NCD980602163_19960424_Warren County PCB Landfill_SERB C_Detoxification Technology Review, 1996-OCR

,.
, .,
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
April 24, 1996
MEMORANDUM:
TO: Joel Hirschhorn
Science Advisor
FROM: Bill Mey~
NA
DEHNR
SUBJECT: Comments on Preliminary Detoxification Technology Assessment
The Division has reviewed the Preliminary Detoxification Technology Assessment and
offers the following comments for your consideration:
I. The assessment is clear, and contains many excellent points for the Working Gruop to
consider.
2. The Division agrees with the two fundamental questions that must be addressed by the
Working Group.
3. The contextual issues statement is both correct and appropriate. The ultimate goal is for
the PCB Landfill is selection of appropriate and feasible detoxification technoJoiY that is
successfuUy funded by an external process (appropriations from General Assembly). The
degree of scrutiny for funding proposals is most likely to be directly proportional to both
the benefit and cost of the proposal. Based on the anticipated cost of full scale
detoxification, it is absolutely essential that all reasonable alternatives be considered.
Rejection or acceptance of a technology must be through a process that is clearly
understood by the General Assembly, defensible on the merits of that process, and takes
into consideration third party competing technologies. Rejection of a technology will
become as important as selection of a technology. A specific example of consideration of
technologies is an attempt by the Division to investigate a soil washing solvent extraction
process (alcohol family extractant) for PCB contaminated soils. A staff engineer was sent
to California for a field demonstration of the soil washing process after notification by
EPA Region IV and the SITE program that this process may have potential for the
Warren County Landfill. The Division was particularly interested in the process because
of the low toxicity of the extractant, the opportunity to observe the engineering design and
operation of the process, the residual levels and process generated waste. The process
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was video taped specifically to provide visual presentations to the Working Group along
with more technical data. The Working Group did not express interest in this technology.
This is not intended as a criticism but simply an acknowledgement that we must have some
scientific rationale for both acceptance and rejection of technology. Appropriations,
feasibility, health and safety, environmental liabilities and benefits, environmental justice,
community risks and concerns ( actual and perceived), cost and sound technical judgment
are all minimum considerations to be successful. No single factor, regardless of individual
biases, will determine success; but a combination of as many factors as possible will give
the highest probabilities of success. The Division is encouraged by and supports your
presentation of contextual issues. The Division is committed to active participation on the
issue and the difficult recommendations that this will generate.
ALTERNATIVE DETOXIFICATION
BCD Detoxification -The Division agrees with BCD evaluation and specifically agrees
with the significant technical issues regarding control of air toxins, treatment of process generated
waste streams, contaminant destruction and residual contaminant levels. The Division's concern is
that BCD, under certain conditions, may be a dioxin generation rather than a destruction process.
BCD appears to be a good PCB dechlorination process. One major consideration is the
concentration of PCB, dioxin & furans that remain after treatment and the resulting long term
O&M cost to the states. The Division concurs with the suggested levels of testing and sequence
of testing. It should also be noted that the US EPA TSCA will require a full-scale demonstration
testing program before a final TSCA permit is approved.
BjoJoKicaJ Treatment -The Division is not aware of any full-scale commercial
demonstration of the applicability of biological detoxification for the PCB Landfill. However,
there is an indication that significant anaerobic dechlorination of PCB has occurred in the landfill
(report enclosed). The Division presented this information and requested consideration of
bioremediation as a potential technology. The Division's proposal was to evaluate potential for
in-situ decomposition. There were four parties interested in research and demonstration of
bioremediation applicability (GE, DOE Oak Ridge, EPA Athens Lab, Institute of Gas
Technologies). When presented to the Working Group, it was rejected primarily because
biological processes take more time since they cannot be engineered beyond some limiting
physiological factor. Bioremediation alternatives have been rejected by the Working Group in a
series of sequential motions -(1) rejection of bioremediation (staff objected due to lack of
scientific considerations); (2) rejection of any technology that requires more than three years (staff
objected since that might result in rejection of other technologies that because of scale might take
37 months); (3) primary consideration of technologies that takes less than three years (staff
commented that this appears to be an indirect method to reject bioremediation and as a matter of
public record would give third parties a basis for criticizing the process from a scientific and
technical perspective). The last motion passed.
Due to the vote and discussion, the Division placed any further activity on bioremediation on hold
(June 95). Bioremediation may offer some positive strategic options including in-situ treatment,
utilization of water in landfill, and long term financing in lieu oflump payment ($5M per year for
four years in lieu of $20M for a high volume rapid one year detoxification).
The Division is not yet convinced that exclusion of bioremediation is appropriate and feasible
because it has not been evaluated sufficiently to make that detennination.
In addition, the State of North Carolina is committed to a significant array of biotechnology issues
including genetic engineering and waste remediation. The Department of Commerce has
successfully recruited bioremediation firms to the State, and these firms are aggressively seeking
opportunities for application of their technology. It is a very competitive market in North
Carolina. If bioremediation of the PCB Landfill is not considered, and rejected, through some
systematic scientific process, there will be a high probability of strong opposition in the General
Assembly for funding.
The Division is committed to assisting the Working Group in any consideration ofbioremediation
efforts.
In-Situ Vitrification -The Division agrees with the evaluation of in-situ vitrification. In
addition, the Division is concerned that application of vitrification technology would have to be an
all-or-nothing approach. Vitrification would essentially result in destruction of the liner system,
soils and PVC. Extreme care from a design and operation perspective would be required as well
as financial assurance. The Division has reviewed a vitrification process, and considered it for
RCRA corrective action. The process was mobile and relatively small. The treatment surficial
area meter square and depth was not a limiting factor.
Eco-Lo"ic Gas Phase Chemical Reaction -The Division is not familiar with this
technology.
Brief Comparative Analysis -The Division supports consideration of two technologies in
lieu of two tests of the same technology.
Field Demonstration of TechnoloKY -The Division agrees with this presentation.
An Alternative Strate~ for the Warren County Landfill Situation -The Division supports
the concept as presented. The Division urges more emphasis on technology selection. For
example, in the previous evaluation of detoxification technologies, vendors were asked to present
a description of technologies, applicability to the landfill (specific) and cost of full-scale
implementation (a copy ofthis is enclosed). For very little funding effort a good process was
implemented. Ifbioremediation technology, in-situ vitrification technology, (and if the Working
Group agrees to soil washing with off-site management of residuals), gas phase chemical
reduction, and other technology vendors were given the opportunity to make proposals and
accepted or rejected on the merits of the proposals, the Working Group may be in a better
position for seeking public funding .
This may appear to cause a delay but these efforts could progress simultaneously. This may be
the only process that would eliminate the pie-in-the-sky claims from competing commercial
vendors plus the opportunity to exclude themselves for claims and costs that cannot be
substantiated from a technical or scientific perspective.
To: Committee Members
From: Doris Fleetwood
PCB Working Group Secretary
ieCE/Vti)
Sol/d Waste
APR 24 11996
April 22, 1996
Enclosed, please find a packet of information that the Science Advisors have
requested that you read before the meeting scheduled for Thursday, April 25 at
4:00pm. This meeting will be held at the C P& L building at 720 Ridgeway,
Warrenton, North Carolina.
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April I, 1996 .................................................................................... by fA.,"(
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To: Co-Chairs, Executive Committee, Joint Warren County/State PCB Landfill Working Group
From: Joel S. Hirschhorn, Scit!D.ce Advisor
Subject: Submission of.initial report; master plan
Enclosed is a copy of a repon by myself entitled "Preliminary Detoxification Technology
Assessment" that I anl sub.mitting to the Co-Chairs.
I had sent a copy of this doCl!IIl.ent on its date to Bill Meyer, marked draft, so that I could obtain
some professional feedback and to check my site information before official submission to th-:
Workmg Group. Subsequently, Bill informed me that he generally agreed \\i.th my repon's
presentation but that he foresaw some potenti.al difficulties \.vith the Group's membership because
of some of my information and recommt!ndations. He suggested no changes or corrections in the
report. I told him that I too realized that I was presenting what could he seen as disturbing new
infonnation aud analysis, but that [ had a professio.ual and ethical responsibility to inform the
Group as soon as possible about information that I knew should have a m.1terial impact on the
Group's thinking and strategy.
Because it has been some time since I have heard from Bm~ and the Group's meeting he had
discussed \vith me did net materialize, I feel it pmdent to submit this report at this time.
This morning I received a memo from tbe Co·Chairs regarding development of a master plau.
The problem I have is that such development seems to be premised on currently available
infonnation and thmking about the fundamental goals and strategies of the Group. It seems
somewhat illogical to me to develop a master plan \vi.th.out first having the Science Advisors
pro\ide some fresh, independent th.inking about what premises and assumptions the master plan is
based on. I do not believe that the interview meeting 1 had or any other discussions or any
materials I have been pro·vided ofier a sound basis for developing a D:k'lster plan. In fact, at this
time there is insufficient definition of what a master plan should attempt to do and inclnde. For
example, I would like to receive from the Group some specifications about what the master plan
pertains to and its desired scope. Does it pertain to the individual Science Advisor's activities or
the entire currently fi.mded effort. for example? Also, in the significant time since the selection of
tht! Science Advisors, I have not been provided with any site documents, without which it is ,/
difficult to carefully assess future activities.
I w:mt to emphasize that I believe it is critically impo1tant for the Group-to seriously examine and
then openly discuss my report, because of its implications for how currently available state
funding ""ill be spent and how the Science Advisors \\-ill be utilized. Hence, it seems logical to me
that my report be considered~ efforts are expended on master plans. Please feel free to call
me v.ith any que~tions you may have.
S d
PRELIML"lARY DETOXffiCATION TECHNOLOGY ASSESSMENT
to
"'"'arren County PCB Landfill Working Group
Jod S. Hirschhorn, Science Advisor
March 7, 1996
Introduction
The commercial development ofremediation technologies has progressed rapidly during
the past decade, aud since early decisions were made that there were no acceptable alternatives to
landfilling the PCB wastes in Warren County. The purpose of this analysis is to review the
current state of understanding and objectives regarding the use of detoxification technology for
the Warren County PCB Landfill. It seems that based upon previous work there is a general view
among Working Group members that BCD dechlorination technology is the preferred technology
and that two companies \\!ill conduct onsite field demonstrations of their forms of the technology
dU1ing the cwTently funded project.
There are two reason.able questions to consider:
1) Are there other technologies that may offer net advantages over BCD dechloxination in terms
of effectiveness, safety or cost and, ilierefore, that merit some level of exammation or testing?
2) Is the plan to field test two di.ffereut forms of the same technology a wise~ necessary and cos.t-
effective approach?
Each of these questions will be examined to encourage a thoughtful discussion by the
Working Group. Also, an alteraative strategy is presented for moving fonvard 'With technology
evaluation and securing funding for acrual cleanup. The alternative strategy is believed to offer a
number of advantages over ilie current plan and merits serious consideration by the Working
Group.
Contextual Issues
The use of the term detoxification technology implies that technologies that are considered
cleanup technologies but that do not by themselves detoxify PCBs are not appropriate for the
Warren County simation. This position is very important, because one of the areas of
considerable development has been separation technologies. These remove toxic contammants
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from soil or other media, concentrate them to a much smaller volume, aud then these are usually
sent offsite for subsequent disposal or treatment. This approach has been used for PCB cleanups
and maoy other types. For example, thermal desorption, solvent extraction, soil washing, and soil
vapor extraction have received considerable suppon. About 75% of cleanups other than those
based on conventional land disposal/containment, incineration, or stabilization/solidificatiou have
used separation technologies. .!!!_ manv cases, se_paration tecb.n.ologies offer ~ignificant cost
advantages and this e:\.-plains whv they are normallv used.
Sometimes, where environmental justice issues have surfaced, communities have taken the
position that cleanups should not impose bw·dens on other communities. This leads to a
preference to avoid concentrated toxic wastes being sent offsite for final disposition. The premise
is that the wastes will be sent to communities that have already been placed at risk because of
hazardous waste disposal or treatment facilities. However, this position is not completely valid,
because it is possible to require that .final disposition of wastes be at a facility that is in a
community where environmental justice iss.ues are not relevant. That is, there are commercially
available and permitted facilities in places where the local community wanted the operation and
where poor, minority people are not a relevant factor.
1b.is Science Advisor assumes that the Working Cn·oup stiJl believes that only an onsite
detoxification technology should be used . .Therefore. there Vvill be no analvsis of either separatlon
!:chnologies that have been widelv used for PCB c!e;mups nor wj)l conventional land
disposal/containment. incineration, or stabilization/solidification be considered. However, it
should be noted that at some poi1.1t in the future, if and when a case is made for using a
detoxification technology, other pa11ies may raise questions regarding the use of either separation
or conventional technologies and may assert that one or more of these would offer cost or other
advantages. In paiticular, when a large amount of money is requested foi: full sea.le use of a
detoxification technology, state officials may question whether there are other lower cost
technologies that should be considered. It is most likelv that actual cJemmp cost based on on site
~detoxification "'-ill be at least $20 million, and perhaps significantly more, depending on exactly
how much material "viJl be treated. 1
This does not me3.ll that the Worldng Group should necessarily abandon its preference for
using onsitc detoxification techno1ogy; but it does ~uggest the need to pay attention to two thmgs.
First, all technicallv feasible detoxification technologies should be fairly considered,a.nd tiaying
att~ution to cost is appropriate. Second, at some point the preferred detoxification technology
must be analvzed in comparismi to separation and conventional technoloeies to make the best,
suppo.ttable case for political support of a high cost cleanup. Anyone opposed to spending a large -
1Assuming 40,000 tons, a .figure used by the state, and a total cost of $500 per ton,
covering detoxification and all other cleanup costs yields $20 million. This author's considerable
experience \vith costs of cleanups based on treatment technologies indicates that an aggregate
cost of $500 per to11 is a very appropriate cost to use at this time; this cost would cover all
spending on the actual cleanup.
2
sum of money on a detoxification cleanup could easily obtain data for a cheaper cleanup
alternative.~
Alternative Detoxification Technologies
BCD Dechlorination While it is correct that BCD technology has gained increasing
acceptance, after years ofresearch and development at EPA, it still is a technology with limited
experience in full-scale cleanup applications for PCBs and similar chlorinated chemicals. A recent
analysis by the General Accounting Office on use of innovative cleanup technologies~J for
example, reported that for Superfond sit.es from 1986 through 1994, dechlorination technology
had been selected in only three cases out of a total of 291 innovative technology applications.
There have also been other applications at non-Superfund sites. Although BCD is only one form
of chemical dechlorination, it has become the preeminent form:
A L 995 GAO report concluded: "It is an efficient, relatively inexpensive treatment process
for PCBs aud potenti.11ly capable of treating PCBs at virtually any concentration .... Field data on
the performance and cost of BCD for PCBs and dio,in are very limited. "4 In. !.his author's ! !
\ \
.E,:Ofessional opinion, the most si_gD.ll!cant technical issue for BCD is the control of toxic air .
em1ss1ons and the possible need to treat other wastestreams. much more so than the abilitv to
r\e~':troy comaminants :ind reach stnmi:ent cleam~r st;'nrl:n:-ds·. Supporting this view are conclusions
ou BCD in a recent study by the Congressional Office of Technology Assessment: "Toe reaction
byproducts m treated soil have not been well characterized. . .. The efficieucy in removing
contaminant$ from the off gases is not well known. Washvvater used to clean the soils after
treatment \\.1ll contain traces of contaminants and process chemicals, and may also reqwre
treatment." 5
l171ere has been a dramatic trend in recent years for botl1 federal Superfund sites and state
cleanup sites nationwide to use lm,v cost remedies, typically based on containment, rather than
treatment options. In this case, off.site disposal or use of separation technology with offsite
hazardous residue disposal might very well be significantly lower cost than onsite detoxification.
3"Superfund -Use .of Innovative Technologies for Site Cleanups," Dec. l 995, GAO/T-
RCED-96-45.
~"Superfund -EPA Has Identified Limited Alternatives to Incineration for Cleanjng up
PCB and Dio,dn Contamination," Dec. 1995, GAO/RCED-96-13.
5..Cleaning Up Contaminated Wood-Treating Sites," Sept. 1995, OTA-BP-ENV-164.
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A recent EPA study of technology decisions at Superfu.nd sites0 provided the follov.1ing
(elevant information about the use of dechlorination technology:
--In studies related to FY9 l and FY92 decisions. dechlorination was treatability tested
once, and that was uusuccessful.
--For this same period, dechlorination vvas c.ousidered in 50 cases, and selected in three.
<1tJ1er than factors related to un~uitable site cont.lmi!l:llits, tb.e most common reasons for
e;;miuating dechlorination was high cost, t1,e need for treataHfoy studi::s; z-i".ltential to form more
toxic or mobile by-prodm.:i;\ and the need for post-treatment er dispos;:l of :r::~iduals.
-from 1982-1992, dechlorination had been selected five times, but in three cases the
decisions were later changed and different cleanup technologies used. In those th.ree cases, the
sites were contaminated -with PCBs.
-EPA said: "Factors affecting the decisions to replace dechlorination ~::;lude the larg~
v')lumes of dechloi.ination residuals that required fu . .rther u-:arment/disposal, cost of ofi:.site
tr~atn::¢ut/-:Usposal, safety concerns rel~tin.g to h:mdling haz .. rdous m.1ter~ls, cost of reagents, low
.,:reduction rates, :~aching of residual reagent from treated son, and offensive odor problems."
To be fair, it should be noted that in most of the cases considered by EPA, dechlorination
was probably based on the early forms of the technology (i.e., KPEG and APEG) and not BCD.
But the general equipment was probably about the same as that used today \\11th BCD. because
the m.1jor difference is tl1e reagents used. Many of the issues, therefore, may be valid for BCD.
EPA has also issued guidance for conducting treatability tests for dechlorin.ation
technology. 7 Perhaps the most impo1tant pan of this document is its presentation of the different
levels of testing appropriate for making decisions about the technology. The EPA framework is
cMrect and is based on three levels of testing: t~chnology screening to determine potential
f"'1sibility, technology selection t~ develop perfon.nance and cost d~ta, anc:I testing to obtain mon:
cetailed data and con.firm perfomm1ce. For the Warren County situation, where the site
-::ontaminant concli:i.on is ~ot compk:: (i.e., there is l!ssentially one chemical type that one
technology can handle) and considerable information already exists on how some technologies
treat PCBs, the screening and selection decisions -!o not require onsite or field testing. In fact,
EPA said that screening testing of this technology 11\-vi.ll geuerally not be required when PCBs or
dioxins are the contaminants of concern .. " Testing in laboratory or bench-scale or full scale
equipment at a vendor's location can be used for selection treatability testing. In the EPA
6"Feasibility Study Analysis, Volume I: Findings and Analysis." EPA-542-X-95-001, May
1995 .
7''Guide for Conducting Treatability Studies Under CERCLA -Chemical Dehalogenation,"
EPA/540/R-92/013a, May 1992.
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f-1mework, the third level of testing is during remedy implementation and after a legally bin.cling
~~cision is made by the government to use the selected technology ar.:i fund the cleanup. Th.is
level of testing definitely requires the use of full scale equipment and the testing of significant
quantities of materials to allow all the necessary detailed data to be obtained. Moreover, for this
third level of testing, EPA has sanctioned the practice of "prequalifying" one or more vendors
based on the results produced during any prei,ious treatability testing at the selection level.
Biological Treatment For many years various fonns ofbiotreatment have been pursued
for PCB cleanups. T~ the opinion of this Science Advisor, biotrea!.!llent is not yet proven effecth·e
:md reliable enough for use either as ;\t! in siru or ex situ technology, :,-~ei-obic or anaerobic form
~r some combination of them. for the Warren County application. While there is no doubt that
significant biodegradation of some PCB congeners occurs uuder va1ious conditions, a tightly and
reliably controlled form ofbiotrcatment from an engineering perspective is not yet proven for fall
scale commerciaJ use.
In-sin1 Vitrification This technology has been under extensive development for many
years, chiefly ·within the DOE system. While some people have viewed this technology as a
variant of incineration, chiefly because it employs very high temperatures, it usually is considered
1s :1 unique tec!mology. .13uried wa5.tes can be heated to melt all materials and form a vit.reous or
Qlassy materi:J. The process thermally icstroys organic contaminants ar~ au ex'tensivc off gas'. air
roUution control system is used. Interestingly, in October 1995 EPA has granted Geosafe a
National TSCA Operating Permit for the nationwide treatment of PCBs ,~ .. i.tlrin a large number of
prescribed circumstances, including max;muu1 average concentrations of 14,700 ppm and
ma:-,.,;mum hot spot concentrations of 17,860 ppm. The company obtained this regulatory permit
on the basis of a site demonstration that .'.!dlieve<l v.::_-ious perfonnance criteria, including six nines
c:.;struction and rem.oval efficiency and less than 2 ppm PCBs in vit1ifie<l pro<luct. ~;o detectable
dio.'1.-ins/fi.trans were fotmd in off gases -:-:: :.:.t ;he demonstration was not on in siti:. wastes similar to
!.he Warren County situation. This technolog-f must be considered detoxification, and it offers the
comparative advantage of being intrinsically applicable for in situ treatmeut, avoiding the need for
excavation of m.-iteri.-tls. In theory, the technology could be applied directly to the Wan-en County
Landfill, perhaps without dewatering the site, i~:hough the site's location would pose significant
problem for using the e:\."tens.ive equipment.
ECO LOGIC Gas Phase Chemical Reductjon This technology has been tested "vvithln
EPA's SITE program on materials containing PCBs in 1992, and technical feasibility and safety
were· demonstrated; it has also been demonstrated in Canada, where the vendor is located. '!lie
process operates m a hydrogen rich atmosphere and in tbe absence of o:\.-ygen, vittually preventing
the forr:n::itio.!l of ,~i0.:"i"s_!fur~ns as side products. The technology was improved after the EPA
test and now incorporates an improved design in its first stage where contaminants are desorbed
from soil in a. heated hall mill. A ~omrnercial unit can treat from 100 to 300 tons per day of
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contaminated soil. One such unit has been used in an Australian project and other unit is to be
used by General Motors and another company iu Canada.
Brief Cornuaratiye Analysis L -~ .... ;,,:;!.:f.116 t::; ~:-~0..rem~nts ofth~ Warren Cnanty landfill
r-lean.up it is ;:!:::~·~:_:~BCD tec..'lrnok,g;· =·:. ~~-:~ med!..:.::::....; .... ~ ;;!t!:;ut_:_)n. One can rnle out
biotreatment on the basis ofinsufficient proven effectiveness. and p~:~~~:ibly in situ '.itr.Bc'.!tion on.
t'. -1)~s.is cf ir.sttffiden.t full s.<:2k app!.:.~2!i-:::1. The other problem with in situ vitrification is that
there is no simple or cost-effective way to test the technology for in situ use at Warren County. lt
is also likely to be much more ex-pensive than BCD. The ECO LOGIC process, however, cannot
be elin.l.in.ated from consideration. It's commercialization has focused on PCB cleanup and it is
fully commercialized. From an environmental perspective it far less likely than BCD to pose
problems with regard to toxic air emissions. The compan) has mobile equipment that could be
tes.1ed and used at the landfill Tt probably is cost ~omr~tifo,.,, ..... !!· ~CD. Therefore, if the
W ork.ing Group was to remain committed to have field demoustrations of detoxification
technology in the near term, then it is recommended :hat it would be more beneficial to consider
1.<lving OT.'" Ben ver,dor .inti ECO LO~T(' r~ef.0::-·~-:~~:.:: rh~ tc h:!\·-! ~·.•.c BCD vendors nm test~.
Field Demonstration of Technolo~
Field testing in pilot or foll scale equipment has been \Vi.dely used in the toxic waste site
cleanup area. But it is imponant to Wlderstand the reasons why this is nonna.Uy done. There are
twr, ... r<..,..,._. --v,-,-: +,",., .. ~,,.1,1 rl"'tn"n,-tr•,t!---s First in some cases tJJe nature of the remedial ... . . --·.; ~ ---------------·'¥ -...... __ .., ____ • ,. . .
technology means that there are~•~;±!,~'.'~~ .:::::!::-s ~i.1! :.::. '..., ...... ~~.::..::. ~:::ific which affect the
perfonnance of the technology. Obviously, any type of in sim technology must be proven
effective at a specific location. -p,.,. core! issue in the..:e c~;;;~:; is ·.-.h~t:i~, the t~chnology is
e::.:.;tive. 'R1.,t: for treatm~t technologies for which exca\';.t;!~ .materials are the inputs. it is not
location that is of co.nc~rn.
r .... ~rMd the issue is •.•.-·hetb.er the tecll!lolcgy is effective on rhe s;· ---:~c '.vastes from the
l""Mion. ::•;.:: can he and US'..!~Uy is determined by testing site waste wim bench scaJt: te1;hoology
in the vendor's facility or in some cases in pilot or full scale equipment that is available either at
the \'endm)s home location or at some other location where the equipment is operating. The term
•rc~:"!L.!.i~y t-2 _.i .d.".;;1.: :) this kind of testing to determine penormance or effectiveness for a
panicular waste, but it is .not onsite field testing.
i_.;:r!g fi 111 scale technology at maximum production (throughp11f, kvels for the equipment at a site.
f\~nionstration, trial, or test activities at a site are done to verify that all previous conclusions
about waste specific effectiveness and technology/equipment safety .t.11d envirou.meutal
perfonnance are fully met a11d, if appropriate, that regulatory reqcir;~:-;:t: ~e satisfied. Unless
ver:,· A~tailed specificatioii"s are met, the vendor :an and should l~s~ t~e job, _although n~rmally the
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vendor may be give:n more than one try at meetjng the specs. Once iu a while a vendor fails to
pass the onsite test, and either :in.other vendor is sought or a different remedial techno1ogy
cou.sidered.
Any field test or demonstration. is e:qJen~ive, not merely because of costs associated Vvith
operating equipment, but also because of the sub~tantial. costs of moving equipment to a location.
and setting it up there. If technology and vendor selection can be don~ hefor~ field te~ting, it is
normal practice to do so. More importantly, if a field demonstration is doue before a commitment
is made to a vendor for actual site cleanup, then the costs are even higher, because th~
presumption is that all the equipment \\-ill have to be removed from the site after completion of
the field test.
TI.1.e sin1ation for the WaITeu County landfill is thatany field demonstration(s) \.v11l be done
before th~re is any finn com.witment by government agencies to fund the cleanup and before a
vendor can be contracted to perform the full scale cleanup. Thus, costs will be high (because
equipment "vill have to be moved to the site twice) and the 1isk.s from the vendor's perspective are
ma,-;mum, meaning that the vendor \\ill want to recover all field demonstration costs. :-!1e
u::.-..::::-;...,,:~,;: ,,f money, schedule :i~ well 1') ·,:;~c'~::-::· sel~..:~~on ~01:r,bia:: tu L.l~J.r. tllat ·., 1::,:-the
l'l1't'P~.,~,n~1~~ a:~ r~:::_0,:~r\ ~~:-· r~_!;"!j,:,~1~~ "-'~-~,.!:~-.. f-'''",·en CJ.'~ that has S'l..LCC':!S:':5.!l~: .. ~0rz:p!!tcd 1 f_::1
-..1 "-:::la3tr~tio:i, ru.1y IV)\ iF~ ~!-.: job .
..,_·~;):-~uve:-, for th: \V3nen County land.fill application , there really is no location speci.fic
u·· -~~:iimie£ to bl! res0lved for an:: detoxification technology based on treating excavated
m:·.1.eri:!ls Treatabiliry tests shouid be used t0 verify performance and eftectiveness for landfill
w·astes, and detailed treatability test repons should be produced to document test results to
support the technology selection (the secoud !evel in EPA's framework).
For Warren County, the ma.in ieasou for conducting a field demonstration of
detoxification technology within the current evaluation project seems to be to raise the comfort
level of concerning citizens about the technology and, particularly, about its safety for the
community. n,;~ could be accomplished at considerably lower cost hy bri,,g.irg t~e people tot'!:-""
t~"1c ~•,..,Jn'.::' rat.her than the teclmolo!=!Y to the people. however.
BC" ·u":"~idors A rcasonnb!e question to ask is \vhether it is necessary or cost-effective to
hiwe m0re tha.i: one site d~monstration of BCD. It is this Science Advisor's position th.at it is
neither necessary or cost-effective. Any BCD vendor should be carefully evaluated on the basis
of all previous testing and full scale use. No vendor should be asked to pe1fo1m a site
demonstration if there are serious un.resolved issues or if the vendor is not comparable to another
that is deemed to be the be!:,"t available one.
If two BCD vendors perfom1 site demonstrations and meet all performance requirements,
then the maul benefit obtained from the considerable costs is that Working Group members
achieve a certain coinfort level \\1th the vendors. ~.:,k;;tbg one of them still requires a careful
7
Hd9 v '6 S66l-LS-8
analysis of data, not only the data from the test, but all other information as well. Only the most
visibly egregious, unlikely behavior by workers would cause members to see some activity at the
site that might be intetpreted as unsafe or sloppy. R11t ~-!~dy ~·::=::~!:i;ig ::i.cp~rt?.!l.C.,. re-ct-; nn
..;. ...... 'In.is author's experience indicates that the cost of a site demonStratio:n for BCD at Warren
County will probably be at least $200,000, and perhaps closer to S300,000 when all costs are
accounted for .3 The cor~ is;.;uc is \\hetl:er ,:me ,;ould make a judgmcut h~sed ori a,•3ifahle
in,.:-.~ .. ~ticn that there is one dear ''best" BCD vendor or whether tvvv ar~ cowp;,.i',,bl..:.
The Working Group should also appreciate the technical reality that a limited field test
based on treating a relatively small amount of contaminated material is :_.:;r 1=~:;-.:y tc p:·~d:.~;.;
snfficient rdiable data to definitively answer importa.n! qu~sticns, especi21ly ones about to,dc air
emi: . .:::-::n::; a.ud materials han.dling problems.
TI1e answer to this question depends on the criteria used to evaluate the information on
the vendors, but this is normal technology assessment. A reasonable set of evaluation criteria
could be:
--:_a-:-ct:Y~i:.'! •s ~: \.veigbt of evidence for effectiveness on safely destroying PCBs and meeting
stringent cleanup standards
c.,~':'.'!v' specific information on controlling all wastestreams. particularly air emissions, and
meeting regulatory requirements
--Commercia1 e,q,erience: proven experience with fulJ scale equipment for cleaning up sites
(panicu.farly the specific equipment that would be used in Warren County), especially PCB sites,
and availability of equipment for actual Warren County cleanup
--Busine<;s perfonnanc~ ex-perience tbai; clients have had v .. ith a vendor, in terms of reliability.
schedules, estimates, regulatory compliance, and prevention and resolution of technical,
administrative aod managerial problems
--~ likely coSts and their uncertainties
The odds are that one BCD vendor will surface as superior on the basis of a total score for
all evaluation criteria. ')'i)i:; author has previo~y ev:llu;ited th.e two vendors currently considered
as potential technology demonstrator~ :11'.ld more recently bas spoken to both ~Q!!!p!?cies ~~ ·vvcii as
8This level of cost is consistent with EPA's figures, ... vhich is that a level two remedy
selection treatability test, normally a laboratory type test~ typically costs between $50,000 and
$100,000. EPA described the cost for remedy selection testing as moderate and for remedial
action as high.
8
I IOd..:l 1 ldL t': (3 Sf3(3 l -L S-8
someone at EPA familiar \.vith them.9
An Alternative Sttategv for the \Varren County Landfill Situation
The sole purpose of presenting this alternatiYc strategy is to off er tbe \Vorking
Group an option th.at has the potential for satisfying their primary goal, namely obtaining
the most effective and safest detoxific!ltion of the landfill without further lengthy de!ays .
..,.,.:,..; ,;;;,J vbj~.:fr,e :';-11ot resting technology but ir1 using the: beSt possitl~ d~,wup tt;(;Luuiu:,y tv
,a.,n.'~ the commnruty's ne!;~;;. The alternative strategy described here is consistent with EPA's
framework described above.
With this alternative strategy, detoxification technologies and vendors would be
considered and carefully evaluated on the basis of all avail.able infom1ation, particularly from full
scale applications, and then a short list of vendors would be determined, followed by treatability
tests :ind pruning of the short list. \Vc--~!--g G-r1.;1.!p lli!~ber£ -~ccld ·vi.5it the pla1,;e where
♦.-~'.:lt1~i!it;· ~esri11g 011 \V:rrreu Conmy L:rudfi.1J w:iste~ \Mas !'eifom1ed.10 Vendors ach.iev:ing
excellent treatability test results would then be asked to provide an opponunity for a group of
people to \isit an operating full scale fucilityY Working Group members could ~pend one or nvo
days at the site, as necessary .
.... ,n~, 1~ J)e made a11d th.~ .,b~s:·• ve!!do1~ ~~]:::'<:: :d. ~ :r t~~-c seltc~c:<l v~nJ.vi· ,'i.U. a~·ct-mcnt \Ve::!: ~e
entered into so that the '-'et\<lor \.vnuln h"'-nri:-_...,.,.,1;f;,.fi for ii,,~t (;:Pll"(".tinn. which \.VOuld have to
'"-'~ir nnril hmr!;n~ u,~,;: <;ecure<l frn"'l th? ""':~T--fnr rho '>~t>1?.l ~, .... !,,,.) 0f"th;.>, h..,rlf;ll. The a!!"".,,,.Olent
"'ot·1d .1lso .-:n,-.rifv •h~ .. th~ ·.--~~.-1 ...... ,. ·. • ... ·,' ·' •. · ·. · •., •. ,,.,,.~ <:?, .... 1·fi--Mi~u.;. m· a field demon,... ... a-t1·011 ,.,,vv L:v vv ll ,I.. ·-_ ·-···• _._. •• ______ ·•-----................... ___ .rr•.._. . ..., ,.~-.--• ~u ~\ f\'-"' v'\l.,( 11
-n,;or to 11<:ina. tb~ fii..!J c:c2!e ~(1lliT,n~~nt it ~~rl"i:IHl:-1';,,~ r:r:e-: ~t tb'." ,v~;,';;':'_ C'J'.:::.t'-' b·--1~11 ,.w /0'.:J -• ,. •. . . . ., l)Je i--&JI--'~ ~,r#Y°
-h> ii -r1' ()-~ vL J.f
9This Science Ad\isor authored "Technology Assessment -Treatment Technologies for ~~e>J.
PCB Contaminated Sediment -A White Paper on the Hudson River PCB Cleanup," for Hudson o.r'
River Sloop CLEARWATER, Nov. 1994. Both companies currently being considered for site
demonstration were evaluated. ~ ~~1T e~½ ".'":~c --::-:~~ tb.2 lii~est ~::fr-:ig, while ETG the lo\vest from
eight technologies that ·were considered viable ( out of a total of 14 ). However, there were some
site specific factors considered in the analysis, and the coropanies have progressed since the
analysis was performed.
10In some respects, visiting a coinpanys facility, meeting its personnel, and discussing
testing and test results may have more impact on a person's view of the vendor than seeing some
aspects of a site demonstration.
11To some ex-tent, a vendor that does not have any ofits equipment in operation
somewhere may be deemed less desirable than one that does. In some cases, a vendor could
operate equipment at its O\-vn facility to provide the necessary opportunity.
9
Currently available funds could be used to compensate the vendor for time and materials
necessary to support an Working Group and state activities for finalizing the cleanup
specifications and other aspects of the remedial design, and securing political support for funding
the actUal cleanup. In other words, several hundred thousand dollars would be spent on what
would normally be seen as technical consulting on remedial design rather than on a field test
during the current project. 12 T-.c0rpor2~~3 a t~ch.nology vendor in remedial design represents
current attempts to greatly improve the process for cle:ining up hazardous waste sites. 13
\Vith ~~'.Yategy the issu~ ~f obt:if"1'1g politica! support f"~ :i rie?o~fication ck~-.;~ 0:
~fiuv.$fl Je;~iy-fk. \V crking ~o,.lp is focused c fi.mc:=::i.s :,lone. n.ot on technok3Y
:::tle.ctlon. Do~ so reffioves risk and uncerta~~y 3.!ld ;\'en intentional delays resu.lti.T'lg fro"::'"
polrtic?.l or ,:;overnmenta.l entities rai~a; questk-;-:: Jhout ted:.r,ology: dther because they h:we
f~,._ ~ arte«1s, '</:mt tc fuid a che.1per ~l'f, or w:mt to delay lll,1}cin3 a dec::;!~n .
\ \ \
~ad. ~ .pn~Dlallf.JJ,t..c..~\ w,fl\~!D ~i•s_i,• '!le~ '1c:tb u:,,:.frnof "'91 r:tl1d 4.
~ifk_~co~ ~tkc•~~~~-~, . .ir~~«:lut.\1d~,@Jni,J-
. v..h~det11Y4? 1' 'O«t-S~ cec Q? bo~~-w,'Jne c{mx ,,., o~e.t words currmtfy availa~ ~
· would be used to consolidate di:ci~~on-JMkm, ~ the 5iont-~ t>f.:f.e c.omp~ .process 311il
_ re.c/uce 'risks '1, r fo" !S" arfrl. ~i/W'6 -z; aca, !'f ush ~ 1tzrda,ne11.JaJ pl oe• Worlin,9 G.rot1p1 J'\3nts?yksafr at.f 1'"1ely den,~ £~ k..ftffill.
'T" ,; ::vc~t'..:al cleanup basd on ..-i:;h!_u~Ggy ...... ill ~e~:witely ;;c;~ S20
... :!!ion or .r:u.ure. This strategy would ensure that sufficient money was spent on obtaining
infonnation on all alternative technologies ( detoxification, separation, and conventional), making
an Ultimpeachable case for the desired technology and vendor, and on complete site investigation
aud characterization that supports actual remedial design, including the specification of amoW1ts
atld types of materials to be remediated (which may mean more testing of the site).
Most imponantly~ with this alternative strategy it is possible to develop a sound,
impressive case for an accurate estimate of actual cleanup cost, because more effon is placed on
remedial design which also allows the vendor (in conjunction with the state and the Science
Advisors) to anive at a firm estimated cost. V.''~h the c· . .1n-e!lt strategy, obtah1ing _political support
fc ?ppropriating S2O million or more wouiJ be difficult because of questions raised about the
'2.4\nother advantage of this altemative strategy is that it would facilitate making the
decision to remove excess water from the landfill at an earlier time; that is, after a vendor is
selected for the main cleanup task of detoxification and dwing the cwTent project.
0 11,is Science Advisor, for example, is CWTeutly serving as a technical advisor for a
community group living near the Marzone Superfund site in Georgia, and where the PRPs and
EPA are using a process that allowed a technology vendor (thermal desorption) to be selected
early enough to allow panicipation in remedial design. The vendor will demonstrate its
equipment as the first step in the actual onsite cleanup. A different company had previously
performed a laboratory treatability test to support the tecbn.ology selection decision.
10
~d6~=6 S66L-LE-8
The selected vendor "vould be funded to support their involvement ¼1th site investigation
and remedial design rather than support an initial field demonstration p1ior to vendor selection.
The selected vendor would have to make a commitment to make equipment available on.ce
fonding for the acmal cleanup was secured from the state. r.-1~nciing for the actual cleanup would
; -),,--1 ,-~on:!~ f:,,. th.-An,itr, , ... ~, ,1 .~._,,, ..... ,-.,t;,,.., -.,-ri .. ,· ~-. ft1ll "c:.11~1-♦-r:duction use ofthr.-eqln'pment •---.-,.\,-;-... ~•-•••---• ---•-V••--A~ , .. ..,&.&.6,lt,,I....,,.. _______ J:'J.··-•• • -•-.,. , -1 ..... '
,. :,;..:h i.; the normal procedure for cleanups t◊d..;y. This type of pilot testing of substantial
amounts of hazardous material in full-seal~ t!quipment usually las.ts for a nwnber of days. Most .
imponantly, it allows considerable data to be obtained to answer all impo1tant safety and
perfonnance questions. The writ can be shut dov.11 for a period of weeks to allow the data to be
colkcred and analyzed. .~ !1 1(ey r~~-:-!""_r".!~? :ui.d :::-1.fety criteria would have been previously
~-..,.~l.:-!~4ed. Upon certification that all criteria have been fully satisfied (a process requiring
e~ensive participation by the Science Advisors), the vendor would be allowed to initiate foll
production levels of detoxification oflandfill materials under appropriate oversight by the state
wd thi,: Science Advisors.
With the current strategy, a vendor that did a successful field test before fonding "vas
s~cured and had to remove the equipment would not necessa.rily have equipm~nt available after
nmding was seemed for the cleanup.
i:::.,h1fy ·' ·s ,c.J.... .... a.v ..i!'r-~-., .-.. ·-•. -~,,-,., . .ii•-· o~r~;.,;.,,,, -,,,:.1·c~1 M'"l'"'T c.01· the c111c1·a1 I I,.,_. . , "'th1 .;:ra.1,,:;y',f ~"' 1'Y'4Y ~v \,o< .... J:"'--•--... ~--,._-1,.u_LJ •-v ..1 u• .iJ :=-t-,1 ,._, __ U . ,
<leci::ion, which is n:miling of the a,.;r-~.!l ~l'!:!::.np , not technology eva.luatio~.-~JJY onsite field
demonstration(s) will require considerable time to plan, conduct aud evaluate as compared to the
a:;ci\,ities that would. under the alternative strategy, lead to both technology and vendor selection,
as well as reliable total cleanup cost estimation.. -:-!.:.:.: S :~~~-:~ Ach i:-:cr'-5. ~=-:pcricrr-:~ i.:ldi<:2!~"' t.hat a
• ~ • ♦ • .... ,. -... • • • •• ~ • • • 11 SJT" ~.".':~:::,~i,t1Ull D)' a VC:ll<lOf Will La.11,,:: .J lU ::, mOHUl~, 1.u ... ,u=o t'~cuu.u,,5, C.'l.c:vUL1.0ll, ili1u .-~0,:t
1,.cparation. T'v"' ~ite demonstrations ,.-vould probably tak~ .1 total of 3 hi 7 .::...:.c.:.~s ~d~:-~h-:
~':'d n~r;,.,,;~t;r ('('\TI(~;-~~-~~-~ 1~~,~~i~!'!:. -:.it!: bact~ to v·«i.:-k d~mouSiratiViJ.S.
CONCLJTSJO~
1•1 co!nn~rison to the cu..-nmt s!:-:!t~!!y. the altemarive strategy_ in thb Sciet:.,.;e Advisor's A -• -.; ,
professional opin.ir.-~, would more lil.;,ely res-.dt fr1. one successfhl at:empt to obtain sufficient
:.:~~,1;,,~ for~ d-:toxili;:a!:on deanup. 111,.. ~mrh~sis on very careful analysis of avail;ll:,}e
inf,,~..:-~•ion on vendors' e"'-perieu.c~s nnd capabili!ies and on treatability testin3 at t!!e v,:udor's
location rather tJrn,. field d.emo.u.:.. :-<1tion at the site is tec!mi.;d!:: :-~~--~ct, because their is no
!"'•·~tjon specitc a:;pe-:ts to de.toxifi;ati~~ technology that tr<.:~ts ~xcavated mntcrials. Onsite field
demonstration of the technology should occur as the first step of the actual cleanup. ·ne main
reac;on for fuY"'l.;.,..,, the altemativ"' strate<T" is: •t.~• =· ,vo~U ~cs,J.1• in,, •~,.,., .. ,.?.,.. oftec~:,..at a.ad · _.,.._ '-' "-c .. ..,, "' ":;;,; -.. _ ... L "'-'" • ..,.__ -... ... .,.. r, .. -...:.1-·-•~,r · .. ...., '·
"'<'.(11tomic info.rm.1.tio!l, including :~;i!!~;!'!!:.£ ,.h:..;i5U icU.i.~: cast data, that \voclc lJe more complete
llnd impressive and. therefore: mor-e capaMe ~f qnit~kl:, ~ecu~na nolitk~l support and ti.!.nd.bg.
11
This is especially important because the cost of a detoxification cleanup will be substantial, at S20
million or more. 1:-·! 10,:il of preparing such a package is to preempt any attempt by any pany to
,,ieJ,c S c;i<.e that som~ <:>t.~ ..... ,:-1~~"''"' ~!'"rn~~h <leserve~ rnnr~ con~i~~-:-:-:f'inn ~ .. 0.ffe>:r;: t::1:.0.::2 .:.
0 co•~-ic:.;;dv:--'-o•,.~'··, .. ,1-,_. ,._ .... _;,.,.,,:..:,..~ct h,· the Wo--kin<T rTT"m''!" ~ 11uH, ~..1.1.JU::::t-"4 --....... v ,,.,'-' ~....,.._ ____ •. -,; .L. • • .. ···c ---·;. ·
12
~id lS : 6 S66 l-lS-8