Landfill is scheduled for Tuesday, January 18 at 3:30 p.m. at the Offices of the North Carolina Episcopal Diocese. The main purpose of this meeting will be (1) to establish expectations and set a scope of work for the coming months and (2) to agree to use the scope of work to develop a contract for technical consultants. A map is attached. For those of you whom I do not speak with between now and then, I look forward to seeing you on Tuesday! P. 0. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-715-4100 An Equal Opportunity Affirmative Action Employer 50~ recycled/10% post-consumer poper JAi~ 13 '94 05: 26PM EHNR• PUBLIC AFFAIRS Directions to Episcoapl Diocese Offices From the I-440 Beltline P.2/3 From the I-440 Beltline, take the six Forks Road exit for North Hills Mall (away from downtown). Turn right at the first light --the light is at the main entrance to North Hills Mall --onto Dartmouth. Go one block. Turn right onto Camelot at sign saying "To St. Alban's Drive." Follow Camelot through a sharp left turn where it becomes St. Alban•s. The Episcopal Diocese Offices are the one-story white building on the left. From Downtown Follow Capitol Boulevard north to Wake Forest Road exit. Take Wake Forest Road exit. Follow Wake Forest Road through several lights to Six Forks Road (McDonald's will be on your left, Pepsi bottling plant on your right). Turn left at light onto Six Forks Road. Follow Six Forks Road through several stoplights and across I-440 Beltline to North Hills Mall. Turn right at the first light past I-440 --the light is at the main entrance to North Hills Mall --onto Dartmouth. Go one block. Turn right onto Camelot at sign saying "To St. Alban's Drive." Follow Camelot through a sharp left turn where it becomes st. Alban's. The Episcopal Diocese Offices are the one-story white building on the left. JAN 13 '94 05:26PM EHNR·PUBLIC AFFAIRS ~ .i.,. Lr ~ 0 e) "' " 1,1) tJ 4) '• ..> :t -0 ,_ 0 "'\ "'("' "' ~ -d .., ,J IJ \l,.. .,:~ s 0 V 0 VI --~ ·-Q.. ,,,. ~ 1$ ~or:.,.., 0. D t ~~ '\.cS,,, u>" ,~ ..... tti ~ " --t" I,) j_ ~ y l.- ~ TO: Members of the Joint Warren County and State PCB Landfill Working Group FROM: John Humphrey, Director Policy Department EHNR SUBJECT: Draft Scope of Work ., The Department has drafted an outline for a scope of work on the PCB Landfill as requested by the members of the work group at the January 18, 1994, meeting. Please review the draft and prepare any additions or deletions that you feel are appropriate. I encourage you to add any ideas that we may have not included. I hope we can finalize as much of the scope of work as possible at the next meeting. I look forward to working with you on the scope of work at our next meeting which is scheduled on (GIVE DATE AND LOCATION). PROPOSED SCOPE OF WORK --PCB LANDFILL TASKS: • Select technical consultant for joint state and citizens working group. • Evaluate existing environmental conditions of landfill. • Determine methodology for removal of water from landfill. • Evaluate potential technologies for detoxification of materials in landfill. • Recommend detoxification technology and budget for implementation for consideration by General Assembly. • Recommend longterm institutional controls for perpetual maintenance of landfill. TASK --Selection of Technical Consultant for Joint Working Group • Pauline Ewald, Environmental Compliance Organization (ECO) of Ashland, Virginia, has been determined to be technically qualified, has demonstrated good communication skills and has the ability to develop credibility, trust and confidence with the working group. • The major responsibility of the technical consultant will be to provide advice, guidance and leadership in the identification, development and implementation of all tasks identified by the working group to address the PCB landfill project. • The approximate cost of the technical consultant is estimated to be $65.00 per hour. • The state has agreed to provide funds for the technical consultant selected by the working group. • Recommended activity to complete selection of technical consultant: 1. Determine all tasks (scope of work) to be assigned to the technical consultant and draft generic personal services contract. 2. Present proposed contract to selected consultant(s) for final cost determination. 3. Make selection (working group) and prepare final contract. 4. Specify state funding and schedule of payment established. TASK --Evaluate Existing Environmental Conditions on Landfill • Develop health and safety plan for all contractor personnel and onsite observers. • Water fluctuation study. • Leachate (water in landfill) volume study. • Gas venting study. • Top liner evaluation. • Bottom liner evaluation. • Groundwater monitoring system study. • Leachate system evaluation. • Water treatment system evaluation. • Surface water/sediment evaluation. • Vegetation evaluation. • Chemical/physical sampling and analysis including all toxic constituents and specifically dioxin and furans. • Other evaluations/studies identified by working group. Note --This task may be further defined as part of a proposed contract for the technical consultant services or this task could be assigned to the consultant after the contract is presented. Note --It is estimated that this task will cost from $25,000 to $50,000. The major difference in cost will be the extent of chemical and physical testing and analysis. For example: dioxin and related compounds cost $1,600 per sample and total scans for all toxics will cost ( combined with dioxin) approximately $2,000 to $2,500 per sample. Note --The state needs to know what extent state resources will be needed and or required. Note --A source of funding for implementation of this task must be identified and contracts developed for implementation. TASK --Determine Methodology /Technology for Removal of Water from Landfill. • Feasibility study of removing water form landfill relative to protecting landfill integrity and detoxification efforts. • Design system for removal of water, treatment and onsite disposal. • • Alternatives include using existing systems with modifications or designing alternative system(s). Note --Regardless of design alternative electricity will need to be extended to site and a surveyed benchmark established. Note --The cost is estimated to range from $50,000 to $200,000 for design and implementation for one year. Note --Funding sources must be identified for multiple contracts (feasibility, design and implementation) for this task. TASK --Evaluation of Potential Technologies for Detoxification of Materials in Landfill • Review published data on technologies including chemical, physical, biological and thermal ( excluding incineration) amenable to detoxification of PCB materials. • Select applicable technologies. • Identify and select vendors with existing capability to apply selected technologies for detoxification of landfill. • Invite selected vendors to make presentations for proposals to detoxify landfill. Presentations should include all technical aspects and risks associated with technology, probability of success, onsite disposal of residues, schedules and budgets, cost and financial capability (liability and assets) of vendor. • Select applicable/successful technologies and determine cost estimates. TASK --Recommend Detoxification Technology(s) and Budget for Implementation for Funding/ Appropriation to General Assembly • Propose detailed reports and data sufficient to provide General Assembly with information to make decision for funding. • Plan efforts to work with elected officials at all levels to build support for detoxification. TASK --Recommend Longterm Institutional Controls for Operation and Maintenance of PCB Landfill • Plans developed for monitoring and upkeep of site. • Responsible agencies assigned for monitoring and care of site. • Budgets for longterm care. • Contingency plans in place for unanticipated events. TASK --Other .. ' January 11 , 1994 Joel Hirschhorn Do you have any recommendations concerning what should be the nature and scope of the initial contract? We need to begin with a technical assessment as related to the specific situation. We need to identify the scientific and technological options out there and how they relate. Are they really available? Will they work? Are they protective of people. They [ the options] need to be related to a whole spectrum of criteria. Then you need to sit down and write it up. It's not an academic exercise. It's a rigorous and comprehensive exercise. The goal is to get to a real-world solution, to balance all objectives and needs. It's really a practical technical assessment, comprehensive, and grounded in the real world, and in the needs and priorities of everyone concerned. It's objective, comprehensive. You look at what is the leading-edge technology and what we might have if we wait. And all this needs to be communicated to ordinary people. Question: The state has concluded that the PCB site is in a state of crisis. On the basis of your knowledge and experience, do you think detoxification technology is presently available, or do you think we're going to have to wait five or ten years? The problem is not about the absence of technological options but about too many of them. There are all kinds of technological options to destroy complex organic compounds, many more today than before. But you need to look at such criteria as safety, cost, reliability, ease of implementation. The key issue is cost as related to volume. Volume is relative to economics and will determine all other issues. It's not just about science. January 11 , 1994 Pauline Ewald Do you have any recommendations concerning what should be the nature and scope of the initial contract? The state was to have gotten me preliminary assessment and site investigation results. I need some technical information in front of me. We're guessing about what might be there. We need to test for dioxin, not just for PCBs. We need a comprehensive characterization of the site so we know what to clean up, a full-scan. We need air, soil, and water samples to understand the full technical and environmental situation. We would not just review what's been done. We would be in on determining the sample parameters, etc. Many projects get derailed because of the lack of a comprehensive site characterization. We can't do a risk assessment or a site remediation design without a full-scan. The state could involve its own staff. But let us have input. Let us have our people at the site. We'd pull off some split samples. We 'd get samples; they'd get samples. It would be more cost effective to involve the state staff. They're drawing salaries already, etc. But we would have a physical presence during the sampling. We would have input concerning sample locations, sample depths, location of monitoring wells, etc. We would have input into the sample plan and the state would agree to our suggestions. We would be there to be sure things were fair. Once the sample plan is in place, you really can't mess it up. You pick your locations, you pick what you're sampling for, and what you want the lab to look for. Sample parameters must be broadened to include dioxin, not just PCBs. PCB oil has been found to be heavily contaminated with impurities. 90% of the time, where you get PCBs, you get dioxin as an impurity of the refining process. The environment can act on PCBs, producing dioxin through heat and through interaction of PCBs with soils, etc. We need to know what's there, the full extent of contamination of air, soil, and water. We need to do a comprehensive site characterization, a full-scan, we need to broaden the sample parameters, to test for other contaminants as well. We can't do a risk assessment or site remediation design until we 've done a comprehensive site characterization. For example, a detoxification process that destroys PCBs might not destroy dioxins. So the full-scan is the first step. The other steps and contracts pertaining to them could be worked out as we went along. ~ ... • State of North Carolina Department of Environment, Health and Natural Resources James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Linda Bray Rimer, Assistant Secretary for Environmental Protection MEMORANDUM DATE: January 1, 1994 NA DEHNR I I • i • SUBJECT: Funding for Warren County PCB Landfill TO: FROM: John Humphrey Bill Meyer Linda Ri~ I have reviewed the application and process for "Environmental Justice Grants to Community Groups" which was recently received from EPA. My initial thought is that it represents a tremendous amount of work for very little money. Besides that, it is not clear to me that our proposal would even be fundable according to the EPA criteria. An additional point on eligibility: is the community group incorporated? as this is a requirement. John, I understand that you have identified $100K -$150K from the old Governor's Waste Management Board Budget which might be used for the landfill. If this is true, I would want to consider using part of that money for the Pollution Prevention Advisory Council as well as for Warren County. Obviously we need to sit down with Doug Lewis and clarify the existence and appropriate use of that money. I will look forward to further discussion of this project. I agree that we need to move as quickly as possible in addressing the concerns of the community. cc: S. Levitas L. Artis D. Lewis P. 0 . Box 27687. Raleigh. North Carolina 27611-7687 Telephone 919-715-4140 FAX 919-715-3060 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper ,f -9</ . State of North Carolina Department of Environment, Health and Natural Resources James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Linda Bray Rimer, Assistant Secretary for Environmental Protection MEMORANDUM DATE: January 1, 1994 ~ NA DEHNR SUBJECT: Funding for Warren County PCB Landfill _'···\~ ,:; .. / '-~!::·j'::.' .... 2,.!.~:_,J_;.> ·' TO: FROM: John Humphrey Bill Meyer Linda Ri~ I have reviewed the application and process for II Environmental Justice Grants to Community Groups II which was recently received from EPA. My initial thought is that it represents a tremendous amount of work for very little money. Besides that, it is not clear to me that our proposal would even be fundable according to the EPA criteria. An additional point on eligibility: is the community group incorporated? as this is a requirement. John, I understand that you have identified $100K -$150K from the old Governor's Waste Management Board Budget which might be used for the landfill. If this is true, I would want to consider using part of that money for the Pollution Prevention Advisory Council as well as for Warren County. Obviously we need to sit down with Doug Lewis and clarify the existence and appropriate use of that money. I will look forward to further discussion of this project. I agree that we need to move as quickly as possible in addressing the concerns of the community. cc: S. Levitas L. Artis D. Lewis P. 0. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-715-4140 FAX 919-715-3060 An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper -9</.